UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     REGION IX
                75 Hawthorne Street
              San Francisco, Ca. 94105
    LABORATORY DOCUMENTATION  REQUIREMENTS

            FOR DATA VALIDATION



     Document Control Number  9QA-07-90
               January, 1990
    Quality Assurance Management Section
               USEPA Region 9
         San Francisco, California
                Prepared by:
              Santiago M. Lee
      ESAT/ICF Technology Incorporated
             San Francisco, CA

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TABLE OF CONTENTS
Introduction
I. Organic
I. A.
I.E.
i.e.
I.D.
I.E.
I.F.
I.G.
II. Inorgan
II. A.
II. B.
II. C.
II. D.
II. E.
II. F.
II. G.

Analyses
Documentation , , , , 	
Case Narrative 	
Cha in-of -Custody Documentation 	

Summary of QA/QC Results 	
I E 1 Instrument Calibration • • •
I E 2 Method Blank Analysis 	
I.E. 3. Surrogate Standard Recovery...
I £ 4 Precision and Accuracy 	
I E 5 Other QC Analyses 	
Raw Data 	
I.F.I. GC Analyses 	
I F 2 GC/KS Analyses 	
Summary of Documentation Requirements..
ic Analyses
Documentation 	
Case Narrative . . 	
Chain-of - Custody Documentation 	
Summary of Environmental Results 	
Summary of QA/QC Results 	
jl F i Instrument Calibration 	
II .E. 2 Method Blank Analysis 	
II. E. 3. ICP Interference Check Sample.
II E 4 Precision and Accuracy. . ...
II E 5 Other QC Analyses 	
Raw Data . 	
Summary of Documentation Requirements..
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                                                             Page   Rev.  Date





III.     QA/QC Requirements Summaries                          14      °    9/89




        III.A.  GC/HS Organics Analyses	       14      0    9/89




        III.B.  Pesticides and PCBs	       16      °    9/89




        III. C.  Purgeables by GC	       18      0    9/89




        III.D.  Metals Analyses	       20      0     9/89
                                       ii

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                                                     Section No.:  Introduction
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                                 INTRODUCTION

In all hazardous site investigations,  it is essential to know the quality of
the data used for decision-making purposes.  The process of generating data of
known quality begins in the planning stages when data quality objectives
(DQOs) are established, continues during sample collection activities and
laboratory analysis, and is completed by validating the analytical data.  This
document was created to identify the specific laboratory documentation
requirements necessary for data validation.

Validation of data requires that appropriate QA/QC and documentation steps be
performed in both the lab and the field.  Professionals trained in data
validation procedures review this information, "flag" data with qualifiers
when QA/QC criteria are not met, and prepare the data validation report.

The "P.K. Memo" and ICF/ESAT documents, which have previously addressed non-
CLP documentation requirements, have been incorporated into this document.
The general requirements are discussed here, but for ease of use it has been
formatted into two (2) sections, pertaining to the organic and inorganic
analyses.  In addition to the documentation requirements, a new and separate
section for non-CLP QA/QC requirements was created.

The documentation provided by the laboratory in conjunction with the sample
results, allows for the evaluation of the following indicators of data
quality:

        o  Integrity and stability of the samples

        o  Instrument performance during sample analysis

        o  Possibility of sample contamination

        o  Identification and quantitation of analytes

        o  Precision

        o  Accuracy of the analytical results

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                             I.   ORGANIC ANALYSES

I. A.     Documentat ion

        The data package submitted for EPA data validation  will  consist of
        five (5) sections:

        o  Case narrative

        o  Chain-of-Custody documentation

        o  Summary of results for environmental  samples
           (including quantitation limits)

        °  Summary of QA/QC results

        o  Raw data

I.E.     Case Narrative

        The case narrative will be written on laboratory letterhead and the
        release of data will be authorized by the  laboratory manager or
        his/her designee.  The Case Narrative will consist  of the following
        information:

        o  Client's sample identification  and the  corresponding laboratory
           identification

        o  Parameters analyzed for each sample and the methodology used: -.-hen
           applicable, cite EPA method numbers

        o  Whether the holding times were  met or exceeded

        o  Detailed description of all problems  encountered

        o  Discussion of possible'reasons  for any QA/QC criteria outside
           acceptance limits

        °  Observations regarding any occurrences  which may affect sample
           integrity or data quality

I.C.     Chain-of-Custody Documentation

        Legible copies of Chain-of-Custody forms for each sample shall be
        submitted in the data package.  The date of receipt and the observed
        sample condition at the time of receipt  must be described on the
        Chain-of-Custody form.  Any internal laboratory tracking document
        should be included.

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I.D.     Summary of Environmental Results
        The following information is  to  be  included in the  summary of  results
        for each environmental sample.   The summary should  follow the  CLP
        format if possible,  but other formats  are  acceptable provided  that  all
        necessary information is included.

        °  Client's sample identification and  the  corresponding laboratory
           identification

        «  Sample matrix

        o  Date of sample extraction, as applicable

        °  Date and time of analysis

        o  Identification of the instrument used for analysis

        o  GC column and detector specifications

        o  Weight or volume of sample used  for analysis/extraction

        o  Dilution or concentration  factor for the samples

        o  Percentage of moisture in  the soil  samples

        o  Method detection limits (MDL) or sample quantitation limits

        °  Definitions for any data qualifiers used

        o  Analytical results

I.E.     Summary of QA/QC Results

        The following QA/QC results will be presented in a  summary.  These
        summaries should follow the CLP  format, if possible.  Other formats
        may be acceptable provided that  all necessary information is included
        and the summary is easy to follow.   These  summaries will require to
        have all the information stated  in  Section I.D.

        I.E.I.   Instrument Calibration  (for each  instrument used)

                 Initial Calibration

                 Report the concentrations  of  the  initial calibration
                 standards and the date  and time of analysis.  List the
                 response factor (RF), percent relative standard deviation
                 (%RSD),  and retention time (for GC analyses) for each
                 analyte.

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         Daily Calibration and Mid-level Standard
         Report the concentration of the calibration standard used for
         the daily calibration and for the mid-level standard, and the
         date and time of analysis.   List the response factor (RF) ,
         percent difference (%D),  and retention time (for GC analyses)
         for each analyte.

I.E.2.   Method Blank Analysis

         List the environmental samples and QC analyses associated
         with each method blank.   Report the concentrations of any
         analytes found in the method blanks.

I.E.3.   Surrogate Standard Recovery

         Report the name and concentration of each surrogate compound
         added.  List the percent recoveries of all surrogates in the
         samples, method blanks,  matrix spike/matrix spike duplicates
         and other QC analyses.

I.E.4.   Precision and Accuracy

         o  Matrix spike/matrix spike duplicate (MS/MSD) analysis

         Report the name and concentration of each spiking compound.
         .Samples are to be spiked with all specified compounds of
         interest.  List the sample results, spiked sample results,
         percent recovery and the relative percent difference (RPD).

         o  Laboratory duplicate  analysis, as applicable.

         Report the relative percent difference (RPD) between
         duplicate analyses.

         o  Laboratory QC check sample analysis

         Report the percent recovery for each analyte in the
         laboratory QC check sample.  List the acceptable control
         limits.

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        I.E.5.    Other  QC  Criteria

                 e   Retention time  windows  determination  (GC)

                 Report the  retention time  window for  each analyte,  for both
                 primary and confirmation analyses.

                 Retention time  windows  are established by performing 3
                 analyses  of standards for  all  analytes being  measured
                 throughout  the  course of a 72-hour  period. The retention
                 time window is  defined as  plus or minus  3 times the standard
                 deviation of the  absolute  retention time.  Retention time
                 windows are to  be  updated  daily.

                 o   Compound identification (GC)

                 Report the  retention times and the  concentrations  of each
                 analyte detected  in the samples for both primary and
                 confirmation analyses.

                 o   Method detection limits (MDL) determination

                 List the  method detection  limits.

                 Method detection  limits are determined by performing at least
                 7  analyses  of standards for all analytes measured at 2-5
                 times  the required detection limit  concentrations.   The
                 method detection  limits are calculated as 3 times  the
                 standard  deviation of the  measured  values.  Refer to 40 CFR
                 Part 136  Appendix  B.

I.F.     Raw Data

        I.F.I.    GC Analyses

                 This section shall include legible  copies of the raw data for
                 the following:

                 o   Environmental  samples (arranged  in increasing client's
                    sample number  order).

                 The raw data for  both the  primary and confirmation analyses
                 are to be included.

                 °   Instrument calibrations

                 o   QC  analyses

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         e  Sample extraction  and  clean-up  logs

         «>  Instrument analysis  logs  for  each  instrument  used

         «  GC/MS confirmation,  as applicable

         The raw data for each analysis  shall  include the following:

         o  Chromatograms (label all  analyte peaks, internal  standards
            and surrogate standards with chemical names)

         o  Area print-outs or quantitation reports

I.F.2.    GC/MS Analyses

         This section shall include legible copies of che raw data ror
         the following:

         «>  Environmental samples  (arranged in increasing client's
            sample number order)

         o  Mass and spectrometer  tuning and mass calibration (BFB;
            DFTPP)

         a  Initial and continuing instrument  calibrations

         «  QC analyses

         o  Sample extraction and clean-up logs

         o  Instrument analysis logs  for each  instrument used

         The raw data for each analysis shall  include the following:

         e  Chromatograms (label all  analyte peaks,  internal  standards
            and surrogate standards with chemical names)

         o  Enhanced spectra of target analytes and  tentatively
            identified compounds (TICs), with the associated  best-
         match spectra

         e  Quantitation reports

Legible copies of the raw data shall  be organized systematically,  and
each page shall be numbered.  The raw data for compound  identification
and quantitation must be sufficient to verify each result presented in
Sections I.D. and I.E.

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                                                                         I
                 I.G.  SUMMARY OF DOCUMENTATION REQUIREMENTS

                                 Organic  Data
Section I.

Section II.
                Case Narrative
                Chain-of-Custody Documentation

                1.    Chain-of-Custody forms
                2.    Internal tracking documents,  as  applicable

Section III.     Summary of Results  -  Forms  for the following:

                1.    Environmental  samples,  with  quantitation  limits
                     (include dilutions and  re-analyses)

Section IV.      QA/QC Results Summaries

                1.    Initial  calibration
                2.    Continuing calibration
                3.    Method blanks
                4.    Surrogate recoveries
                5.    Matrix spike (MS)
                6.    Laboratory duplicate or matrix spike  duplicate  (MSD)
                7.    Laboratory QC  check sample,  if applicable
                8.    Retention time windows
                9.    Method detection limits (MDL)

Section V.       Raw Data -  chromatograms and area/quantitation reports

                1.    Environmental  samples  (include dilutions  and re-analyses)
                2.    Instrument tuning,  for  mass  spectrometry  (GC/MS)  analyses
                3.    Initial  calibration
                4.    Continuing calibration
                5.    Method blanks
                6.    Surrogate recoveries
                7.    Matrix spike (MS)
                8.    Laboratory duplicate or matrix spike  duplicate  (MSD)
                9.    Laboratory QC  check sample,  as applicable
                10.   Retention time windows
                11.   Percent  moisture for soil samples
                12.   Sample extraction and clean-up logs
                13.   Instrument analysis log for  each instrument used

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                           II.  INORGANIC ANALYSES

II.A.   Documentation

        The data package submitted for EPA data validation will consist of
        five (5) sections:

              ®  Case narrative

              «  Chain-of-Custody documentation

              o  Summary of results for environmental samples
                 (including quantitation limits)

              e  Summary of QA/QC results

              o  Raw data

II.B.   Case Narrative

        The case narrative will be written on laboratory letterhead and the
        release of data will be authorized by the laboratory manager or
        his/her designee.  The Case Narrative will consist of the following
        information:

              •  Client's sample identification and the corresponding
                 laboratory identification

              •  Parameters analyzed for each sample and the methodology used;
                 when applicable, cite EPA method numbers

              »  Whether the holding times were met or exceeded

              •  Detailed description of all problems encountered

              ®  Discussion of possible reasons for any QA/QC criteria outside
                 acceptance limits

              e  Observations regarding any occurrences which may affect
                 sample integrity or data quality

II.C.   Chain-of-Custody Documentation

        Legible copies of Chain-of-Custody forms for each sample shall be
        submitted in the data package.  The date of receipt and the observed
        sample condition at the time of receipt must be described on the
        Chain-of-Custody form.

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II.D.    Summary of Environmental Results
        The following information is to be included in the summary of results
        for each environmental sample.   The summary should follow the CLP
        format if possible, but other formats are acceptable provided that all
        necessary information is included.

              «  Client's sample identification and the corresponding
                 laboratory identification

              o  Sample matrix

              ®  Date of sample digestion, as applicable

              e  Date and time of analysis

              e  Identification of the instrument used for analysis

              o  Instrument specifications

              e  Weight or volume of sample used for analysis/digestion

              e  Dilution or concentration factor for the samples

              «  Percentage of moisture in the soil samples

              e  Instrument detection limits  (IDL) or method detection limits
                 (MDL)

              o  Definitions for any data qualifiers used

              e  Analytical results

II.E.   Summary of QA/QC Results

        The following QA/QC results will  be  presented  in  a  summary.   These
        summaries should follow  the CLP format,  if possible.  Other  formats
        are acceptable provided  that all  necessary information  is  included and
        the summary  is easy to follow.  These summaries will require  to  have
        all information stated in Section II.D.

        II.E.I.  Instrument Calibration

                 The order of reporting of calibrations for each analyte must
                 follow the temporal order in which  the standards  were
                 analyzed.

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          Initial Calibration Verification
         Report the source for the calibrations standards.  Report the
         concentration for the true value, the concentration found,
         and the percent recovery for each element analyzed.  Record
         the date and time of analysis.

         Continuing Calibration Verification

         Report the source for the calibrations standards.  Report the
         concentration for the true value, the concentration found,
         and the percent recovery for each element analyzed.  Record
         the date and time analysis.

         Report results for (low-level) standards used to verify
         instrument sensitivity (that the reported detection limits
         can be achieved) in the manner described for continuing
         calibration verification.

II.E.2.  Method Blank Analysis

         Report analyte concentrations found in the initial
         calibration blank (ICB), the continuing calibration blank
         (CCB), and in the preparation blank.  Record the date and
         time of analysis.

         The order of reporting ICB and CCB for each analyte must
         follow the temporal order in which the blanks were analyzed.

II.E.3.  ICP Interference Check Sample

         Identify the source for the interference check sample.
         Report the true  value,  the initial and final results and the
         calculated percent recovery.

II.E.4.  Precision and Accuracy

         o   Matrix spike  (MS)  analysis

         Report the concentration of the spiked sample result,  the
         sample result and  the spiking solution added for each element
         in the predigestion spike.   Calculate  and report the percent
         recovery  and list  the control limits.

         e   Post Digest Spike

         In addition to matrix spikes,  post-digest spikes are analyzed
         during furnace, analysis.   Report  the concentration of the
         spiked sample  result,  the sample  result,  and the spiking

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         solution added  for  each  element.  Calculate  and  report  the
         percent  recovery and list  the control  limits.

         o   Laboratory Duplicate  Analysis

         Report the  original concentration,  duplicate concentration
         and relative percent difference  (RPD).   List the control
         limits.

         o   Laboratory Control Sample

         Identify the source for  the  laboratory control sample.
         Report the  concentration of  the  spiked sample result,  the
         sample results  and  the spiking solution added for  each
         element  analyzed.   Calculate  and report the  percent  recovery
         and list the control limits.

         The laboratory  control check sample is prepared in the same
         way as the  analytical samples.

II.E.5.   Other QC Criteria

         o   Method of Standard Additions  (MSA)

         This summary must be included when  MSA analyses are  required.
         Report the  absorbance values with corresponding concentration
         values.   Report the final  analyte concentration and list the
         correlation coefficient.

         «   ICP serial  dilution

         Report the  initial  and serial dilution results and the
         percent  difference.

         «   ICP Linear  Ranges

         For each instrument and wavelength  used, report the date on
         which the linear ranges were established, the integration
         time, and the  upper limit  concentration.

         o   ICP Interelement Correction Factors

         For each instrument and wavelength  used, report the date on
         which the correction factors were determined.   List the
         interelenient correction factors  for Al, Ca,  Fe, Mg and  any
         other element  and the analytes to which they  are applied.

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                 ®  Instrument detection limits  (IDL)  determination

                 List the instrument detection limits.

                 Instrument detection limits  are determined by multiplying by
                 3,  the average of the standard deviations obtained on three
                 nonconsecutive days from the analysis of a standard solution
                 at a concentration 3-5 times the required detection limit
                 concentrations,  with 7 consecutive measurements  per day.
                 Refer to the 40 CFR Part 136 Appendix B.
II.F.    Raw data
        This section shall include  legible  copies  of the raw data for the
        following:

        o  Environmental samples  (arranged  in increasing client's sample
           number order)

        o  Instrument calibrations

        o  QC analyses

        o  Sample preparation and digestion logs

        o  Instrument analysis logs  for  each instrument used

        °  Percent  moisture  in the  soil  samples

        The raw data for each analysis shall include the following:

        o  Measurement print-outs and quantitation reports  for  each  instrument
           used

        o  Absorbance,  titrimetric,  or other measurements for wet chemical
           analysis

        Legible copies  of the raw data shall be organized systematically,  and
        each page shall be numbered.  The raw data for  compound identification
        and quantitation must be  sufficient  to verify each  result presented in
        Sections  II.D.  and II.E.

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                 II.G.   SUMMARY OF DOCUMENTATION REQUIREMENTS

                                Inorganic Data
Section I.       Case Narrative

Section II.      Chain-of-Custody Documentation

                1.   Chain-of-Custody forms
                2.   Internal tracking documents,  as applicalbe

Section III.     Summary of Results - Forms for the following:

                1.   Environmental samples, with quantitation limits
                    (include dilutions and re-analyses)

Section IV.      QA/QC Result Summaries

                1.   Initial and continuing calibrations
                2.   Method blanks, continuing calibration blanks,  and prep
                    blanks
                3.   ICP interference check sample
                4.   Matrix spike
                5.   Laboratory duplicate
                6.   Laboratory control sample
                7.   Method of standard additions
                8.   ICP serial dilution
                9.   Instrument detection limits
                10.  ICP linear range

Section V.       Raw Data - sequential measurement readout records for ICP,
                graphite furnace AA, flame AA, cold vapor mercury, cyanide,
                and/or other inorganic analyses.

                1.   Environmental samples (including dilutions and reanalyses)
                2.   Initial and continuing calibrations
                3.   Continuing calibration and Preparation blanks
                4.   Matrix spikes
                5.   Post digest spikes
                .6.   Method of standard additions, when applicable
                7.   Laboratory duplicate or matrix spike duplicates
                8.   ICP Serial Dilution
                9.   Laboratory control samples, when applicable
               10.   Percent moisture for soil samples
               11.   Sample digestion and/or sample preparation logs
               12.   Instrument analysis log, for each instrument used
               13.   Instrument tuning for ICP-MS, when applicable

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                         III.   QC REQUIREMENTS SUMMARY

                        III.A.  GC/MS Organic Analyses


QC limits, unless specified below,  shall be according to the analytical
methods.  When QC limits are not specified in the methods,  good laboratory
practices (GLP) are to be followed.  Re-analyses may be necessary when QC
limits are not met.

1.    Instrument Tuning

           o  At the beginning of each day that samples are analyzed

2.    Initial Calibration

           °  At the beginning of the QC program

           °  Whenever percent difference (%D) of the response factors for
              specified compounds of interest or calibration check compounds
              (CCC; a minimum of 5  compounds total)  between continuing
              calibration and initial calibration exceeds +25%

           °  Whenever the response factors for specified compounds of
              interest or system performance check compounds (SPCC; a minimum
              of 5 compounds total) are less than 0.300 (0.250 for bromoform)
              for volatiles or less than 0.050 for semi-volatiles analyses

           0  After installation of a new column or  after maintenance
              service/repair of the gas chromatography/mass spectromecry
              (GC/MS)

3.    Continuing Calibration

           0  Prior to the analysis of environmental samples, on each 12-hour
              shift that samples are analyzed

4.    Method Blank

           0  Volatiles:   After each continuing calibration analysis and after
              the analyses of unusually concentrated samples, to demonstrate
              that the system is free of contamination.

           o  Semi-volatiles:   One  for each extraction  batch of 20 or fewer
              samples,  for each sample matrix.   Analyze method blanks on all
              instruments used for  sample analysis.

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           ®   Method blanks  should not  contain  any  analytes  of  interest and
              are to be free of interfering peaks.

5.     Calibration Range

           ©   For samples containing one  or more  analytes  at concentrations
              above the initial calibration range,  the samples  are  to be
              diluted and re-analyzed.

6.     Surrogate Standard

           ©   Surrogate standards (3 for  volatiles; 3 phenolic  and  3  neutral
              compounds for semi-volatiles) are to  be added to  the  calibration
              standards, method blanks, environmental samples and QC  samples.

7.     Internal Standard

           o   Internal standards (3 for volatiles and 6 for semi-volatiles)
              are to be added to the calibration standards,  method blanks,
              environmental samples and QC samples.

           e   If the extracted ion chromatogram profile (EICP)  area  for any of
              the internal standards changes  by a factor of two (-50% to
              +100%) from the last continuing calibration, re-analysis of the
              samples  is required after corrective action.

8.    Matrix Spike  (MS) Analysis

           e  For each extraction/analysis batch of  20 or fewer samples,  for
              each  sample matrix

           e  MS solutions  are to contain all  specified compounds of interest.

9.    Sample Duplicate or Matrix  Spike Duplicate (MSD) Analysis

           e  For each extraction/analysis batch of  20 or fewer samples,  for
              each  sample matrix

 10.   Laboratory QC Check Sample

           ©  At the beginning of the  QC program and as needed

 11.   Method  Detection Limits  Determination

           e  At the beginning of the  QC program and as needed

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                        III.  QC REQUIREMENTS SUMMARY

                           III.B.  Pesticides/PCBs


QC limits, unless specified below,  shall be according to the  analytical
methods.  When QC limits are not specified in the methods,  good laboratory
practices (GLP) are to be followed.   Re-analyses may be necessary when QC
limits are not met.

1.     Initial Calibration

            »  At beginning of the QC program

            o  Whenever the percent difference (%D) in calibration factors
               (CF) between continuing calibration and initial calibration
               exceeds ±15%

            o  After installation of a new column or after maintenance
               service/repair of the gas chromatography (GC)

2.     Daily Calibration

            
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       Surrogate  Standard
            «   Surrogate standards  are  to be  added  to  the calibration
               standards,  method blanks, environmental  samples  and QC  samples.

7.      Matrix  Spike (MS) Analysis

            e   For each extraction batch of 20 or fewer samples,  for each
               sample matrix

            «   MS solutions are to contain  all specified compounds  of
               interest.

8.      Sample  Duplicate or Matrix Spike Duplicate (MSD) Analysis

            •   For each extraction batch of 20 or fewer samples, for each
               sample matrix

9.     Laboratory QC Check Sample

            o  At beginning of  the QC program and as needed

10.    Retention Time Windows Determination

            e  For each GC column, to be updated daily

11.    Method  Detection Limits  Determination

            e  At  beginning of  the QC  program and  as  needed

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                        III.  QC REQUIREMENTS SUMMARY

                       III.C.   Purgeable Organics by GC


QC limits, unless specified below,  shall be according to the analytical
methods.  When QC limits are not specified in the methods,  good laboratory
practices (GLP) are to be followed.   Re-analyses may be necessary when QC
limits are not met.

1.     Initial Calibration

            °  At beginning of the  QC program

            e  Whenever the percent difference (%D) in calibration factors
               (CF) between continuing calibration and initial calibration
               exceeds +15%

            •  After installation of a new column or after maintenance
               service/repair of the gas chromatography (GC)

2.     Daily Calibration

            »  Prior to the analysis of environmental samples, on each day
               that samples are analyzed

3.     Mid-level Standard

            °  After each group of  10 samples

4.     Method Blank

            o  After each daily calibration and mid-level standard analysis
               and after the analyses of unusually concentrated samples,  to
               demonstrate that the system is free of contamination.

            o  Method blanks should not contain any analytes of interest and
               are to be free of interfering peaks.

5.     Calibration Range

            o  For samples containing one or more analytes at concentrations
               above the initial calibration range, the samples are to be
               diluted and re-analyzed.

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       Surrogate Standard
            °  Surrogate standards  are to be added to the  calibration
               standards,  method blanks,  environmental samples and QC samples.

7.      Matrix Spike (MS) Analysis

            «  For each analysis batch of 20 or fewer samples, for each sample
               matrix

            «  MS solutions are to  contain all specified compounds of
               interest.

8.      Sample Duplicate or Matrix Spike Duplicate (MSD) Analysis

            «  For each analysis batch of 20 or fewer samples, for each sample
               matrix

9.      Laboratory QC Check Sample

            •  At beginning of the  QC program and as needed

10.    Retention Time Windows Determination

            •  For each GC column,  to be updated daily

11.    Method Detection Limits Determination

            «  At beginning of the QC program and as needed

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                        III.  QC REQUIREMENTS SUMMARY

                           III.D.  Metals Analyses


QC limits,  unless specified below,  shall be  according to the analytical
methods.   When QC limits are not specified in the methods,  good laboratory
practices (GLP) are to be followed.   Re-analyses may be necessary when QC
limits are not met.

1.    Initial Calibration

            e  Daily and each time the instrument is set up

            ®  Whenever the percent difference between the initial calibration
               and the continuing calibration exceeds 10% (20% for mercury)

            «  Whenever the percent difference between either of the ICP
               interference check samples and the true value exceeds 20%

            °  Blank standard required as part of initial calibration

2.    Continuing Calibration Verification Standard

            s  After every ten or fewer samples

            ®  Analyses are required to have calibrations with acceptable
               recoveries  (the percent difference between  the  initial
               calibration and the continuing calibration  less than  10%  [20%
               for mercury]) before and after the sample analysis.

3.    Blanks

            a  Continuing calibration blank run  immediately  following
               continuing calibration verification  standard

            *  Method blank for each preparation batch  of  20 or  fewer samples,
               for each sample matrix

U.    ICP Interference Check Sample

            »  At  the beginning and at  the end of the analytical run

            o  ICP analyses are required  to have both ICP  interference check
               samples with acceptable  recoveries (the  percent difference
               between the true value and the ICP interference check sample
               less than 20%).

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5.     Calibration Range
            o  For samples containing one or more analytes at concentrations
               above the initial calibration range,  the samples are to be
               diluted and re -analyzed.
6.    Matrix Spike (MS) Analysis
               For each preparation batch of 20 or fewer samples, for each
               sample matrix

               MS solutions are to contain all specified compounds of
               interest.
      Sample Duplicate Analysis
            o  For each preparation batch of 20 or fewer samples, for each
               sample matrix

8.    Laboratory Control Sample (LCS)

            o  For each preparation batch of 20 or fewer samples, for each
               sample matrix

            o  Analyses are required to have the laboratory check sample with
               acceptable recoveries (the percent difference between the true
               value and the laboratory check sample less than 20%).

            °  Laboratory control samples are not required for mercury or
               cyanide determinations.

9.    Graphite Furnace Post Digest QC

            o  A post digest spike at 10 to 20 ug/L  is  required  for all
               furnace analyses.  If the result is greater than  or  equal to  10
               ug/L  in the digestate and the recovery of the spike  is not
               within 85% to 115%, the method of standard additions is
               required to be used.

            o  If  the method of standard additions correlation coefficient  is
               less  than 0.995, the method of standard  additions analysis  is
               required to be repeated once.

10.   ICP  Serial Dilution

            o  For each preparation batch of 20 or fewer samples,  for  each
               sample matrix, dilute the digestate by  five and re-analyze.

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