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
               DSEPA Region 9
         San Francisco, California
                Prepared by:
              Santiago M. Lee
      ESAT/ICF Technology Incorporated
             San Francisco. CA

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TABLE OF CONTENTS

Introduce ion 	
Z . Organic
I. A.
I.B.
i.e.
Z.D.
I.E.





I.F.


i.e.


Analyses

Case Narrative 	

Summary of Environmental Results 	
Summary of QA/QC Results 	
I.E.I. Instrument Calibration 	
I.E. 2. Method Blank Analysis 	
I.E. 3. Surrogate Standard Recovery...
I. E.4. Precision and Accuracy 	
I.E. 5. Other QC Analyses 	

I.F.I. CC Analyses 	
I.F. 2. CC/MS Analyses 	 	 	
Summary of Documentation Requirements . .
XI. Inorganic Analyses
II. A.
II. B.
II. C.
II. D.
II. E.





II. F.
II. C.
Documentation 	
Case Narrative 	
Chain -of -Custody Documentation 	
Summary of Environmental Results 	
Summary of QA/QC Results 	
II. E.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 	
Rav Data 	
Summary of Documentation Requirements..
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III.    QA/QC Requirements Summaries                          1*     0    9/89




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




        XXI.B.  Pesticides and FCBs	       16     0    9/89




        IIX.C.  Furgeables by GC	       16     0    9/89




        XXX.D.  Metals Analyses	       20     0    9/89
                                      Li

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                                                     Section No.:
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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:

        •  Integrity and stability of the samples

        •  Instrument performance during sample analysis

        •  Possibility of sample contamination

        •  Identification and quantitation of analytes

        •  Precision

        •  Accuracy of the analytical results

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                             I.  ORGANIC ANALYSES

 I. A.    Documentation

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

        •  Case narrative

        •  Chain-of-Custody documentation

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

        •  Summary of QA/QC results

        •  Raw data

 I.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: vhen
           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

        •  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 ocher formats  are  acceptable provided  thac  all
        necessary information is included.

        •  Client's sample identification and  the  corresponding laboratory
           identification

        •  Sample matrix

        •  Date of sample extraction, as  applicable

        •  Date and time of analysis

        •  Identification of the instrument used for analysis

        •  GC column and detector specifications

        •  Weight or volume of sample used  for analysis/extraction

        •  Dilution or concentration factor for the samples

        •  Percentage of moisture in Che  soil  samples

        •  Method detection limits (MDL)  or sample quantitation limits

        •  Definitions for any data qualifiers used

        •  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 Kid-level Standard
         Report the concentration of che calibration standard used for
         the daily calibration and for the mid-level standard,  and the
         date and time of analysis.   List che 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

         •  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)

         •  Laboratory duplicate analysis, as applicable.

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

         •  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

                 •   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.

                 •   Compound identification (CC)

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

                 •   Method detection limits (HDL)  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  &0 CFR
                 Part 136  Appendix B.

I.F.     Raw Data

        Z.F.I.    GC Analyses

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

                 •   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

                 •   QC analyses

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         •  Sample extraction and clean-up logs

         •  Instrument analysis logs for each instrument used

         •  GC/KS confirmation, as applicable

         The rav data for each analysis shall include the following:

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

         •  Area print-outs or quantitation reports

I.F.2.   GC/XS Analyses

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

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

         •  Mass and spectrometer tuning and mass calibration (BFfi:
            DFTPP)

         •  Initial and continuing instrument calibrations

         •  QC analyses

         •  Sample extraction and clean-up logs

         •  Instrument analysis logs for each instrument used

         The raw data for each analysis shall include the following:

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

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

         •  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.C.  SUMMARY OF DOCUMENTATION REQUIREMENTS

                                 Organic Data
Seccion I.      Case Narracive

Section II.     Chain-of-Custody Documentation

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

Seccion 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
                6.    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)

Seccion V.      Raw Data -  chromacograms and area/quantization reports

                1.    Environmental  samples (include dilutions  and re-analyses)
                2.    Instrument tuning,  for  mass spectrometry  (GC/MS)  analyses
                3.    Initial calibration
                &.    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

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

              •  Summary of QA/QC results

              •  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

              •  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

              •  Sample matrix

              •  Date of sample digestion,  as  applicable

              •  Date and time of  analysis

              •  Identification of the instrument  used for  analysis

              •  Instrument  specifications

              •  Weight or volume  of  sample used for analysis/digestion

              •  Dilution or concentration  factor  for the samples

              •  Percentage  of moisture  in  the soil  samples

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

              •  Definitions for any  data qualifiers used

              •  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 muse
                 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.  ICF 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

         •  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.

         •  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.

         •  Laboratory Duplicate  Analysis

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

         •  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.S.   Other QC Criteria

         •  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.

         •  ICP Interelement Correction Factors

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

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                                                                     of
                 •  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:

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

        •  Instrument calibrations

        •  QC analyses

        •  Sample preparation and digestion logs

        •  Instrument analysis logs for each instrument used

        •  Percent moisture in the soil samples

        The raw data for each analysis  shall include the following:

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

        •  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.C.  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.
Section V.
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

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

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                         III.  QC REQUIREMENTS SUMMARY

                        III.A.  CC/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 (GLF) are to be followed.  Re-analyses nay be necessary when QC
limits are not met.

1.    Instrument Tuning

           •  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 (SFCC; 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

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

3.    Continuing Calibration

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

4.    Method Blank

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

           •  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 analytcs 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

           •  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.

           •  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

           •  For each extraction/analysis batch of  20 or fever samples, for
              each sample matrix

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

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

           •  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

           •  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 Co  the analytical
methods.  When QC limits are not specified in the  methods,  good laboratory
practices (GLP) are to be followed.   Re-analyses nay be necessary when QC
limits are not met.

1.     Initial Calibration

            •  At beginning of the  QC program

            •  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

            •  Report the percent breakdown for 4,4'-DDT  and for endrin.

A.     Method Blank

            •  For each extraction  batch of 20 or  fewer samples,  for each
               sample matrix.  Analyze method blanks on all instruments  used
               for sample analysis.

            •  Method blanks must demonstrate that the analytical system is
               free of contaminants  and 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.

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6.     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 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

            •  At beginning of the QC program and as needed

10.    Retention Time Vindovs 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.C.   Furgeable 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 (CLP) are to be followed.  Re -analyses may be necessary when QC
limits are not met.

1.     Initial Calibration

            •  At beginning of the  QC program

            •  Whenever the percent difference (%D)  in calibration factors
               (CF) between continuing calibration and initial calibration
               exceeds
            •  After installation of a new column or after maintenance
               service/repair of Che 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

            •  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.

            •  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.

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                                                           Revision No.:    0
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6.     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 tfindows 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 (CLP) are to be followed.   Re-analyses nay be necessary when QC
limits are not net.

1.    Initial Calibration

            •  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 Che  true value exceeds  20% •

            •  Blank standard required as  part of  initial calibration

2.    Continuing Calibration Verification  Standard

            •  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

            •  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

4.    ICP Interference Check Sample

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

            •  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
                                                                             ce)
            •  For samples containing one or more analytes at concentrations
               above the initial  calibration range,  the samples'iarei to be
               diluted and re-analyzed.

6.    Matrix Spike (MS) Analysis

            •  For each preparation batch of 20 or fewer sampllS* fo* tfdfltfir- .
               sample matrix

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

7.    Sample Duplicate Analysis

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

8.    Laboratory Control Sample (LCS)

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

            •  Analyses are required to have the laboratory cKeck sample with
               acceptable recoveries (the percent difference between the true
               value and the laboratory check sample less thfeSf 20%7?crunen"

            •  Laboratory control samples are not required fbWhercury or
               cyanide determinations.

9.    Graphite Furnace Post Digest QC

            •  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 :s$5Lke is -riot'
               within 85% to 115%, the method of standard additions'is
               required to be used.

            •  If the method of standard additions correlatioif fcoefficient  is
               less than 0.995, the method of standard addiC&fcs'-'ttrialysis is
               required to be repeated once.

10.   ICP Serial Dilution

            •  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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