Office of Superfund Remediation and Technology Innovation (OSRTI)
United States Environmental Protection Agency (USEPA)
Washington, DC 20460
  OSWER 9240.1-46
USEPA-540-R-04-009

   January 2005
                                            USEPA Contract Laboratory Program

                                            National
                                            Functional
                                            Guidelines
                                            for Superfund Organic Methods Data Review
                                  Draft Final

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                                          NOTICE

The polices and procedures set forth here are intended as guidance to the United States Environmental
Protection Agency (hereafter referred to as USEPA) and other Governmental employees.  They do not
constitute rule-making by the USEPA, 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 a variance with the policies
and procedures in this manual.
This document can be obtained from the USEPA's Contract Laboratory Program (CLP) Web site at:

                   http://www.epa.gov/superfund/programs/clp/guidance.htm

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                                TABLE OF CONTENTS




INTRODUCTION  	  1




DATA QUALIFIER DEFINITIONS                                                      2




DATA PACKAGE INSPECTION                                                         2




PRELIMINARY REVIEW                                                              3




DATA REVIEW NARRATIVE                                                           4







TRACE VOLATILE DATA REVIEW                                                     5




I.      Preservation	  6




II.     Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check  	  8




III.     Initial Calibration  	  17




IV.     Continuing Calibration Verification (CCV)	  22




V.     Blanks	  26




VI.     Deuterated Monitoring Compounds (DMCs)	  31




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)	  35




VIII.   Regional Quality Assurance (QA) and Quality Control (QC) 	  38




IX.     Internal Standards	  39




X.     Target Compound Identification	  42




XI.     Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs)	  44




XII.    Tentatively Identified Compounds (TICs)  	  46




XIII.   System Performance	  50




XIV.   Overall Assessment of Data  	  52







LOW/MEDIUM VOLATILE DATA REVIEW                                            53




I.      Preservation	  54




II.     Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check  	  57




III.     Initial Calibration  	  66

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                                 TABLE OF CONTENTS




IV.    Continuing Calibration Verification (CCV)	 71




V.     Blanks	 75




VI.    Deuterated Monitoring Compounds (DMCs)	 80




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)	 85




VIII.   Regional Quality Assurance (QA) and Quality Control (QC) 	 88




IX.    Internal Standards	 89




X.     Target Compound Identification	 92




XI.    Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs)	 94




XII.    Tentatively Identified Compounds (TICs) 	 96




XIII.   System Performance	 100




XIV.   Overall Assessment of Data  	 102







SEMIVOLATILE DATA REVIEW	 103




I.      Preservation	 104




II.     Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check 	 107




III.    Initial Calibration 	 116




IV.    Continuing Calibration Verification (CCV)	 121




V.     Blanks	 125




VI.    Deuterated Monitoring Compounds (DMCs)	 130




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)	 135




VIII.   Regional Quality Assurance (QA) and Quality Control (QC) 	 138




IX.    Gel Permeation Chromatography (GPC) Performance Check 	 139




X.     Internal Standards	 141




XI.    Target Compound Identification	 144




XII.    Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs) .... 146




XIII.   Tentatively Identified Compounds (TICs) 	 148






                                            ii

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                                 TABLE OF CONTENTS

XIV.   System Performance	  152

XV.    Overall Assessment of Data 	  154


PESTICIDE DATA REVIEW                                                           155

I.      Preservation	  156

II.     Gas Chromatograph with Electron Capture Detector (GC/ECD) Instrument
       Performance Check	  159

III.     Initial Calibration 	  166

IV.     Continuing Calibration Verification (CCV)  	  173

V.     Blanks	  177

VI.     Surrogate Spikes	  181

VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)	  184

VIII.   Laboratory Control Samples (LCSs)	  187

IX.     Regional Quality Assurance (QA) and Quality Control (QC)  	  189

X.     Florisil Cartridge Performance Check  	  190

XI.     Gel Permeation Chromatography (GPC) Performance Check  	  192

XII.    Target Compound Identification	  195

XIII.   Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation  	  197

XIV.   Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs) ....  199

XV.    Overall Assessment of Data 	  201
                                           in

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                                TABLE OF CONTENTS




AROCLOR DATA REVIEW                                                          202




I.      Preservation	 203




II.     Initial Calibration 	 206




III.     Continuing Calibration Verification (CCV)	 210




IV.     Blanks	 213




V.     Surrogate Spikes	 217




VI.     Matrix Spike/Matrix Spike Duplicates (MS/MSDs)	 220




VII.    Laboratory Control Samples (LCSs)	 223




VIII.   Regional Quality Assurance (QA) and Quality Control (QC)  	 225




IX.     Gel Permeation Chromatography (GPC) Performance Check  	 226




X.     Target Compound Identification	 228




XI.     Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation  	 230




XII.    Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs) .... 232




XIII.   Overall Assessment of Data 	 234







APPENDIX A: GLOSSARY	 235







APPENDIX B: ORGANIC DATA REVIEW SUMMARY	 240
                                          IV

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                                     LIST OF TABLES

Table 1    Holding Time Actions for Trace Volatile Analyses	 7

Table 2.   Ion Abundance Criteria For Bromofluorobenzene (BFB) 	  14

Table 3.   Volatile Compounds Exhibiting Poor Response  	  18

Table 4.   Initial Calibration Actions for Trace Volatiles Analyses	  21

Table 5.   Continuing Calibration Verification (CCV) Actions for Trace Volatiles Analyses	  25

Table 6.   Blank Actions for Trace Volatiles Analyses  	  30

Table 7.   Volatile Deuterated Monitoring Compounds (DMCs) and Recovery Limits	  31

Table 8.   Deuterated Monitoring Compound (DMC) Recovery Actions For
          Trace Volatiles Analyses 	  33

Table 9.   Volatile Deuterated Monitoring Compounds (DMCs) and the
          Associated Target Compounds	  33

Table 10.  Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Trace Volatiles Analysis . .  37

Table 11.  Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) Limits	  37

Table 12.  Internal Standard Actions for Trace Volatiles Analyses 	  41

Table 13.  Holding Time Actions for Low/Medium Volatile Analyses  	  56

Table 14.  Ion Abundance Criteria For Bromofluorobenzene (BFB) 	  63

Table 15.  Volatile Compounds Exhibiting Poor Response  	  67

Table 16.  Initial Calibration Actions for Low/Medium Volatiles Analyses	  69

Table 17.  Continuing Calibration Verification (CCV) Actions for
          Low/Medium Volatiles Analyses	  74

Table 18.  Blank Actions for Low/Medium Volatiles Analyses	  79

Table 19.  Volatile Deuterated Monitoring Compounds (DMCs) and Recovery Limits	  80

Table 20.  Deuterated Monitoring Compound (DMC) Recovery Actions For
          Low/Medium Volatiles Analyses	  82

Table 21.  Volatile Deuterated Monitoring Compounds (DMCs) and the
          Associated Target Compounds	  83

Table 22.  Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for
          Low/Medium Volatiles Analysis 	  87

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                                     LIST OF TABLES

Table 23.   Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) Limits	  87

Table 24.   Internal Standard Actions for Low/Medium Volatiles Analyses	  91

Table 25.   Percent Moisture Actions for Low/Medium Volatiles Analysis For
           Non-Aqueous Samples	  95

Table 26.   Holding Time Actions for Semivolatile Analyses 	  106

Table 27.   Ion Abundance Criteria For Decafluorotriphenylphosphine (DFTPP) 	  113

Table 28.   Semivolatile Target Compounds Exhibiting Poor Response	  117

Table 29.   Initial Calibration Actions for Semivolatile Analyses 	  120

Table 30.   Continuing Calibration Verification (CCV) Actions for Semivolatile Analyses	  124

Table 31.   Blank Actions for Semivolatiles Analyses	  129

Table 32.   Semivolatile Deuterated Monitoring  Compound (DMC) and Recovery Limits  	  130

Table 33.   Deuterated Monitoring Compound (DMC) Recovery Actions For
           Semivolatile Analyses 	  132

Table 34.   Semivolatile Deuterated Monitoring  Compounds (DMCs) and the Associated Target
           Compounds	  133

Table 35.   Semivolatile Deuterated Monitoring  Compounds (DMCs) for Selective Ion
           Monitoring (SIM) and the Associated Target Compounds  	  134

Table 36.   Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Semivolatiles Analysis .  . .  137

Table 37.   Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) 	  137

Table 38.   Internal Standard Actions For Semivolatiles Analyses  	  143

Table 39.   Percent Moisture Actions for Semivolatiles Analyses for Non-Aqueous Samples 	  147

Table 40.   Holding Time Actions for Pesticide Analyses	  158

Table 41.   Resolution Check Mixture Components	  159

Table 42.   Performance Evaluation Mixture (PEM) Components	  160

Table 43.   Individual Standard Mixtures A and  B Components	  161

Table 44.   Individual Standard Mixture C Components 	  162
                                             VI

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                                     LIST OF TABLES

Table 45.   Gas Chromatograph with Electron Capture Detector (GC/ECD) Instrument
           Performance Check Actions	 165

Table 46.   Concentration Levels of Calibration Standards 	 167

Table 47.   Initial Calibration Sequence 1  	 168

Table 48.   Initial Calibration Sequence 2  	 169

Table 49.   Initial Calibration Action for Pesticide Analyses	 172

Table 50.   Continuing Calibration Verification (CCV) Action for Pesticide Analyses 	 176

Table 51.   Blank Actions for Pesticide Analyses  	 180

Table 52.   Surrogate Actions for Pesticide Analyses  	 183

Table 53.   Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Pesticide Analysis  	 186

Table 54.   Matrix Spike (MS) Recovery and Relative Percent Difference (RPD)  	 186

Table 55.   Pesticides Laboratory Control Sample (LCS) Spike Compounds and Recovery Limits .  . 187

Table 56.   Laboratory Control Sample (LCS) Recovery Actions	 188

Table 57.   Florisil Cartridge Performance Check Actions	 191

Table 58.   Gel Permeation Chromatography (GPC) Performance Check Actions  	 194

Table 59.   Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation Actions 	 198

Table 60.   Percent Moisture Actions for Pesticides Analyses for Non-Aqueous Samples  	 200

Table 61.   Holding Time Actions for Aroclor	 205

Table 62.   Initial Calibration Sequence	 207

Table 63.   Initial Calibration Action for Aroclor Analyses	 209

Table 64.   Continuing Calibration Verification (CCV) Action for Aroclor Analyses 	 212

Table 65.   Blank Actions for Aroclor Analyses  	 216

Table 66.   Surrogate Actions for Aroclor Analyses  	 219

Table 67.   Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Aroclor Analysis  	 222

Table 68.   Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) Limits	 222

Table 69.   Aroclor Laboratory Control Sample (LCS) Recovery - Aqueous and Non-Aqueous .... 223


                                             vii

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                                    LIST OF TABLES




Table 70.  Laboratory Control Sample (LCS) Recovery Actions	  224




Table 71.  Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation Actions 	  231




Table 72.  Percent Moisture Actions for Aroclors Analyses for Non-Aqueous Samples	  233
                                           Vlll

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                                      ACRONYMS

%D             Percent Difference
ARO            Aroclor
BFB             Bromofluorobenzene
CF              Calibration Factor
CCS             Contract Compliance Screening
CCV            Continuing Calibration Verification
CLP             Contract Laboratory Program
CLP PO         Contract Laboratory Program Project Officer
COC            Chain of Custody
CRQL           Contract Required Quantitation Limit
CSF             Complete SDG File
DCB            Decachlorobiphenyl
DFTPP          Decafluorotriphenylphosphine
DMC            Deuterated Monitoring Compound
DQA            Data Quality Assessment
DQO            Data Quality Objective
GC              Gas Chromatograph
GC/ECD         Gas Chromatograph/Electron Capture Detector
GC/MS          Gas Chromatograph/Mass Spectrometer
GPC            Gel Permeation Chromatography
INDA            Individual Standard Mixture A
INDB            Individual Standard Mixture B
INDC            Individual Standard Mixture C
LCS             Laboratory Control Sample
OSRTI          Office of Superfund Remediation and Technology Innovation
PCBs            Polychlorinated Biphenyls
PE              Performance Evaluation
PEM            Performance Evaluation Mixture
QA              Quality Assurance
QAC            Quality Assurance Coordinator
QAPP           Quality Assurance Project Plan
QC              Quality Control
RIC             Reconstructed Ion Chromatogram
RPD             Relative Percent Difference
RRF             Relative Response Factor
RRT            Relative Retention Time
RSCC           Regional Sample Control Center
RSD             Relative Standard Deviation
RT              Retention Time
SAP             Sampling and Analysis Plan
SCP             Single Component Pesticide
SDG             Sample Delivery Group
SIM             Selected Ion Monitoring
                                           IX

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                                     ACRONYMS

SMO           Sample Management Office
SOP            Standard Operating Procedure
SOW           Statement of Work
TCX           Tetrachloro-m-xylene
TIC            Tentatively Identified Compound
TR             Traffic Report/Chain of Custody Record
USEPA         United States Environmental Protection Agency
UV             Ultraviolet
VTSR          Validated Time of Sample Receipt

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                                       INTRODUCTION

This document is designed to offer the data reviewer guidance in determining the usability of analytical
data generated through the Contract Laboratory Program's (CLP) Statement of Work (SOW) for Multi-
Media, Multi-Concentration Organics Analysis (SOM01.0), and any future editorial revisions of
SOM01.0, hereinafter referred to as the SOM01.0 SOW. The guidance is somewhat limited in scope and
is intended to be used as an aid in the formal technical review process.  It should not be used to establish
specific contract compliance (use of this document to evaluate data generated under Organic SOWs other
than the SOM01.0 SOW is cautioned). Definitive guidance is provided where performance should be
fully under a laboratory's control (e.g., blanks, calibration standards, instrument performance checks),
while general guidance is provided for evaluating subjective data that is affected by the site conditions.

The guidelines presented in the document will aid the data reviewer in establishing: (a) if data meets the
specific technical and quality control (QC) criteria established in the SOW;  and (b) the usability of any
data not meeting the specific technical and QC criteria established in the SOW. It must be understood by
the reviewer that acceptance of data not meeting technical requirements is based upon many factors,
including, but not limited to, site-specific technical requirements, the need to facilitate  the progress of
specific projects, and availability for resampling.  To make judgments at this level requires the reviewer
to have a complete understanding of the intended use of the  data.  The reviewer is strongly encouraged to
establish a dialogue with the user to discuss usability issues  and to answer questions regarding the review,
prior to, and after data review.  It should also be understood that in all cases, data which do not meet
specified criteria are never to be fully acceptable without qualification.

The data reviewer should note that while this document is to be used as an aid in the formal data review
process, other sources of guidance and information, as well as professional judgment, should also be used
to determine the ultimate usability of data, especially in those cases where all data does not meet specific
technical criteria.  The reviewer should also be aware that minor modifications to the analytical methods
may be made through the CLP's Request For Quote For Modified Analysis  form to meet site-specific
requirements, and that these modifications could affect certain validation criteria such as the Contract
Required Quantitation Limits (CRQLs), initial calibration levels, Continuing Calibration Verification
(CCV) levels, and Target Compound Lists (TCLs). A full copy of a request for modified analysis made
to the analytical method should be included in the data package by the laboratory.
January 2005                                   1                                     Draft Final

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                              DATA QUALIFIER DEFINITIONS

The following definitions provide brief explanations of the national qualifiers assigned to results in the
data review process. If the Regions choose to use additional qualifiers, a complete explanation of those
qualifiers should accompany the data review.
   U
The analyte was analyzed for, but was not detected at a level greater than or equal to the level
of the adjusted Contract Required Quantitation Limit (CRQL) for sample and method.
         The analyte was positively identified and the associated numerical value is the approximate
         concentration of the analyte in the sample (due either to the quality of the data generated
         because certain quality control criteria were not met, or the concentration of the analyte was
         below the CRQL).
   NJ
The analysis indicates the presence of an analyte that has been "tentatively identified" and the
associated numerical value represents its approximate concentration.
   UJ
The analyte was not detected at a level greater than or equal to the adjusted CRQL.  However,
the reported adjusted CRQL is approximate and may be inaccurate or imprecise.
   R
The sample results are unusable due to the quality of the data generated because certain
criteria were not met. The analyte may or may not be present in the sample.
         This qualifier applies to pesticide and Aroclor results when the identification has been
         confirmed by Gas Chromatograph/Mass Spectrometer (GC/MS).
   X
This qualifier applies to pesticide and Aroclor results when GC/MS analysis was attempted
but was unsuccessful.
                               DATA PACKAGE INSPECTION

For data obtained through the CLP, the Data Assessment Tool (DAT) report is a useful tool in the data
review process. The DAT report incorporates Contract Compliance Screening (CCS) and computer-aided
data evaluation results and is transmitted via the Data Assessment Rapid Transmittal (DART) system.
For more information about the DAT report, please refer to the following USEPA Web site:

                        http://www.epa.gov/superfund/programs/clp/dat.htm

The DAT report will identify any missing and/or incorrect information in the data package. The CLP
laboratory may submit a reconciliation package for any missing items or to correct data.

To obtain the DAT report and/or the reconciliation package, or if there are any other concerns regarding
the data package, contact the Contract Laboratory Program Project Officer (CLP PO) from the Region
where the samples were taken.  For personnel contact information, please refer to the following USEPA
Web site:

                      http://www.epa.gov/superfund/programs/clp/contacts.htm
January 2005
                                                                          Draft Final

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                                  PRELIMINARY REVIEW

This document is for the review of analytical data generated through the SOMO1.0 SOW and any future
editorial revisions of SOM01.0. To use this document effectively, the reviewer should have an
understanding of the analytical method used and a general overview of the Sample Delivery Group (SDG)
or sample Case at hand. The exact number of samples, their assigned numbers, their matrix, and the
number of laboratories involved in their analyses are essential information.

It is suggested that an initial review of the data package be performed taking into consideration all
information specific to the data package (flexible analysis approval notices, Traffic Report/Chain of
Custody Records (TR/COCs), SDG Narratives, etc.).

The reviewer should also have a copy of the Quality Assurance Project Plan (QAPP) or similar document
for the project for which samples were analyzed. The reviewer should contact the appropriate Regional
Contract Laboratory Program Project Officer (CLP PO) to obtain copies of the QAPP and relevant site
information. This information is necessary in determining the final usability of the analytical data.

Sample Cases (SDGs) routinely have unique field quality control (QC) samples which require special
attention from the reviewer. These include field and trip blanks, field duplicates, and Performance
Evaluation (PE) samples which must be identified.  The sampling records (e.g., TR/COC Records, field
logs, and/or contractor tables) should identify:

    1.  The Region where the samples were taken,

    2.  The Case number,

    3.  The complete list of samples, with information on:
       a. Sample matrix;
       b. Field Blanks (i.e., equipment blanks or rinsate blanks) and trip blanks;
       c. Field duplicates;
       d. Field spikes;
       e. QC audit samples;
       f  Shipping dates;
       g. Preservatives; and
       h. Laboratories involved.

The TR/COC Record includes sample descriptions and date(s) of sampling.  The reviewer must consider
lag times between sampling and start of analysis when assessing technical sample holding times.

The laboratory's SDG Narrative is another source of general information.  Notable problems with
matrices, insufficient sample volume for analysis or re-analysis, samples received in broken containers,
preservation, and unusual events should be documented in the SDG Narrative. The reviewer should also
inspect any email correspondence, telephone, or other communication logs detailing any discussions of
sample preparation  and/or analysis issues between the laboratory, CLP Sample Management Office
(SMO) and the USEPA Region.
January 2005                                 3                                    Draft Final

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                                DATA REVIEW NARRATIVE

A Data Review Narrative, including the Organic Data Review Summary form, (see Appendix B) must
accompany the laboratory data forwarded to the intended data recipient (client) or user to promote
communications. A copy of the Data Review Narrative should be submitted to the Contract Laboratory
Program Project Officer (CLP PO) assigned oversight responsibility for the laboratory producing the data.

The Data Review Narrative should include comments that clearly identify the problems associated with a
Case or SDG and state the limitations of the data.  Documentation should include the CLP Sample
Number, analytical method, extent of the problem, and assigned qualifiers.
January 2005                                 4                                    Draft Final

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                                                             Trace Volatiles Organic Analysis
                            TRACE VOLATILE DATA REVIEW




The data requirements to be checked are:




I.      Preservation




II.     Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check




III.    Initial Calibration




IV.    Continuing Calibration Verification (CCV)




V.     Blanks




VI.    Deuterated Monitoring Compounds (DMCs)




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)




VIII.   Regional Quality Assurance (QA) and Quality Control (QC)




IX.    Internal Standards




X.     Target Compound Identification




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




XII.    Tentatively Identified Compounds (TICs)




XIII.   System Performance




XIV.   Overall Assessment of Data







NOTE: Language  specific to Selective Ion Monitoring (SIM) analyses is shown in italic.
January 2005                                 5                                   Draft Final

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                                                               Trace Volatiles Organic Analysis
                                        I. Preservation

A.  Review Items:

    Form I VOA-1, Form I VOA-2, Form I VOA-SIM, Form I VOA-TIC, Traffic Report/Chain of
    Custody Records (TR/COCs), raw data, and the Sample Delivery Group (SDG) Narrative checking
    for:

    1.  pH
    2.  Sample temperature
    3.  Holding time
    4.  Other sample conditions (e.g., headspace)

B.  Objective:

    The objective is to ascertain the validity of the analytical results based on sample condition
    (e.g., preservation, temperature, headspace) and the holding time of the sample from the time of
    collection to the time of analysis.

C.  Criteria:

    The technical holding time criterion for aqueous samples are as follows:

    For volatile compounds in properly cooled (4°C ± 2°C) aqueous samples that are acid-preserved (with
    HC1 to a pH of 2 or below), the maximum holding time is 14 days from sample collection.  For
    aqueous samples that were properly cooled (4°C ± 2°C), but which have no indication of being
    preserved, the maximum holding time is seven (7) days from sample collection.

D.  Evaluation:

    Technical holding times are established by comparing the sample collection dates on the TR/COC
    Record with the dates of analysis on Form I VOA-1, Form I VOA-2, Form IVOA-SIM, Form I VOA-
    TIC and the raw data. Information contained in the Complete SDG File (CSF) should also be
    considered in the determination of holding times. Verify that the analysis dates on Form I(s) and the
    raw data/SDG file are identical. Review the  SDG Narrative to determine if the samples were
    preserved and arrived at the laboratory in proper condition (e.g., received intact, appropriate sample
    temperature at receipt, pH, absence of air bubbles or detectable headspace). If there is no indication
    in the  SDG Narrative, the TR/COC, or the sample records that there was a problem with the samples,
    the integrity of samples can be assumed to be acceptable. If it is indicated that there were problems
    with the samples, the integrity of the sample  may have been compromised and professional judgment
    should be used to evaluate the effect of the problem on the sample results.

E.  Action:

    1.  Qualify sample results using preservation and technical holding time information as follows (see
       Table 1):

       a.   If there is no evidence that the  samples were properly preserved, but the samples were
           analyzed within the technical holding time [seven (7) days from sample collection], no
           qualification of the data is necessary.
January 2005                                  6                                    Draft Final

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                                                                Trace Volatiles Organic Analysis
       b.  If there is no evidence that the samples were properly preserved, and the samples were
           analyzed outside of the technical holding time [seven (7) days from sample collection],
           qualify detects for all volatile compounds with a "J" and non-detects as unusable "R".

       c.  If the samples were properly preserved, and the samples were analyzed within the technical
           holding time [fourteen (14) days from sample collection], no qualification of the data is
           necessary.

       d.  If the samples were properly preserved, but were analyzed outside of the technical holding
           time [fourteen (14) days from sample collection], qualify detects with a "J" and non-detects
           as unusable "R".
                   Table 1. Holding Time Actions for Trace Volatile Analyses
Matrix
Aqueous
Aqueous
Aqueous
Aqueous
Preserved
No
No
Yes
Yes
Criteria
< 7 days
> 7 days
< 14 days
> 14 days
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
No qualification
J
R
No qualification
J
R
    2.  Whenever possible, the reviewer should comment on the effect of the holding time exceedance on
       the resulting data in the Data Review Narrative.

    3.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, when technical holding
       times are exceeded.
January 2005
Draft Final

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                                                             Trace Volatiles Organic Analysis
      II. Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check

A.  Review Items:

    Form V VOA, bromofluorobenzene (BFB) mass spectra, and mass listing.

B.  Objective:

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

    NOTE:    This requirement does not apply when samples are analyzed by the Selected Ion
              Monitoring (SIM) technique.

C.  Criteria:

    1.  The 12-hour clock begins with either the injection of BFB, or in cases where a closing Continuing
       Calibration Verification (CCV) can be used as an opening CCV, the 12-hour clock begins with
       the injection of the opening CCV.

    2.  Listed below are some, but not necessarily all, examples of acceptable analytical sequences
       incorporating the use of the opening and/or closing CCV.  Use these examples as a guide for the
       possible analytical sequences that can be expected. The criteria associated with these analytical
       sequences have been evaluated as part of the Contract Compliance Screening (CCS) process.
 Conditions for When
 Example Sequence is
 Appropriate:
Acceptable Criteria That Must
Be Met:
Notes:
 Use Example 1 if time
 remains on the 12-hour
 clock after the initial
 calibration sequence
    BFB tunes meet instrument
    performance criteria.
    The five Initial Calibration
    standards meet initial
    calibration criteria.
    CCV A meets both opening
    and closing CCV criteria.
    CCV B meets closing CCV
    criteria.
The requirement of starting the new
12-hour clock for Analytical
Sequence 2 with a new BFB tune is
waived if CCV A meets opening
CCV criteria.  If CCV B meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after CCV
B.
January 2005
                                                     Draft Final

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                                                            Trace Volatiles Organic Analysis
 Conditions for When
 Example Sequence is
 Appropriate:
Acceptable Criteria That Must
Be Met:
Notes:
 Use Example 2 if time
 remains on the 12-hour
 clock after the initial
 calibration sequence
•  BFB tunes meet instrument
   performance criteria.
•  The five Initial Calibration
   standards meet initial
   calibration criteria.
•  CCV A meets closing CCV
   criteria (but does not meet
   opening CCV criteria).
•  CCV B meets opening CCV
   criteria.
•  CCV C meets closing CCV
   criteria.
CCV A does not meet opening
CCV criteria, therefore a new BFB
tune must be performed,
immediately followed by CCV B
before a method blank and any
samples may be analyzed. In this
case, the new 12-hour clock and
Analytical Sequence 2 begins with
the injection of the new BFB tune.
 Use Example 3
 if more than 12-hours have
 elapsed since the most
 recent initial calibration or
 closing CCV,

 OR

 if the most recent closing
 CCV was not or could not
 be used as an opening CCV.
•  BFB tunes meet instrument
   performance criteria.
•  CCV A meets opening CCV
   criteria.
•  CCV B meets both opening
   and closing CCV criteria.
•  CCV C meets both opening
   and closing CCV criteria.
The requirement of starting the new
12-hour clock for Analytical
Sequence 2 with a new BFB tune is
waived if CCV B meets opening
CCV criteria. If CCV C meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
 Use Example 4
 if more than 12-hours have
 elapsed since the most
 recent initial calibration or
 closing CCV,

 OR

 if the most recent closing
 CCV was not or could not
 be used as an opening CCV.
•  BFB tunes meet instrument
   performance criteria.
•  CCV A meets opening CCV
   criteria.
•  CCV B meets closing CCV
   criteria (but does not meet
   opening CCV criteria).
•  CCV C meets opening CCV
   criteria.
•  CCV D meets both opening
   and closing CCV criteria.
CCV B does not meet opening
CCV criteria, therefore a new BFB
tune must be performed,
immediately followed by CCV B
before a method blank and any
samples may be analyzed. In this
case, the new 12-hour clock and
Analytical Sequence 2 begins with
the injection of the new BFB tune.
The requirement of starting the new
12-hour clock for Analytical
Sequence 3 with a new BFB tune is
waived if CCV D meets opening
CCV criteria. If CCV D meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
January 2005
                                                    Draft Final

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                                                              Trace Volatiles Organic Analysis
 Example 1:

 Start of 12-hour clock for
 Analytical Sequence 1
 End of 12-hour clock for
 Analytical Sequence I/
 Beginning of 12-hour clock
 for Analytical Sequence 2
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour clock
 for Analytical Sequence 3
Time

 Ohr
      Material Injected
12 hr
24 hr
BFB
                                       Initial Calibration 0.5

                                       Initial Calibration 1.0

                                       Initial Calibration 5.0

                                       Initial Calibration 10

                                       Initial Calibration 20

                                       Method Blank

                                       Subsequent Samples
CCVA
(meets opening CCV criteria)
                                       Method Blank

                                       Subsequent Samples
CCVB
(meets opening CCV criteria)
Analytical Sequence #

          1


          1

          1

          1

          1

          1

          1

          1

          1

          1

          1

          1

         1/2
          2

          2

          2

          2

          2

          2

         2/3
January 2005
               10
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                                                            Trace Volatiles Organic Analysis
Example 2:
Start of 12-hour clock for
Analytical Sequence 1











End of 12-hour clock for
Analytical Sequence 1
Beginning of 12-hour
clock for Analytical
Sequence 2







End of 12-hour clock for
Analytical Sequence 2
Time Material Injected Analytical Sequence #
0 hr BFB 1
Initial Calibration 0.5
Initial Calibration 1.0
Initial Calibration 5.0
Initial Calibration 10
Initial Calibration 20
Method Blank
Subsequent Samples
•
•
•
•
12 hr CCV A
(meets closing CCV criteria;
fails opening CCV criteria)
13 hr BFB
CCVB
(meets opening CCV criteria)
Method Blank
Subsequent Samples
•
•
•
•
25 hr CCV C
(meets closing CCV criteria)
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
January 2005
11
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                                                            Trace Volatiles Organic Analysis
 Example 3:
Time
      Material Injected
Analytical Sequence #
 Start of 12-hour clock for
 Analytical Sequence 1
 0 hr    BFB
 End of 12-hour clock for
 Analytical Sequence I/
 Beginning of 12-hour clock
 for Analytical Sequence 2
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour clock
 for Analytical Sequence 3
12 hr
24 hr
                                    CCVA
                                    (meets opening CCV criteria)

                                    Method Blank

                                    Subsequent Samples
CCVB
(meets opening CCV criteria)
                                    Method Blank

                                    Subsequent Samples
ccvc
(meets opening CCV criteria)
          1


          1


          1

          1

          1

          1

          1

          1

         1/2
         2

         2

         2

         2

         2

         2/3
January 2005
                12
                                           Draft Final

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                                                            Trace Volatiles Organic Analysis
 Example 4:

 Start of 12-hour clock for
 Analytical Sequence 1
Time

 Ohr
       Material Injected
 End of 12-hour clock for
 Analytical Sequence 1


 Beginning of 12-hour
 clock for Analytical
 Sequence 2
12 hr
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour
 clock for Analytical
 Sequence 3
25 hr
BFB
Analytical Sequence #
          1
                                    CCVA
                                    (meets opening CCV criteria)

                                    Method Blank

                                    Subsequent Samples
CCVB
(meets closing CCV criteria;
fails opening CCV criteria)
13 hr    BFB
                                    CCVC
                                    (meets opening CCV criteria)

                                    Method Blank

                                    Subsequent Samples
CCVD
(meets opening CCV criteria)
         2

         2

         2

         2

         2

         2/3
January 2005
                 13
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                                                              Trace Volatiles Organic Analysis
    3.  Inject a sufficient amount of the instrument performance check solution (up to 50 ng BFB on-
       column) at the beginning of each 12-hour period during which samples or standards are analyzed.
       The instrument performance check, BFB for trace volatile analysis, must meet the ion abundance
       criteria listed in Table 2. This criteria is waived in cases where a closing CCV can be used as an
       opening CCV (i.e., a BFB instrument performance check analysis is not required when a closing
       CCV analysis meets the requirements of an opening CCV analysis).

                Table 2. Ion Abundance Criteria For Bromofluorobenzene (BFB)
Mass
50
75
95
96
173
174
175
176
177
Ion Abundance Criteria
15.0 -40.0% of mass 95
30.0 -80.0% of mass 95
Base peak, 100% relative abundance
5.0 -9.0% of mass 95*
Less than 2.0% of mass 174
50.0% -120% of mass 95
5.0 -9.0% of mass 174
95.0- 101% of mass 174
5.0 -9.0% of mass 176
*   All ion abundances must be normalized to mass to charge (m/z) 95, the nominal base peak, even
    though the ion abundance of m/z 174 may be up to 120% that of m/z 95.

D.  Evaluation:

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

       a.   Form V VOA is present and completed for each  12-hour period during which samples were
           analyzed. In cases where a closing CCV is used as an opening CCV for the next 12-hour
           period, an additional Form V VOA is not required.

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

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

       d.   The laboratory has not made any calculation errors.
January 2005
14
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                                                                Trace Volatiles Organic Analysis
    2.  Verify that samples were not analyzed before a valid instrument performance check or were not
       analyzed 12 hours after the injection of the Instrument Performance Check Solution. This
       evaluation is not to be performed in cases where a closing CCV is used as an opening CCV.

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

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

    5.  If possible, verify that spectra were generated using appropriate background subtraction
       techniques.  Since the BFB spectrum is obtained from chromatographic peaks that should be free
       from coelution problems, background subtraction should be done in accordance with the
       following procedure:

       a.  Three scans (the peak apex scan and the scans immediately preceding and following the
           apex) are acquired and averaged.

       b.  Background subtraction is required, and must be accomplished using a single scan no more
           than 20 scans prior to the elution of BFB. Do not subtract the BFB peak as part of the
           background.

           NOTES:   All mass spectrometer instrument conditions must be identical to those used
                      during the sample analysis.  Background subtraction actions resulting in spectral
                      distortions for the sole purpose of meeting the method specifications are contrary
                      to the Quality Assurance (QA) objectives, and are therefore unacceptable.

                      For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the CCS process. Information regarding the
                      laboratory's compliance with these criteria can be obtained from the Data
                      Assessment Tool (DAT) reports, and may be used as part of the evaluation
                      process.

E.  Action:

    1.  If samples are analyzed without a preceding valid instrument performance check or are analyzed
       12 hours after the Instrument Performance Check and are not preceded by an analysis of a closing
       CCV that meets the opening CCV criteria, qualify all data in those samples as unusable  "R".

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

    3.  If the laboratory has failed to provide the correct forms or has made significant transcription or
       calculation errors, the Region's designated representative should contact the laboratory and
       request corrected data. If the information is  not available, the reviewer must use professional
       judgment to assess the data. Notify the laboratory's Contract Laboratory Program Project Officer
       (CLP PO).

    4.  If mass assignment is in error (e.g., m/z 96 is indicated as the base peak rather than m/z 95),
       classify all associated data as unusable "R".
January 2005                                  15                                    Draft Final

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                                                                Trace Volatiles Organic Analysis
    5.  If ion abundance criteria are not met, professional judgment may be applied to determine to what
       extent the data may be utilized. When applying professional judgment to this topic, the most
       important factors to consider are the empirical results that are relatively insensitive to location on
       the chromatographic profile and the type of instrumentation. Therefore, the critical ion
       abundance criteria for BFB are the m/z 95/96, 174/175, 174/176, and 176/177 ratios. The relative
       abundances of m/z 50 and 75 are of lower importance.  This issue is more critical for Tentatively
       Identified Compounds (TICs) than for target analytes.

    6.  Note, in the Data Review Narrative, decisions to use analytical data associated with BFB
       instrument performance checks not meeting contract requirements.

    7.  If the reviewer has reason to believe that instrument performance check criteria were achieved
       using techniques other than those described in Trace Volatiles Organic Analysis, Section II.D.5,
       obtain additional information on the instrument performance checks.  If the techniques employed
       are found to be at variance with the contract requirements, the performance and procedures of the
       laboratory may merit evaluation.  Note, for CLP PO action, concerns  or questions regarding
       laboratory performance.  For example, if the reviewer has reason to believe that an inappropriate
       technique was used to obtain background subtraction (such as background subtracting from the
       solvent front or from another region of the chromatogram rather than  from the BFB peak), note
       this for CLP PO action.
January 2005                                  16                                    Draft Final

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                                                                Trace Volatiles Organic Analysis
                                     III. Initial Calibration

A.  Review Items:

    Form VI VOA-1, Form VI VOA-2, Form VI VOA-3, Form VI VOA-SIM, quantitation reports, and
    chromatograms.

B.  Objective:

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

C.  Criteria:

    1.  Initial calibration standards containing both volatile target compounds and Deuterated Monitoring
       Compounds (DMCs) are analyzed at concentrations of 0.50, 1.0, 5.0,  10, and 20 (ig/L for non-
       ketones, 5.0, 10, 50, 100, and 200 (ig/L for ketones, and 20, 40, 250, 400, and 800 (ig/L for 1,4-
       dioxane at the beginning of each analytical sequence, or as necessary  if the continuing calibration
       verification acceptance criteria are not met.  The initial calibration (and any associated samples
       and blanks) must be analyzed within 12 hours of the associated instrument performance check.
       All three xylene isomers (o-, m-, and p-xylene) must be present in calibration standards.  The o-
       xylene calibration standard concentrations must be at 0.50, 1.0, 5.0, 10 and 20 (ig/L, while the
       concentration of the m-, plus the p-xylene isomers must total 0.50, 1.0, 5.0,  10, and 20 (ig/L.

       If analysis by the Selected Ion Monitoring (SIM) technique is requested for 1,4-dioxane, prepare
       calibration standards containing 1,4-dioxane at concentrations of 2.0, 4.0, 25, 40, and 80 [tg/L.
       If analysis by the SIM technique is requested for all other compounds of interest, prepare
       calibration standards containing the compounds of interest and their  associated DMCs at
       concentrations of 0.05, 0.1, 0.5, 1.0, and 2.0 jUg/L.

    2.  Initial calibration Relative Response Factors (RRFs) for the volatile target compounds listed in
       Table 3 and all DMCs must be greater than or equal to 0.010.  The RRF for all other volatile
       target compounds must be greater than or equal to 0.050.

    3.  The Percent Relative Standard Deviation (%RSD) of the initial calibration RRFs must be less
       than or equal to 40.0% for the volatile  target compounds listed in Table 3 and the associated
       DMCs (see Table 9), except for 1,4-dioxane and its associated DMC (±50.0%). The %RSD for
       all  other volatile target compounds  and associated DMCs must be less than or equal to 30.0%.

       NOTE:    The flexibility clause in the method may impact some of the  preceding criteria. A
                  copy of the  flexibility clause should be present in the Sample Delivery Group (SDG).
                  Refer to the Contract Laboratory Program (CLP) home page at
                  http://www.epa.gov/oerrpage/superfund/programs/clp/modifiedanalyses.htm for the
                  specific method flexibility requirements.
January 2005                                  17                                    Draft Final

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                                                                 Trace Volatiles Organic Analysis
D.  Evaluation:

    1.  Verify that the correct concentrations of standards were used for the initial calibration (i.e., 0.50,
       1.0, 5.0, 10, and 20 (ig/L for non-ketones, 5.0, 10, 50, 100, and 200 (ig/L for ketones, and 20, 40,
       250, 400, and 800 (ig/L for 1,4-dioxane).

       If analysis by the SIM technique is requested, verify that the  correct concentrations of standards
       were used for the initial calibration (i.e., 2.0, 4.0, 20, 40, and 80 ^g/Lfor 1,4-dioxane and
       associatedDMC, 0.05, 0.1, 0.5, 1.0, and 2.0 /ug/L for all other compounds and associated
       DMCs).
    2.  Verify that the RRF obtained from the associated initial calibration was used for calculating
       sample results and the samples were analyzed within 12 hours of the associated instrument
       performance check.

    3.  Evaluate the initial calibration RRFs and the RRFs for all volatile target compounds and DMCs:

       a.  Check and recalculate the RRFs and RRF for at least one volatile target compound associated
           with each internal standard. Verify that the recalculated value(s) agrees with the laboratory
           reported value(s).

       b.  Verify that for the volatile target compounds listed in Table 3 and for all DMCs, the initial
           calibration RRFs are greater than or equal to 0.010, and for all other volatile target
           compounds, RRFs are greater than or equal to 0.050.

                     Table 3.  Volatile Compounds Exhibiting Poor Response
Volatile Compounds
Acetone
2-Butanone
Carbon disulfide
Chloroethane
Chloromethane
Cyclohexane
1,4-Dioxane
1 ,2-Dibromoethane
Dichlorodifluoromethane
cis- 1,2-Dichloroethene
1 ,2-Dichloropropane
l,2-Dibromo-3-chloropropane
Isopropylbenzene
Methyl acetate
Methylene chloride
Methylcyclohexane
Methyl tert-butyl ether
trans- 1 ,2-Dichloroethene
4-Methyl-2-pentanone
2-Hexanone
Trichlorofluoromethane
1 , 1 ,2-Trichloro- 1 ,2,2-trifluoroethane
January 2005
18
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                                                                Trace Volatiles Organic Analysis
    4.  Evaluate the %RSD for all volatile target compounds and DMCs:

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

       b.  If the %RSD is greater than the maximum criteria [40.0% for the volatile target compounds
           listed in Table 3 and associated DMCs listed in Table 9, except for 1,4-dioxane (±50.0%) and
           its associated DMC, and 30.0% for all other volatile target compounds and associated
           DMCs], the reviewer should use professional judgment to determine the need to check the
           points on the curve for the cause of the non-linearity. This is checked by eliminating either
           the high-point or the low-point and recalculating the %RSD (see Trace Volatiles Organic
           Analysis, Section III.E.2).

    5.  If errors are detected in the calculations of either the RRFs or the %RSD, perform a more
       comprehensive recalculation.

       NOTE:    For data obtained from the CLP, the preceding criteria are evaluated as part of the
                  Contract Compliance Screening (CCS) process.  Information regarding the
                  laboratory's compliance with these criteria can be obtained from the Data Assessment
                  Tool (DAT) reports, and may be used  as part of the evaluation process.

E.  Action:

    1.  Qualify all volatile target compounds, including the compounds exhibiting poor response listed in
       Table 3, using the following criteria (see Table 4):

       a.  If any volatile target compound has an RRF value less than the minimum criterion (0.050 for
           the compounds exhibiting poor response listed in Table 3, and 0.050 for all other volatile
           compounds), use professional judgment for detects, based on mass spectral identification, to
           qualify the data as a "J" or unusable "R".

       b.  If any volatile target compound has an RRF value less than the minimum criterion (0.050 for
           the compounds exhibiting poor response listed in Table 3, and 0.050 for all other volatile
           compounds), qualify non-detected compounds as unusable "R".

       c.  If any of the volatile target compounds listed in Table 3 has %RSD greater than 40.0%,
           except for 1,4-dioxane (±50.0%), qualify detects with a "J", and non-detected compounds
           using professional judgment (see Trace Volatiles Organic Analysis, Section III.E.2).

       d.  For all other volatile target compounds, if %RSD is greater than 30.0%, qualify detects with a
           "J", and non-detected compounds using professional judgment (see Trace Volatiles Organic
           Analysis, Section III.E.2).

       e.  If the volatile target compounds meet the acceptance criteria for RRF and the %RSD, no
           qualification of the data is necessary.

       f  No qualification of the data is necessary on the DMC RRF and %RSD data alone. However,
           use professional judgment and follow the guidelines in Trace Volatiles Organic Analysis,
           Section III.E.2, to  evaluate the DMC RRF and %RSD data in conjunction with the DMC
           recoveries to determine the need for qualification of data.
January 2005                                  19                                    Draft Final

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                                                                 Trace Volatiles Organic Analysis
    2.  At the reviewer's discretion, and based on the project-specific Data Quality Objectives (DQOs), a
       more in-depth review may be considered using the following guidelines:

       a.  If any volatile target compound has a %RSD greater than the maximum criterion [40.0% for
           the compounds listed in Table 3, except for 1,4-dioxane (±50.0%), and 30.0% for all other
           volatile compounds], and if eliminating either the high or the low-point of the curve does not
           restore the %RSD to less than or equal to the required maximum:

           i.   Qualify detects for that compound(s) with a " J".

           ii.  Qualify non-detected volatile target compounds using professional judgment.

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

           i.   Qualify detects outside of the linear portion of the curve with a "J".

           ii.  No qualifiers are required for detects in the linear portion of the curve.

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

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

           i.   Qualify low-level detects in the area of non-linearity with a "J".

           ii.  No qualifiers are required for detects in the linear portion of the curve.

           iii.  For non-detected volatile compounds, use the lowest point of the linear portion of the
               curve to determine the new quantitation limit.

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

    4.  Note in the Data Review Narrative, whenever possible, the potential effects on  the data due to
       calibration criteria exceedance.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if calibration criteria are
       grossly exceeded.
January 2005                                  20                                     Draft Final

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                                                             Trace Volatiles Organic Analysis
                Table 4.  Initial Calibration Actions for Trace Volatiles Analyses
        Criteria for Trace Analysis
                                                               Action
                                                  Detected
                                           Associated Compounds
                            Non-Detected
                        Associated Compounds
 RRF< 0.010
 (target compounds listed in Table 3)
 RRF < 0.050 (all other target compounds)
       JorR
   (based on mass
spectral identification)
R
 RRF> 0.010
 (target compounds listed in Table 3)
 RRF > 0.050 (all other target compounds)
               No qualification
 % RSD < 50.0 (1,4-Dioxane)
 % RSD < 40.0
 (target compounds listed in Table 3)
 % RSD < 30.0 (all other target compounds)
               No qualification
 % RSD > 50.0 (1,4-Dioxane)
 % RSD > 40.0
 (target compounds listed in Table 3)
 % RSD > 30.0 (all other target compounds)
                           Use professional
                              judgment
January 2005
21
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                                                               Trace Volatiles Organic Analysis
                        IV.  Continuing Calibration Verification (CCV)

A.  Review Items:

    Form VIIVOA-1, Form VII VOA-2, Form VII VOA-3, Form VII VOA-SIM, quantitation reports, and
    chromatograms.

B.  Objective:

    Compliance requirements for satisfactory instrument calibration are established to ensure that the
    instrument is capable of producing acceptable qualitative and quantitative data. The CCV checks
    satisfactory performance of the instrumenton a day-to-day basis, however, quantitations are based on
    the Mean Relative Response Factors (RRFs ) obtained from the initial calibration.

C.  Criteria:

    1.  The  12-hour clock begins with either the injection of BFB or in cases where a closing CCV can
       be used as an opening CCV, the 12-hour clock begins with the injection of the opening  CCV.

    2.  CCV standards containing both target compounds and Deuterated Monitoring Compounds
       (DMCs) are analyzed both at the beginning and end of each 12-hour analysis period following the
       analysis of the instrument performance check and prior to the analysis of the method blank and
       samples.  An instrument performance check is not required prior to the analysis of a closing CCV
       or prior to a closing CCV which can be used as an opening CCV for the next 12-hour period. If
       time remains in the 12-hour time period after initial calibration and samples are to be analyzed,
       the mid-point standard from the initial calibration can be used as an opening CCV.

    3.  For an opening CCV, the Relative Response Factors (RRFs) for the volatile target compounds
       listed in Table 3, and for all DMCs, must be greater than or equal to 0.010. The RRF for all other
       volatile target compounds must be greater than or equal to 0.050.

    4.  For a closing CCV, the RRFs for all volatile target compounds and DMCs must be greater than or
       equal to 0.010.

    5.  The Percent Difference (%D) between the initial calibration RRF and the opening CCV RRF
       must be within ±40.0% for the volatile target compounds listed in Table 3 and associated DMCs
       listed in Table 9, except for 1,4-dioxane and its associated DMC (±50.0%). The Percent
       Difference for all other volatile target compounds and associated DMCs must be within ±30.0%.
    6.  For a closing CCV, the Percent Difference between the initial calibration RRF and the CCV RRF
       must be within ±50.0% for all volatile target compounds and associated DMCs.

D.  Evaluation:

    1.  Verify that the CCV was run at the required frequency (an opening and closing CCV must be run
       within a 12-hour period)  and the CCV was compared to the correct initial calibration.  If the mid-
       point standard from the initial calibration is used_as_an opening CCV, verify that the result (RRF)
       of the mid-point standard was compared to the RRF from the correct initial calibration.

    2.  Evaluate the CCV RRF for all volatile target compounds and DMCs:
January 2005                                 22                                   Draft Final

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                                                                Trace Volatiles Organic Analysis
       a.  Check and recalculate the CCV RRF for at least one volatile target compound and DMC
           associated with each internal standard. Verify that the recalculated value(s) agrees with the
           laboratory reported value (s).

       b.  For an opening CCV, verify that all volatile target compounds listed in Table 3 and all DMCs
           have CCV RRFs of greater than or equal to 0.010, and all other volatile target compounds
           and DMCs have RRFs greater than or equal to 0.050.

       c.  For a closing CCV, verify that all volatile target compounds and DMCs have CCV RRFs of
           greater than or equal to 0.010.
    3.  Evaluate the Percent Difference between initial calibration RRF and CCV RRF (both opening and
       closing RRF) for all volatile target compounds and DMCs:

       a.  Check and recalculate the Percent Difference for one or more volatile target compound(s) and
           DMCs associated with each internal standard. Verify that the recalculated value(s) agrees
           with the laboratory-reported value(s).

       b.  For an opening CCV, verify that the Percent Difference is within ±40.0% for the volatile
           target compounds listed in Table 3 and DMCs listed in Table 9, except for 1,4-dioxane and
           the associated DMCs (±50.0%), and within ±30.0% for all other volatile target compounds
           and associated DMCs.

       c.  For a closing CCV, verify that the Percent Difference is within ±50.0% for all volatile target
           compounds and associated DMCs.

    4.  If errors are detected in the calculations of either the CCV (both opening and closing) RRF or the
       Percent Difference, perform a more comprehensive recalculation.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are  evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E .  Action:

    1.  If a CCV (opening and  closing) was not run at the appropriate frequency, qualify all data as
       unusable "R".

    2.  Qualify all volatile target compounds, including the compounds exhibiting poor response listed in
       Table 3 using the following criteria (see Table 5):

       a.  For an opening CCV, if any volatile target compound has an RRF value less than the
           minimum criterion  (0.010 for the compounds exhibiting poor response and 0.050 for all other
           volatile compounds), use professional judgment for detects, based on mass spectral
           identification, to qualify the data as a "J" or unusable "R".
January 2005                                 23                                    Draft Final

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                                                               Trace Volatiles Organic Analysis
       b.  For a closing CCV, if any volatile target compound has an RRF value less than 0.010, use
           professional judgment for detects based on mass spectral identification to qualify the data as a
           "J" or unusable "R".

       c.  For an opening CCV, if any volatile target compound has an RRF value less than the
           minimum criterion (0.010 for the compounds listed in Table 3 and 0.050 for all other volatile
           compounds), qualify non-detected compounds as unusable "R".

       d.  For a closing CCV, if any volatile target compound has an RRF value less than 0.010, qualify
           non-detected compounds as unusable "R".

       e.  For an opening CCV, if the Percent Difference value for any of the volatile target compounds
           listed in Table 3 is outside the ±40.0% criterion, except for 1,4-dioxane (±50.0%), qualify
           detects with a "J" and non-detected compounds with an approximated "UJ".

       f  For a closing CCV, if the Percent Difference value for any of the  volatile target compounds
           listed in Table 3 is outside the ±50.0% criterion, qualify detects with a "J" and non-detected
           compounds with an approximated "UJ".

       g.  For an opening CCV, if the Percent Difference value for any other volatile target compound
           is outside the ±30.0% criterion, qualify detects with a "J" and non-detected compounds with
           an approximated "UJ".

       h.  For a closing CCV, if the Percent Difference value for any other volatile target compound is
           outside the ±50.0% criterion, qualify detects with a "J" and non-detected compounds with an
           approximated "UJ".

       i.  If the volatile target compounds meet the acceptable criteria for RRF and the Percent
           Difference, no qualification of the data is necessary.

       j.  No qualification of the data is necessary on the DMC RRF and the Percent Difference data
           alone. Use professional judgment to evaluate the DMC RRF and Percent Difference data in
           conjunction with the DMC recoveries to determine the need for qualification of data.

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

    4.  Note in the Data Review Narrative, whenever possible, the potential effects on the data due to
       calibration criteria exceedance.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if calibration criteria are
       grossly exceeded.
January 2005                                 24                                    Draft Final

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                                                             Trace Volatiles Organic Analysis
     Table 5. Continuing Calibration Verification (CCV) Actions for Trace Volatiles Analyses
Criteria for
Opening CCV
RRF < 0.010 (volatile target compounds
listed in Table 3)
RRF < 0.050 (all other volatile target
compounds)
RRF > 0.010 (volatile target compounds
listed in Table 3)
RRF > 0.050 (all other volatile target
compounds)
%D > 50.0 or < -50.0 (1,4-Dioxane)
%D > 40.0 or < -40.0 (volatile target
compounds listed in Table 3)
%D > 30.0 or < -30.0 (all other volatile
target compounds)
%D < 50.0 and > -50.0 (1,4-Dioxane)
%D < 40.0 and > -40.0 (volatile target
compounds listed in Table 3)
%D < 30.0 and > -30.0 (all other volatile
target compounds)
Opening CCV not performed at required
frequency (see Trace, Section IV. C.I)
Criteria for
Closing CCV
RRF < 0.010
(for all volatile target
compounds)
RRF> 0.010
(for all volatile target
compounds)
%D > 50.0 or < -50.0
(for all volatile target
compounds)
%D < 50.0 and > -50.0
(for all volatile target
compounds)
Closing CCV not
performed at required
frequency
(see Trace, Section
IV.C.l)
Action
Detected
Associated
Compounds
J or R (based
on mass
spectral
identification)
Non-Detected
Associated
Compounds
R
No qualification
J
UJ
No qualification
R
January 2005
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                                                               Trace Volatiles Organic Analysis
                                          V. Blanks

A.  Review Items:

    Form I VOA-1, Form I VOA-2, Form I VOA-TIC, Form IVOA-SIM, Form IV VGA, Form IV VOA-
    SIM, chromatograms, and quantitation reports.

B.  Objective:

    The purpose of laboratory, field, or trip blank analyses is to determine the existence and magnitude of
    contamination resulting from laboratory or field activities. The purpose of the method blank is to
    determine the levels of contamination associated with the processing and analysis of the samples.
    The storage blank indicates whether contamination may have occurred during storage of samples.
    The results from the instrument blank analysis indicate whether there is contamination from the
    analysis of a previous sample.  The criteria for evaluation of blanks apply to any blank associated
    with the samples (e.g., method blanks, instrument blanks, storage blanks, field blanks, or trip blanks).
    If problems with any blank exist, all associated data must be carefully evaluated to  determine whether
    or not there is an inherent variability in the data or if the problem is an isolated occurrence not
    affecting other data.

C.  Criteria:

    1.   Method Blanks

        A method blank analysis must be performed after the calibration standards and once for every 12-
        hour time period.

        The method blank must be analyzed on each Gas Chromatograph/Mass Spectrometer (GC/MS)
        system used to analyze samples.

    2.   Storage Blanks

        A storage blank must be prepared upon receipt of the first samples from a Sample Delivery Group
        (SDG), and stored with the samples until analysis. The storage blank must be analyzed once per
        SDG.

    3.   Instrument Blanks

        An instrument blank must be analyzed immediately after any sample that has saturated ions
        (target compounds  that exceed the calibration range or non-target compounds that exceed 100
        (ig/L) from a given compound to check that the blank is  free of interference and the system is not
        contaminated.  The concentration of each target compound in the instrument blank must be less
        than its Contract Required Quantitation Limit (CRQL) listed in the method.

        NOTE:    The concentration of each target compound  found in the storage, method, field, or
                  trip blanks must be less than its CRQL listed in the method, except for methylene
                  chloride, acetone, and 2-butanone, which must be less than 2x their respective
                  CRQLs. The concentration of non-target compounds in all blanks  must be less than
                  2.0 jig/L.
January 2005                                 26                                   Draft Final

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                                                               Trace Volatiles Organic Analysis
D .  Evaluation:

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

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

    3.  Verify that a storage blank has been analyzed and included with each SDG.

    4.  Verify that the instrument blank analysis has been performed following any sample analysis
       where a target analyte(s) is/are reported at high concentration(s).

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process. Data concerning the field or trip blanks are not evaluated as part
                  of the CCS  process. If field or trip blanks are present, the data reviewer should
                  evaluate this data in a similar fashion as the method blanks.

E.  Action:

    Action regarding unsuitable blank results depends on the circumstances and origin of the blank. In
    instances where more than one of the same type  of blank is associated with a given sample,
    qualification  should be based upon a comparison with the associated blank having the highest
    concentration of a contaminant.  Do not correct the results by subtracting any blank value.

    1.  If a volatile compound is found in a method blank, but not found in the sample, no qualification
       of the data is necessary  (see Table 6).

    2.  If the method blank concentration is less than the CRQL (less than 2x the CRQL for methylene
       chloride,  2-butanone, and acetone) and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, and less than 2x the CRQL
           (less  than 4x the CRQL for methylene chloride,  2-butanone, and acetone), use professional
           judgment.

       c.  the sample concentration is greater than or equal to 2x the CRQL (greater than 4x the CRQL
           for methylene chloride, 2-butanone, and acetone), no qualification of the data is necessary.

    3.  If the method blank concentration is greater than the CRQL (greater than 2x the CRQL for
       methylene chloride, 2-butanone, and acetone) and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".
January 2005                                 27                                   Draft Final

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                                                                Trace Volatiles Organic Analysis
       b.  the sample concentration is greater than or equal to the CRQL, and less than the blank
           concentration, report the concentration of the compound in the sample at the same
           concentration found in the blank and qualify with a "U", or the reviewer may elect to qualify
           the data as unusable "R".

       c.  the sample concentration is greater than or equal to the CRQL and greater than the blank
           concentration, use professional judgment to qualify the data.

    4.  If the method blank concentration is equal to the CRQL (equal to 2x the CRQL for methylene
       chloride, 2-butanone, and acetone) and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    5.  If gross contamination exists (i.e., saturated peaks by GC/MS), qualify all affected compounds in
       the associated samples as  unusable "R" due to interference. Note, for Contract Laboratory
       Program Project Officer (CLP PO) action, if the contamination is suspected of having an effect on
       the sample results.

    6.  Give the same consideration as the target compounds to the Tentatively Identified Compounds
       (TICs), which are found in both the sample and associated blank(s) (see Trace Volatiles Organic
       Analysis, Section XII, for TIC guidance).

    7.  If the contaminants found in the blank are interfering non-target compounds at concentrations
       greater than 2 (ig/L, use professional judgment to qualify the data.

       NOTE:    There may be instances where little or no contamination was present in the associated
                  blanks, but qualification  of the sample is deemed necessary.  If the reviewer
                  determines that the contamination is from a source other than the sample, they should
                  qualify the data. Contamination introduced through dilution water is one example.
                  Although it is not always possible to determine, instances of this occurring can be
                  detected when contaminants are found in the diluted sample result, but are absent in
                  the undiluted sample result.

    8.  If an instrument blank was not analyzed following a sample analysis which contained an
       analyte(s) at high concentration(s), evaluate the  sample analysis results immediately after the high
       concentration sample for carryover. Use professional judgment to determine if instrument cross-
       contamination has affected any positive  compound identification(s). Note, for CLP PO action, if
       instrument cross-contamination is suggested and suspected of having an effect on the sample
       results.

    9.  If contaminants are found in the storage, field, or trip blanks, the following is recommended:

       a.  Review the associated method blank data to determine if the contaminant(s) was also present
           in the method blank.
January 2005                                 28                                    Draft Final

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                                                              Trace Volatiles Organic Analysis
           i.  If the analyte was present at a comparable level in the method blank, the source of the
              contamination may be in the analytical system and the action recommended for the
              method blank would apply.

           ii.  If the analyte was not present in the method blank, the source of contamination may be in
              the storage area, in the field, or during sample transport.  Consider all associated samples
              for possible cross-contamination.

       b.  If the storage, field, or trip blanks contain a volatile Target Compound List (TCL)
           compound(s) at a concentration less than the CRQL and:

           i.  the sample concentration is less than the CRQL (2x the CRQL for methylene chloride,
              2-butanone and acetone), report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to 2x the CRQL (4x the CRQL for
              methylene chloride, 2-butanone and acetone), no qualification of the data is necessary.

           iii. the sample concentration is greater than or equal to the CRQL and less than 2x the CRQL
              (4x the CRQL for methylene chloride, 2-butanone and acetone), use professional
              judgment to qualify the data.

       c.  If the storage, field, or trip blanks contain a volatile TCL compound(s) at a concentration
           equal to the CRQL (2x the CRQL for methylene chloride, 2-butanone and acetone) and:

           i.  the sample concentration is less than or equal to the CRQL (2x the CRQL for methylene
              chloride, 2-butanone and acetone), report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL (2x the CRQL for
              methylene chloride, 2-butanone and acetone), use professional judgment to qualify the
              data.

       d.  If the storage, field, or trip blanks contain a volatile TCL compound(s) at a concentration
           greater than the CRQL, and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, and less than the blank
              concentration, report the concentration of the compound in the sample at the same
              concentration found in the blank and qualify with a "U", or the reviewer may elect to
              qualify the data as unusable "R".

           iii. the sample concentration is greater than or equal to the CRQL and greater than or equal
              to the blank concentration, use professional judgment to qualify the data.

       e.  If gross contamination [greater than 2x the CRQL (4x the CRQL for methylene chloride,
           2-butanone and acetone)] exists in the storage, field, or trip blank, positive sample  results
           may require rejection and be qualified as unusable "R". Non-detected volatile target
           compounds do not require qualification unless the contamination is  so high that it interferes
           with the analyses of non-detected compounds.
January 2005                                 29                                   Draft Final

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                                                              Trace Volatiles Organic Analysis
       f.   If the contaminants found in the blank are interfering non-target compounds at concentrations
           greater than 2 (ig/L, use professional judgment to qualify the data.

                      Table 6.  Blank Actions for Trace Volatiles Analyses
Blank Type





Method,
Storage, Field,
Trip,
Instrument* * *



Blank Result
Detects

< CRQL *


- CRQL*

> CRQL *

Gross
contamination* *
TIC >2 (ig/L
Sample Result
Not detected
 CRQL and
<2x the CRQL**
>2x the CRQL**
CRQL
 CRQL and
< blank concentration
> CRQL and
> blank concentration
Detects
Detects
Action for Samples
No qualification
Report CRQL value with a U
Use professional judgment
No qualification
Report CRQL value with a U
Use professional judgment
Report CRQL value with a U
Report the concentration for the sample
with a U or qualify the data as unusable
R
Use professional judgment
Qualify results as unusable R
Use professional judgment
    *
    **
    ***
2xthe CRQL for methylene chloride, 2-butanone and acetone.
2xthe CRQL (4xthe CRQL for methylene chloride, 2-butanone, and acetone).
Qualifications based on instrument blank results affect only the sample analyzed immediately
after the sample that has target compounds that exceed the calibration range or non-target
compounds that exceed 100 (ig/L.
January 2005
                                  30
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                                                               Trace Volatiles Organic Analysis
                        VI. Deuterated Monitoring Compounds (DMCs)
A.  Review Items:
    Form IIVOA-1, Form II VOA-2, Form II VOA-SIM1, Form IIVOA-SIM2, quantitation reports, and
    chromatograms.

B.  Objective:

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

C.  Criteria:

    The fourteen DMCs listed in Table 7 are added to all samples and blanks to measure their recovery in
    environmental samples.

        Table 7. Volatile Deuterated Monitoring Compounds (DMCs) and Recovery Limits
DMC
Vinyl chloride -d3
Chloroethane-d5
1 , 1 -Dichloroethene-d2
2-Butanone-d5
Chloroform-d
1 ,2-Dichloroethane-d4
Benzene-d6
Recovery
Limits (%)
65-131
71 -131
55 - 104
49-155
78-121
78 - 129
77 - 124
DMC
1 ,2-Dichloropropane-d6
Toluene -ds
trans- l,3-Dichloropropene-d4
2-Hexanone-d5
l,4-Dioxane-d8
1 , 1 ,2,2-Tetrachloroethane-d2
1 ,2-Dichlorobenzene-d4
Recovery
Limits (%)
79 - 124
77- 121
73- 121
28- 135
50- 150
73 - 125
80- 131
    Recoveries for DMCs in volatile samples and blanks must be within the limits specified in
    Table 7.

    NOTE:   The recovery limits for any of the compounds listed in Table 7 may be expanded at any
              time during the period of performance if USEPA determines that the limits are too
              restrictive.
January 2005
31
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                                                                Trace Volatiles Organic Analysis
D.  Evaluation:

    1.  Check raw data (e.g., chromatograms and quantitation reports) to verify the recoveries on the
       Deuterated Monitoring Compound Recovery Forms (Form IIVOA-1, Form II VOA-2, Form II
       VOA-3, Form II VOA-4, Form IIVOA-SIM, and Form II VOA SIM2).

       Check for any calculation or transcription errors; verify that the DMC recoveries were calculated
       correctly using the equation in the method.

    2.  Whenever there are two or more analyses for a particular sample, the reviewer must determine
       which are the most acceptable data to report. Considerations include, but are not limited to:

       a.  DMC recovery (marginal versus gross deviation).

       b.  Technical holding times.

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

       d.  Other Quality Control (QC) information, such as performance of internal standards.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E .  Action:

    Table 9 lists the volatile DMCs and their associated target compounds.  If any DMC recovery in the
    volatiles fraction is out of specification, qualify the data considering the existence of interference in
    the raw data (see Table 8).  Considerations include, but are not limited to:

    1.  For any recovery greater than the upper acceptance limit:

       a.  Qualify detected associated volatile target compounds as a "J".

       b.  Do not qualify non-detected associated volatile target compounds.

    2.  For any recovery greater than or equal to 20%, and less than the lower acceptance limit:

       a.  Qualify detected associated volatile target compounds as a "J".

       b.  Qualify non-detected associated volatile target compounds as approximated "UJ".

    3.  For any recovery less than 20%:

       a.  Qualify detected associated volatile target compounds as a "J".

       b.  Qualify non-detected associated volatile target compounds as unusable "R".
January 2005                                  32                                    Draft Final

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                                                              Trace Volatiles Organic Analysis
    4.  For any recovery within acceptance limits, no qualification of the data is necessary.

    5.  In the special case of a blank analysis having DMCs out of specification, the reviewer must give
       special consideration to the validity of associated sample data.  The basic concern is whether the
       blank problems represent an isolated problem with the blank alone, or whether there is a
       fundamental problem with the analytical process. For example, if one or more samples in the
       batch show acceptable  DMC recoveries, the reviewer may choose to consider the blank problem
       to be an isolated occurrence. However, even if this judgment allows some use of the affected
       data, note analytical problems for Contract Laboratory Program Project Officer (CLP PO) action.

              Table 8.  Deuterated Monitoring Compound (DMC) Recovery Actions
                                 For Trace Volatiles Analyses
Criteria
%R > Upper Acceptance
Limit
20% <%R < Lower Acceptance Limit
%R < 20%
Lower Acceptance Limit
< %R < Upper Acceptance Limit
Action
Detected
Associated
Compounds
J
J
J
Non-detected
Associated
Compounds
No qualification
UJ
R
No qualification
                  Table 9. Volatile Deuterated Monitoring Compounds (DMCs)
                            and the Associated Target Compounds
 Chloroethane-d5 (DMC)
l,2-Dichloropropane-d6
(DMC)
l,2-Dichlorobenzene-d4
(DMC)
 Dichlorodifluoromethane

 Chloromethane

 Bromomethane

 Chloroethane

 Carbon disulfide
Cyclohexane

Methylcyclohexane

1,2-Dichloropropane

Bromodichloromethane
Chlorobenzene

1,3 -Dichlorobenzene

1,4-Dichlorobenzene

1,2-Dichlorobenzene

1,2,4-Trichlorobenzene

1,2,3-Trichlorobenzene
January 2005
             33
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                                                              Trace Volatiles Organic Analysis
                 Table 9. Volatile Deuterated Monitoring Compounds (DMCs)
                        and the Associated Target Compounds (CON'T)
 l,4-Dioxane-d8 (DMC)
trans-l,3-Dichloropropene-d4
(DMC)
Chloroform-d (DMC)
 1,4-Dioxane
cis-1,3 -Dichloropropene

trans-l,3-Dichloropropene

1,1,2-Trichloroethane
1,1 -Dichloroethane

Bromochloromethane

Chloroform

Dibromochloromethane

Bromoform
 2-Butanone-ds (DMC)
l,l-Dichloroethene-d2 (DMC)
2-Hexanone-ds(DMC)
 Acetone

 2-Butanone
trans-1,2-Dichloroethene

cis-1,2-Dichloroethene
4-Methyl-2-pentanone

2-Hexanone
 Vinyl chloride-d3 (DMC)
Benzene-d6 (DMC)
1,1,2,2-Tetr achloroethane-d2
(DMC)
 Vinyl chloride
Benzene
1,1,2,2,-Tetrachlororethane

1,2-Dibromo-3 -chloropropane
 l,2-Dichloroethane-d4 (DMC)
                              Toluene-d8(DMC)
 Trichlorofluoromethane

 1,1 -Dichloroethene

 1,1,2-Trichloro-1,2,2-
 trifluoroethane

 Methyl acetate

 Methylene chloride

 Methyl-tert-butyl ether

 1,1,1 -Trichloroethane

 Carbon tetrachloride

 1,2-Dibromoethane

 1,2-Dichloroethane
                              Trichloroethene

                              Toluene

                              Tetrachloroethene


                              Ethylbenzene

                              o-Xylene

                              m,p-Xylene

                              Styrene

                              Isopropylbenzene
January 2005
             34
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                                                               Trace Volatiles Organic Analysis
                     VII.  Matrix Spike/Matrix Spike Duplicates (MS/MSDs)

A.  Review Items:

    Form III VOA-1, chromatograms, and quantitation reports.

    NOTE:    Data for MS and MSDs will not be present unless requested by the Region.

B.  Objective:

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

C.  Criteria:

    1.  If requested, MS and MSD samples are analyzed at a frequency of one MS and MSD per 20 or
       fewer samples.

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

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

D.  Evaluation:

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

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

    3.  Verify transcriptions from raw data and check calculations.

    4.  Verify that the MS and MSD recoveries and RPD were calculated correctly.

       NOTE:    For data obtained from the Contract  Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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                                                                Trace Volatiles Organic Analysis
E.  Action:

    1.  No qualification of the data is necessary on MS and MSB data alone.  However, using informed
       professional judgment, the data reviewer may use the MS and MSB results in conjunction with
       other QC criteria to determine the need for some qualification of the data. Table 11 lists the
       volatile target compounds that are spiked into samples to test for matrix effects. If any MS and
       MSB Percent Recovery or RPB in the volatiles fraction is out of specification,  qualify data to
       include the consideration of the existence of interference in the raw data (see Table 10).
       Considerations include, but are not limited to:

       a.  For any recovery or RPB greater than the upper acceptance limit:

           i.   Qualify detected spiked volatile target compounds as a "J".

    2.  Bo not qualify non-detected spiked volatile target compounds.

       b.  For any recovery greater than or equal to 20%, and less than the lower acceptance limit:

           i.   Qualify detected spiked volatile target compounds as a "J".

           ii.  Qualify non-detected spiked volatile target compounds as approximated "UJ".

       c.  For any recovery less than 20%:

           i.  Qualify detected spiked volatile target compounds as a "J".

           ii. Qualify non-detected spiked volatile target compounds using professional judgment.

       d.  For any recovery or RPB within acceptance limits, no qualification of the data is necessary.

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

    3.  In those instances where it can be determined that the results  of the MS and MSB affect only the
       sample spiked, limit qualification to this sample only.  However, it may be determined through
       the MS and MSB results that a laboratory  is having a systematic problem in the analysis of one or
       more analytes that affects all associated samples and the reviewer should use professional
       judgment to qualify the data from all associated samples.

    4.  The reviewer must use professional judgment to determine the need for qualification of detects of
       non-spiked compounds.

       NOTE:    Notify the Contract Laboratory Program Project Officer (CLP PO) if a field or trip
                  blank was used for the MS and MSB.
January 2005                                  36                                    Draft Final

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                                                            Trace Volatiles Organic Analysis
                  Table 10.  Matrix Spike/Matrix Spike Duplicate (MS/MSD)
                             Actions for Trace Volatiles Analysis
Criteria
%R or RPD> Upper Acceptance Limit
20% <%R< Lower Acceptance Limit
%R < 20%
Lower Acceptance Limit < %R; RPD <
Upper Acceptance Limit
Action
Detected
Spiked Compounds
J
J
J
Non-detected
Spiked Compounds
No qualification
UJ
Use professional judgment
No qualification
      Table 11. Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) Limits
Compound
1 , 1 -Dichloroethene
Benzene
Trichloroethene
Toluene
Chlorobenzene
Percent Recovery
61 - 145
76 - 127
71 - 120
76 - 125
75 - 130
RPD
0- 14
0- 11
0- 14
0- 13
0- 13
January 2005
37
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                                                              Trace Volatiles Organic Analysis
                VIII. Regional Quality Assurance (OA) and Quality Control (OC)

A.  Review Items:

    Form I VOA-1, Form I VOA-2, Form I VOA-SIM, chromatograms, Traffic Report/Chain of Custody
    Record (TR/COC), quantitation reports, and other raw data from QA/QC samples.

B.  Objective:

    Regional QA/QC samples refer to any QA and/or QC samples initiated by the Region, including field
    duplicates, Performance Evaluation (PE) samples, blind spikes, and blind blanks. The use of these
    QA/QC samples are highly recommended (e.g., the use of field duplicates can provide information on
    sampling precision and homogeneity).

C.  Criteria:

    Criteria are determined by each Region.

    1.  PE sample frequency may vary.

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

D.  Evaluation:

    1.  Evaluation procedures must follow the Region's Standard Operating Procedure (SOP) for data
       review. Each Region will handle the evaluation of PE samples on an individual basis.  Compare
       results for PE samples to the acceptance criteria for the specific PE samples, if available.

    2.  Calculate Relative Percent Difference (RPD) between field duplicates. Provide this information
       in the Data Review Narrative.

E.  Action:

    Any action must be in accordance with Regional specifications and the criteria for acceptable PE
    sample results.  Note, for Contract Laboratory Program Project Officer (CLP PO) action,
    unacceptable results for PE samples.
January 2005                                38                                   Draft Final

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                                                                Trace Volatiles Organic Analysis
                                    IX.  Internal Standards

A.  Review Items:

    Form VIII VOA, Form VIIIVOA-SIM, quantitation reports, and chromatograms.

B.  Objective:

    Internal standard performance criteria ensures that Gas Chromatograph/Mass Spectrometer (GC/MS)
    sensitivity and response are stable during each analysis.

C.  Criteria:

    1.  The internal standard area counts for all samples [including Matrix Spike and Matrix Spike
       Duplicate (MS/MSD), and Performance Evaluation (PE) samples] and all blanks must not vary
       more than ±40.0% from the associated 12-hour calibration standard [opening Continuing
       Calibration Verification (CCV) or mid-point standard from initial calibration].

    2.  The Retention Time (RT) of the internal standard in the sample or blank must not vary more than
       ±20 seconds from the RT of the internal standard in the associated  12-hour calibration standard
       (opening CCV or mid-point standard from initial calibration).

D.  Evaluation:

    1.  Check raw data (e.g., chromatograms and quantitation lists) to verify the internal standard RTs
       and areas reported on the Internal Standard Area Summary (Form VIII VOA, Form VIII VOA-
       SIM).

    2.  Verify that all RTs and internal standard areas are within criteria for all samples and blanks.

    3.  If there  are two analyses for a particular fraction, the reviewer must determine which are the best
       data to report. Considerations include, but are not limited to:

       a.   Magnitude and direction of the internal standard area shift.

       b.   Magnitude and direction of the internal standard RT shift.

       c.   Technical holding times.

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

       e.   Other Quality Control (QC).

           NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the Contract Compliance Screening (CCS)
                      process. Information regarding the laboratory's compliance with these criteria
                      can be obtained from the Data Assessment Tool (DAT) reports, and may be used
                      as part of the  evaluation process.
January 2005                                  39                                   Draft Final

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                                                                 Trace Volatiles Organic Analysis
E.  Action:

    1.  If an internal standard area count for a sample or blank is greater than 140.0% of the area for the
       associated standard (opening CCV or mid-point standard from initial calibration) (see Table 12):

       a.  Qualify detects for compounds quantitated using that internal standard with a "J".

       b.  Do not qualify non-detected associated compounds.

    2.  If an internal standard area count for a sample or blank is less than 60.0% of the area for the
       associated standard (opening CCV or mid-point standard from initial calibration):

       a.  Qualify detects for compounds quantitated using that internal standard with a " J".

       b.  Qualify non-detected associated compounds as unusable "R".

    3.  If an internal standard area count for a sample or blank is greater than or equal to 60.0%, and less
       than 140% of the area for the associates standard opening CCV or mid-point standard from initial
       calibration, no qualification of the data is necessary.

    4.  If an internal standard RT varies by more than 20.0 seconds:

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

    5.  If an internal standard RT varies by less than or equal to 20.0 seconds, no qualification of the data
       is necessary.

    6.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if the internal standard
       performance criteria are grossly exceeded.  Note in the Data Review Narrative potential effects on
       the data resulting from unacceptable internal standard performance.
January 2005                                  40                                     Draft Final

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                                                               Trace Volatiles Organic Analysis
                Table 12. Internal Standard Actions for Trace Volatiles Analyses
Criteria
Area counts > 140% of 12-hour standard (opening CCV or
mid-point standard from initial calibration)
Area counts < 60% of 12-hour standard (opening CCV or
mid-point standard from initial calibration)
Area counts > 60% but < 140% of 12-hour standard
(opening CCV or mid-point standard from initial calibration)
RT difference > 20.0 seconds between samples and 12-hour
standard (opening CCV or mid-point standard from initial
calibration)
RT difference < 20.0 seconds between samples and 12-hour
standard (opening CCV or mid-point standard from initial
calibration)
Action
Detected
Associated
Compounds*
J
J
Non-detected
Associated
Compounds*
No qualification
R
No qualification
j^ **
No qualification
    *   For volatile compounds associated to each internal standard, see Table 3 - Trace Volatile Target
       Compounds and Deuterated Monitoring Compounds with Corresponding Internal Standards for
       Quantitation in SOMO 1.0. Exhibit D. available at:

                       http://www.epa.gov/superfund/programs/clp/soml.htm

    ** See Trace Volatiles Organic Analysis, Section IX.E.4.
January 2005
41
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                                                               Trace Volatiles Organic Analysis
                              X. Target Compound Identification

A.  Review Items:

    Form I VOA-1, Form I VOA-2, Form I VOA-SIM, quantitation reports, mass spectra, and
    chromatograms.

B.  Objective:

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

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

C.  Criteria:

    1.  The Relative Retention Times (RRTs) must be within ±0.06 RRT units of the standard RRT
       [opening Continuing Calibration Verification (CCV) or mid-point standard from initial
       calibration].

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

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

       b.  The relative intensities of these ions must agree within ±20% between the standard and
           sample spectra (e.g., for an ion with an abundance of 50% in the standard spectrum, the
           corresponding  sample ion abundance must be between 30-70%).

       c.  Ions present at greater than 10% in the sample mass spectrum, but not present in the standard
           spectrum, must be evaluated by a reviewer experienced in mass spectral interpretation.

D.  Evaluation:

    1.  Check that the RRT of reported compounds is within ±0.06 RRT units of the standard RRT
       (opening CCV or mid-point standard from the initial calibration).

    2.  Check the sample compound spectra against the laboratory standard spectra to verify that it meets
       the specified criteria.
January 2005                                 42                                    Draft Final

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                                                                Trace Volatiles Organic Analysis
    3.  The reviewer should be aware of situations when sample carryover is a possibility and should use
       professional judgment to determine if instrument cross-contamination has affected any positive
       compound identification.  The method specifies that an instrument blank must be run after
       samples which contain target compounds at levels exceeding the initial calibration range (20 (ig/L
       for non-ketones, 200 (ig/L for ketones, 800 (ig/L for 1,4-dioxane), or non-target compounds at
       concentrations greater than 100 (ig/L, or saturated ions from a compound (excluding the
       compound peaks in the solvent front).

    4.  Check the chromatogram to verify that peaks are identified. Major peaks are either identified as
       target compounds, TICs, Deuterated Monitoring Compounds (DMCs), or internal standards.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  The application of qualitative criteria for GC/MS analysis of target compounds requires
       professional judgment. It is up to the reviewer's discretion to obtain additional information from
       the laboratory. If it is  determined that incorrect identifications were made, qualify all such data as
       not detected "U" or unusable  "R".

    2.  Use professional judgment to qualify the data if it is determined that cross-contamination has
       occurred.

    3.  Note in the Data Review Narrative any changes made to the reported compounds or concerns
       regarding target compound identifications. Note, for Contract Laboratory Program Project
       Officer (CLP PO) action, the necessity for numerous or significant  changes.
January 2005                                 43                                    Draft Final

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                                                               Trace Volatiles Organic Analysis
   XL Compound Ouantitation and Reported Contract Required Ouantitation Limits (CRQLs)

A.  Review Items:

    Forms I VOA-1, Form IVOA-2, Form I VOA-SIM, sample preparation sheets, Sample Delivery
    Group (SDG) Narrative, quantitation reports, and chromatograms.

B.  Objective:

    The objective is to ensure that the reported quantitation results and CRQLs are accurate.

C.  Criteria:

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

    2.  Compound Relative Response Factors (RRFs) must be calculated based on the internal standard
       associated with that compound, as listed in the method.  Quantitation must be based on the
       quantitation ion (m/z) specified in the method for both the internal standards and target analytes.
       The compound quantitation must be based on the RRF from the appropriate daily standard
       [opening Continuing Calibration Verification (CCV) or mid-point standard from initial
       calibration].

D.  Evaluation:

    1.  Examine raw data to verify the correct calculation of all sample results reported by the laboratory.
       Compare quantitation lists and chromatograms to the reported detects and non-detects sample
       results.  Check the reported values.

    2.  Verify that the correct internal standard, quantitation ion, and Mean Relative Response Factor
       (RRF) we_re used to quantitate the compound. Verify that the same internal standard, quantitation
       ion, and RRF are used consistently throughout, in both the calibration as well as the quantitation
       process.

    3.  Verify that the CRQLs have been adjusted to reflect all sample dilutions.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated  as part of the Contract Compliance Screening  (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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                                                                Trace Volatiles Organic Analysis
E.  Action:

    1.  If any discrepancies are found, the Region's designated representative may contact the laboratory
       to obtain additional information that could resolve any differences.  If a discrepancy remains
       unresolved, the reviewer must use professional judgment to decide which value is the most
       accurate.  Under these circumstances, the reviewer may determine that qualification of data is
       warranted. Note in the Data Review Narrative a description of the reasons for data qualification
       and the qualification that is applied to the data.

    2.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, numerous or significant
       failures to accurately quantify the target compounds or to properly evaluate and adjust CRQLs.
January 2005                                  45                                    Draft Final

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                                                                Trace Volatiles Organic Analysis
                         XII. Tentatively Identified Compounds (TICs)

A.  Review Items:

    Form I VOA-TIC, chromatograms, library search printouts, and spectra for the TIC candidates.

B.  Objective:

    Chromatographic peaks in volatile fraction analyses that are not target analytes, Deuterated
    Monitoring Compounds (DMCs), or internal standards are potential TICs. TICs must be qualitatively
    identified via a forward search of the NIST/USEPA/NIH Mass Spectral Library (May 2002 release or
    later)1, and/or Wiley Mass Spectral Library (1998 release or later)2, or the equivalent. The
    identifications must be assessed by the data reviewer.

C.  Criteria:

    For each sample, the laboratory  must conduct a mass spectral search of the NIST/USEPA/NIH (May
    2002 release or later), and/or Wiley (1998 release or later), or equivalent mass spectral library, and
    report the possible identity for 30 of the largest volatile fraction peaks which are not DMCs, internal
    standards, or target compounds, but which have an area or height greater than 10% of the area or
    height of the nearest internal standard.  Estimated concentrations for TICs are calculated similarly to
    the Target Compound List (TCL) compounds, using total ion areas for the TIC and the internal
    standard, and assuming a Relative Response Factor (RRF) of 1.0. TIC results are reported for each
    sample on the Organic Analyses Data Sheet (Form I VOA-TIC).

D.  Evaluation:

    1.  Guidelines for tentative identification are as follows:

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

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

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

       d.   Review ions present in the sample spectrum, but not in the reference spectrum, for possible
           background contamination, interference, or presence of coeluting compounds.

       e.   Review ions present in the reference spectrum, but not in the sample spectrum, for possible
           subtraction from the sample spectrum because of background contamination or coeluting
       1       NIST/USEPA/NIH Mass Spectral Library (May 2002 release or later), National Institute
               of Standards and Technology, Gaithersburg, Maryland.

       2       Wiley Mass Spectral Library (1998 release or later) John Wiley & Sons, Inc., Hoboken,
               New Jersey.
January 2005                                 46                                    Draft Final

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                                                               Trace Volatiles Organic Analysis
           compounds.  Data system library reduction programs can sometimes create these
           discrepancies.

       f.   Non-target compounds receiving a library search match of 85% or higher are considered a
           "likely match". Report the compound unless the mass spectral interpretation specialist feels
           there is evidence not to report the compound as identified by the library search program.
           Note in the Sample Delivery Group (SDG) Narrative the justification for not reporting a
           compound as listed by the search program.

       g.  If the library search produces more than one compound greater than or equal to 85%, report
           the compound with the highest percent match (report first compound if percent match is the
           same for two or more compounds), unless the mass spectral interpretation specialist feels that
           the highest match compound should not be reported or another compound with a lower match
           should be reported. The laboratory should include the justification for not reporting the
           compound with the highest spectral match within the SDG Narrative.  Do not report DMCs,
           internal  standards, and volatile target compounds as TICs, unless the only compounds having
           a percent match of greater than 85% are DMCs, internal standards, or volatile target
           compounds.

       h.  If the library search produces a series of obvious isomer compounds with library search
           matches greater than or equal to 85%, report the compound with the highest library search
           percent match (or the first compound if the library search matches are  the same). Note in the
           SDG Narrative that the exact isomer configuration, as reported, may not be accurate.

       i.   If the library search produces no matches greater than or equal to 85%, and in the technical
           judgment of the mass spectral interpretation specialist, no valid tentative identification can be
           made, report the compound as unknown. The mass spectral specialist should give  additional
           classification of the unknown compound, if possible (e.g., unknown aromatic, unknown
           hydrocarbon, unknown acid type, unknown chlorinated compound). If probable molecular
           weights  can be distinguished, include them.

       j.   Alkanes are not to be reported as TICs on Form IVOA-TIC. An alkane is defined as any
           hydrocarbon with the general formula CnH2n+2 that contains only C-H and C-C single bonds.
           When the preceding alkanes are tentatively identified, the concentration(s) are to be estimated
           and reported in the SDG Narrative as alkanes by class (i.e., straight-chain, branched, cyclic,
           as a series, or as applicable). Total alkanes concentration will be reported on Form I VOA-
           TIC.

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

    3.  Examine blank chromatograms to verify that TIC peaks present in samples are not found in
       blanks.  When a low-level, non-target compound that is a common artifact or laboratory
       contaminant is detected in a sample, a thorough check of blank chromatograms may require
       looking for peaks which are less than 10% of the internal standard height,  but present in the blank
       chromatogram at a similar Relative Retention Time (RRT).

    4.  Examine all  mass spectra for  every sample and blank.
January 2005                                 47                                    Draft Final

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                                                                 Trace Volatiles Organic Analysis
    5.  Consider all reasonable choices since TIC library searches often yield several candidate
       compounds having a close matching score.

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

       Examples:

       a.  Common laboratory contaminants include CO2 (m/z 44), siloxanes (m/z 73), diethyl ether,
           hexane, certain freons, and phthalates at levels less than 100 (ig/L.

       b.  Solvent preservatives include cyclohexene, (a methylene chloride preservative). Related by-
           products include cyclohexanone, cyclohexenone, cyclohexanol, cyclohexenol,
           chlorocyclohexene, and chlorocyclohexanol.

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

    7.  A target compound may be identified in the proper analytical fraction by non-target library search
       procedures, even though it was not found on the quantitation list (false negative). If the total area
       quantitation method was used, request that the laboratory recalculate the result using the proper
       quantitation ion and Relative Response Factor (RRF).

       A non-target compound may be incorrectly identified by the instrument's target analyte data
       processor as a target compound (false positive).  When this happens, the non-target library search
       procedure will not detect the false positive as a TIC.  In this case, request that the laboratory
       properly identify the compound and recalculate the result using the total area quantitation method
       and a RRF of 1.0.

       Evaluate other sample chromatograms and check for both false negatives  and false positives to
       determine if the occurrence is isolated or systematic.

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

    9.  Do not perform library searches on internal standards or DMCs.

    10. Estimate TIC concentration assuming an RRF of 1.0.

E .  Action:

    1.  Qualify all TIC results for which there is presumptive evidence of a match (e.g. greater than or
       equal to 85% match) as "NJ", tentatively identified, with approximated concentrations.

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

       a.  If it is determined that a tentative identification of a non-target compound is unacceptable,
           change the tentative identification to "unknown" or another appropriate identification, and
           qualify the result with a "J".
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                                                                Trace Volatiles Organic Analysis
       b.  If all contractually-required peaks were not library searched and quantitated, the Region's
           designated representative may request these data from the laboratory.

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

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

    5.  Other Case factors may influence TIC judgments. If a sample TIC match is poor, but other
       samples have a TIC with a valid library match, similar RRT, and the same ions, infer
       identification information from the other sample TIC results.

    6.  Note  in the Data Review Narrative any changes made to the reported data or any concerns
       regarding TIC identifications.

    7.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, failure to properly
       evaluate and report TICs.
January 2005                                  49                                    Draft Final

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                                                                Trace Volatiles Organic Analysis
                                   XIII. System Performance

A.  Review Items:

    Form VIII VOA, Form VIIIVOA-SIM, and chromatograms.

B.  Objective:

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

C.  Criteria:

    There  are no specific criteria for system performance. Use professional judgment to assess the system
    performance.

D.  Evaluation:

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

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

       a.   High PJC background levels or shifts in Absolute Retention Times (RTs) of internal
           standards.

       b.   Excessive baseline rise at elevated temperature.

       c.   Extraneous peaks.

       d.   Loss of resolution.

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

    3.  A  drift in  instrument sensitivity may occur during the 12-hour time period and may be an
       indication of possible internal standard spiking problems.  This could be discerned by
       examination of the internal standard area on Form VIII VOA for trends such as a continuous or
       near-continuous increase or decrease in the internal standard area overtime.
January 2005                                  50                                    Draft Final

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                                                               Trace Volatiles Organic Analysis
E.  Action:

    Use professional judgment to qualify the data if it is determined that system performance has
    degraded during sample analyses. Note, for Contract Laboratory Program Project Officer (CLP PO)
    action, any degradation of system performance which significantly affected the data.
January 2005                                 51                                   Draft Final

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                                                                Trace Volatiles Organic Analysis
                                XIV.  Overall Assessment of Data

A.  Review Items:

    Entire data package, data review results, and (if available), the Quality Assurance Project Plan
    (QAPP) and Sampling and Analysis Plan (SAP).

B.  Objective:

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

C.  Criteria:

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

D.  Evaluation:

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

    2.  If appropriate information is available, the reviewer may assess the usability of the data to help
       the data user avoid inappropriate use of the data. Review all available information, including the
       QAPP (specifically the acceptance and performance criteria), SAP, and communication with the
       data user that concerns the intended use and desired quality of these data.

E.  Action:

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

    2.  Write a brief narrative to give the user an indication of the analytical limitations of the data.
       Note, for Contract Laboratory Program Project Officer (CLP PO) action, any inconsistency of the
       data with the Sample Delivery Group (SDG) Narrative. If sufficient information on the intended
       use and required quality of the data are available, the reviewer should include their assessment of
       the usability of the data within the given context.  This may be used as part of a formal Data
       Quality Assessment (DQA).
January 2005                                  52                                    Draft Final

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                                                      Low/Medium Volatiles Organic Analysis
                        LOW/MEDIUM VOLATILE DATA REVIEW




The data requirements to be checked are:




I.      Preservation




II.     Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check




III.     Initial Calibration




IV.     Continuing Calibration Verification (CCV)




V.     Blanks




VI.     Deuterated Monitoring Compounds (DMCs)




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)




VIII.   Regional Quality Assurance (QA) and Quality Control (QC)




IX.     Internal Standards




X.     Target Compound Identification




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




XII.    Tentatively Identified Compounds (TICs)




XIII.   System Performance




XIV.   Overall Assessment of Data
January 2005                                53                                  Draft Final

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                                                       Low/Medium Volatiles Organic Analysis
                                        I. Preservation

A.  Review Items:

    Form I VOA-1, Form I VOA-2, Form I VOA-TIC, Traffic Report/Chain of Custody Record
    (TR/COC), raw data, and the Sample Delivery Group (SDG) Narrative checking for:

    1.  pH
    2.  Sample temperature
    3.  Holding time
    4.  Other sample conditions (e.g., headspace)

B.  Objective:

    The objective is to ascertain the validity of the analytical results based on sample condition
    (i.e., preservation, temperature, headspace) and the holding time of the sample from the time of
    collection to the time of analysis.

C.  Criteria:

    The technical holding time criterion for aqueous samples are as follows:

       For volatile compounds in properly cooled (4°C ± 2°C) aqueous samples that are acid-preserved
       (with HC1 to a pH of 2 or below), the maximum holding time is 14 days from sample collection.

       For aqueous samples that were properly cooled (4°C ± 2°C), but which have no indication of
       being preserved, the  maximum holding time is 7  days from sample collection.

    The technical holding time criterion for non-aqueous samples are as follows:

       For volatile components that are frozen (less than ~7°C) or are properly cooled (4°C ± 2°C) and
       preserved with NaHSO4, the maximum holding time is fourteen (14) days from sample collection.

D.  Evaluation:

    Technical holding times  are established by comparing the sample collection dates on the TR/COC
    Record with the dates of analysis on Form I VOA-1,  Form I VOA-2, Form I VOA-TIC, and the raw
    data.   Information contained in the Complete SDG File (CSF) should also be considered in the
    determination of holding times.  Verify that the analysis dates on Form I(s) and the raw data/SDG file
    are identical. Review the SDG Narrative to determine if samples were preserved and arrived at the
    laboratory in proper condition (e.g., received intact, appropriate sample temperature at receipt, pH,
    absence of air bubbles or detectable headspace). If there is no indication in the SDG Narrative, the
    TR/COC Record, or the sample records that there was a problem with the samples, the integrity of
    samples can be assumed to be acceptable. If it is indicated that there were problems with the samples,
    the integrity of the sample may have been compromised and professional judgment should be used to
    evaluate the effect of the problem on the sample results.
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E.  Action:

    1.  Qualify aqueous sample results using preservation and technical holding time information as
       follows (see Table 13):

       a.  If there is no evidence that the samples were properly preserved, and the samples were
           analyzed within the technical holding time (7 days from sample collection), no qualification
           of the data is necessary.

        b.  If there is no evidence that the samples were properly preserved, and the samples were
           analyzed outside of the technical holding time (7 days from sample collection), qualify
           detects for all volatile compounds with a "J" and non-detects as unusable "R".

       c.  If the samples were properly preserved, and the samples were analyzed within the technical
           holding time (14 days from sample collection), no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were analyzed outside of the technical holding
           time (14 days from sample collection), qualify detects with a "J" and non-detects as
           unusable "R".

    2.  Qualify non-aqueous sample results using the preservation and technical holding time
       information as follows (see Table 13):

       a.  If there is no evidence that the samples were properly preserved, and the samples were
           analyzed within technical holding time (14 days from sample collection) qualify detects for
           all volatile compounds with a "J" and non-detects as unusable "R".

       b.  If the samples were properly preserved and the samples were analyzed within the technical
           holding time (14 days from sample collection), no qualification of the data is necessary.

       c.  If there is no evidence that the samples were properly preserved, and the samples were
           analyzed outside the technical holding time (14 days from sample collection), qualify detects
           for all volatile compounds with a "J" and non-detects as unusable "R".

       d.  If the samples were properly preserved, and the samples were analyzed outside the technical
           holding time (14 days from sample collection), qualify detects for all volatile compounds
           with a "J" and non-detects as unusable  "R".
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                                                       Low/Medium Volatiles Organic Analysis
               Table 13.  Holding Time Actions for Low/Medium Volatile Analyses
Matrix
Aqueous
Non-Aqueous
Preserved
No
No
Yes
Yes
No
Yes
Yes/No
Criteria
< 7 days
> 7 days
< 14 days
> 14 days
< 14 days
< 14 days
> 14 days
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
No qualification
J
R
No qualification
J
J
R
R
No qualification
J
R
    3.  Due to limited information concerning holding times for non-aqueous samples, it is left to the
       discretion of the data reviewer to apply aqueous holding times or other information that is
       available.

    4.  Note in the Data Review Narrative, whenever possible, the effect of the holding time exceedance
       on the resulting data.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, when technical holding
       times are exceeded.
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                                                      Low/Medium Volatiles Organic Analysis
      II. Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check

A.  Review Items:

    Form V VOA, bromofluorobenzene (BFB) mass spectra, and mass listing.

B.  Objective:

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

C.  Criteria:

    1.  The 12-hour clock begins with either the injection of BFB, or in cases where a closing Continuing
       Calibration Verification (CCV) can be used for an opening CCV, the 12-hour clock begins with
       the injection of the opening CCV.

    2.  Listed below are some, but not necessarily all, examples of acceptable analytical sequences
       incorporating the use of the opening and/or closing CCV.  Use these examples as a guide for
       possible analytical sequences that can be expected. The criteria associated with these analytical
       sequences have been evaluated as part of the Contract Compliance Screening (CCS) process.
 Conditions for When
 Example Sequence is
 Appropriate:
Acceptable Criteria That Must
Be Met:
Notes:
 Use Example 1 if time
 remains on the 12-hour
 clock after the initial
 calibration sequence
    BFB tunes meet instrument
    performance criteria.
    The five Initial Calibration
    standards meet initial
    calibration criteria.
    CCV A meets both opening
    and closing CCV criteria.
    CCV B meets closing CCV
    criteria.
The requirement of starting the new
12-hour clock for Analytical
Sequence 2 with a new BFB tune is
waived if CCV A meets opening
CCV criteria.  If CCV B meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
 Use Example 2 if time
 remains on the 12-hour
 clock after the initial
 calibration sequence
    BFB tunes meet instrument
    performance criteria.
    The five Initial Calibration
    standards meet initial
    calibration criteria.
    CCV A meets closing CCV
    criteria (but does not meet
    opening CCV criteria).
    CCV B meets opening CCV
    criteria.
    CCV C meets closing CCV
    criteria.
CCV A does not meet opening
CCV criteria, therefore, a new BFB
tune must be performed,
immediately followed by CCV B
before the method blank and any
samples may be analyzed.  In this
case, the new 12-hour clock and
Analytical Sequence 2 begins with
the injection of the new BFB tune.
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 Conditions for When
 Example Sequence is
 Appropriate:
Acceptable Criteria That Must
Be Met:
Notes:
 Use Example 3
 if more than 12-hours have
 elapsed since the most
 recent initial calibration or
 closing CCV,

 OR

 if the most recent closing
 CCV was not or could not
 be used as an opening CCV.
   BFB tunes meet instrument
   performance criteria.
   CCV A meets opening CCV
   criteria.
   CCV B meets both opening
   and closing CCV criteria.
   CCV C meets both opening
   and closing CCV criteria.
The requirement of starting the new
12-hour clock for Analytical
Sequence 2 with a new BFB tune is
waived if CCV B meets opening
CCV criteria. If CCV C meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
 Use Example 4
 if more than 12-hours have
 elapsed since the most
 recent initial calibration or
 closing CCV,

 OR

 if the most recent closing
 CCV was not or could not
 be used as an opening CCV.
   BFB tunes meet instrument
   performance criteria.
   CCV A meets opening CCV
   criteria.
   CCV B meets closing CCV
   criteria (but does not meet
   opening CCV criteria).
   CCV C meets opening CCV
   criteria.
   CCV D meets both opening
   and closing CCV criteria.
Because CCV B does not meet
opening CCV criteria before the
method blank and any samples may
be analyzed,  a new BFB tune must
be performed, immediately
followed by CCV B.  In this case,
the new 12-hour clock and
Analytical Sequence 2 begins with
the injection of the new BFB tune.
The requirement of starting the new
12-hour clock for Analytical
Sequence 3 with a new BFB tune is
waived if CCV D meets opening
CCV criteria. If CCV D meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
January 2005
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                                                       Low/Medium Volatiles Organic Analysis
 Example 1:

 Start of 12-hour clock for
 Analytical Sequence 1
 End of 12-hour clock for
 Analytical Sequence I/
 Beginning of 12-hour clock
 for Analytical Sequence 2
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour clock
 for Analytical Sequence 3
Time   Material Injected

 0 hr   BFB


        Initial Calibration 5.0

        Initial Calibration 10

        Initial Calibration 50

        Initial Calibration 100

        Initial Calibration 200

        Method Blank

        Subsequent Samples
 12 hr   CCV A
        (meets opening CCV criteria)
                                     Method Blank

                                     Subsequent Samples
 24 hr   CCV B
        (meets opening CCV criteria)
Analytical Sequence #

           1


           1

           1

           1

           1

           1

           1

           1

           1

           1

           1

           1

          1/2
           2

           2

           2

           2

           2

           2

          2/3
January 2005
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                                                      Low/Medium Volatiles Organic Analysis
 Example 2:

 Start of 12-hour clock for
 Analytical Sequence 1
Time

  Ohr
 End of 12-hour clock for
 Analytical Sequence 1


 Beginning of 12-hour
 clock for Analytical
 Sequence 2
  12 hr
  13 hr
Material Injected

BFB


Initial Calibration 5.0

Initial Calibration 10

Initial Calibration 50

Initial Calibration 100

Initial Calibration 200

Method Blank

Subsequent Samples
CCVA
(meets closing CCV criteria,
fails opening CCV criteria)

BFB
                                     CCVB
                                     (meets opening CCV criteria)

                                     Method Blank

                                     Subsequent Samples
Analytical Sequence #

           1
 End of 12-hour clock for
 Analytical Sequence 2
  25 hr
ccvc
(meets closing CCV criteria)
           2

           2

           2

           2

           2

           2

           2
January 2005
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                                                     Low/Medium Volatiles Organic Analysis
 Example 3:

 Start of 12-hour clock for
 Analytical Sequence 1
 End of 12-hour clock for
 Analytical Sequence I/
 Beginning of 12-hour clock
 for Analytical Sequence 2
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour clock
 for Analytical Sequence 3
Time          Material Injected

 0 hr    BFB


        CCVA
        (meets opening CCV criteria)

        Method Blank

        Subsequent Samples
12 hr
24 hr
CCVB
(meets opening CCV criteria)
                                    Method Blank

                                    Subsequent Samples
Analytical Sequence #

          1


          1


          1

          1

          1

          1

          1

          1

         1/2
ccvc
(meets opening CCV criteria)
         2

         2

         2

         2

         2

        2/3
January 2005
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                                                     Low/Medium Volatiles Organic Analysis
 Example 4:

 Start of 12-hour clock for
 Analytical Sequence 1
Time

 Ohr
      Material Injected
 End of 12-hour clock for
 Analytical Sequence 1


 Beginning of 12-hour
 clock for Analytical
 Sequence 2
12 hr
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour
 clock for Analytical
 Sequence 3
25 hr
BFB
Analytical Sequence #
          1
                                    CCVA
                                    (meets opening CCV criteria)

                                    Method Blank

                                    Subsequent Samples
CCVB
(meets closing CCV criteria,
fails opening CCV criteria)
13 hr    BFB
                                    CCVC
                                    (meets opening CCV criteria)

                                    Method Blank

                                    Subsequent Samples
CCVD
(meets opening CCV criteria)
         2

         2

         2

         2

         2

        2/3
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                                                       Low/Medium Volatiles Organic Analysis
    3.  Inject a sufficient amount of the instrument performance check solution (50 ng BFB on-column)
       at the beginning of each 12-hour period during which samples or standards are analyzed. The
       instrument performance check, BFB for volatile analysis, must meet the ion abundance criteria
       listed in Table 14. This criteria is waived in cases where a closing CCV can be used as an
       opening CCV (i.e., a BFB instrument performance check analysis is not required when a closing
       CCV analysis meets the requirements of an opening CCV analysis).

               Table 14. Ion Abundance Criteria For Bromofluorobenzene (BFB)
Mass
50
75
95
96
173
174
175
176
177
Ion Abundance Criteria
15.0 -40.0% of mass 95
30.0 -80.0% of mass 95
Base peak, 100% relative abundance
5.0 -9.0% of mass 95*
Less than 2.0% of mass 174
50.0% -120% of mass 95
5.0 -9.0% of mass 174
95.0- 101% of mass 174
5.0 -9.0% of mass 176
    *   All ion abundances must be normalized to mass to charge (m/z) 95, the nominal base peak, even
       though the ion abundance of m/z 174 may be up to 120% that of m/z 95.

D.  Evaluation:

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

       a.  Form V VOA is present and completed for each 12-hour period during which samples were
          analyzed. In cases where a closing CCV is used as an opening CCV for the next 12-hour
          period, an additional Form V VOA is not required.

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

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

       d.  The laboratory has not made any calculation errors.
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                                                        Low/Medium Volatiles Organic Analysis
    2.  Verify that samples were not analyzed before a valid instrument performance check or were not
       analyzed 12 hours after the injection of the Instrument Performance Check Solution. This
       evaluation is not to be performed in cases where a closing CCV is used as an opening CCV.

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

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

    5.  If possible, verify that spectra were generated using appropriate background subtraction
       techniques.  Since the BFB spectrum is obtained from chromatographic peaks that should be free
       from coelution problems, background subtraction should be done in accordance with the
       following procedure:

       a.  Three scans (the peak apex scan and the scans immediately preceding and following the
           apex) are acquired and averaged.

       b.  Background subtraction is required, and must be accomplished using a single scan no more
           than 20 scans prior to the elution of BFB. Do not subtract the BFB peak as part of the
           background.

           NOTES:   All mass spectrometer instrument conditions must be identical to those used
                      during the sample analysis.  Background subtraction actions resulting in spectral
                      distortions for the sole purpose of meeting the method specifications are contrary
                      to the Quality Assurance (QA) objectives, and are therefore unacceptable.

                      For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the CCS process. Information regarding the
                      laboratory's compliance with these criteria can be obtained from the Data
                      Assessment Tool (DAT) reports, and may be used as part of the evaluation
                      process.

E.  Action:

    1.  If samples are analyzed without a preceding valid instrument check or are analyzed 12 hours after
       the Instrument Performance Check and are not preceded by an analysis of a closing CCV that
       meets opening CCV criteria, qualify all data for those samples as unusable "R".

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

    3.  If the laboratory has failed to provide the correct forms or has made significant transcription or
       calculation errors, the Region's designated representative should contact the laboratory and
       request corrected data. If the information is  not available, the reviewer must use professional
       judgment to assess the data. Notify the laboratory's Contract Laboratory Program Project Officer
       (CLP PO).

    4.  If mass assignment is in error (e.g., m/z 96 is indicated as the base peak rather than m/z 95),
       classify all associated data as unusable "R".
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                                                        Low/Medium Volatiles Organic Analysis
    5.  If ion abundance criteria are not met, professional judgment may be applied to determine to what
       extent the data may be utilized. When applying professional judgment to this topic, the most
       important factors to consider are the empirical results that are relatively insensitive to location on
       the chromatographic profile and the type of instrumentation. Therefore, the critical ion
       abundance criteria for BFB are the m/z 95/96, 174/175, 174/176, and 176/177 ratios.  The relative
       abundances of m/z 50 and 75 are of lower importance.  This issue is more critical for Tentatively
       Identified Compounds (TICs) than for target analytes.

    6.  Note in the Data Review Narrative decisions to use analytical data associated with BFB
       instrument performance checks not meeting contract requirements.

    7.  If the reviewer has reason to believe that instrument performance check criteria were achieved
       using techniques other than those described in Low/Medium Volatiles Organic Analysis, Section
       II.D.5, obtain additional information on the instrument performance checks. If the techniques
       employed are found to be at variance with the contract requirements, the performance and
       procedures of the laboratory may merit evaluation. Note, for CLP PO action, concerns or
       questions regarding laboratory performance.  For example, if the reviewer has reason to believe
       that an inappropriate technique was used to obtain background subtraction (such as background
       subtracting from the solvent front or from another region of the chromatogram rather than from
       the BFB  peak), this should be noted for CLP PO action.
January 2005                                 65                                    Draft Final

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                                                         Low/Medium Volatiles Organic Analysis
                                     III. Initial Calibration

A.  Review Items:

    Form VI VOA-1, Form VI VOA-2, Form VIVOA-3, quantitation reports, and chromatograms.

B.  Objective:

    Compliance requirements for satisfactory instrument calibration are established to ensure that the
    instrument is capable of producing acceptable qualitative and quantitative data for compounds on the
    volatile Target Compound List (TCL). Initial calibration demonstrates that the instrument is capable
    of acceptable performance in the beginning of the analytical_run and of producing a linear calibration
    curve and provides the Mean Relative Response Factors (RRFs) used for quantitation.

C.  Criteria:

    1.  Initial calibration standards containing both volatile target compounds and Deuterated Monitoring
       Compounds (DMCs) are analyzed at concentrations of 5.0, 10, 50, 100, and 200 (ig/L for non-
       ketones, 10, 20,  100, 200, and 400 (ig/L for ketones, and 100, 200, 1250, 2000, and 4000 (ig/L
       for 1,4-dioxane at the beginning of each analytical sequence, or as necessary if the continuing
       calibration verification acceptance criteria are not met. All three xylene isomers (o-, m-, and
       p-xylene) must be present in the calibration standards. The o-xylene calibration standard
       concentrations must be at 5.0, 10, 50, 100, and 200 (ig/L, while the concentration of the m- plus
       the p-xylene isomers must total 5.0, 10, 50, 100, and 200 (ig/L.  The initial calibration (and any
       associated samples and blanks) must be analyzed within  12 hours of the associated instrument
       performance check.

    2.  Initial calibration standard Relative Response Factors (RRFs) for the volatile target compounds
       listed in Table 15 and all DMCs must be greater than or equal to 0.010.  The RRF for all other
       volatile target compounds must be greater than or equal to 0.050.

    3.  The Percent Relative Standard Deviation (%RSD) of the initial calibration RRFs must be less
       than or equal to 40.0% for the volatile target compounds and DMCs listed in Table  15 except for
       1,4-dioxane and its associated DMC (±50.0%).  The %RSD for all other volatile target
       compounds and associated DMCs must be less than or equal to 20.0%.

       NOTE:    The flexibility clause in the method may impact some of the criteria preceding.  A
                  copy of the flexibility clause should be present in the Sample Delivery Group (SDG).
                  Refer to the  Contract Laboratory Program (CLP) home page at
                  http://www.epa.gov/oerrpage/superfund/programs/clp/modifiedanalyses.htm for the
                  specific method flexibility requirements.

D.  Evaluation:

    1.  Verify that the correct concentrations of standards were used for the initial calibration (i.e. 5.0,
       10, 50, 100, and 200 (ig/L for non-ketones, 10, 20,  100, 200, and 400 (ig/L for ketones, and 100,
       200, 1250, 2000, and 4000 (ig/L for 1,4-dioxane).
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                                                        Low/Medium Volatiles Organic Analysis
    2.  Verify that the RRF obtained from the associated initial calibration was used for calculating
       sample results and the samples were analyzed within 12 hours of the associated instrument
       performance check.

    3.  Evaluate the initial calibration RRFs and the RRF for all volatile target compounds and DMCs:

       a.  Check and recalculate the RRFs and RRF for at least one volatile target compound associated
           with each internal standard.  Verify that the recalculated value(s) agrees with the laboratory
           reported value(s).

       b.  Verify that for all volatile target compounds listed in Table 15 and for all DMCs, the initial
           calibration RRFs are greater than or equal to 0.050, and for all other volatile target
           compounds, RRFs are greater than or equal to 0.050.

                    Table 15. Volatile Compounds Exhibiting Poor Response
Volatile Compounds
Acetone
2-Butanone
Carbon disulfide
Chloroethane
Chloromethane
Cyclohexane
1 ,2-Dibromoethane
Dichlorodifluoromethane
1 ,2-Dichloropropane
cis- 1 ,2-Dichloroethene
1,4-Dioxane
l,2-Dibromo-3-chloropropane
Isopropylbenzene
Methyl acetate
Methylene chloride
Methylcyclohexane
Methyl tert-butyl ether
trans- 1 ,2-Dichloroethene
4-Methyl-2-pentanone
2-Hexanone
Trichlorofluoromethane
1 , 1 ,2-Trichloro- 1 ,2,2-trifluoroethane
    4.  Evaluate the %RSD for all volatile target compounds and DMCs:

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

           i.   If the %RSD is greater than the maximum criteria [40.0% for the volatile target
               compounds listed in Table 15, and associated DMCs (see Table 21) except for 1,4-
               dioxane (±50.0%) and its associated DMC, and 20.0% for all other volatile target
               compounds and associated DMCs], the reviewer should use professional judgment to
               determine the need to check the points on the curve for the cause of the non-linearity.
               This is checked by eliminating either the high-point or the low-point and recalculating the
               %RSD (see Low/Medium Volatiles Organic Analysis, Section III.E.2).
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                                                        Low/Medium Volatiles Organic Analysis
    5.  If errors are detected in the calculations of either the RRFs or the %RSD, perform a more
       comprehensive recalculation.

       NOTE:    For data obtained from the CLP, the preceding criteria are evaluated as part of the
                  Contract Compliance Screening (CCS) process. Information regarding the
                  laboratory's compliance with these criteria can be obtained from the Data Assessment
                  Tool (DAT) reports, and may be used as part of the evaluation process.

E.  Action:

    1 .  Qualify all volatile target compounds, including the compounds  exhibiting poor response listed in
       Table 15, using the following criteria (see Table  16):

       a.  If any volatile target compound has an RRF value less than the minimum criterion (0.010 for
           the compounds exhibiting poor response listed in Table 15, and 0.050 for all other volatile
           compounds), use professional judgment for detects, based on mass spectral identification, to
           qualify the data as a "J" or unusable "R".

       b.  If any volatile target compound has an RRF value less than the minimum criterion (0.010 for
           the compounds exhibiting poor response listed in Table 15, and 0.050 for all other volatile
           compounds), qualify non-detected compounds as unusable "R".

       c.  If any of the volatile target compounds listed in Table 15 has %RSD greater than 40.0%,
           except for 1,4-dioxane (±50.0%), qualify detects with a "J" and non-detected compounds
           using professional judgment (see Low/Medium Volatiles Organic Analysis, Section III.E.2).

       d.  For all other volatile target compounds, if %RSD is greater than 20.0%, qualify detects with a
           "J" and non-detected compounds using professional judgment (see Low/Medium Volatiles
           Organic Analysis, Section III.E.2).
       e.  If the volatile target compounds meet the acceptance criteria for RRF and %RSD, no
           qualification of the data is necessary.

       f  No qualification of the data is necessary on the DMC RRF and %RSD data alone. Use
           professional judgment and follow the guidelines in Low/Medium Volatiles Organic Analysis,
           Section III.E.2, to use the DMC RRF and %RSD data in conjunction with the DMC
           recoveries for determination of the need for qualification of the data.

    2.  At the reviewer's discretion, and based on the project-specific data quality objectives, a more in-
       depth review may be considered using the following guidelines:

       a.  If any volatile target compound has a %RSD greater than the maximum criterion [40.0% for
           the compounds listed in Table 15, except for 1,4-dioxane (±50.0%), and 20.0% for all other
           volatile compounds], and if eliminating either the high or the low-point of the curve does not
           restore the %RSD to less than or equal to the required maximum:

           i.  Qualify detects for that compound(s) with a " J" .

           ii.  Qualify non-detected volatile target compounds using professional judgment.
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                                                         Low/Medium Volatiles Organic Analysis
       b.  If the high-point of the curve is outside of the linearity criteria (e.g., due to saturation):

           i.   Qualify detects outside of the linear portion of the curve with a "J".

           ii.  No qualifiers are required for detects in the linear portion of the curve.

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

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

           i.   Qualify low-level detects in the area of non-linearity with a "J".

           ii.  No qualifiers are required for detects in the linear portion of the curve.

           iii.  For non-detected volatile compounds, use the lowest point of the linear portion of the
               curve to determine the new quantitation limit.

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

    4.  Note in the Data Review Narrative, whenever possible, the potential effects on the data due to
       calibration criteria exceedance.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if calibration criteria are
       grossly exceeded.

             Table 16. Initial Calibration Actions for Low/Medium Volatiles Analyses
Criteria for Low/Med Analysis
RRF< 0.010
(target compounds listed in Table 15)
RRF < 0.050 (all other target compounds)
RRF> 0.010
(target compounds listed in Table 15)
RRF > 0.050 (all other target compounds)
%RSD < 50.0 (1,4-dioxane)
%RSD < 40.0
(target compounds listed in Table 15)
%RSD < 20.0 (all other target compounds)
Action
Detected Non-Detected
Associated Compounds Associated Compounds
JorR
(based on mass R
spectral identification)
No
No
qualification
qualification
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                                                    Low/Medium Volatiles Organic Analysis
       Table 16.  Initial Calibration Actions for Low/Medium Volatiles Analyses (CON'T)
Criteria for Low/Med Analysis
%RSD > 50.0 (1,4-dioxane)
%RSD > 40.0
(target compounds listed in Table 15)
%RSD > 20.0 (all other target compounds)
Action
Detected
Associated Compounds
J
Non-Detected
Associated Compounds
Use professional
judgment
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                                                       Low/Medium Volatiles Organic Analysis
                        IV.  Continuing Calibration Verification (CCV)

A.  Review Items:

    Form VII VOA-1, Form VIIVOA-2, Form VIIVOA-3, quantitation reports, and chromatograms.

B.  Objective:

    Compliance requirements for satisfactory instrument calibration are established to ensure that the
    instrument is capable of producing acceptable qualitative and quantitative data. The CCV checks
    satisfactory performance of the instrument on a day-to-day basis, however, quantitations are based on
    the Mean Relative Response Factors (RRFs) obtained from the initial calibration.

C.  Criteria:

    1.  The  12-hour clock begins with either the injection of Bromofluorobenzene (BFB), or in cases
       where a closing CCV can be used in an opening CCV, the 12-hour clock begins with the  injection
       of the opening CCV.

    2.  CCV standards containing both target compounds and associated Deuterated Monitoring
       Compounds (DMCs) are analyzed both at the beginning (opening  CCV) and end (closing CCV)
       of each 12-hour analysis period following the analysis of the instrument performance check, and
       prior to the analysis of the method blank and samples.  An instrument performance check is not
       required prior to the analysis of a closing CCV or prior to a closing CCV which can be used as an
       opening CCV for the next 12-hour period. If time remains in the 12-hour time period after initial
       calibration and samples are to be analyzed, the mid-point standard from the initial calibration can
       be used as the opening CCV.

    3.  For an opening CCV, the Relative Response Factors (RRFs) for the volatile target compounds
       listed in Table 15 and for all DMCs must be greater than or equal to 0.010. The RRF for all other
       volatile target compounds must be greater than or equal to 0.050.

    4.  For a closing CCV, the RRFs for all volatile target compounds and DMCs must be greater than or
       equal to 0.010.
    5.  The Percent Difference (%D) between the initial calibration RRF and the opening CCV RRF must
       be within ±40.0% for the volatile target compounds listed in Table 15 and associated DMCs listed
       in Table 21, except for 1,4-dioxane and its associated DMC (±50.0%). The Percent Difference
       for all other volatile target compounds and associated DMCs must be within ±25.0%.

    6.  For the closing CCV, the Percent Difference between the initial calibration RRF and the CCV
       RRF must be with ±50.0% for all volatile target compounds and associated DMCs.

D.  Evaluation:

    1.  Verify that the CCV was run at the required frequency (an opening and closing CCV must be run
       within a 12-hour period) and the CCV was compared to the correct initial calibration. If the mid-
       point standard from the initial calibration is used as an opening CCV, verify that the result (RRF)
       of the mid-point standard was compared to the RRF from the correct initial calibration.
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                                                        Low/Medium Volatiles Organic Analysis
    2.  Evaluate the CCV RRF for all volatile target compounds and DMCs:

       a.  Check and recalculate the CCV RRF for at least one volatile target compound and DMC
           associated with each internal standard. Verify that the recalculated value(s) agrees with the
           laboratory reported value (s).

       b.  For an opening CCV, verify that for the volatile target compounds listed in Table 15 and all
           DMCs have CCV RRFs greater than or equal to 0.010, and all other volatile target
           compounds and DMCs have RRFs greater than or equal to 0.050.

       c.  For a closing CCV, verify that all volatile target compounds and DMCs have CCV RRFs of
           greater than or equal to 0.010.
    3.  Evaluate the Percent Difference between initial calibration RRF and CCV RRF (both opening and
       closing) for all volatile target compounds and DMCs:

       a.  Check and recalculate the Percent Difference for one or more volatile target compound(s) and
           DMCs associated with each internal standard. Verify that the recalculated value(s) agrees
           with the laboratory-reported value(s).

       b.  For an opening CCV, verify that the Percent Difference is within ±40.0% for the volatile
           target compounds listed in Table 15 and associated DMCs listed in Table 21, except for 1,4-
           dioxane and its associated DMC (±50.0%), and within ±25.0% for all other volatile target
           compounds and associated DMCs.

       c.  For a closing CCV, verify that the Percent Difference is within ±50.0% for all volatile target
           compounds and DMCs.

    4.  If errors are detected in the calculations of either the CCV (both opening and closing) RRF or the
       Percent Difference, perform a more comprehensive recalculation.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are  evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E .  Action:

    1.  If a CCV (opening and  closing) was not run at the appropriate frequency, qualify all data as
       unusable "R" (see Table 17).

    2.  Qualify all volatile target compounds, including the compounds exhibiting poor response listed in
       Table 15 using the following criteria:

       a.  For an opening CCV, if any volatile target compound has an RRF value less than the
           minimum criterion  (0.010 for the compounds listed in Table 15 and 0.050 for all other
           volatile compounds), use professional judgment for detects based on mass spectral
           identification to qualify the data as a "J" or unusable  "R".
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                                                        Low/Medium Volatiles Organic Analysis
       b.  For a closing CCV, if any volatile target compound has an RRF value less than 0.010, use
           professional judgment for detects based on mass spectral identification to qualify the data as a
           "J" or unusable "R".

       c.  For an opening CCV, if any volatile target compound has an RRF value less than the
           minimum criterion (0.010 for the compounds exhibiting poor response and 0.050 for all other
           volatile compounds), qualify non-detected compounds as unusable "R".

       d.  For a closing CCV, if any volatile target compound has an RRF value less than 0.010, qualify
           non-detected compounds as unusable "R".

       e.  For an opening CCV, if the Percent Difference value for any of the volatile target compounds
           listed in Table 15 is outside the ±40.0% criterion, except for 1,4-dioxane (±50.0%), qualify
           detects with a "J" and non-detected compounds with an approximated "UJ".

       f  For a closing CCV, if the Percent Difference value for any of the volatile target compounds
           listed in Table 15 is outside the ±50.0% criterion, qualify detects with a "J" and non-detected
           compounds with an approximated "UJ".

       g.  For an opening CCV, if the Percent Difference value for any other volatile target compound
           is outside the ±25.0% criterion, qualify detects with a "J" and non-detected compounds with
           an approximated "UJ".

       h.  For a closing CCV, if the Percent Difference value for any other volatile target compound is
           outside the ±50.0% criterion, qualify detects with a "J" and non-detected compounds with an
           approximated "UJ".

       i.  If the volatile target compounds meet the acceptance criteria for RRF and Percent Difference,
           no qualification of the data is necessary.

       j.  No qualification of the data is necessary on the DMC RRF and Percent Difference data alone.
           However, use professional judgment to evaluate the DMC RRF and Percent Difference data
           in conjunction with the DMC recoveries to determine the need for qualification of data.

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

    4.  Note in the Data Review Narrative, whenever possible, the potential effects on the data due to
       calibration criteria exceedance.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if calibration criteria are
       grossly exceeded.
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                                                    Low/Medium Volatiles Organic Analysis
               Table 17. Continuing Calibration Verification (CCV) Actions for
                              Low/Medium Volatiles Analyses
Criteria for
Opening CCV
RRF< 0.010
(target compounds listed in Table 15)
RRF < 0.050 (all other target compounds)
RRF> 0.010
(target compounds listed in Table 15)
RRF > 0.050 (all other target compounds)
%D > 50.0 or < -50.0 (1,4-dioxane)
%D > 40.0 or < -40.0
(target compounds listed in Table 15)
%D > 25.0 or < -25.0
(all other target compounds)
%D < 50.0 and > -50.0 (1,4-dioxane)
%D < 40.0 and > -40.0
(target compounds listed in Table 15)
%D < 25.0 and > -25.0
(all other target compounds)
Opening CCV not performed at required
frequency (see Low/Med, Section IV. C.I)
Criteria for
Closing CCV
RRF < 0.010
(all volatile target
compounds)
RRF> 0.010
(all volatile target
compounds)
%D > 50.0 or
< -50.0
(all volatile target
compounds)
%D < 50.0 and
> -50.0
(all volatile target
compounds)
Closing CCV not
performed at
required frequency
(see Low/Med,
Section IV.C.l)
Action
Detected
Associated
Compounds
J or R (based
on mass
spectral
identification)
Non-Detected
Associated
Compounds
R
No qualification
J
UJ
No qualification
R
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                                                        Low/Medium Volatiles Organic Analysis
                                          V.  Blanks

A.  Review Items:

    Form I VOA-1, Form I VOA-2, Form IVOA-TIC, Form IV VOA, chromatograms, and quantitation
    reports.

B.  Objective:

    The purpose of laboratory, field, or trip blank analyses is to determine the existence and magnitude of
    contamination resulting from laboratory, field,  or sample transport activities.  The purpose of the
    method blank is to determine the levels of contamination associated with the processing and analysis
    of samples.  The storage blank indicates whether contamination may have occurred during storage of
    samples. The results from the instrument blank analysis indicate whether there is contamination from
    a previous sample. The criteria for evaluation of blanks apply to any blank associated with the
    samples (e.g., method blanks, instrument blanks, storage blanks, field blanks, or trip blanks). If
    problems with any blank exist, all associated data must be carefully evaluated to  determine whether
    or not there  is an inherent variability in the data or if the problem is an isolated occurrence not
    affecting other data.

C.  Criteria:

    1.  Method Blanks

       A method blank analysis must be performed after the calibration standards and once for every 12-
       hour time period.

       The method blank must be analyzed on each Gas Chromatograph/Mass Spectrometer (GC/MS)
       system used to analyze samples.  The method blank must be matrix specific (i.e., a non-aqueous
       method  blank is required for non-aqueous samples, and an aqueous  method blank is required for
       aqueous samples).

    2.  Storage Blanks

       A storage blank must be prepared upon receipt of the first samples from a Sample Delivery Group
       (SDG),  and stored with the samples until analysis. The storage blank must be analyzed once per
       SDG.

    3.  Instrument Blank

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

       The concentration of each target compound in the instrument blank  must be less than its Contract
       Required Quantitation Limit (CRQL) listed in the method.
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                                                        Low/Medium Volatiles Organic Analysis
       NOTE:    The concentration of each target compound found in the storage, method, field, or
                  trip blanks must be less than its CRQL listed in the method, except for methylene
                  chloride, acetone, and 2-butanone which must be less than 2 times (2x) their
                  respective CRQLs.

D .  Evaluation:

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

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

    3.  Verify that a method blank has been analyzed  for each matrix present (i.e. if non-aqueous
       samples are present, verify that there is a non-aqueous method blank).

    4.  Verify that a storage blank has been analyzed and included with each SDG.

    5.  Verify that the instrument blank analysis has been performed following any sample analysis
       where a target analyte(s) is/are reported at high concentration(s).

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be  used as part of the
                  evaluation process. Data concerning the field or trip blanks are not evaluated as part
                  of the CCS  process. If field or trip blanks are present, the data reviewer should
                  evaluate this data in a similar fashion as method blanks.

E.  Action:

    Action regarding unsuitable blank results depends on the circumstances and origin of the blank.  In
    instances where more than one of the same type of blank is associated with a given sample,
    qualification should be based upon a comparison with the associated blank having the highest
    concentration of a contaminant. Do not correct the results by subtracting any blank value.

    1.  If a volatile compound is found in a method blank, but not found in the sample, no qualification
       of the data is necessary  (see Table 18).

    2.  If the method blank concentration is greater than the CRQL (greater than 2x the CRQL for
       methylene chloride, 2-butanone, and acetone)  and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, and less than the blank
           concentration, report the concentration of the compound in the sample at the same
           concentration found in the blank and qualify with a "U", or the reviewer may elect to qualify
           the data as unusable "R".
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                                                        Low/Medium Volatiles Organic Analysis
       c.  the sample concentration is greater than or equal to the CRQL and greater than or equal to the
           blank concentration, use professional judgment to qualify the data.

    3.  If the method blank concentration is less than the CRQL (less than 2x the CRQL for methylene
       chloride, 2-butanone, and acetone) and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    4.  If the method blank concentration is equal to the CRQL (equal to 2x the CRQL for methylene
       chloride, 2-butanone, and acetone) and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    5.  If gross contamination exists  (i.e., saturated peaks by GC/MS), qualify all affected compounds in
       the associated samples as unusable "R" due to interference.  Note, for Contract Laboratory
       Program Project Officer (CLP PO) action, if the contamination is suspected of having an effect on
       the sample results.

    6.  Give the same consideration as the target compounds to the Tentatively Identified  Compounds
       (TICs), which are found in both the sample and associated blank(s) (see  Low/Medium Volatiles
       Organic Analysis, Section XII, for TIC guidance).

       NOTE:    There may be instances where  little or no contamination was present in the associated
                  blanks, but qualification of the sample is deemed necessary. If the reviewer
                  determines that the contamination is from a source other than the sample, they should
                  qualify the data.  Contamination introduced through dilution water is one example.
                  Although it is not always possible to determine, instances of this occurring can be
                  detected when contaminants are found in the diluted sample result, but are absent in
                  the undiluted sample result.

    7.  If an instrument blank was not analyzed following  a sample analysis which contained an
       analyte(s) at high concentration(s), evaluate the sample analysis results immediately after the high
       concentration sample for carryover. Use professional judgment to determine if instrument cross-
       contamination has affected any positive compound identification(s). Note, for CLP PO  action, if
       instrument cross-contamination is suggested and is suspected of having an effect on the  sample
       results.

    8.  If contaminants are found in the storage, field, or trip blanks, the following is recommended:

       a.  Review the associated method blank data to determine if the contaminant(s) was also present
           in the method blank.
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                                                       Low/Medium Volatiles Organic Analysis
           i.  If the analyte was present at a comparable level in the method blank, the source of the
              contamination may be in the analytical system and the action recommended for the
              method blank would apply.

           ii.  If the analyte was not present in the method blank, the source of contamination may be in
              the storage area, in the field, or during sample transport, consider all associated samples
              for possible cross-contamination.

       b.  If the storage, field, or trip blanks contain a volatile Target Compound List (TCL)
           compound(s) at a concentration less than the CRQL and:

           i.  the sample concentration is less than the CRQL (2x the CRQL for methylene chloride, 2-
              butanone, and acetone), report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL [2x the CRQL (4x the
              CRQL for methylene chloride, 2-butanone, and acetone)], use professional judgment to
              qualify the data.

       c.  If the storage, field, or trip blanks contain a volatile TCL compound(s) at a concentration
           greater than the CRQL and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, and less than the blank
              concentration, report the concentration of the compound in the sample at the same
              concentration found in the blank and qualify with a "U", or the reviewer may elect to
              qualify the data as unusable "R".

           iii. the sample concentration is greater than or equal to the CRQL and greater than or equal
              to the blank concentration, use professional judgment to qualify the data.

       d.  If the storage, field, or trip blanks contain a volatile TCL compound(s) at a concentration
           equal to the CRQL (2x the CRQL for methylene chloride, 2-butanone, and acetone) and:

           i.  the sample concentration is less than the CRQL (2x the CRQL for methylene chloride, 2-
              butanone, and acetone), report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL (2x the CRQL for
              methylene chloride, 2-butanone, and acetone), use professional judgment to qualify the
              data.

       e.  If gross contamination (i.e.,  saturated by GC/MS) exists in the storage, field or trip blank,
           positive sample results may  require rejection and be qualified as unusable "R". Non-detected
           volatile target compounds do not require qualification unless the contamination is so high that
           it interferes with the analyses of non-detected compounds.
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                                                      Low/Medium Volatiles Organic Analysis
                  Table 18. Blank Actions for Low/Medium Volatiles Analyses
Blank Type




Method,
Storage, Field,
Trip,
Instrument * *



Blank Result
Detects

< CRQL*

> CRQL*


— CRQL*
Gross
contamination
Sample Result
Not detected
 CRQL
 CRQL and
< blank concentration
> CRQL and
> blank concentration
CRQL
Detects
Action for Samples
No qualification
Report CRQL value with a U
Use professional judgment
Report CRQL value with a U
Report the concentration for the sample
with a U or qualify the data as unusable R
Use professional judgment
Report CRQL value with a U
Use professional judgment
Qualify results as unusable R
    *   2x the CRQL for methylene chloride, 2-butanone, and acetone.
    **  Qualifications based on instrument blank results affect only the sample analyzed immediately
       after the sample that has target compounds that exceed the calibration range or non-target
       compounds that exceed 100 (ig/L.
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                                                        Low/Medium Volatiles Organic Analysis
                        VI. Deuterated Monitoring Compounds (DMCs)
A.  Review Items:
    Form IIVOA-1, Form IIVOA-2, Form II VOA-3, Form II VOA-4, quantitation reports, and
    chromatograms.

B.  Objective:

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

C.  Criteria:

    1.  The DMCs listed in Table 19 are added to all samples and blanks to measure their recovery in
       environmental samples.

       Table 19. Volatile Deuterated Monitoring Compounds (DMCs) and Recovery Limits
DMC
Vinyl chloride -d3
Chloroethane-d5
1 , 1 -Dichloroethene-d2
2-Butanone-d5
Chloroform-d
1 ,2-Dichloroethane-d4
Benzene-d6
1 ,2-Dichloropropane-d6
Toluene-d8
trans- 1 ,3-Dichloropropene-d4
2-Hexanone-d5
l,4-Dioxane-d8
1 , 1 ,2,2-Tetrachloroethane-d2
1 ,2-Dichlorobenzene-d4
Recovery Limits (%) for
Water Samples
65- 131
71 - 131
55 - 104
49 - 155
78- 121
78 - 129
77 - 124
79 - 124
77- 121
73 - 121
28 - 135
50- 150
73 - 125
80- 131
Recovery Limits (%)
for Soil Samples
68 - 122
61- 130
45 - 132
20- 182
72 - 123
79 - 122
80- 121
74 - 124
78- 121
72- 130
17- 184
50-150
56- 161
70- 131
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                                                        Low/Medium Volatiles Organic Analysis
    2.  Recoveries for DMCs in volatile samples and blanks must be within the limits specified in
       Table 19.

       NOTE:    The recovery limits for any of the compounds listed in Table 19 may be expanded at
                  any time during the period of performance if USEPA determines that the limits are
                  too restrictive.

D.  Evaluation:

    1.  Check raw data (e.g., chromatograms and quantitation reports) to verify the recoveries on the
       Deuterated Monitoring Compound Recovery Forms (Form IIVOA-1, Form II VOA-2, Form II
       VOA-3, and Form IIVOA-4).

       Check for any calculation or transcription errors; verify that the DMC recoveries were calculated
       correctly using the equation in the method.

    2.  Whenever there are two or more analyses for a particular sample, the reviewer must determine
       which are the most acceptable data to report.  Considerations include, but are not limited to:

       a.  DMC recovery (marginal versus gross deviation).

       b.  Technical holding times.

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

       d.  Other Quality Control (QC) information, such as performance of internal standards.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    Table 21 lists the volatile DMCs and their associated target compounds. If any DMC recovery in the
    volatiles fraction is  out of specification, qualify data considering the existence of interference in the
    raw data (see Table 20). Considerations include, but are not limited to:

    1.  For any recovery greater than the upper acceptance limit:

       a.  Qualify detected associated volatile target compounds as a "J".

       b.  Do not qualify non-detected associated volatile target compounds.

    2.  For any recovery greater than or equal to 20%, and less than the lower acceptance limit:

       a.  Qualify detected associated volatile target compounds as a "J".

       b.  Qualify non-detected associated volatile target compounds as approximated "UJ".



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                                                        Low/Medium Volatiles Organic Analysis
    3.  For any recovery less than 20%:

       a.  Qualify detected associated volatile target compounds as a "J".

       b.  Qualify non-detected associated volatile target compounds as unusable "R".

    4.  For any recovery within acceptance limits, no qualification of the data is necessary.

    5.  In the special case of a blank analysis having DMCs out of specification, the reviewer must give
       special consideration to the validity of associated sample data. The basic concern is whether the
       blank problems represent an isolated problem with the blank alone, or whether there is a
       fundamental problem with the analytical process. For example, if one or more samples in the
       batch show acceptable DMC recoveries, the reviewer may choose to consider the blank problem
       to be an isolated occurrence. However, even if this judgment allows some use of the affected
       data, note analytical problems for Contract Laboratory Program Project Officer (CLP PO) action.
             Table 20. Deuterated Monitoring Compound (DMC) Recovery Actions
                              For Low/Medium Volatiles Analyses
Criteria
%R > Upper Acceptance
Limit
20% < %R < Lower Acceptance Limit
%R < 20%
Lower Acceptance Limit
< %R < Upper Acceptance Limit
Action
Detected
Associated
Compounds
J
J
J
Non-detected
Associated
Compounds
No qualification
UJ
R
No qualification
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                                                     Low/Medium Volatiles Organic Analysis
                Table 21. Volatile Deuterated Monitoring Compounds (DMCs)
                            and the Associated Target Compounds
 Chloroethane-d5 (PMC)
l,2-Dichloropropane-d6 (PMC)
l,2-Pichlorobenzene-d4 (PMC)
 Dichlorodifluoromethane

 Chloromethane

 Bromomethane

 Chloroethane

 Carbon disulfide
Cyclohexane

Methylcyclohexane

1,2-Dichloropropane

Bromodichloromethane
Chlorobenzene

1,3 -Dichlorobenzene

1,4-Dichlorobenzene

1,2-Dichlorobenzene

1,2,4-Trichlorobenzene

1,2,3-Trichlorobenzene
January 2005
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                                                       Low/Medium Volatiles Organic Analysis
                 Table 21. Volatile Deuterated Monitoring Compounds (DMCs)
                        and the Associated Target Compounds (CON'T)
 l,4-Dioxane-d8 (DMC)
trans-l,3-Dichloropropene-d4
(DMC)
Chloroform-d (DMC)
 1,4-Dioxane
cis-1,3 -Dichloropropene

trans-1,3 -Dichloropropene

1,1,2-Trichloroethane
1,1 -Dichloroethane

Bromochloromethane

Chloroform

Dibromochloromethane

Bromoform
 2-Butanone-d5 (DMC)
l,l-Dichloroethene-d2 (DMC)
2-Hexanone-ds (DMC)
 Acetone

 2-Butanone
trans-1,2-Dichloroethene

cis-1,2-Dichloroethene
4-Methyl-2-pentanone

2-Hexanone
 Vinyl chloride-d3 (DMC)
Benzene-d6 (DMC)
1,1,2,2-Tetr achloroethane-d2
(DMC)
 Vinyl chloride
Benzene
1,1,2,2,-Tetrachlororethane

1,2-Dibromo-3 -chloropropane
 l,2-Dichloroethane-d4
 (DMC)
                                  Toluene-d8 (DMC)
 Trichlorofluoromethane

 1,1 -Dichloroethene

 1,1,2-Trichloro-1,2,2-
 trifluoroethane

 Methyl acetate

 Methylene chloride

 Methyl-tert-butyl ether

 1,1,1 -Trichloroethane

 Carbon tetrachloride

 1,2-Dibromoethane

 1,2-Dichloroethane
                                  Trichloroethene

                                  Toluene

                                  Tetrachloroethene


                                  Ethylbenzene

                                  o-Xylene

                                  m,p-Xylene

                                  Styrene

                                  Isopropylbenzene
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                                                        Low/Medium Volatiles Organic Analysis
                     VII.  Matrix Spike/Matrix Spike Duplicates (MS/MSDs)

A.  Review Items:

    Form III VOA-1, Form III VOA-2, chromatograms, and quantitation reports.

    NOTE:    Data for MS and MSDs will not be present unless requested by the Region.

B.  Objective:

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

C.  Criteria:

    1.  If requested, MS and MSD samples are analyzed at a frequency of one MS and MSD per 20 or
       fewer samples per sample matrix and concentration level.

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

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

D.  Evaluation:

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

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

    3.  Verify transcriptions from raw data and check calculations.

    4.  Verify that the MS recoveries and RPD were calculated correctly.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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E.  Action:

    1.  No qualification of the data is necessary on MS and MSB data alone. However, using informed
       professional judgment, the data reviewer may use the MS and MSB results in conjunction with
       other QC criteria to determine the need for some  qualification of the data. Table 23 lists the
       volatile target compounds that are spiked into samples to test for matrix effects.  If any MS  and
       MSB Percent Recovery or RPB in the volatiles fraction is out of specification, qualify data to
       include the consideration of the existence of interference in the raw data (see Table 22).
       Considerations include, but are not limited to:

       a.  For any recovery or RPB greater than the upper acceptance limit:

           i.   Qualify detected spiked volatile target compounds as a "J".

           ii.  Bo not qualify non-detected spiked volatile target compounds.

       b.  For any recovery greater than or equal to 20%, and less than the lower acceptance limit:

           i.   Qualify detected spiked volatile target compounds as a "J".

           ii.  Qualify non-detected spiked volatile target compounds as approximated "UJ".

       c.  For any recovery less than 20%:

           i.   Qualify detected spiked volatile target compounds as a "J".

           ii.  Use professional judgment to qualify non-detected spiked volatile target compounds.

       d.  For any recovery or RPB within acceptance limits, no qualification of the data is necessary.

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

    3.  In those instances where it can be determined that the results of the MS and MSB affect only the
       sample spiked, limit qualification to this sample only. However, it may be determined through
       the MS and MSB results that a laboratory  is having a systematic problem in the analysis of one or
       more analytes that affects all associated samples, and the reviewer must use professional
       judgment to qualify the data from all associated samples.

    4.  The reviewer must use professional judgment to determine the need for qualification of detects of
       non-spiked compounds.

       NOTE:    Notify the Contract Laboratory Program Project Officer (CLP PO) if a field or trip
                  blank was used for the MS and MSB.
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                                                     Low/Medium Volatiles Organic Analysis
              Table 22. Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions
                             for Low/Medium Volatiles Analysis
Criteria
%R or RPD > Upper Acceptance Limit
20% <%R < Lower Acceptance Limit
%R < 20%
Lower Acceptance Limit < %R; RPD <
Upper Acceptance Limit
Action
Detected
Spiked Compounds
J
J
J
Non-detected
Spiked Compounds
No qualification
UJ
Use professional judgment
No qualification
      Table 23.  Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) Limits
Compound
1 , 1 -Dichloroethene
Trichloroethene
Benzene
Toluene
Chlorobenzene
% Recovery for
Water Samples
61 - 145
71 - 120
76 - 127
76 - 125
75 - 130
RPD for
Water Samples
0- 14
0- 14
0- 11
0- 13
0- 13
% Recovery for
Soil/Sediment
Samples
59 - 172
62 - 137
66 - 142
59- 139
60-133
RPD for
Soil/Sediment
Samples
0-22
0-24
0-21
0-21
0-21
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                                                       Low/Medium Volatiles Organic Analysis
                VIII. Regional Quality Assurance (OA) and Quality Control (OC)

A.  Review Items:

    Form I VOA-1, Form I VOA-2, chromatograms, Traffic Report/Chain of Custody Record (TR/COC),
    quantitation reports, and other raw data from QA/QC samples.

B.  Objective:

    Regional QA/QC samples refer to any QA and/or QC samples initiated by the Region, including field
    duplicates, Performance  Evaluation (PE) samples, blind spikes, and blind blanks.  The use of these
    QA/QC samples are highly recommended (e.g., the use of field duplicates can provide information on
    sampling precision and homogeneity).

C.  Criteria:

    Criteria are determined by each Region.

    1.  PE sample frequency may vary.

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

D.  Evaluation:

    1.  Evaluation procedures must follow the Region's Standard Operating Procedure (SOP) for data
       review. Each Region will handle the evaluation of PE samples on an individual basis.  Compare
       results for PE samples to the acceptance criteria for the specific PE samples, if available.

    2.  Calculate Relative Percent Difference (RPD) between field duplicates. Provide this information
       in the Data Review Narrative.

E.  Action:

    Any action must be in accordance with Regional specifications and the criteria for acceptable PE
    sample results.  Note, for Contract Laboratory Program Project Officer (CLP PO) action,
    unacceptable results for PE samples.
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                                                        Low/Medium Volatiles Organic Analysis
                                    IX.  Internal Standards
A.  Review Items:

    Form VIII VOA, quantitation reports, and chromatograms.

B.  Objective:

    Internal standard performance criteria ensures that Gas Chromatograph/Mass Spectrometer (GC/MS)
    sensitivity and response are stable during each analysis.

C.  Criteria:

    1.  The internal standard area counts for all samples [including Matrix Spike/Matrix Spike Duplicate
       (MS/MSD) and Performance Evaluation (PE) samples] and all blanks must be within the
       inclusive range of 50.0% and 200% of its response from the associated 12-hour calibration
       standard [opening Continuing Calibration Verification (CCV) or mid-point standard from the
       initial calibration].

    2.  The Retention Time (RT) of the internal standard in the sample or blank must not vary more than
       ±30 seconds from the RT of the internal standard in the associated  12-hour calibration standard
       (opening CCV or mid-point standard from initial calibration).

D.  Evaluation:

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

    2.  Verify that all RTs and internal standard areas are within criteria for all samples and blanks.

    3.  If there  are two analyses for a particular fraction, the reviewer must determine which are the best
       data to report. Considerations include, but are not limited to:

       a.   Magnitude and direction of the internal standard area shift.

       b.   Magnitude and direction of the internal standard RT shift.

       c.   Technical holding times.

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

       e.   Other Quality Control (QC).

           NOTE:     For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the Contract Compliance Screening (CCS)
                      process.  Information regarding the laboratory's compliance with these criteria
                      can be obtained from the Data Assessment Tool  (DAT) reports, and may be used
                      as part of the evaluation process.
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E.  Action:

    1.  If an internal standard area count for a sample or blank is greater than 200% of the area for the
       associated standard (opening CCV or mid-point standard from the initial calibration) (see
       Table 24):

       a.  Qualify detects for compounds quantitated using that internal standard with a " J".

       b.  Do not qualify non-detected associated compounds.

    2.  If an internal standard area count for a sample or blank is less than 50.0% of the area for the
       associated standard (opening CCV or mid-point standard from initial calibration):

       a.  Qualify detects for compounds quantitated using that internal standard with a "J".

       b.  Qualify non-detected associated compounds as unusable "R".

    3.  If an internal standard area count for a sample or blank is greater than or equal to 50.0%, and less
       than or equal to 200% of the area for the associated standard opening CCV or mid-point standard
       from initial calibration, no qualification of the data is necessary.

    4.  If an internal standard RT varies by more than 30.0 seconds:

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

    5.  If an internal standard RT varies by less than or equal to 30.0 seconds, no qualification of the data
       is necessary.

    6.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if the internal standard
       performance criteria are grossly exceeded.  Note in the Data Review Narrative potential effects on
       the data resulting from unacceptable internal standard performance.
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                                                       Low/Medium Volatiles Organic Analysis
            Table 24. Internal Standard Actions for Low/Medium Volatiles Analyses
Criteria
Area counts < 50.0% of 12-hour standard
(opening CCV or mid-point standard from the initial calibration)
Area counts > 50.0% and < 200% of 12-hour standard
(opening CCV or mid-point standard from the initial calibration)
Area counts > 200% of 12-hour standard
(opening CCV or mid-point standard from the initial calibration)
RT Difference < 30.0 seconds between samples and 12-hour
standard (opening CCV or mid-point standard from the initial
calibration)
RT Difference > 30.0 seconds between samples and 12-hour
standard (opening CCV or mid-point standard from the initial
calibration)
Action
Detected
Associated
Compounds*
J
Non-Detected
Associated
Compounds*
R
No qualification
J
No
qualification
No qualification
j^ **
R
*   For volatile compounds associated with each internal standard, see Table 3 - Volatile Target
    Compounds and Deuterated Monitoring Compounds with Corresponding Internal Standards for
    Quantitation in SOMO 1.0. Exhibit D. available at:

                      http://www.epa.gov/superfund/programs/clp/soml.htm

**  See Low/Medium Volatiles Organic Analysis, Section IX.E.4 for exceptions.
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                                                        Low/Medium Volatiles Organic Analysis
                              X.  Target Compound Identification

A.  Review Items:

    Form I VOA-1, Form I VOA-2, quantitation reports, mass spectra, and chromatograms.

B.  Objective:

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

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

C.  Criteria:

    1.  The Relative Retention Times (RRTs) must be within ±0.06 RRT units of the standard RRT
       [opening Continuing Calibration Verification (CCV) or mid-point standard from the initial
       calibration].

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

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

       b.  The relative intensities of these ions must agree within ±20% between the standard and
           sample spectra (e.g., for an ion with an abundance of 50% in the standard spectrum, the
           corresponding  sample ion abundance must be between 30-70%).

       c.  Ions present at greater than 10% in the sample mass spectrum, but not present in the standard
           spectrum, must be evaluated by a reviewer experienced in mass spectral interpretation.

D.  Evaluation:

    1.  Check that the RRT of reported compounds is within ±0.06 RRT units of the standard RRT
       (opening CCV or mid-point standard from the initial calibration).

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

    3.  The reviewer should be aware of situations when sample carryover is a possibility and use
       professional judgment to determine if instrument cross-contamination has affected any positive
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                                                        Low/Medium Volatiles Organic Analysis
       compound identification.  The method specifies that an instrument blank must be run after
       samples which contain target compounds at levels exceeding the initial calibration range (200
       (ig/L for non-ketones, 400 (ig/L for ketones, and 4000 (ig/L for 1,4-dioxane).

    4.  Check the chromatogram to verify that peaks are identified. Major peaks are either identified as
       target compounds, TICs, Deuterated Monitoring Compounds (DMCs), or internal standards.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT)  reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  The  application of qualitative criteria for GC/MS analysis of target compounds requires
       professional judgment.  It is up to the reviewer's discretion to obtain additional information from
       the laboratory. If it is determined that incorrect identifications were made, qualify all such data as
       not detected "U" or unusable  "R".

    2.  Use  professional judgment to qualify the data if it is determined that cross-contamination has
       occurred.

    3.  Note in the Data Review Narrative any changes made to the reported compounds or concerns
       regarding target compound identifications. Note, for Contract Laboratory Program Project
       Officer (CLP PO) action, the  necessity for numerous or significant changes.
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                                                        Low/Medium Volatiles Organic Analysis
   XL Compound Ouantitation and Reported Contract Required Ouantitation Limits (CRQLs)

 A. Review Items:

    Forms IVOA-1, Form IVOA-2, sample preparation sheets, Sample Delivery Group (SDG)
    Narrative, quantitation reports, and chromatograms.

B.  Objective:

    The objective is to ensure that the reported quantitation results and CRQLs are accurate.

C.  Criteria:

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

    2.  Compound Relative Response Factors (RRFs) must be calculated based on the internal standard
       associated with that compound, as listed in the method. Quantitation must be based on the
       quantitation ion (m/z) specified in the method for both the internal  standards and target analytes.
       The compound quantitation must be based on the RRF from the appropriate daily standard
       [opening Continuing Calibration Verification (CCV) or mid-point standard from initial
       calibration].

D.  Evaluation:

    1.  Examine raw data to verify the correct calculation of all sample results reported by the laboratory.
       Compare quantitation lists and chromatograms to the reported detects and non-detects sample
       results.  Check the reported values.

    2.  Verify that the correct internal standard, quantitation ion,  and Mean Relative Response Factor
       (RRF) were_used to quantitate the  compound. Verify that the same internal standard, quantitation
       ion, and RRF were used consistently throughout, in both the calibration as well as the
       quantitation process.

    3.  Verify that the CRQLs have been  adjusted to reflect all sample  dilutions and dry weight factors
       (for non-aqueous samples).

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated  as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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                                                         Low/Medium Volatiles Organic Analysis
E.  Action:

    1.  If any discrepancies are found, the Region's designated representative may contact the laboratory
       to obtain additional information that could resolve any differences.  If a discrepancy remains
       unresolved, the reviewer must use professional judgment to decide which value is the most
       accurate value. Under these circumstances, the reviewer may determine that qualification of data
       is warranted. Note in the Data Review Narrative a description of the reasons for data
       qualification and the qualification that is applied to the data.

    2.  For non-aqueous samples, if the Percent Moisture is less than 70.0%, no qualification of the data
       is necessary. If the Percent Moisture is greater than  or equal to 70.0% and less than 90.0%,
       qualify detects as "J" and non-detects as approximated "UJ".  If the Percent Moisture is greater
       than or equal to 90.0%, qualify detects as "J" and non-detects as unusable "R" (see Table 25).

             Table 25. Percent Moisture Actions for Low/Medium Volatiles Analysis
                                   For Non-Aqueous Samples
Criteria
% Moisture < 70.0
70.0 < % Moisture < 90.0
% Moisture > 90.0
Action
Detected
Associated Compounds
Non-detected
Associated Compounds
No qualification
J
J
UJ
R
    3.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, numerous or significant
       failures to accurately quantify the target compounds or to properly evaluate and adjust CRQLs.
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                                                        Low/Medium Volatiles Organic Analysis
                         XII. Tentatively Identified Compounds (TICs)

A.  Review Items:

    Form I VOA-TIC, chromatograms, library search printouts, and spectra for the TIC candidates.

B.  Objective:

    Chromatographic peaks in volatile fraction analyses that are not target analytes, Deuterated
    Monitoring Compounds (DMCs), or internal standards are potential TICs.  TICs must be qualitatively
    identified via a forward search of the NIST/USEPA/NIH Mass Spectral Library (May 2002 release or
    later)1, and/or Wiley Mass Spectral Library (1998 release or later)2, or the equivalent.  The
    identifications must be assessed by the data reviewer.

C.  Criteria:

    For each sample, the laboratory  must conduct a mass spectral search of the NIST/USEPA/NIH (May
    2002 release or later), and/or Wiley (1998 release or later), or equivalent mass spectral library, and
    report the possible identity for 30 of the largest volatile fraction peaks which are not DMCs, internal
    standards, or target compounds, but which have an area or height greater than 10% of the area or
    height of the nearest internal standard.  Estimated concentrations for TICs are calculated similarly to
    the Target Compound List (TCL) compounds, using total ion areas for the TIC and the internal
    standard, and assuming a Relative Response Factor (RRF) of 1.0. TIC results are reported for each
    sample on the Organic Analyses Data Sheet (Form I VOA-TIC).

D.  Evaluation:

    1.  Guidelines for tentative identification are as follows:

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

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

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

       d.   Review ions present in the sample spectrum, but not in the reference spectrum, for possible
           background contamination, interference, or presence of coeluting compounds.

       e.   Review ions present in the reference spectrum, but not in the sample spectrum, for possible
           subtraction from the sample  spectrum because of background contamination or coeluting
       1       NIST/USEPA/NIH Mass Spectral Library (May 2002 release or later), National Institute
               of Standards and Technology, Gaithersburg, Maryland.

       2       Wiley Mass Spectral Library (1998 release or later), John Wiley & Sons, Inc., Hoboken,
               New Jersey.
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                                                        Low/Medium Volatiles Organic Analysis
           compounds.  Data system library reduction programs can sometimes create these
           discrepancies.

       f.   Non-target compounds receiving a library search match of 85% or higher are considered a
           "likely match". Report the compound unless the mass spectral interpretation specialist feels
           there is evidence not to report the compound as identified by the library search program.
           Note in the Sample Delivery Group (SDG) Narrative the justification for not reporting a
           compound as listed by the search program.

       g.  If the library search produces more than one compound greater than or equal to 85%, report
           the compound with the highest percent match (report the first compound if percent match is
           the same for two or more compounds), unless the mass spectral interpretation specialist feels
           that the highest match compound should not be reported or another compound with a lower
           match should be reported. The laboratory should include the justification for not reporting
           the compound with the highest spectral match within the SDG Narrative.  DMCs, internal
           standards, and volatile target compounds should not be reported as TICs unless the only
           compounds having a percent match of greater than 85% are DMCs, internal standards, or
           volatile target compounds.

       h.  If the library search produces a series of obvious isomer compounds with library search
           matches greater than or equal to 85%, report the compound with the highest library search
           percent match (or the first compound if the library search matches are the same). Note in the
           SDG Narrative that the exact isomer configuration, as reported, may not be accurate.

       i.   If the library search produces no matches greater than or equal to 85%, and in the technical
           judgment of the mass spectral interpretation specialist, no valid tentative identification can be
           made, report the compound as unknown. The mass spectral specialist should give additional
           classification of the unknown compound, if possible (e.g., unknown aromatic, unknown
           hydrocarbon, unknown acid type, unknown chlorinated compound). If probable molecular
           weights can be distinguished, include them.

       j.   Alkanes are not to be reported as TICs on Form IVOA-TIC. An alkane is defined as any
           hydrocarbon with the generic formula CnH2n+2 that contains only C-H and C-C single bonds.
           When the preceding alkanes are tentatively identified, estimate the concentration(s) and
           report them in the  SDG Narrative as alkanes by class (i.e., straight-chain, branched, cyclic, as
           a series, or as applicable). Report total alkanes concentration on Form I VOA-TIC.

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

    3.  Examine blank chromatograms to verify that TIC peaks present in samples are not found in
       blanks.  When a low-level, non-target compound that is a common artifact or laboratory
       contaminant is detected in a sample, a thorough check of blank chromatograms may require
       looking for peaks which are less than 10% of the internal standard height,  but present in the blank
       chromatogram at a similar Relative Retention Time (RRT).

    4.  Examine all mass spectra for every sample and blank.

    5.  Consider all reasonable choices since TIC library searches often yield several candidate
       compounds having a close matching score.
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                                                         Low/Medium Volatiles Organic Analysis
    6.  Be aware of common laboratory artifacts/contaminants and their sources (e.g., Aldol
       condensation products, solvent preservatives, and reagent contaminants).  These may be present
       in blanks and not reported as sample TICs.

       Examples:

       a.  Common laboratory contaminants include CO2 (m/z 44), siloxanes (m/z 73), diethyl ether,
           hexane, certain freons, and phthalates at levels less than 100 (ig/L.

       b.  Solvent preservatives include cyclohexene (a methylene chloride preservative). Related by-
           products include cyclohexanone, cyclohexenone, cyclohexanol, cyclohexenol,
           chlorocyclohexene, and chlorocyclohexanol.

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

    7.  A target compound may be identified in the proper analytical fraction by non-target library search
       procedures, even though it was not found on the quantitation list (false negative). If the total area
       quantitation method was used, request that the laboratory recalculate the result using the proper
       quantitation ion and Relative Response Factor (RRF).

       A non-target compound may be incorrectly identified by the instrument's target analyte data
       processor as a target compound (false positive).  When this happens, the non-target library search
       procedure will not detect the false positive as a TIC. In this case, request that the laboratory
       properly identify the compound and recalculate the result using the total area quantitation method
       and a RRF of 1.0.

       Evaluate other sample chromatograms and check for both false negatives  and  false positives to
       determine if the occurrence is isolated or systematic.

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

    9.  Do not perform library searches on internal standards or DMCs.

    10. Estimate TIC concentration assuming an RRF of 1.0.

E .  Action:

    1.  Qualify all TIC results for which there is presumptive evidence of a match (e.g., greater than or
       equal to 85% match) as "NJ", tentatively identified, with approximated concentrations.

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

       a.  If it is determined that a tentative identification of a non-target compound is unacceptable,
           change the tentative identification to "unknown" or another appropriate identification, and
           qualify the result with a "J".

       b.  If all contractually-required peaks were not library searched and quantitated, the Region's
           designated representative may request these data from the  laboratory.
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                                                        Low/Medium Volatiles Organic Analysis
    3.  In deciding whether a library search result for a TIC represents a reasonable identification, use
       professional judgment.  If there is more than one possible match, report the result as "either
       compound X or compound Y".  If there is a lack of isomer specificity, change the TIC result to a
       non-specific isomer result (e.g., 1,3,5-trimethyl benzene to trimethyl benzene isomer) or to a
       compound class (e.g., 2-methyl, 3-ethyl benzene to a substituted aromatic compound).

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

    5.  Other case factors may influence TIC judgments. If a sample TIC match is poor, but other
       samples have a TIC with a valid library match, similar RRT, and the same ions, infer
       identification information from the other sample TIC results.

    6.  Note in the Data Review Narrative any changes made to the reported data or any concerns
       regarding TIC  identifications.

    7.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, failure to properly
       evaluate and report TICs.
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                                                         Low/Medium Volatiles Organic Analysis
                                   XIII. System Performance

A.  Review Items:

    Form VIII VOA and chromatograms.

B.  Objective:

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

C.  Criteria:

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

D.  Evaluation:

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

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

       a.   High RIC background levels or shifts in Absolute Retention Times (RTs) of internal
           standards.

       b.   Excessive baseline rise at elevated temperature.

       c.   Extraneous peaks.

       d.   Loss of resolution.

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

    3.  A  drift in instrument sensitivity may occur during the 12-hour time period and may be an
       indication of internal standard spiking problems. This could be discerned by examination of the
       internal standard area on Form VIII VOA for trends such as a continuous or near-continuous
       increase or decrease in the internal standard area overtime.
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                                                       Low/Medium Volatiles Organic Analysis
E.  Action:

    Use professional judgment to qualify the data if it is determined that system performance has
    degraded during sample analyses. Note, for Contract Laboratory Program Project Officer (CLP PO)
    action, any degradation of system performance which significantly affected the data.
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                                                         Low/Medium Volatiles Organic Analysis
                                XIV.  Overall Assessment of Data

A.  Review Items:

    Entire data package, data review results, and (if available) the Quality Assurance Project Plan
    (QAPP) and Sampling and Analysis Plan (SAP).

B.  Objective:

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

C.  Criteria:

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

D.  Evaluation:

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

    2.  If appropriate information is available, the reviewer may assess the usability  of the data to help
       the data user avoid inappropriate use of the data. Review all available information, including the
       QAPP (specifically the acceptance and performance criteria), SAP, and communication with the
       data user that concerns the intended use and desired quality of these data.

E.  Action:

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

    2.  Write a brief narrative to give the user an indication of the analytical limitations of the data.
       Note, for Contract Laboratory Program Project Officer (CLP PO) action, any inconsistency of the
       data with the Sample Delivery Group (SDG) Narrative. If sufficient information on the intended
       use and required quality of the data are available, the reviewer should include their assessment of
       the usability of the data within the given context.  This may be used as part of a formal Data
       Quality Assessment (DQA).
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                                                               Semivolatiles Organic Analysis
                             SEMIVOLATILE DATA REVIEW




The semivolatile data requirements to be checked are:




I.      Preservation




II.     Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check




III.    Initial Calibration




IV.    Continuing Calibration Verification (CCV)




V.     Blanks




VI.    Deuterated Monitoring Compounds (DMCs)




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)




VIII.   Regional Quality Assurance (QA) and Quality Control (QC)




IX.    Gel Permeation Chromatography (GPC) Performance Check




X.     Internal Standards




XI.    Target Compound Identification




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




XIII.   Tentatively Identified Compounds (TICs)




XIV.   System Performance




XV.    Overall Assessment of Data




NOTE:   Language specific to Selective Ion Monitoring (SIM) analyses is shown in italic.
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                                                                Semivolatiles Organic Analysis
                                       I. Preservation

A.  Review Items:

    Form I SV-1, Form I SV-2, Form SV-SIM, Form I SV-TIC, Traffic Report/Chain of Custody Record
    (TR/COC), raw data, sample extraction sheets, and the Sample Delivery Group (SDG) Narrative
    checking for:

    1.  pH
    2.  Sample temperature
    3.  Holding time
    4.  Other sample conditions

B.  Objective:

    The objective is to  ascertain the validity of the analytical results based on sample condition (e.g.,
    preservation and temperature) and the holding time of the sample from time of collection to time of
    sample extraction and analysis.

C.  Criteria:

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

       For semivolatile compounds in properly cooled (4°C ± 2°C) aqueous samples, the maximum
       holding time for extraction is seven (7) days from sample collection, and the maximum holding
       time for analysis is  forty (40) days from sample extraction.

    The technical holding time criteria for non-aqueous samples are as follows:

       For semivolatiles compounds in properly cooled (4°C ± 2°C) non-aqueous samples, the
       maximum holding time for extraction is fourteen (14) days from sample collection, and the
       maximum holding time for analysis is forty (40) days from sample extraction.

D.  Evaluation:

    Technical holding times for  sample extraction are established by comparing the sample collection
    dates on the TR/COC Record with the dates of extraction on Form I SV-1, Form I SV-2, Form I SV-
    SIM, Form I SV-TIC, and the sample extraction sheets.  To determine  if the samples were analyzed
    within the holding time after extraction, compare the dates of extraction on the sample extraction
    sheets with the dates  of analysis on Form I SV-1, Form I SV-2, Form I SV-SIMand Form I SV-TIC.
    Verify that the analysis dates on Form I(s) and the raw data/SDG File are identical. Review the SDG
    Narrative and the TR/COC Record to determine if the samples were received intact and iced. If there
    is no indication in the SDG Narrative, the TR/COC Record,  or the sample records that there was a
    problem with the samples, the integrity of the samples can be assumed to be acceptable. If it is
    indicated that there were problems with the samples, the integrity of the sample may have been
    compromised and professional judgment should be used to evaluate the effect  of the problem on the
    sample results.
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E.  Action:

    1.  Qualify aqueous sample results using preservation and technical holding time information as
       follows (see Table 26):

       a.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed within the technical holding times
           [seven (7) days from sample collection for extraction; forty (40) days from sample collection
           for analysis], use professional judgment to qualify the data.

       b.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed outside the technical holding
           times [seven (7) days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       c.  If the samples were properly preserved, and were  extracted and analyzed within the technical
           holding times  [seven (7) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were  extracted or analyzed outside the technical
           holding times  [seven (7) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], qualify detects with a "J" and non-detects as estimated with
           an approximated "UJ". Note in the Data Review Narrative that holding times were exceeded
           and the effect of exceeding the holding time on the resulting data.

    2.  Qualify non-aqueous sample results using preservation and technical holding time information as
       follows (see Table 26):

       a.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed within the technical holding time
           [fourteen (14)  days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       b.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed outside the technical holding time
           [fourteen (14)  days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       c.  If the samples were properly preserved, and were  extracted and analyzed within the technical
           holding time [fourteen (14) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were  extracted or analyzed outside the technical
           holding time [fourteen (14) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], qualify detects with a "J" and non-detects as estimated with
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                                                                 Semivolatiles Organic Analysis
           an approximated "UJ". Note in the Data Review Narrative that holding times were exceeded
           and the effect of exceeding the holding time on the resulting data.

    3.  If technical holding times are grossly exceeded, qualify all detects as estimated with a "J" and use
       professional judgment to qualify sample non-detects as "UJ" or "R".

    4.  Note in the Data Review Narrative, whenever possible, the effect of exceeding the holding time
       on the resulting data.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, when technical holding
       times are grossly exceeded.
                    Table 26. Holding Time Actions for Semivolatile Analyses
Matrix
Aqueous
Non-aqueous
Preserved
No
No
Yes
Yes
Yes/No
No
No
Yes
Yes
Yes/No
Criteria
< 7 days (for extraction) and
< 40 days (for analysis)
> 7 days (for extraction) and
> 14 days (for analysis)
< 7 days (for extraction) and
< 40 days (for analysis)
> 7 days (for extraction) and
> 40 days (for analysis)
Grossly Exceeded
< 14 days (for extraction) and
< 40 days (for analysis)
> 14 days (for extraction) and
> 40 days (for analysis)
< 14 days (for extraction) and
< 40 days (for analysis)
> 14 days (for extraction) and
> 40 days (for analysis)
Grossly Exceeded
Action
Detected
Associated
Compounds
Non-Detected
Associated
Compounds
Use professional judgment
Use professional judgment
No qualification
J
J
UJ
UJorR
Use professional judgment
Use professional judgment
No qualification
J
J
UJ
UJorR
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                                                               Semivolatiles Organic Analysis
      II. Gas Chromatograph/Mass Spectrometer (GC/MS) Instrument Performance Check

A.  Review Items:

    Form V SV, decafluorotriphenylphosphine (DFTPP) mass spectra, and mass listing.

B.  Objective:

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

    NOTE:    This requirement does not apply when samples are analyzed by the Selected Ion
              Monitoring (SIM) technique.

C.  Criteria:

    1.  The 12-hour clock begins with either the injection of DFTPP or in cases where a closing
       Continuing Calibration Verification (CCV) can be used as an opening CCV, the 12-hour clock
       begins with the injection of the opening CCV.

    2.  Listed below are some, but not necessarily all, examples of acceptable analytical sequences
       incorporating the use of the opening and/or closing CCV. These examples are to be used as a
       guide  for the data reviewer as to the possible analytical sequences that can be expected; however,
       the criteria associated with these analytical sequences have been evaluated as part of the Contract
       Compliance Screening (CCS) process.
 Conditions for When
 Example Sequence is
 Appropriate:
Acceptable Criteria That Must
Be Met:
Notes:
 Use Example 1 if time
 remains on the 12-hour
 clock after the initial
 calibration sequence
    DFTPP tunes meet
    instrument performance
    criteria.
    The five Initial Calibration
    standards meet initial
    calibration criteria.
    CCV A meets both opening
    and closing CCV criteria.
    CCV B meets closing CCV
    criteria.
The requirement of starting the new
12-hour clock for Analytical
Sequence 2 with a new DFTPP tune
is waived if CCV A meets opening
CCV criteria.  If CCV B meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
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                                                              Semivolatiles Organic Analysis
 Conditions for When
 Example Sequence is
 Appropriate:
Acceptable Criteria That Must
Be Met:
Notes:
 Use Example 2 if time
 remains on the 12-hour
 clock after the initial
 calibration sequence
•  DFTPP tunes meet
   instrument performance
   criteria.
•  The five Initial Calibration
   standards meet initial
   calibration criteria.
•  CCV A meets closing CCV
   criteria (but does not meet
   opening CCV criteria).
•  CCV B meets opening CCV
   criteria.
•  CCV C meets closing CCV
   criteria.
CCV A does not meet opening
CCV criteria, therefore a new
DFTPP tune must be performed,
immediately followed by CCV B,
before the method blank and any
samples may be analyzed. In this
case, the new 12-hour clock and
Analytical Sequence 2 begins with
the injection of the new DFTPP
tune.
 Use Example 3
 if more than 12-hours have
 elapsed since the most
 recent initial calibration or
 closing CCV,

 OR

 if the most recent closing
 CCV was not or could not
 be used as an opening CCV.
•  DFTPP tunes meet
   instrument performance
   criteria.
•  CCV A meets opening CCV
   criteria.
•  CCV B meets both opening
   and closing CCV criteria.
•  CCV C meets both opening
   and closing CCV criteria.
The requirement of starting the new
12-hour clock for Analytical
Sequence 2 with a new DFTPP tune
is waived if CCV B meets opening
CCV criteria. If CCV C meets
opening CCV criteria, a method
blank and subsequent samples may
be analyzed immediately after
CCVB.
 Use Example 4
 if more than 12-hours have
 elapsed since the most
 recent initial calibration or
 closing CCV,

 OR

 if the most recent closing
 CCV was not or could not
 be used as an opening CCV.
•  DFTPP tunes meet
   instrument performance
   criteria.
•  CCV A meets opening CCV
   criteria.
•  CCV B meets closing CCV
   criteria (but does not meet
   opening CCV criteria).
•  CCV C meets opening CCV
   criteria.
•  CCV D meets both opening
   and closing CCV criteria.
CCV B does not meet opening
CCV criteria, therefore a new
DFTPP tune must be performed,
immediately followed by CCV B,
before the method blank and any
samples may be analyzed. In this
case, the new 12-hour clock and
Analytical Sequence 2 begins with
the injection of the new DFTPP
tune. The requirement of starting
the new 12-hour clock for
Analytical Sequence 3 with a new
DFTPP tune is waived if CCV D
meets opening CCV criteria. If
CCV D meets opening CCV
criteria, a method blank and
subsequent samples may be
analyzed immediately after CCV B.
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                                                                Semivolatiles Organic Analysis
 Example 1:

 Start of 12-hour clock for
 Analytical Sequence 1
 End of 12-hour clock for
 Analytical Sequence I/
 Beginning of 12-hour clock
 for Analytical Sequence 2
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour clock
 for Analytical Sequence 3
Time         Material Injected

 0 hr    DFTPP


        Initial Calibration 5.0

        Initial Calibration 10

        Initial Calibration 20

        Initial Calibration 40

        Initial Calibration 80

        Method Blank

        Subsequent Samples
12 hr   CCV A
        (meets opening CCV criteria)
                                     Method Blank

                                     Subsequent Samples
24 hr   CCV B
        (meets opening CCV criteria)
Analytical Sequence #

          1


          1

          1

          1

          1

          1

          1

          1

          1

          1

          1

          1

         1/2
          2

          2

          2

          2

          2

          2

         2/3
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                                                               Semivolatiles Organic Analysis
 Example 2:

 Start of 12-hour clock for
 Analytical Sequence 1
 End of 12-hour clock for
 Analytical Sequence 1


 Beginning of 12-hour
 clock for Analytical
 Sequence 2
Time          Material Injected

 0 hr     DFTPP


         Initial Calibration 5.0

         Initial Calibration 10

         Initial Calibration 20

         Initial Calibration 40

         Initial Calibration 80

         Method Blank

         Subsequent Samples
12 hr    CCV A
         (meets closing CCV criteria,
         fails opening CCV criteria)

13 hr    DFTPP
                                     CCVB
                                     (meets opening CCV criteria)

                                     Method Blank

                                     Subsequent Samples
Analytical Sequence #

          1
 End of 12-hour clock for
 Analytical Sequence 2
25 hr    CCV C
         (meets closing CCV criteria)
          2

          2

          2

          2

          2

          2

          2
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                                                             Semivolatiles Organic Analysis
 Example 3:

 Start of 12-hour clock for
 Analytical Sequence 1
 End of 12-hour clock for
 Analytical Sequence I/
 Beginning of 12-hour clock
 for Analytical Sequence 2
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour clock
 for Analytical Sequence 3
Time          Material Injected

 0 hr    DFTPP


        CCVA
        (meets opening CCV criteria)

        Method Blank

        Subsequent Samples
12 hr
24 hr
CCVB
(meets opening CCV criteria)
                                    Method Blank

                                    Subsequent Samples
Analytical Sequence #

          1


          1


          1

          1

          1

          1

          1

          1

         1/2
ccvc
(meets opening CCV criteria)
         2

         2

         2

         2

         2

         2/3
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                                                              Semivolatiles Organic Analysis
 Example 4:

 Start of 12-hour clock for
 Analytical Sequence 1
Time          Material Injected

 0 hr    DFTPP


        CCVA
        (meets opening CCV criteria)

        Method Blank

        Subsequent Samples
 End of 12-hour clock for
 Analytical Sequence 1


 Beginning of 12-hour
 clock for Analytical
 Sequence 2
12 hr    CCV B
        (meets closing CCV criteria,
        fails opening CCV criteria)

13 hr    DFTPP
                                    CCVC
                                    (meets opening CCV criteria)

                                    Method Blank

                                    Subsequent Samples
 End of 12-hour clock for
 Analytical Sequence 21
 Beginning of 12-hour
 clock for Analytical
 Sequence 3
Analytical Sequence #

          1
25 hr    CCV D
        (meets opening CCV criteria)
         2

         2

         2

         2

         2

         2/3
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                                                               Semivolatiles Organic Analysis
    3.  Inject a sufficient amount of the instrument performance check solution (50 ng DFTPP on-
       column) at the beginning of each 12-hour period during which samples or standards are analyzed.
       This requirement is waived if a closing CCV can be used as an opening CCV. The instrument
       performance check, DFTPP for semivolatile analysis, must meet the ion abundance criteria
       provided in Table 27.

         Table 27. Ion Abundance Criteria For Decafluorotriphenylphosphine (DFTPP)
Mass
51
68
69
70
127
197
198
199
275
365
441
442
443
Ion Abundance Criteria
10.0
Less
-80.0% of mass 198
than 2.0% of mass 69
Present
Less
10.0
Less
Base
5.0-
10.0
than 2.0% of mass 69
- 80.0% of mass 198
than 2.0% of mass 198
peak, 100% relative abundance*
9.0% of mass 198
-60.0% of mass 198
Greater than 1.0% of mass 198
Present, but less than mass 443
50.0
15.0
- 100% of mass 198
-24.0% of mass 442
    NOTE:    All ion abundances must be normalized to m/z 198, the nominal base peak, even though
              the ion abundance of m/z 442 may be up to 100% that of m/z 198.

D.  Evaluation:

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

       a.   Form V SV is present and completed for each 12-hour period during which samples were
           analyzed. In cases where a closing CCV is used as an opening CCV for the next 12-hour
           period, an additional Form V SV is not required.

       b.   The laboratory has not made any transcription errors between the data and the form. If there
           are major differences between the mass listing and the Form Vs, a more in-depth review of
           the data is required.  This may include obtaining and reviewing additional information from
           the laboratory.
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                                                                  Semivolatiles Organic Analysis
       c.  The appropriate number of significant figures has been reported (number of significant
           figures given for each ion in the ion abundance criteria column) and that rounding is correct.

       d.  The laboratory has not made any calculation errors.

    2.  Verify that samples were not analyzed before a valid instrument performance check or were not
       analyzed 12 hours after the injection of the Instrument Performance Check Solution. This
       evaluation is not to be performed in cases where a closing CCV is used as an opening CCV.

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

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

    5.  If possible, verify that spectra were generated using appropriate background subtraction
       techniques.  Since the DFTPP spectrum is obtained from chromatographic peaks that should be
       free from coelution problems, background subtraction  should be done in accordance with the
       following procedure:

       a.  Three scans (the peak apex scan and the scans immediately preceding and following the
           apex) are acquired and averaged.

       b.  Background subtraction is required, and must be accomplished using a single scan acquired
           no more than 20 scans prior to the elution of DFTPP. Do not subtract the DFTPP peak as
           part of the background.

           NOTES:   All mass spectrometer instrument conditions must be identical to those used
                      during the sample analysis.  Background subtraction actions resulting in spectral
                      distortions for the sole purpose of meeting the contract specifications are contrary
                      to the Quality Assurance (QA) objectives and are, therefore, unacceptable.

                      For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated  as part of the CCS process. Information regarding the
                      laboratory's compliance with these criteria can be obtained from the Data
                      Assessment Tool (DAT) reports, and may be used as part of the evaluation
                      process.

E.  Action:

    1.  If samples are analyzed without a preceding valid instrument performance check or are analyzed
       12 hours after the Instrument Performance Check and are not preceded by an analysis of a closing
       CCV that meets the opening CCV criteria, qualify all data in those samples as unusable  "R".

    2.  If the laboratory has made minor transcription errors that do not significantly affect the data, the
       data reviewer should make the necessary corrections on a copy of the form.

    3.  If the laboratory has failed to provide  the correct forms or has made significant transcription or
       calculation errors, the Region's designated representative should contact the laboratory and
       request corrected data. If the information is not available, the reviewer must use professional
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                                                                  Semivolatiles Organic Analysis
       judgment to assess the data. Notify the laboratory's Contract Laboratory Program Project Officer
       (CLP PO).

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

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

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

       b.  For the ions at m/z 51, 127, and 275, the actual relative abundance is not as critical.   For
           instance, if m/z 275 has 80.0% relative abundance (criteria: 10.0-60.0%) and other criteria are
           met, the deficiency is minor.

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

    6.  Note in the Data Review Narrative decisions to use analytical data associated with DFTPP
       instrument performance checks not meeting method requirements.

    7.  If the reviewer has reason to believe that instrument performance check criteria were achieved
       using techniques other than those specified in Semivolatiles Organic Analysis, Section II.D.5,
       obtain additional information on the DFTPP instrument performance checks. If the techniques
       employed are found to be at variance with contract requirements, the procedures of the laboratory
       may merit evaluation.  Note, for CLP PO action, concerns or questions regarding laboratory
       performance. For example, if the reviewer has reason to believe that an inappropriate technique
       was used to obtain background subtraction (such as background subtracting from the solvent front
       or from another region of the chromatogram rather than from the DFTPP peak), this should be
       noted for CLP PO action.
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                                                                  Semivolatiles Organic Analysis
                                     III. Initial Calibration

A.  Review Items:

    Form VI SV-1, Form VI SV-2, Form VI SV-3, Form VISV-SIM, quantitation reports, and
    chromatograms.

B.  Objective:

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

C.  Criteria:

    1.  Initial calibration standards containing both semivolatile target compounds and Deuterated
       Monitoring Compounds (DMCs) are analyzed.  All target compounds (except the seven
       compounds listed below) and the DMCs are analyzed at concentrations of 5.0, 10, 20, 40, and
       80 ng/(iL at the beginning of each analytical sequence or as necessary if the continuing
       calibration verification acceptance criteria are not met. The seven compounds are: 2,4-
       dinitrophenol; pentachlorophenol; 2-nitroaniline; 3-nitroaniline; 4-nitroaniline; 4-nitrophenol, and
       4,6-dinitro-2-methylphenol.  These compounds require a 4-point calibration at  10, 20, 40, and 80
       ng/(iL. The initial calibration (and any associated samples and blanks) must be analyzed within
       12 hours of the associated instrument performance check.

       If analysis by the Selected Ion Monitoring (SIM) technique is requested for
       PAHs/pentachlorophenols, calibration standards are analyzed at 0.10, 0.20, 0.40, 0.80, and 1.0
       ng/pLfor each target compound of interest and the associated DMCs (see Table 34).
       Pentachlorophenol will require only a four-point initial calibration at 0.20, 0.40, 0.80, and 1.0
       ng/^L.

    2.  Initial calibration standard Relative Response Factors (RRFs) for the semivolatile target
       compounds listed in Table 28 and for all DMCs must be greater than or equal to 0.010.  The RRF
       for all other semivolatile target compounds must be greater than or equal to 0.050.

    3.  The Percent Relative Standard Deviation (%RSD) of the initial calibration RRFs must be less
       than or equal to 40.0% for the semivolatile target compounds and associated DMCs listed in
       Table 28. The %RSD for all other semivolatile target compounds and associated DMCs must be
       less than or equal to 20.0% .

       NOTE:    The flexibility clause in the method may impact some of the preceding criteria.  A
                  copy of the flexibility clause should be present in the Sample Delivery Group (SDG).
                  Refer to the Contract Laboratory Program (CLP) Web site at
                  http://www.epa.gov/oerrpage/superfund/programs/clp/modifiedanalvses.htm for the
                  specific method flexibility requirements.
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D.  Evaluation:

    1.  Verify that the correct concentrations of standards were used for the initial calibration (i.e., 5.0,
       10, 20, 40, and 80 ng/(iL). For the seven compounds with higher Contract Required Quantitation
       Limits (CRQLs) listed in Semivolatiles Organic Analysis, Section III.C.I, verify that a four-point
       initial calibration at 10, 20, 40, 80 ng/(iL was performed.

       If analysis by the SIM technique is requested, verify that the correct concentrations of standards
       were used for the initial calibration (i.e., 0.10, 0.20, 0.40, 0.80, and 1.0 ng/pL.  The 0.10
       standard is not required for pentachlorophenol).
    2.  Verify that the RRF obtained from the associated initial calibration was used for calculating
       sample results and the samples were analyzed within 12 hours of the associated instrument
       performance check.

    3.  Evaluate the initial calibration RRFs and the RRFs for all semivolatile target compounds and
       DMCs:

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

       b.  Verify that for the semivolatile target compounds listed in Table 28 and for all DMCs, the
           initial calibration RRFs are greater than or equal to 0.010, and for all other semivolatile target
           compounds, RRFs are greater than or equal to 0.050.

               Table 28.  Semivolatile Target Compounds Exhibiting Poor Response
Compounds
2,2'-Oxybis-( 1 -chloropropane)
4-Chloroaniline
Hexachlorobutadiene
Hexachlorocyclopentadiene
2-Nitroaniline
3-Nitroaniline
2,4-Dinitrophenol
4-Nitrophenol
Acetophenone
Caprolactam
Atrazine
Di-n-butylphthalate
Bis-2(ethylhexyl) phthalate
Benzaldehyde
4-Nitroaniline
4,6-Dinitro-2-methylphenol
N-Nitrosodiphenylamine
3 -3 '-Dichlorobenzidine
l,l'-Biphenyl
Dimethylphthalate
Diethylphthalate
1,2,4,5-Tetrachlorobenzene
Carbazole
Butylbenzylphthalate
Di-n-octylphthalate

    4.  Evaluate the %RSD for all semivolatile target compounds and DMCs:
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                                                                 Semivolatiles Organic Analysis
       a.  Check and recalculate the %RSD for one or more semivolatile target compound(s) and
           DMCs. Verify that the recalculated value(s) agrees with the laboratory reported value(s).

       b.  If the %RSD is greater than the maximum criteria (40.0% for the semivolatile target
           compounds listed in Table 28 and associated DMCs (see Table 34), and 20.0% for all other
           semivolatile target compounds and associated DMCs), the reviewer should use professional
           judgment to determine the need to check the points on the curve for the cause of the non-
           linearity.  This is checked by eliminating either the high-point or the low-point and re-
           calculating the %RSD (see Semivolatiles Organic Analysis, Section III.E.2).

    5.  If errors are detected in the calculations of either the RRF or the %RSD, perform a more
       comprehensive recalculation.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  Qualify all  semivolatile target compounds, including the compounds exhibiting poor response
       listed in Table 28, using the following criteria (see Table 29):

       a.  If any semivolatile target compound has an RRF value less than the minimum criterion (0.010
           for the target compounds exhibiting poor response listed in Table 28, and 0.050 for all other
           semivolatile compounds), use professional judgment for detects, based on mass spectral
           identification, to qualify the  data as a "J" or unusable "R".

       b.  If any semivolatile target compound has an RRF value less than the minimum criterion (0.010
           for the target compounds exhibiting poor response listed in Table 28, and 0.050 for all other
           semivolatile compounds), qualify non-detected compounds as unusable "R".

       c.  If any of the semivolatile target compounds listed in Table 28 has %RSD greater than 40.0%,
           qualify detects with a "J" and non-detected compounds using professional judgment (see
           Semivolatiles Organic Analysis, Section III.E.2).

       d.  For all other semivolatile target compounds, if %RSD is greater than 20.0%, qualify detects
           with  a " J" and non-detected compounds using professional judgment (see Semivolatiles
           Organic Analysis, Section III.E.2).

       e.  If the semivolatile target compounds meet the acceptance criteria for RRF and %RSD, no
           qualification of the data is necessary.

       f  No qualification of the data is necessary on the DMC RRF and %RSD data alone. However,
           use professional judgment and follow the guidelines in Semivolatiles Organic Analysis,
           Section III.E.2, to evaluate the DMC RRF and %RSD data in conjunction with the DMC
           recoveries to determine the need for qualification of data.
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    2.  At the reviewer's discretion, and based on the project-specific data quality objectives, a more in-
       depth review may be considered using the following guidelines:

       a.  If any semivolatile target compound has a %RSD greater than the maximum criterion (40.0%
           for the target compounds listed in Table 28, and 20.0% for all other semivolatile compounds),
           and if eliminating either the high or the low-point of the curve does not restore the %RSD to
           less than or equal to the required maximum:

           i.   Qualify  detects for that compound(s) with a "J".

           ii.  Qualify  non-detected semivolatile target compounds using professional judgment.

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

           i.   Qualify  detects outside of the linear portion of the curve with a "J".

           ii.  No qualifiers are required for detects in the linear portion of the curve.

           iii.  No qualifiers are required for semivolatile target compounds  that were not detected.

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

           i.   Qualify  low-level detects in the area of non-linearity with a "J".

           ii.  No qualifiers are required for detects in the linear portion of the curve.

           iii.  For non-detected semivolatile compounds, use the lowest point of the linear portion of
               the curve to determine the new quantitation limit.

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

    4.  Note in the Data Review Narrative, whenever possible, the potential effects on the data due to
       calibration criteria exceedance.

    5.  Note, for Contract Laboratory  Program Project Officer (CLP PO) action, if calibration criteria are
       grossly exceeded.
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                                                               Semivolatiles Organic Analysis
                 Table 29.  Initial Calibration Actions for Semivolatile Analyses
Criteria for Semivolatile Analysis
RRF < 0.010 (target compounds listed in Table 28)
RRF < 0.050 (all other target compounds)
RRF > 0.010 (target compounds listed in Table 28)
RRF > 0.050 (all other target compounds)
%RSD < 40.0 (target compounds listed in Table 28)
%RSD < 20.0 (all other target compounds)
%RSD > 40.0 (target compounds listed in Table 28)
%RSD > 20.0 (all other target compounds)
Action
Detected
Associated
Compounds
JorR
(based on mass
spectral
identification)
Non-Detected
Associated
Compounds
R
No qualification
No qualification
J
Use professional
judgment
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                                                                Semivolatiles Organic Analysis
                        IV. Continuing Calibration Verification (CCV)

A.  Review Items:

    Form VII SV-1, Form VII SV-2, Form VII SV-3, Form VIISV-SIM, quantitation reports, and
    chromatograms.

B.  Objective:

    Compliance requirements for satisfactory instrument calibration are established to ensure that the
    instrument is capable of producing acceptable qualitative and quantitative data.  The CCV checks
    satisfactory performance of the instrumenton a day-to-day basis, however quantitations are based on
    the Mean Relative Response Factors  (RRFs) obtained from the initial calibration.

C.  Criteria:

    1.  The  12-hour clock begins with either the injection of Decafluorotriphenylphosphine (DFTPP), or
       in cases where a closing CCV can be used as on opening CCV, the 12-hour clock begins with the
       injection of the opening CCV.

    2.  CCV standards containing both target compounds and associated Deuterated Monitoring
       Compounds (DMCs) are analyzed both at the beginning (opening CCV) and end (closing CCV)
       of each 12-hour analysis period following the analysis of the instrument performance check, and
       prior to the analysis of the method blank and samples. An instrument performance check is not
       required prior to the analysis of a closing CCV or prior to a closing CCV which can be used as an
       opening CCV for the next 12-hour period. If time remains in the 12-hour time period after initial
       calibration and samples are to be analyzed, the  mid-point standard from the initial calibration can
       be used as an opening CCV.

    3.  For an opening CCV, the Relative Response Factors (RRFs)  for the semivolatile target
       compounds listed in Table 28 and for all associated DMCs must be greater than or equal to 0.010.
       The RRF for all other semivolatile target compounds must be greater than or equal to 0.050.

    4.  For a closing CCV, RRFs must be greater than or equal to 0.010 for all semivolatile target
       compounds and associated DMCs.

    5.  For an opening CCV, the Percent Difference (%D) between the initial calibration RRF and the
       opening CCV RRF must be within ±40.0% for the semivolatile target compounds and associated
       DMCs listed in Table 28. For an opening CCV, the Percent Difference for all other semivolatile
       target compounds and associated DMCs must be within ±25.0%.
       For a closing CCV, the Percent Difference between the initial calibration RRF and the opening
       CCV RRF must be within ±50.0% for all semivolatile target compounds and associated DMCs.
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D.  Evaluation:

    1.  Verify that the CCV was run at the required frequency (an opening and closing CCV must be run
       within a 12-hour period) and the CCV was compared to the correct initial calibration. If the mid-
       point standard from the initial calibration is used as an opening CCV, verify that the result (RRF)
       of the mid-point standard was compared to the RRF from the correct initial calibration.

    2.  Evaluate the CCV RRF for all semivolatile target compounds and DMCs:

       a.  Check and recalculate the CCV RRF for at least one semivolatile target compound and DMC
           associated with each internal standard. Verify that the recalculated value(s) agrees with the
           laboratory reported value (s).

       b.  For an opening CCV, verify that all semivolatile target compounds listed in Table 28 and all
           DMCs have CCV RRFs of greater than or equal to 0.010, and all other semivolatile target
           compounds have RRFs of greater than or equal to 0.050.

       c.  For a closing CCV, verify that all  semivolatile target compounds and DMCs have CCV RRFs
           of greater than or equal to 0.010.
    3.  Evaluate the Percent Difference between initial calibration RRF and CCV (both opening and
       closing) RRF for one or more semivolatile target compound(s) and DMCs:

       a.  Check and recalculate the Percent Difference for one or more semivolatile target
           compound(s) and DMCs associated with each internal standard. Verify that the recalculated
           value(s) agrees with the laboratory-reported value(s).

       b.  For an opening CCV, verify that the Percent Difference is within ±40.0% for the semivolatile
           target compounds and DMCs listed in Table 28, and within ±25.0% for all other semivolatile
           target compounds and associated DMCs.

       c.  For a closing CCV, verify that the Percent Difference is within ±50.0% for all  semivolatile
           target compounds and DMCs.

    4.  If errors are detected in the calculations of either the CCV (both opening and closing) RRF or the
       Percent Difference, perform a more  comprehensive recalculation.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are  evaluated as part of the Contract Compliance Screening  (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  If a CCV (opening and  closing) was not run at the appropriate frequency, qualify all data as
       unusable "R".

    2.  Qualify all  semivolatile target compounds, including the compounds exhibiting  poor response
       listed in Table 28, using the following criteria (see Table 30):
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       a.  For an opening CCV, if any semivolatile target compound has an RRF value less than the
           minimum criterion (0.010 for the compounds listed in Table 28 and 0.050 for all other
           semivolatile compounds), use professional judgment for detects, based on mass spectral
           identification, to qualify the data as a "J" or unusable "R".

       b.  For a closing CCV, if any semivolatile target compound has an RRF value less than 0.010,
           use professional judgment for detects based on mass spectral identification to qualify the data
           as a "J" or unusable "R".

       c.  For an opening CCV, if any semivolatile target compound has an RRF value less than the
           minimum criterion (0.010 for the compounds listed in Table 28 and 0.050 for all other
           semivolatile compounds), qualify non-detected compounds as unusable "R".

       d.  For a closing CCV, if any semivolatile target compound has an RRF of less  than 0.010,
           qualify non-detected compounds as unusable "R".

       e.  For an opening CCV, if the Percent Difference value for any of the semivolatile target
           compounds listed in Table 28 is outside the ±40.0% criterion, qualify detects with a "J" and
           non-detected compounds with an approximated "UJ".

       f  For a closing CCV, if the Percent Difference value for any of the semivolatile target
           compounds exhibiting poor response is outside the ±50.0% criterion, qualify detects with a
           "J" and non-detected compounds with an approximated "UJ".

       g.  For an opening CCV, if the Percent Difference value for any other semivolatile target
           compound is outside the ±25.0% criterion, qualify detects with a "J" and non-detected
           compounds with an approximated "UJ".

       h.  For a closing  CCV, if the Percent Difference value for any other semivolatile target
           compound is outside the ±50.0% criterion, qualify detects with a "J" and non-detected
           compounds with an approximated "UJ".

       i.  No qualification of the data is necessary on the DMC RRF and Percent Difference data alone.
           However, use professional judgment to evaluate the DMC RRF and Percent Difference data
           in conjunction with the DMC recoveries to determine the need for qualification of data.

       j.  If the semivolatile target compounds meet the acceptance criteria for RRF and the Percent
           Difference, no qualification of the data is necessary.

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

    4.  Note in the Data Review Narrative, whenever possible, the potential effects on the data due to
       calibration criteria exceedance.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if calibration criteria are
       grossly exceeded.
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                                                               Semivolatiles Organic Analysis
      Table 30. Continuing Calibration Verification (CCV) Actions for Semivolatile Analyses
               Criteria for
              Opening CCV
    Criteria for
    Closing CCV
                                                                           Action
  Detected
 Associated
Compounds
   Non-
  Detected
 Associated
Compounds
 Opening CCV not performed at required
 frequency (see Semivolatiles,
 Section IV C.I)
  Closing CCV not
performed at required
     frequency
  (see Semivolatiles,
   Section IV C.I)
            R
 RRF< 0.010
 (target compounds listed in Table 28)
 RRF < 0.050 (all other target compounds)
    RRF< 0.010
(all target compounds)
   JorR
     R
 RRF> 0.010
 (target compounds listed in Table 28)
 RRF > 0.050 (all other target compounds)
    RRF> 0.010
(all target compounds)
      No qualification
 % D < 40.0 or > -40.0
 (target compounds listed in Table 28)
 %D <25.0or>-25.0
 (all other target compounds)
%D < 50.0 or > -50.0
(all target compounds)
      No qualification
 % D > 40.0 or < -40.0
 (target compounds listed in Table 28)
 %D > 25.0 or <-25.0
 (all other target compounds)
%D > 50.0 or <-50.0
(all target compounds)
                   UJ
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                                          V. Blanks

A.  Review Items:

    Form I SV-1, Form I SV-2, Form I SV-TIC, Form ISV-SIM, Form IV SV, Form IV SV-SIM,
    chromatograms, and quantitation reports.

B.  Objective:

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

C.  Criteria:

    1.  Method Blanks

       A  method blank must be extracted each time samples are extracted.  A method blank is required
       per matrix (e.g., a non-aqueous method blank is required for non-aqueous samples and an
       aqueous method blank is required for aqueous samples) and concentration level (e.g., low or
       medium).  The number of samples extracted with each method blank shall not exceed 20 field
       samples [excluding Matrix Spike/Matrix Spike Duplicates (MS/MSDs) and Performance
       Evaluation (PE) samples]. The method blank must be analyzed on each Gas
       Chromatograph/Mass Spectrometer (GC/MS) system used to analyze the set of samples prepared
       with the method blank.

       For low-level non-aqueous and aqueous samples, the concentration of each target compound
       [except bis(2-ethylhexyl)phthalate] found in the method blank must be less than its Contract
       Required Quantitation  Limit (CRQL) listed in the method. The concentration of bis(2-
       ethylhexyl)phthalate found in the method blank must be less than five times (5x) its respective
       CRQL listed in the method.  For medium-level non-aqueous samples, the concentration of each
       target compound found in the method blank must be less than its CRQL listed in the method.

       NOTE:    The concentration of non-target compounds in all blanks must be less than or equal to
                  10 ng/L.

D.  Evaluation:

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

    2.  Verify that a method blank analysis has been reported for each extraction batch and for each
       GC/MS system used to analyze semivolatile samples. There must be a method blank per sample
       matrix (i.e., if non-aqueous samples are present, verify that there is a non-aqueous method blank)
       and concentration level. The reviewer may use the  Method Blank Summary (Form IV SV and
       Form IVSV-SIM) to identify the samples associated with each method blank.
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       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process. Data concerning the field blanks are not evaluated as part of the
                  CCS process. If field blanks are present, the data reviewer should evaluate this data
                  in a similar fashion as the method blanks.

E.  Action:

    Action regarding unsuitable blank results depends on the circumstances and origin of the blank. In
    instances where more than one of the same type of blank is associated with a given sample,
    qualification should be based upon a comparison with the associated blank having the highest
    concentration of a contaminant.  Do not correct the sample results by subtracting any blank value (see
    Table 31).

    1.  If a semivolatile compound is found in a method blank, but not found in the sample, no
       qualification of the data is necessary.

    2.  If the method blank concentration is less than the CRQL [less than 5x the CRQL for bis(2-
       ethylhexyl)phthalate in low-level non-aqueous and aqueous samples] and:

       a.   the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.   the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    3.  If the method blank concentration is greater than the CRQL [greater than  5x the  CRQL for bis(2-
       ethylhexyl)phthalate in low-level non-aqueous and aqueous samples] and:

       a.   the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.   the sample concentration is greater than or equal to the CRQL, and less than the blank
           concentration, report the concentration of the compound in the sample at the same
           concentration found in the blank with a "U", or the reviewer may elect to qualify the data as
           unusable "R".

       c.   the sample concentration is greater than or equal to the CRQL and greater than or equal to the
           blank concentration, use professional judgment to qualify the data.

    4.  If the method blank concentration is equal to the CRQL [equal to 5x the CRQL for
       bis(2-ethylhexyl)phthalate in low-level non-aqueous and aqueous samples], and:

       a.   the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.   the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    5.  If gross contamination exists (i.e., saturated peaks by GC/MS), qualify all affected compounds in
       the associated samples as unusable  "R", due to interference. Note,  for Contract Laboratory
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                                                                 Semivolatiles Organic Analysis
       Program Project Officer (CLP PO) action, if the contamination is suspected of having an effect on
       the sample results.

    6.  Give the same consideration as the target compounds to the Tentatively Identified Compounds
       (TICs), which are found in both the sample and associated blank(s) (see Semivolatiles Organic
       Analysis, Section XIII, for TIC guidance).

    7.  If the contaminants found in the blank are interfering non-target compounds at concentrations
       greater than 10 (ig/L, the reviewer may use professional judgment to qualify the data.

       NOTE:    There may be instances where little or no contamination was present in the associated
                  blanks, but qualification of the sample is deemed necessary. If the reviewer
                  determines that the contamination is from a source other than the sample, they should
                  qualify the data.  Contamination introduced through dilution water is one example.
                  Although it is not always possible to determine, instances of this occurring can be
                  detected when contaminants are found in the diluted sample result, but are absent in
                  the undiluted sample result.

    8.  If contaminants are found in the field blanks, the following is recommended:

       a.  Review the associated method blank data to determine if the contaminant(s) was also present
           in the method blank.

           i.   If the analyte was present at a comparable level in the method blank, the source of the
               contamination may be in the analytical system and the action recommended for the
               method blank would apply.

           ii.  If the analyte was not present in the method blank, the source of contamination may be in
               the field. Consider all associated samples for possible cross-contamination.

       b.  If the field blank contains a semivolatile Target  Compound List (TCL) compound(s) at a
           concentration greater than or equal to the CRQL, and:

           i.   the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, and less than the blank
               concentration, report the concentration of the compound in the sample at the same
               concentration found in the blank and qualify with a "U", or the reviewer may elect to
               qualify the data as unusable "R".

           iii.  the sample concentration is greater than the  CRQL and greater than or equal to the blank
               concentration, use professional judgment to qualify the data.

       c.  If the field blanks contain a semivolatile TCL compound(s) at a concentration less than the
           CRQL and:

           i.   the sample concentration is less than the CRQL [5x the CRQL for bis(2-
               ethylhexyl)phthalate for low-level non-aqueous and aqueous samples], report the CRQL
               value with a "U".
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           ii.  the sample concentration is greater than or equal to the CRQL [5x the CRQL for bis(2-
              ethylhexyl)phthalate for low-level non-aqueous and aqueous samples], no qualification
              of the data is necessary.

       d.  If the field blanks contain a semivolatile TCL compound(s) at a concentration equal to the
           CRQL  [5x the CRQL for bis(2-ethylhexyl)phthalate for low-level non-aqueous and aqueous
           samples] and:

           i.  the sample concentration is less than to the CRQL [5x the CRQL for bis(2-
              ethylhexyl)phthalate for low-level non-aqueous and aqueous samples], report the  CRQL
              value with a"U".

           ii.  the sample concentration is greater than or equal to the CRQL [5x the CRQL for bis(2-
              ethylhexyl)phthalate for low-level non-aqueous and aqueous samples], use professional
              judgment to qualify the data.

       e.  If gross contamination (i.e., saturated peaks by GC/MS) exists in the field blank, positive
           sample results may require rejection and be qualified as unusable "R".  Non-detected
           semivolatile target compounds do not require qualification unless the contamination is so
           high that it interferes with the analyses of non-detected compounds.

       f  If the contaminants found in the field blank are interfering non-target compounds at
           concentrations greater than  10 (ig/L (for aqueous blanks) or 330 (ig/kg (for non-aqueous
           blanks), use professional judgement to qualify the data.
January 2005                                 128                                   Draft Final

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                                                               Semivolatiles Organic Analysis
                      Table 31.  Blank Actions for Semivolatiles Analyses
Blank
Type





Method,
Field




Blank Result
Detects

< CRQL*

> CRQL*


— CRQL*
Gross contamination
TIC> 10 jig/L
(for aqueous blanks)
TIC > 330 (ig/kg
(for non-aqueous blanks)
Sample Result
Not detected
CRQL
 CRQL and
< blank concentration
> CRQL and
> blank concentration
 CRQL
Detects
Detects
Action for Samples
No qualification
Report CRQL value with a U
Use professional judgment
Report CRQL value with a U
Report the concentration for the
sample with a U or qualify the data
as unusable R
Use professional judgment
Report CRQL with a U
Use professional judgment
Qualify results as unusable R
Use professional judgment
    *   5x the CRQL for bis(2-ethylhexyl)phthalate for low-level non-aqueous and aqueous samples.
January 2005
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                                                                 Semivolatiles Organic Analysis
                        VI. Deuterated Monitoring Compounds (DMCs)
A.  Review Items:
    Form II SV-1, Form II SV-2 , Form II SV-3, Form II SV-4, Form IISV-SIM1, Form IISV-SIM2,
    chromatograms, and quantitation reports.

B.  Objective:

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

C.  Criteria:

    1.  The DMCs listed in Table 32 are added to all samples and blanks to measure their recovery in
       environmental samples.
      Table 32.  Semivolatile Deuterated Monitoring Compound (DMC) and Recovery Limits
DMC
Phenol-d5
Bis-(2-chloroethyl) ether-ds
2-Chlorophenol-d4
4-Methylphenol-d8
Nitrobenzene -d5
2-Nitrophenol-d4
2,4-Dichlorophenol-d3
4-Chloroaniline-d4
Dimethylphthalate-d6
Acenaphthylene-d8
4-Nitrophenol-d4
Fluorene-d10
Recovery Limits (%) for Water
Samples
39- 106
40 - 105
41- 106
25-111
43 - 108
40- 108
37- 105
1 - 145
47-114
41- 107
33- 116
42 - 1 1 1
Recovery Limits (%)
for Soil/Sediment Samples
17-103
12-98
13- 101
8- 100
16- 103
16- 104
23 - 104
1- 145
43- 111
20-97
16- 166
40 - 108
January 2005
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                                                                Semivolatiles Organic Analysis
 Table 32. Semivolatile Deuterated Monitoring Compound (DMC) and Recovery Limits (CON'T)
DMC
4,6-Dinitro-2-methylphenol-d2
Anthracene-d10
Pyrene-d10
Benzo(a)pyrene-d12
Fluoranthene-d10 (SIM)
2-Methylnaphthalene-d10 (SIM)
Recovery Limits (%) for
Water Samples
22 - 104
44-110
52- 119
32- 121
50-150
50-150
Recovery Limits (%)
for Soil/Sediment Samples
1- 121
22-98
51 - 120
43- 111
50- 150
50- 150
    2.  Recoveries for DMCs in semivolatile samples and blanks must be within the limits specified in
       Table 32.
       NOTE:
D.  Evaluation:
The recovery limits for any of the compounds listed in Table 32 may be expanded at
any time during the period of performance is USEPA determines that the limits are
too restrictive.
    1.  Check raw data (e.g., chromatograms and quantitation reports) to verify the recoveries on the
       Deuterated Monitoring Compound Recovery Forms (Form II SV-1, Form II SV-2, Form II SV-3,
       Form II SV-4, Form IISV-SIM1, and Form IISV-SIM2}. Check for any calculation or
       transcription errors; verify that the DMC recoveries were calculated correctly using the equation
       in the method.

    2.  Whenever there are two or more analyses for a particular sample, the reviewer must determine
       which are the most accurate data to report.  Considerations include, but are not limited to:

       a.  DMC recovery (marginal versus gross deviation).

       b.  Technical holding times.

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

       d.  Other Quality Control (QC) information, such as performance of internal standards.

           NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                     criteria are evaluated as part of the Contract Compliance Screening (CCS)
                     process.  Information regarding the laboratory's compliance with these criteria
                     can be obtained from the Data Assessment Tool (DAT) reports, and may be used
                     as part of the evaluation process.
January 2005
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                                                                  Semivolatiles Organic Analysis
E.  Action:

    Table 34 and Table 35 (SIMAnalysis) list the semivolatile DMCs and their associated target
    compounds.  If any DMC recovery in the semivolatiles fraction is out of specification, qualify data
    considering the existence of interference in the raw data (see Table 33). Considerations include, but
    are not limited to:

    1.  For any recovery greater than the upper acceptance limit:

       a.  Qualify detected associated semivolatile target compounds as a "J".

       b.  Do not qualify non-detected associated semivolatile target compounds.

    2.  For any recovery less than the lower acceptance limit:

       a.  Qualify detected associated semivolatile target compounds as a "J".

       b.  Qualify non-detected associated semivolatile target compounds as approximated "U" or
           unusable "R".

    3.  For any recovery within acceptance limits, no qualification of the data is necessary.

    4.  In the special case of a blank analysis having DMCs out of specification, the reviewer must give
       special consideration to the validity of associated sample data. The basic concern is whether the
       blank problems represent an isolated problem with the blank alone, or whether there  is a
       fundamental problem with the analytical process. For example, if one or more samples in the
       batch show acceptable DMC recoveries, the reviewer may choose to consider the blank problem
       to be an isolated occurrence.  Note, for Contract Laboratory Program Project Officer (CLP PO)
       action, analytical problems, even if this judgment allows some use of the affected data.

 Table 33. Deuterated Monitoring Compound (DMC) Recovery Actions For Semivolatile Analyses
Criteria
%R > Upper Acceptance Limit
%R < Lower Acceptance Limit
Lower Acceptance < %R < Upper Acceptance Limit
Action
Detected
Associated
Compounds
J
J
Non-Detected
Associated
Compounds
No qualification
UJorR
No qualification
January 2005
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                                                            Semivolatiles Organic Analysis
              Table 34. Semivolatile Deuterated Monitoring Compounds (DMCs)
                           and the Associated Target Compounds
Phenol-d, (DMC)
Benzaldehyde
Phenol
bis(2-Chloroethyl) ether-ds (DMC)
bis-(2-Chloroethyl) ether
2,2'-oxybis( 1 -Chloropropane)
bis(2-Chloroethoxy) methane
Nitrobenzene-d5 (DMC)
Acetophenone
N-Nitroso-di-n-propylamine
Hexachloroethane
Nitrobenzene
2,6-Dinitrotoluene
2,4-Dinitrotoluene
N-Nitrosodiphenylamine
Fluorene-din (DMC)
Dibenzofuran
Fluorene
4-Chlorophenyl-phenylether
4-Bromophenyl-phenylether
Carbazole
Acenaphthylene-ds (DMC)
Naphthalene
2-Methylnaphthalene
2-Chloronaphthalene
Acenaphthylene
Acenaphthene
4,6-Dinitro-2-methylphenol-d2
(DMC)
4,6-Dinitro-2-methylphenol
2-Chlorophenol-d, (DMC)
2-Chlorophenol
4-Methylphenol-ds (DMC)
2-Methylphenol
4-Methylphenol
2,4-Dimethylphenol
2,4-Dichlorophenol-d3
(DMC)
2,4-Dichlorophenol
Hexachlorobutadiene
4-Chloro-3-methylphenol
2,4,6-Trichlorophenol
2,4,5 -Trichlorophenol
1, 2,4,5 -Tetrachlorobenzene
Pentachlorophenol
2,3,4,6-Tetrachlorophenol
Anthracene-d,n (DMC)
Hexachlorobenzene
Atrazine
Phenanthrene
Anthracene
4-Nitrophenol-d, (DMC)
2-Nitroaniline
3-Nitroaniline
2,4-Dinitrophenol
4-Nitrophenol
4-Nitroaniline


2-Nitrophenol-d,, (DMC)
Isophorone
2-Nitrophenol
4-Chloroaniline-d^ (DMC)
4-Chloroaniline
Hexachlorocyclopentadiene
3 ,3 '-Dichlorobenzidine
Dimethylphthalate-d6 (DMC)
Caprolactam
l,l'-Biphenyl
Dimethylphthalate
Diethylphthalate
Di-n-butylphthalate
Butylbenzylphthalate
bis(2-Ethylhexyl) phthalate
Di-n-octylphthalate
Pyrene-din (DMC)
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo (a) pyrene-d,, (DMC)
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene


January 2005
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                                                             Semivolatiles Organic Analysis
              Table 35. Semivolatile Deuterated Monitoring Compounds (DMCs)
           for Selective Ion Monitoring (SIM) and the Associated Target Compounds
Fluoranthene-d10 (DMC)
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Indeno(l,2,3-cd)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene
2-Methylnapthalene-d10 (DMC)
Napthalene
2-Methylnapthalene
Acenapthylene
Acenaphthene
Fluorene
Pentachlorophenol
Phenanthrene
Anthracene


January 2005
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                                                                Semivolatiles Organic Analysis
                    VII. Matrix Spike/Matrix Spike Duplicates (MS/MSDs)

A.  Review Items:

    Form III SV-1, Form III SV-2, Form III SV-SIM1 and Form IIISV-SIM2, chromatograms, and
    quantitation reports.

    NOTE:     Data for MS and MSDs will not be present unless requested by the Region.

B.  Objective:

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

C.  Criteria:

    1.  If requested, MS and MSD samples are analyzed at a frequency of one MS and MSD per 20 or
       fewer samples per sample matrix and concentration level.

    2.  Spike recoveries should be within the advisory limits provided on Form III SV-1, Form III SV-2,
       Form III SV-SIM, and Form III SV-SIM2.

    3.  Relative Percent Differences (RPDs) between MS and MSD recoveries must be within the
       advisory limits provided on Form III SV-1, Form III SV-2, Form III SV-SIM, and
       Form III SV-SIM2.

D.  Evaluation:

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

    2.  Inspect results for the MS and MSD Recovery on Form III SV, Form III SV-1, Form III SV-2,
       Form III SV-SIM and Form III SV-SIM2 and verify that the results for recovery and RPD are
       within the advisory limits.

    3.  Verify transcriptions from raw data and verify calculations.

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

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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                                                                  Semivolatiles Organic Analysis
E.  Action:

    1.  No qualification of the data is necessary on MS and MSB data alone. However, using informed
       professional judgment, the data reviewer may use the MS and MSB results in conjunction with
       other QC criteria to determine the need for some  qualification of the data (see Table 36).
       Table 37 lists the semivolatile target compounds  that are spiked into samples to test for matrix
       effects. If any MS and MSB Percent Recovery or RPB in the semivolatiles fraction is out of
       specification (see Table 37), qualify data to include the consideration of the existence of
       interference in the raw data. Considerations include, but are not limited to:

       a.  For any recovery or RPB greater than the upper acceptance limit:

           i.   Qualify detected spiked semivolatile target compounds as a "J".

           ii.  Bo not qualify non-detected spiked semivolatile target compounds.

       b.  For any recovery less than the lower acceptance limit:

           i.   Qualify detected spiked semivolatile target compounds as a "J".

           ii   Use professional judgment to qualify non-detected spiked semivolatile target compounds.

       c.  For any recovery or RPB within acceptance limits, no qualification of the data is necessary.

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

    3.  In those instances where it can be determined that the results  of the MS and MSB affect only the
       sample spiked, limit qualification to this sample only.  However, it may be determined through
       the MS and MSB results that a laboratory  is having a systematic problem in the analysis of one or
       more analytes, that affects all associated samples. Use professional judgment to qualify the data
       from all associated samples.

    4.  The reviewer must use professional judgment to determine the need for qualification of detects of
       non-spiked compounds.

       NOTE:    Note, for Contract Laboratory Program Project Officer (CLP PO) action, if a field
                  blank was used for the MS and MSB.
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                                                              Semivolatiles Organic Analysis
   Table 36. Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Semivolatiles Analysis
Criteria
%R or RPD > Upper Acceptance Limit
%R < Lower Acceptance Limit
Lower Acceptance Limit < %R; RPD <
Upper Acceptance Limit
Action
Detected
Spiked Compounds
J
J
Non-detected
Spiked Compounds
No qualification
Use professional judgment
No qualification
          Table 37. Matrix Spike (MS) Recovery and Relative Percent Difference (RPD)
Compound
Phenol
2-Chlorophenol
N-Nitroso-di-n-
propylamine
4-Chloro-3-methylphenol
Acenaphthene
4-Nitrophenol
2,4-Dinitrotoluene
Pentachlorophenol
Pyrene
%Recovery for
Water Samples
12- 110
27 - 123
41 - 116
23-97
46- 118
10-80
24-96
9- 103
26 - 127
RPD
for Water
Samples
0-42
0-40
0-38
0-42
0-31
0-50
0-38
0-50
0-31
%Recovery for
Soil/Sediment
Samples
26-90
25 - 102
41 - 126
26 - 103
31- 137
11- 114
28-89
17- 109
35 - 142
RPD for
Soil/Sediment
Samples
0-35
0-50
0-38
0-33
0-19
0-50
0-47
0-47
0-36
January 2005
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                                                                Semivolatiles Organic Analysis
                VIII. Regional Quality Assurance (OA) and Quality Control (OC)

A.  Review Items:

    Form I SV-1, Form I SV-2 , Form ISV-SIM, chromatograms, Traffic Report/Chain of Custody
    Record (TR/COC), quantitation reports, and other raw data from QA/QC samples.

B.  Objective:

    Regional QA/QC refers to any QA and/or QC samples initiated by the Region, including field
    duplicates, Performance Evaluation (PE) samples, blind spikes, and blind blanks. The use of these
    QA/QC samples is highly recommended (e.g., the use of field duplicates can provide information on
    sampling precision and homogeneity).

C.  Criteria:

    Criteria are determined by each Region.

    1.  PE sample frequency may vary.

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

D.  Evaluation:

    1.  Evaluation procedures must follow the Region's Standard Operating Procedure (SOP) for data
       review. Each Region will handle the evaluation of PE samples on an individual basis.  Compare
       results for PE samples to the acceptance criteria for the specific PE samples, if available.

    2.  Calculate Relative Percent Difference (RPD) between field duplicates. Provide this information
       in the Data Review Narrative.

E.  Action:

    Any action must be in accordance with Regional specifications and the criteria for acceptable PE
    sample results.  Note, for Contract Laboratory Program Project Officer (CLP PO) action,
    unacceptable results for PE samples.
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                                                                 Semivolatiles Organic Analysis
                IX. Gel Permeation Chromatography (GPC) Performance Check

A.  Review Items:

    Two Ultraviolet (UV) traces, GPC cleanup blank quantitation reports, and chromatograms.

B.  Objective:

    GPC is used to remove high molecular weight contaminants that can interfere with the analysis of
    target analytes. GPC cleanup procedures are checked by adding the GPC calibration mixture to the
    GPC cleanup columns and setting the appropriate elution window, and verifying the recovery of
    target compounds through the cleanup procedure by the analysis of a cleanup blank.

C.  Criteria:

    1.   GPC is used for the cleanup of all non-aqueous sample extracts and for aqueous sample extracts
        that contain high molecular weight components that interfere with the analysis of the target
        analytes.

    2.   At least once every 7 days, the calibration of the GPC unit must be checked by injecting the
        calibration solution.

    3.   The GPC calibration is  acceptable if the two UV traces meet the following requirements:

        a.   Peaks must be observed and symmetrical for all compounds in the calibration solution.

        b.   Corn oil and the phthalate peaks exhibit greater than 85% resolution.

        c.   The phthalate and methoxychlor peaks exhibit greater than 85% resolution.

        d.   Methoxychlor and perylene peaks exhibit greater than 85% resolution.

        e.   Perylene and sulfur peaks must not be saturated and should exhibit greater than 90% baseline
           resolution.

        f   The Retention Time (RT) shift is less than 5% between UV traces for bis (2-ethylhexyl)
           phthalate and perylene.

    4.   A GPC blank must be analyzed after each GPC calibration and is acceptable if the blank does not
        exceed the Contract Required Quantitation Limits (CRQL) for any target analytes, except for
        bis(2-ethylhexyl)phthalate, which must be less than 5x the CRQL.

D.  Evaluation

    1.   Verify that there are two UV traces present and that the RT shift for bis(2-ethylhexyl) phthalate
        and perylene is less than 5%.

    2.   Verify that the compounds listed in Semivolatiles Organic Analysis, Section IX.C.3, are present
        and symmetrical in both UV traces and that the compound pairs meet the minimum resolution
        requirements.
January 2005                                 139                                   Draft Final

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                                                                Semivolatiles Organic Analysis
    3.  Verify that no target compound exceeds the CRQL except for bis(2-ethylhexyl) phthalate, which
       must not exceed 5x the CRQL.

E.  Action:

    1.  If GPC criteria are not met, examine the raw data for the presence of high molecular weight
       contaminants; examine subsequent sample data for unusual peaks; and use professional judgment
       in qualifying the data. Notify the Contract Laboratory Program Project Officer (CLP PO) if the
       laboratory chooses to analyze samples under unacceptable GPC criteria.

    2.  Note in the Data Review Narrative potential effects on the sample data resulting from the GPC
       cleanup analyses not yielding acceptable results.
January 2005                                140                                   Draft Final

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                                                                 Semivolatiles Organic Analysis
                                     X. Internal Standards

A.  Review Items:

    Form VIII SV-1, Form VIII SV-2, Form VIIISV-SIM1, Form VIIISV-SIM2, quantitation reports, and
    chromatograms.

B.  Objective:

    Internal standards performance criteria ensure that Gas Chromatograph/Mass Spectrometer (GC/MS)
    sensitivity and response are stable during each analysis.

C.  Criteria:

    1.  Internal standard area counts for all samples [including Matrix Spike/Matrix Spike Duplicate
       (MS/MSD), or Performance Evaluation (PE) samples] and all blanks must be within the inclusive
       range of 50.0% and 200% of its response from the associated 12-hour calibration standard
       [opening Continuing Calibration Verification (CCV) or mid-point standard from the initial
       calibration].

    2.  The Retention Time (RT) of the internal standard in the sample or blank must not vary by more
       than ±30.0 seconds from the RT of the internal standard in the associated 12-hour calibration
       standard [opening CCV or mid-point standard from the initial calibration].

D.  Evaluation:

    1.  Check raw data (e.g., chromatograms and quantitation lists) to verify the internal standard RTs
       and areas reported  on the Internal Standard Area Summary (Form VIII SV-1, Form VIII SV-2,
       Form VIIISV-SIM1, and Form VIIISV-SIM2}.

    2.  Verify that all RTs and internal standard areas are within the required criteria for all samples and
       blanks.

    3.  If there are two analyses for a particular fraction, the reviewer must determine which are the most
       accurate data to report. Considerations include, but are not limited to:

       a.   Magnitude and direction of the internal standard area shift.

       b.   Magnitude and direction of the internal standard RT shift.

       c.   Technical holding times.

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

       e.   Other Quality Control (QC) information.
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                                                                  Semivolatiles Organic Analysis
           NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the Contract Compliance screening (CCS)
                      process.  Information regarding the laboratory's compliance with these criteria
                      can be obtained from the Data Assessment Tool (DAT) reports, and may be used
                      as part of the evaluation process.
E.  Action:

    1.  If an internal standard area count for a sample or blank is greater than 200% of the area for the
       associated standard (opening CCV or mid-point standard from the initial calibration) (see
       Table 38):

       a.  Qualify detects for compounds quantitated using that internal standard with a " J".

       b.  Do not qualify non-detected associated compounds.

    2.  If an internal standard area count for a sample or blank is less than 50.0% of the area for the
       associated standard (opening CCV or mid-point standard from the initial calibration):

       a.  Qualify detects for compounds quantitated using that internal standard with a " J".

       b.  Qualify non-detected associated compounds as unusable "R".

    3.  If an internal standard area count for a sample or a blank is greater than or equal to 50.0%, and
       less than or equal to 200% of the area for the associated standard opening CCV or mid-point
       standard from the initial calibration, no qualification is necessary.

    4.  Absolute RTs of internal standards should not vary dramatically between samples and the
       associated 12-hour calibration standard (opening CCV or mid-point standard from the initial
       calibration).  If an internal standard RT varies by more than 30.0 seconds, qualify all data as
       unusable "R".

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, if the internal standard
       performance criteria are grossly exceeded.  Note in the Data Review Narrative potential effects on
       the data resulting from unacceptable internal standard performance.
January 2005                                  142                                   Draft Final

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                                                                Semivolatiles Organic Analysis
                 Table 38. Internal Standard Actions For Semivolatiles Analyses
Criteria
Area counts >200% of 12-hour standard (opening CCV or mid-
point standard from the initial calibration)
Area counts <50.0% of 12-hour standard (opening CCV or mid-
point standard from the initial calibration)
Area counts > 50.0% and <200% of 12-hour standard (opening
CCV or mid-point standard from the initial calibration)
RT difference > 30.0 seconds between samples and 12-hour
standard (opening CCV or mid-point standard from the initial
calibration)
RT difference < 30.0 seconds between samples and 12-hour
standard (opening CCV or mid-point standard from the initial
calibration)
Action
Detected
Associated
Compounds*
J
J
Non-Detected
Associated
Compounds*
No
qualification
R
No qualification
R
No qualification
    For semivolatile compounds associated to each internal standard, see Table 2 - Semivolatile Internal
    Standards with Corresponding Target and Deuterated Monitoring Compounds Assigned for
    Quantitation in SOM01.0. Exhibit D. available at:

                       http://www.epa.gov/superfund/programs/clp/soml.htm
January 2005
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                                                                 Semivolatiles Organic Analysis
                              XL Target Compound Identification

A.  Review Items:

    Form I SV-1, Form I SV-2, Form ISV-SIM, quantitation reports, mass spectra, and chromatograms.

B.  Objective:

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

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

C.  Criteria:

    1.  The Relative Retention Times (RRTs) must be within ±0.06 RRT units of the standard RRT
       [opening Continuing Calibration Verification (CCV) or mid-point standard from the initial
       calibration].

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

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

       b.   The relative intensities of these ions must agree within ±20% between the standard and
           sample spectra (e.g., for an ion with an abundance of 50% in the standard spectrum, the
           corresponding sample ion abundance must be between 30-70%).

       c.   Ions present at greater than 10% in the sample mass spectrum, but not present in the standard
           spectrum, must be evaluated by a reviewer experienced in mass spectral interpretation.

D.  Evaluation:

    1.  Check that the RRT of reported compounds is within ±0.06 RRT units  of the standard RRT
       (opening CCV or mid-point standard from the initial calibration).

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

    3.  Be aware of situations when sample carryover is a possibility and use professional judgment to
       determine if instrument cross-contamination has affected any positive compound identification.
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                                                                 Semivolatiles Organic Analysis
    4.  Check the chromatogram to verify that peaks are identified. Major peaks are either identified as
       target compounds, TICs, Deuterated Monitoring Compounds (DMCs), or internal standards.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  The application of qualitative criteria for GC/MS analysis of target compounds requires
       professional judgment. It is up to the reviewer's discretion to obtain additional information from
       the laboratory. If it is  determined that incorrect identifications were made, qualify all such data as
       not detected "U" or unusable  "R".

    2.  Use professional judgment to qualify the data if it is determined that cross-contamination has
       occurred.

    3.  Note in the Data Review Narrative any changes made to the reported compounds or concerns
       regarding target compound identifications. Note, for Contract Laboratory Program Project
       Officer (CLP PO) action, the  necessity for numerous or significant changes.
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                                                                 Semivolatiles Organic Analysis
   XII.  Compound Ouantitation and Reported Contract Required Ouantitation Limits (CRQLs)

A.  Review Items:

    Form I SV-1, Form I SV-2 , Form ISV-SIM, sample preparation sheets, Sample Delivery Group
    (SDG) Narrative, quantitation reports, and chromatograms.

B.  Objective:

    The objective is to ensure that the reported quantitation results and CRQLs are accurate.

C.  Criteria:

    1.  Compound quantitation, adjustment of the CRQL, and Percent Moisture (for non-aqueous
       samples) must be calculated according to the correct equation.

    2.  Compound Relative Response Factors (RRFs) must be calculated based on the internal standard
       associated with that compound, as listed in the method.  Quantitation must be based on the
       quantitation ion (m/z) specified in the method for both the internal standard and target analytes.
       The compound quantitation must be based on the RRF from the appropriate daily calibration
       standard [opening Continuing Calibration Verification (CCV) or mid-point standard from initial
       calibration].

D.  Evaluation:

    1.  Examine raw data to verify the correct calculation of all sample results reported by the laboratory.
       Compare quantitation lists and chromatograms to the reported detect and non-detect sample
       results.  Check the reported values.

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

    3.  Verify that the CRQLs have been adjusted to reflect all sample dilutions and Percent Moisture
       factors (for non-aqueous samples).

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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                                                                  Semivolatiles Organic Analysis
E.  Action:

    1.  For non-aqueous samples, if the Percent Moisture is less the 70.0%, no qualification of the data is
       necessary.  If the Percent Moisture is greater than or equal to 70.0% and less than 90.0%, qualify
       detects as "J" and non-detects as approximated "UJ". If the Percent Moisture is greater than or
       equal to 90.0%, qualify detects as "J" and non-detects as unusable "R" (see Table 39).

     2. If any discrepancies are found, the Region's designated representative may contact the laboratory
       to obtain additional information that could resolve any differences. If a discrepancy remains
       unresolved, the reviewer must use professional judgment to decide which value is the most
       accurate value. Under these circumstances, the reviewer may determine that qualification of data
       is warranted. Note in the Data Review Narrative a description of the reasons for data
       qualification and the qualification that is applied to the data.

    3.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, numerous or significant
       failures to accurately quantify the target compound or to properly evaluate and adjust CRQLs.
     Table 39. Percent Moisture Actions for Semivolatiles Analyses for Non-Aqueous Samples
Criteria
%Moisture < 70.0%
70.0% < %Moisture < 90.0%
%Moisture > 90.0%
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
No qualification
J
J
UJ
R
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                                                                 Semivolatiles Organic Analysis
                         XIII.  Tentatively Identified Compounds (TICs)

A.  Review Items:

    Form I SV-TIC , chromatograms, library search printouts, and spectra for the TIC candidates.

B.  Objective:

    Chromatographic peaks in semivolatile fraction analyses that are not target analytes, Deuterated
    Monitoring Compounds (DMCs), or internal standards are potential TICs. TICs must be qualitatively
    identified via a forward search of the NIST/USEPA/NIH Mass Spectral Library (May 2002 release or
    later)1, and/or Wiley Mass Spectral Library (1998 release or later)2, or equivalent. The identifications
    must be assessed by the data reviewer.

C.  Criteria:

    For each sample, the laboratory must conduct a mass spectral search of the NIST/USEPA/NIH (May
    2002 release or later), and/or Wiley (1998 release or later), or equivalent mass spectral library, and
    report the possible identity for 30 of the largest semivolatile fraction peaks which are not DMCs,
    internal standards, or target compounds, but which have area or height greater than  10% of the area or
    height of the nearest internal standard. Estimated concentrations for TICs are calculated similarly to
    the Target Compound List (TCL) compounds, using total ion areas for the TIC and the internal
    standard, and assuming a Relative  Response Factor (RRF) of 1.0. TIC results are reported for each
    sample on the Organic Analyses Data Sheet (Form I SV-TIC).

D.  Evaluation:

    1.  Guidelines for tentative identification are as follows:

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

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

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

       d.   Review ions present in the sample spectrum, but not in the reference spectrum, for possible
           background contamination, interference, or presence of coeluting compounds.

       e.   Review ions present in the reference spectrum, but not in the sample spectrum, for possible
           subtraction from the sample spectrum because of background  contamination or coeluting
           compounds. Data system  library reduction programs can sometimes create  these
           discrepancies.
       1       NIST/USEPA/NIH Mass Spectral Library (May 2002 release or later), National Institute
               of Standards and Technology, Gaithersburg, Maryland.

       2       Wiley Mass Spectral Library (1998 release or later) John Wiley & Sons, Inc.,  Hoboken,
               New Jersey.
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                                                                 Semivolatiles Organic Analysis
       f.   Non-target compounds receiving a library search match of 85% or higher are a "likely
           match". Report the compound unless the mass spectral interpretation specialist feels there is
           evidence not to report the compound as identified by the library search program.  Note in the
           Sample Delivery Group (SDG) Narrative the justification for not reporting a compound as
           listed by the search program.

       g.  If the library search produces more than one compound greater than or equal to 85%, report
           the compound with the highest percent match (report the first compound if percent match is
           the same for two  or more compounds), unless the mass spectral interpretation specialist feels
           that the highest match compound should not be reported or another compound with a lower
           match should be reported. The laboratory should include the justification for not reporting
           the compound with the highest spectral match within the SDG Narrative.  DMCs, internal
           standards, and volatile target compounds should not be reported as TICs unless the only
           compounds having a percent match of greater than 85% are DMCs, internal standards,  or
           semi volatile target compounds.

       h.  If the library search produces a series of obvious isomer compounds with library search
           matches greater than or equal to 85% (e.g., tetramethyl naphthalenes), report the compound
           with the highest library search percent match (or the first compound if the library search
           matches are the same). Note in the SDG Narrative that the exact isomer configuration, as
           reported, may not be accurate.

       i   If the library search produces no matches greater than or equal to 85%, and in the technical
           judgment of the mass spectral interpretation specialist, no valid tentative identification can be
           made, report the compound as unknown. The mass spectral specialist should give additional
           classification of the unknown compound, if possible (e.g., unknown phthalate,  unknown
           hydrocarbon, unknown acid type, unknown chlorinated compound).  If probable molecular
           weights can be distinguished, include them.

       j.   Alkanes are not to be reported as TICs on Form I SV-TIC. An alkane is defined as any
           hydrocarbon with the generic formula CnH2n+2 that contains only C-H and C-C single bonds.
           When these alkanes are tentatively identified, estimate the concentration(s) and report them in
           the SDG Narrative as alkanes by class (i.e., straight-chain, branched, cyclic, as a series, or as
           applicable). Report total alkanes concentration on Form I SV-TIC.

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

    3.  Examine blank chromatograms to verify that TIC peaks present in samples are not found in
       blanks.  When a low-level, non-target compound that is a common artifact or laboratory
       contaminant is detected in a sample, a thorough check of blank chromatograms may require
       looking for peaks which are less than 10% of the internal standard height, but present in the blank
       chromatogram at a similar Relative Retention Time (RRT).

    4.  Examine all mass spectra for each sample and blank.

    5.  Consider all reasonable choices since TIC library searches often yield several candidate
       compounds having a  close matching score.
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    6.  Be aware of common laboratory artifacts/contaminants and their sources (e.g., Aldol
       condensation products, solvent preservatives, and reagent contaminants).  These may be present
       in blanks and not reported as sample TICs.

       Examples:

       a.  Common laboratory contaminants include CO2 (m/z 44), siloxanes (m/z 73), diethyl ether,
           hexane, certain freons, and phthalates at levels less than 100 (ig/L.

       b.  Solvent preservatives include cyclohexene (a methylene chloride preservative). Related by-
           products include cyclohexanone, cyclohexenone, cyclohexanol, cyclohexenol,
           chlorocyclohexene, and chlorocyclohexanol.

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

    7.  A target compound may be identified in the proper analytical fraction by non-target library search
       procedures, even though it was not found on the quantitation list (false negative). If the total area
       quantitation method was used, request that the laboratory recalculate the result using the proper
       quantitation ion and Relative Response Factor (RRF).

       A non-target compound may be incorrectly identified by the instrument's target analyte data
       processor as a target compound (false positive).  When this happens, the non-target library search
       procedure will not detect the false positive as a TIC. In this case, request that the laboratory
       properly identify the compound and recalculate the result using the total area quantitation method
       and a RRF of 1.0.

       Evaluate other sample chromatograms and check for both false negatives  and  false positives to
       determine if the occurrence is isolated or systematic.

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

    9.  Do not perform library searches on internal standards or DMCs.

    10. Estimate TIC concentration  assuming an RRF of 1.0.

E.  Action:

    1.  Qualify all TIC results for which there is presumptive evidence of a match (i.e., greater than or
       equal to 85% match) as "NJ", tentatively identified, with approximated concentrations.

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

       a.  If it is determined that a tentative identification of a non-target compound is unacceptable,
           change the tentative identification to "unknown" or another appropriate identification and
           qualify the result with a "J".

       b.  If all contractually-required peaks were not library searched and quantitated, the Region's
           designated representative may request these data from the  laboratory.
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    3.  In deciding whether a library search result for a TIC represents a reasonable identification, use
       professional judgment.  If there is more than one possible match, report the result as "either
       compound X or compound Y". If there is a lack of isomer specificity, change the TIC result to a
       non-specific isomer result (e.g., 1,3,5-trimethyl benzene to trimethyl benzene isomer), or to a
       compound class (e.g., 2-methyl, 3-ethyl benzene to a substituted aromatic compound).

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

    5.  Other Case factors may influence TIC judgments.  If a sample TIC match is poor, but other
       samples have a TIC with a good library match, similar RRT, and the same ions, infer
       identification information from the other sample TIC results.

    6.  Note in the Data Review Narrative any changes made to the reported data or any concerns
       regarding TIC  identifications.

    7.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, failure to properly
       evaluate and report TICs.
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                                   XIV.  System Performance

A.  Review Items:

    Form VIII SV-1, Form VIII SV-2 , Form VIIISV-SIM1, Form VIIISV-SIM2, and chromatograms.

B.  Objective:

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

C.  Criteria:

    There  are no specific criteria for system performance.  Use professional judgment to assess the system
    performance.

D.  Evaluation:

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

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

       a.   High PJC background levels or shifts in Absolute Retention Times (RTs) of internal
           standards.

       b.   Excessive baseline rise at elevated temperature.

       c.   Extraneous peaks.

       d.   Loss of resolution.

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

    3.  A  drift in instrument sensitivity may  occur during the 12-hour time period and may be an
       indication of internal standard spiking problems. This could be discerned by examination of the
       internal standards area on Form VIII  SV-1, Form VIII SV-2, Form VIIISV-SIM1, and Form VIII
       SV-SIM2, for trends such as a continuous or near-continuous increase or decrease in the internal
       standard area over time.
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E.  Action:

    Use professional judgment to qualify the data if it is determined that system performance has
    degraded during sample analyses. Note, for Contract Laboratory Program Project Officer (CLP PO)
    action, any degradation of system performance which significantly affected the data.
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                                                                  Semivolatiles Organic Analysis
                                XV. Overall Assessment of Data

A.  Review Items:

    Entire data package, data review results, and (if available) Quality Assurance Project Plan (QAPP),
    and Sampling and Analysis Plan (SAP).

B.  Objective:

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

C.  Criteria:

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

D.  Evaluation:

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

    2.   If appropriate information is available, the reviewer may assess the usability of the data to assist
        the data user in avoiding inappropriate use of the data.  Review all available information,
        including the QAPP (specifically the acceptance or performance criteria), SAP, and
        communication with the data user that concerns the intended use and desired quality of these data.

E.  Action:

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

    2.   Write a brief narrative to give the user an indication of the analytical limitations of the data.
        Note, for Contract Laboratory Program Project Officer (CLP PO) action, any inconsistency of the
        data with the Sample Delivery Group (SDG) Narrative. If sufficient information on the intended
        use and required quality of the data are available, the reviewer should include their assessment of
        the usability of the data within the given context.  This may be used as part of a formal Data
        Quality Assessment (DQA).
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                                                                 Pesticides Organic Analysis
                               PESTICIDE DATA REVIEW




The pesticide data requirements to be checked are:




I.      Preservation




II.     Gas Chromatograph/Electron Capture Detector (GC/ECD) Instrument Performance Check




III.     Initial Calibration




IV.     Continuing Calibration Verification (CCV)




V.     Blanks




VI.     Surrogate Spikes




VII.    Matrix Spike/Matrix Spike Duplicates (MS/MSDs)




VIII.   Laboratory Control Samples (LCSs)




IX.     Regional Quality Assurance (QA) and Quality Control (QC)




X.     Florisil Cartridge Performance Check




XI.     Gel Permeation Chromatography (GPC) Performance Check




XII.    Target Compound Identification




XIII.   Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation




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




XV.    Overall Assessment of Data
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                                                                    Pesticides Organic Analysis
                                        I. Preservation

A.  Review Items:

    Form I PEST, Traffic Report/Chain of Custody Record (TR/COC), raw data, sample extraction
    sheets, and Sample Delivery Group (SDG) Narrative checking for:

    1.  pH
    2.  Sample temperature
    3.  Holding time
    4.  Other sample conditions

B.  Objective:

    The objective is to ascertain the validity of the analytical results based on sample condition (e.g.,
    preservation and temperature) and the holding time of the sample from time of collection to time of
    sample extraction and analysis.

C.  Criteria:

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

       For pesticides in properly cooled (4°C ± 2°C) aqueous samples, the maximum holding time for
       extraction is seven (7) days from sample collection, and the maximum holding time for analysis is
       forty (40) days from sample extraction.

    The technical holding time criteria for non-aqueous samples are as follows:

       For pesticides in properly cooled (4°C ± 2°C) non-aqueous samples, the maximum holding time
       for extraction is fourteen (14) days from sample collection, and the maximum holding time for
       analysis is forty (40) days from sample extraction.

D.  Evaluation:

    Technical holding times for sample extraction are established by comparing the sample collection
    date on the TR/COC Record with the dates of extraction on Form I PEST and the sample extraction
    sheets. Information contained in the Complete SDG File (CSF) should also be considered in the
    determination of holding times. To determine if the samples were analyzed within the holding time
    after extraction, compare the dates of extraction on the sample extraction sheets with the dates of
    analysis  on Form I PEST. Verify that the analysis dates in Form I(s) and the raw data/SDG file are
    identical.

    Review the SDG Narrative and the TR/COC Record to determine if the samples were received intact
    and iced. If there is no indication in the SDG Narrative, the TR/COC Record, or the sample records
    that there was a problem with the samples, assume the integrity of the samples is acceptable.  If it is
    indicated that there were problems with the samples, the integrity of the sample may have been
    compromised.  Use professional judgment to evaluate the effect of the problem on the sample results.
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                                                                      Pesticides Organic Analysis
E.  Action:

    1.  Qualify aqueous sample results using preservation and technical holding time information as
       follows (see Table 40):

       a.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed within the technical holding times
           [seven (7) days from sample collection for extraction; forty (40) days  from sample collection
           for analysis], use professional judgment to qualify the data.

       b.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed outside the technical holding
           times [seven (7) days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       c.  If the samples were properly preserved, and were extracted and analyzed within the technical
           holding times  [seven (7) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were extracted or analyzed outside the technical
           holding times  [seven (7) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], qualify detects with a "J" and non-detects as estimated with
           an approximated "UJ" or unusable "R".  Note in the Data Review Narrative that holding times
           were exceeded and the effect of exceeding the holding time on the resulting data.

    2.  Qualify non-aqueous sample results using preservation and technical holding time  information as
       follows (see Table 40):

       a.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed within the technical holding times
           [fourteen (14)  days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       b.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed outside the technical holding
           times [fourteen (14) days from sample collection; forty (40) days from sample  collection for
           analysis], use professional judgment to qualify the data.

       c.  If the samples were properly preserved, and were extracted and analyzed within the technical
           holding times  [fourteen (14) days from sample collection; forty (40) days from sample
           collection for analysis], no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were extracted or analyzed outside the technical
           holding times  [fourteen (14) days from sample collection; forty (40) days from sample
           collection for analysis], qualify detects with a "J" and non-detects as estimated with an
           approximated  "UJ" or unusable "R". Note in the Data Review Narrative that holding times
           were exceeded and the effect of exceeding the holding time on the resulting data.
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    3.  If technical holding times are grossly exceeded, qualify all detects as estimated with a "J" and use
       professional judgment to qualify sample non-detects.

    4.  Note in the Data Review Narrative, whenever possible, the effect of exceeding the holding time
       on the resulting data.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, when technical holding
       times are grossly exceeded.

                     Table 40. Holding Time Actions for Pesticide Analyses
Matrix
Aqueous
Non-aqueous
Preserved
No
No
Yes
Yes
Yes/No
No
No
Yes
Yes
Yes/No
Criteria
< 7 days (for extraction) and
< 40 days (for analysis)
> 7 days (for extraction) and
> 14 days (for analysis)
< 7 days (for extraction) and
< 40 days (for analysis)
> 7 days (for extraction) and
> 40 days (for analysis)
Grossly Exceeded
< 14 days (for extraction) and
< 40 days (for analysis)
> 14 days (for extraction) and
> 40 days (for analysis)
< 14 days (for extraction) and
< 40 days (for analysis)
> 14 days (for extraction) and
> 40 days (for analysis)
Grossly Exceeded
Action
Detected
Associated
Compounds
Non-Detected
Associated
Compounds
Use professional judgment
Use professional judgment
No qualification
J
J
UJ
UJorR
Use professional judgment
Use professional judgment
No qualification
J
J
UJ
UJorR
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                                                                   Pesticides Organic Analysis
               II. Gas Chromatograph with Electron Capture Detector (GC/ECD)
                               Instrument Performance Check
A.  Review Items:

    Form VI PEST-5, Form VI PEST-6, Form VI PEST-7, Form VI PEST-8, Form VI PEST-9, Form VI
    PEST-10, Form VII PEST-1, chromatograms, and data system printouts.

B.  Objective:

    GC/ECD instrument performance checks are performed to ensure adequate resolution and instrument
    sensitivity. These criteria are not sample-specific. Conformance is determined using standard
    materials, therefore, these criteria should be met in all circumstances.

C.  Criteria:

    1.  Resolution Check Mixture

       a.   The Resolution Check Mixture is analyzed at the beginning of every initial calibration
           sequence, on each Gas Chromatograph (GC) column and instrument used for analysis.  The
           Resolution Check Mixture contains the following pesticides and surrogates (see Table 41):

                       Table 41.  Resolution Check Mixture Components
Compounds
gamma-Chlordane
Endosulfan I
4,4'-DDE
Dieldrin
Endosulfan sulfate
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC
Aldrin
Heptachlor
Endrin ketone
Methoxychlor
Endosulfan II
Heptachlor-epoxide
alpha-Chlordane
4,4'-DDD
4,4'-DDT
Endrin
Endrin aldehyde
Tetrachloro-m-xylene (surrogate)
Decachlorobiphenyl (surrogate)
       b.  The resolution between two adjacent peaks in the Resolution Check Mixture must be greater
           than or equal to 80.0% for all analytes for the primary column and greater than or equal to
           50.0% for the confirmation column in order to use one Individual Standard Mixture (C).  If
           two Individual Standard Mixtures (A and B) are to be used, the resolution between two
           adjacent peaks in the Resolution Check Mixture must be greater than or equal to 60.0%.
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                                                                    Pesticides Organic Analysis
    2.  Performance Evaluation Mixture (PEM)

       a.  The PEM is analyzed at the beginning (following the Resolution Check Mixture) and at the
           end of the initial calibration sequence.  The PEM analysis must bracket one end of each 12-
           hour analytical period.  The PEM contains the following pesticides and surrogates (see
           Table  42):

                 Table 42. Performance Evaluation Mixture (PEM) Components
Compounds
gamma-BHC
alpha-BHC
4,4'-DDT
beta-BHC
Endrin
Methoxychlor
Tetrachloro-m-xylene (surrogate)
Decachlorobiphenyl (surrogate)
       b.  The resolution between any two adjacent peaks in the initial calibration and continuing
           calibration verification PEMs must be greater than or equal to 90% on each GC column.

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

           i.  The Percent Breakdown of 4,4'-DDT and Endrin in the PEMs must each be less than or
              equal to 20.0% on each GC column.

           ii.  The combined Percent Breakdown for 4,4'-DDT and Endrin in PEMs must be less than or
              equal to 30.0% on each GC column.

    3.  Mid-point Individual Standard Mixtures (A and B) or (C)

       a.  The resolution capabilities of the GC/ECD system used will dictate whether two Individual
           Standard Mixtures (A and B) (see Table 43) or one Individual Mixture (C) (see  Table 44) can
           be used. This is determined by the analysis of the Resolution Check Mixture to see if the
           criteria in II.C. l.b are met.  If Individual Standard Mixtures (A and B) are used, follow the
           procedure in 3b.  If Individual Standard Mixture (C) is used, follow the procedure in 3c.

       b.  Mid-point Individual Standard Mixtures (A and B)

           i.  The mid-point Individual Standard Mixtures (A and B; INDA/INDB) are analyzed as part
              of the initial calibration. The mid-point INDA and INDB analysis must bracket one end
              of each 12-hour analytical period. The Individual Standard Mixtures contain the
              following pesticides and surrogates:
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                  Table 43. Individual Standard Mixtures A and B Components
Individual Standard Mixture A
Individual Standard Mixture B
Compounds
alpha-BHC
Heptachlor
gamma-BHC
Endosulfan I
Dieldrin
Endrin
4,4'-DDD
4,4'-DDT
Methoxychlor
Tetrachloro-m-xylene (surrogate)
Decachlorobiphenyl (surrogate)


beta-BHC
delta-BHC
Aldrin
Heptachlor-epoxide
alpha-Chlordane
gamma-Chlordane
4,4'-DDE
Endosulfan sulfate
Endrin aldehyde
Endrin ketone
Endosulfan II
Tetrachloro-m-xylene (surrogate)
Decachlorobiphenyl (surrogate)
           ii.  The resolution between any two adjacent peaks in the mid-point concentration of
               Individual Standard Mixtures (A and B) in the initial calibration and continuing
               calibration verification must be greater than or equal to 90.0% on each column.

       c.  Mid-point Individual Standard Mixture (C)

           i.   The mid-point Individual Standard Mixture (C; INDC) is analyzed as part of the initial
               calibration. The mid-point INDC analysis must bracket one end of each 12-hour
               analytical period. The Individual Standard Mixture (C) contains the pesticides and
               surrogates listed in Table 44.

           ii.  The resolution between any two adjacent peaks in the mid-point concentration of
               Individual Standard Mixture (C) in the initial calibration and continuing calibration
               verification must be greater than or equal to 80.0% for the primary column and greater
               than or equal to 50.0% for the secondary column.
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                     Table 44. Individual Standard Mixture C Components
Compounds
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC
Aldrin
Heptachlor
Heptachlor-epoxide
alpha-Chlordane
gamma-Chlordane
Endosulfan I
Endosulfan II
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dieldrin
Endrin
Endosulfan sulfate
Endrin ketone
Endrin aldehyde
Methoxychlor
Tetrachloro-m-xylene
Decachlorobiphenyl
D.  Evaluation:

    1.  Resolution Check Mixture

       Check the Resolution Check Mixture data and Form VI PEST-5 to verify that if two Individual
       Standard Mixtures (A and B) are used, the resolution between two adjacent peaks for the required
       compounds in the Resolution Check Mixture is greater than or equal to 60.0% on both GC
       columns. Verify that if one Individual Standard Mixture (C) is used, the resolution between two
       adjacent peaks for the required compounds in the Resolution Check Mixture is greater than or
       equal 80.0% on the primary column and greater than or equal to 50.0% on the secondary column.
    2.  PEM
       b.
Check the initial calibration and continuing calibration verification PEM data and Form VI
PEST-6 to verify that the resolution between adjacent peaks is greater than or equal to 90.0%
on both GC columns.

Check Form VII PEST-1 to verify that the breakdown of 4,4'-DDT is less than or equal to
20.0%, the breakdown of Endrin is less than or equal to 20.0%, and the combined breakdown
of 4,4'-DDT and Endrin is less than or equal to 30.0% in all PEMs on both GC columns.
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    3.  Mid-point Individual Standard Mixtures (A and B)

       Check the initial calibration and continuing calibration verification mid-point Individual Standard
       Mixtures  (A and B) data on Form VI PEST-7 and Form VI PEST-8 to verify that the resolution
       between adjacent peaks is greater than or equal to 90.0% on both GC columns.

    4.  Mid-point Individual Standard Mixture (C)

       Check the initial calibration and continuing calibration verification mid-point Individual Standard
       Mixture (C) data on Form VI PEST-9 and Form VI PEST-10 to verify that the resolution between
       adjacent peaks is greater than or equal to 80.0% for the primary column and 50.0% for the
       secondary column.

       NOTE:   For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  Resolution Check Mixture

       a.  If resolution criteria are not met, the quantitative results may not be accurate due to
           inadequate resolution.  Qualitative identifications may also be questionable if coelution
           exists.

           i.   Qualify detects for target compounds that were not adequately resolved with an "NJ" (see
               Table 45).

           ii.  Qualify non-detected compounds as unusable "R".

    2.  PEM

       a.  If PEM analysis is not performed at the required frequency (see Pesticides Organic Analysis,
           Section II.C.2.a), qualify all associated sample and blank results as unusable "R".

       b.  If PEM resolution criteria are not met, the quantitative results may not be accurate due to
           inadequate resolution.  Qualitative identifications may be questionable if coelution exists.

           i.   Qualify detects with an "NJ".

           ii.  Qualify non-detects as unusable "R".

       c.  If 4,4'-DDT breakdown is greater than 20.0%:

           i.   Qualify detects for 4,4'-DDT with a "J".

           ii.  Qualify detects for 4,4'-DDD and/or 4,4'-DDE with a "J".
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           iii.  If 4,4'-DDT was not detected, but 4,4'-DDD and/or 4,4'-DDE were detected, qualify
               non-detects for 4,4'-DDT as unusable "R", and qualify detects for 4,4'-DDD and/or
               4,4'-DDE as presumptively present at an approximated quantity "NJ".

       d.  If Endrin breakdown is greater than 20.0%:

           i.   Qualify detects for Endrin with a "J".

           ii.  Qualify detects for Endrin aldehyde and/or Endrin ketone with a "J".

           iii.  If Endrin was not detected, but Endrin aldehyde and/or Endrin ketone were detected,
               qualify the non-detects for Endrin as unusable "R", and qualify detects for Endrin
               aldehyde and/or Endrin ketone as presumptively present at an approximated quantity
               "NJ".

       e.  If the combined 4,4'-DDT and Endrin breakdown is greater than 30.0%, the reviewer should
           consider the degree of individual breakdown of 4,4'-DDT and Endrin and apply qualifiers as
           described in this section.

    3.  Mid-point Individual Standard Mixtures (A and B) or (C)

       a.  If mid-point Individual Standard Mixture analysis is not performed at the required frequency
           (see Pesticides Organic Analysis, Sections II.C.3.b and II.C.3.c), qualify all associated sample
           and blank results as unusable "R".

       b.  If mid-point Individual Standard Mixtures (A and B) or (C) resolution criteria are not met, the
           quantitative results may not be accurate due to inadequate resolution. Qualitative
           identifications may be questionable if coelution exists.

           i.   Qualify detected target compounds that were not adequately resolved with an "NJ".

           ii.  Qualify non-detects as unusable "R".

    4.  Note in the Data Review Narrative the potential effects on the sample data resulting from the
       instrument performance  check criteria. Notify the Contract Laboratory Program Project Officer
       (CLP PO) if the laboratory has repeatedly failed to comply with the requirements for linearity,
       resolution, or 4,4'-DDT/Endrin breakdown.
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                                                                     Pesticides Organic Analysis
             Table 45.  Gas Chromatograph with Electron Capture Detector (GC/ECD)
                             Instrument Performance Check Actions
      Criteria
[(Individual Standard
 Mixtures (A and B)]
                Criteria
    (Individual Standard Mixture C)
           Action
Resolution Check
Mixture
% Resolution <60.0%
Resolution Check Mixture
% Resolution <80.0% (primary column)
% Resolution <50.0% (secondary column)
Detects: NJ
Non-detects: R
(Use professional judgment)
PEM % Resolution <90.0%
                                          Detects: NJ
                                          Non-detects: R
                                          (Use professional judgment)
PEM: 4,4'-DDT % Breakdown >20.0% and 4,4'-DDT is detected
                                          Detects for 4,4'-DDT: J
                                          Detects for 4,4'-DDD: J
                                          Detects for 4,4'-DDE: J
PEM: 4,4'-DDT % Breakdown >20.0% and 4,4'-DDT is not detected
                                          Non-detects for 4,4'- DDT: R
                                          Detects for 4,4'-DDD: NJ
                                          Detects for 4,4'-DDE: NJ
PEM: Endrin % Breakdown >20.0% and Endrin is detected
                                          Detects for Endrin: J
                                          Detects for Endrin aldehyde: J
                                          Detects for Endrin ketone: J
PEM: Endrin % Breakdown >20.0% and Endrin is not detected
                                          Non-detects for Endrin: R
                                          Detects for Endrin aldehyde:
                                          NJ
                                          Detects for Endrin ketone: NJ
PEM: Combined % Breakdown >30%
                                          Apply qualifiers as described
                                          above considering degree of
                                          individual breakdown.
Mid-point Individual
Standard Mixtures
(A and B)
 % Resolution <90.0%
Mid-point Individual Standard Mixture (C)
 % Resolution <80.0% (primary column)

Mid-point Individual Standard Mixture (C)
% Resolution <50.0% (secondary column)
Detects: NJ
Non-detects: R
(Use professional judgment)
PEM analysis not performed at the required frequency
(see Pesticides, Section II.C.2.a.)
                                          All results: R
Mid-point Individual Standard Mixtures analysis not performed at the
required frequency (see Pesticides, Sections Il.C.S.b.l and II.C.S.c.l)
                                          All results: R
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                                                                    Pesticides Organic Analysis
                                    III.  Initial Calibration

A.  Review Items:

    Form VI PEST-1, Form VI PEST-2, Form VI PEST-3, Form VI PEST-4, chromatograms, and data
    system printouts.

B.  Objective:

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

C.  Criteria:

    1.  Individual Standard Mixtures (A and B) or (C) (containing all of the pesticides and surrogates)
       must be analyzed at five concentration levels during the initial calibration, on each Gas
       Chromatograph (GC) column and instrument used for analysis.

       a.   The Mean Retention Times (RTs) of each of the Single Component Pesticides (SCPs) and
           surrogates are determined from the five-point initial calibration.  The Retention Time (RT)
           for the surrogates is measured from each Individual Standard Mixtures (A and B).

       b.   An RT Window must be calculated for each single component analyte and surrogate
           according to SOM01.0. Exhibit D - Pesticides, Table 1 - Retention Time Windows for Single
           Component Analytes, Toxaphene, and Surrogates, available at:

                       http://www.epa.gov/superfund/programs/clp/soml.htm

           NOTE:     At least one chromatogram from each of the Individual Standard Mixtures
                      (A and B) or (C) must yield peaks that give recorder deflections between 50-
                      100% of full scale.

       c.   The five concentration level standards containing all of the Single Component Pesticides
           (SCPs) and surrogates should be prepared in either two mixtures (A and B) or one mixture
           (C) at the following concentration levels listed in Table 46.
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                    Table 46. Concentration Levels of Calibration Standards
Compound
alpha-BHC
gamma-BHC
Heptachlor
Endosulfan I
Dieldrin
Endrin
4,4'-DDD
4,4'-DDT
Methoxychlor
beta-BHC
delta-BHC
Aldrin
Heptachlor-epoxide
4,4'-DDE
Endosulfan II
Endosulfan sulfate
Endrin ketone
Endrin aldehyde
alpha-Chlordane
gamma-Chlordane
Tetrachloro-m-xylene
Decachlorobiphenyl
Toxaphene
Concentration (ng/mL)
CS1
5.0
5.0
5.0
5.0
10
10
10
10
50
5.0
5.0
5.0
5.0
10
10
10
10
10
5.0
5.0
5.0
10
500
CS2
10
10
10
10
20
20
20
20
100
10
10
10
10
20
20
20
20
20
10
10
10
20
1000
CS3
20
20
20
20
40
40
40
40
200
20
20
20
20
40
40
40
40
40
20
20
20
40
2000
CS4
40
40
40
40
80
80
80
80
400
40
40
40
40
80
80
80
80
80
40
40
40
80
4000
CSS
80
80
80
80
160
160
160
160
800
80
80
80
80
160
160
160
160
160
80
80
80
160
8000
           d.  Mean Calibration Factor (CF) must be calculated for each single component analyte and
              surrogate over the initial calibration range.

           e.  The Percent Relative Standard Deviation (%RSD) of the Calibration Factors (CFs) for
              each of the single component target compounds must be less than or equal to 20.0%,
              except for alpha-BHC and delta-BHC.  The %RSD of the CFs for alpha-BHC and delta-
              BHC must be less than or equal to 25.0%.  The %RSD of the CFs for the two surrogates
              (tetrachloro-m-xylene and decachlorobiphenyl) must be less than or equal to 30.0%.
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              NOTE:
Either peak area or peak height may be used to calculate the CFs that are, in
turn, used to calculate %RSD. However, the type of peak measurement used
to calculate each CF for a given compound must be consistent.  For example,
if peak area is used to calculate the low-point CF for Endrin, the mid-point
and high-point CFs for Endrin must also be calculated using peak area.
    2.  Toxaphene
       a.  Toxaphene must be analyzed separately at a minimum of five different concentration levels
           during the initial calibration sequence. The analysis of Toxaphene compounds must also
           contain the pesticide surrogates.

       b.  For each Toxaphene, the Retention Times (RTs) are determined for three to five peaks. The
           peaks chosen must not share the same RT Window as any SCP in any Individual Standard
           Mixture.  The RT Window is calculated as ±0.07 minutes around the Absolute RTs.

       c.  A CF must be determined for each peak selected for Toxaphene.

       d.  The %RSD of the CFs for each of the Toxaphene peaks must be less than or equal to 30.0%;
           the %RSD of the CFs for the two surrogates (tetrachloro-m-xylene and decachlorobiphenyl)
           must be less than or equal to 30.0%.

       e.  The five concentration level standards containing Toxaphene and surrogates should be
           prepared at the concentration levels listed in Table 46.

    3.  Initial Calibration Sequence

       The initial calibration must be  performed following a specific sequence, depending upon whether
       one Individual Standard Mixture (C) (Initial Calibration Sequence 1) (see Table 47) or two
       Individual Standard Mixtures (A and B)  (Initial Calibration  Sequence 2) are used (see Table 48).

                            Table 47. Initial Calibration Sequence 1
Initial Calibration Sequence 1
1.
2.
3.
4.
5.
6.
7.
Resolution Check
Performance Evaluation Mixture (PEM)
Toxaphene CS1
Toxaphene CS2
Toxaphene CS3
Toxaphene CS4
Toxaphene CSS
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                       Table 47. Initial Calibration Sequence 1 (CON'T)
Initial Calibration Sequence 1
8. CS 1 Individual Standard Mixture C
9.
10.
11.
12.
13.
14.
CS2 Individual Standard Mixture C
CSS Individual Standard Mixture C
CS4 Individual Standard Mixture C
CSS Individual Standard Mixture C
Instrument Blank
PEM
                           Table 48.  Initial Calibration Sequence 2
Initial Calibration Sequence 2
1.
2.
3.
4.
5.
6.
7.
Resolution Check
Performance Evaluation Mixture (PEM)
Toxaphene CS1
Toxaphene CS2
Toxaphene CS3
Toxaphene CS4
Toxaphene CSS
8. CS1 Individual Standard Mixture A
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
CS1 Individual Standard Mixture B
CS2 Individual Standard Mixture A
CS2 Individual Standard Mixture B
CS3 Individual Standard Mixture A
CS3 Individual Standard Mixture B
CS4 Individual Standard Mixture A
CS4 Individual Standard Mixture B
CSS Individual Standard Mixture A
CSS Individual Standard Mixture B
Instrument Blank
PEM
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    NOTE:     For Initial Calibration Sequence 2, Individual Standards for Mixture B may be analyzed
               before corresponding Individual Standards for Mixture A.

D.  Evaluation:

    For SCPs, follow the procedure in D. 1 if either two Individual Standard Mixtures (A and B) or one
    Individual Standard Mixture (C) are used. For Toxaphene, follow the procedure in Pesticides
    Organic Analysis, Section III.D.2.

    1.  Individual Standard Mixtures (A and B) or (C)

       a.  Check the raw data (chromatograms and data system printouts) for each standard to verify
          that each of the standards was analyzed at the required concentration levels.

       b.  Check the Individual Standard Mixtures (A and B) data and Form VIPEST-1 and review the
           calculated RT Windows for calculation and transcription errors.
       c.  Check the chromatograms and verify that at least one chromatogram from each of the
           Individual Standard Mixtures (A and B) or (C) yields peaks registering recorder/printer
           deflections between 50-100% of full scale.

       d. Verify that the concentrations of the five standards of Individual Standard Mixtures
           (A and B) or (C) meet the criteria defined in Pesticides Organic Analysis, Section Ill.C.l.d.

       e.  Check the Individual Standard Mixtures (A and B) or (C) data and Form VI PEST-2 to verify
          that the %RSD for the CFs are in compliance with the criteria defined in Pesticides Organic
          Analysis, Section III.C.

       f  Check and recalculate the CFs, CFs and %RSD for one or more pesticides in Individual
           Mixtures (A and B) or (C). Verify that the recalculated values agree with the reported values.
           If errors are detected, perform a more comprehensive recalculation and review.

    2.  Toxaphene

       a.  Check the raw data for the standards to verify that Toxaphene was analyzed at the required
           concentration.

       b.  Check the data for Toxaphene and Form VI PEST-3 to verify that at least three peaks were
          used for identification, and RT Windows were calculated as required. Verify that the peaks
           chosen do not share the same RT Window as any SCP in any Individual Standard Mixture.

       c.  Check the data to verify that CFs have been determined for each selected peak.

       d.  Check the chromatograms and verify that at least one chromatogram from each of the
           Toxaphene standards yields peaks registering recorder/printer deflections between 50-100%
           of full scale.

       e. Verify that the concentrations of the Toxaphene standards meet the criteria defined in
           Pesticides Organic Analysis, Section Ill.C.l.d.

       f.  Check the Toxaphene data and Form VI PEST-4 to verify that the %RSD for the CFs are in
           compliance with the criteria defined in Pesticides Organic Analysis, Section III.C.
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       g.  Check and recalculate the CFs, CFs, and %RSD for one or more Toxaphene peaks. Verify
           that the recalculated values agree with the reported values. If errors are detected, perform a
           more comprehensive recalculation and review.

    3.  Initial Calibration Sequence

       a.  Verify that the proper initial calibration sequence (1 or 2) is used depending on if one (C) or
           two Individual Standard Mixtures (A and B) are used.

       b.  Verify that the steps of initial calibration is followed in the proper sequence.

           NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the Contract Compliance Screening (CCS)
                      process.  Information regarding the laboratory's compliance with these criteria
                      can be obtained from the Data Assessment Tool (DAT) reports, and may be used
                      as part of the evaluation process.

E .  Action:

    1.  If the proper initial calibration  sequence is not performed or the steps of the initial calibration are
       not followed in the proper sequence, use professional judgment to evaluate the effect on the data
       and notify the Contract Laboratory Program Project Officer (CLP PO) (see Table 49).  This is
       especially critical for the low-level standards and non-detects.

    2.  If RT Windows are not calculated correctly, recalculate the windows and use the corrected values
       for all evaluations.

    3.  If the chromatogram display (recorder deflection) criteria are not met, use professional judgment
       to evaluate the effect on the data.

    4.  If the standard concentration criteria are not met, use professional judgment to evaluate the  effect
       on the data and notify the CLP PO. This is especially critical for the low-level standards and non-
       detects.

    5.  If the %RSD criteria are not met, qualify detects with a "J" and use professional judgment to
       qualify non-detected target compounds.

    6.  If the %RSD criteria are within allowable limits, no qualification of the data is necessary.

    7.  At the reviewer's discretion, and based on the project-specific data quality objectives, consider a
       more in-depth review using the following guidelines:

       a.  If any pesticide target compound has a %RSD greater than the maximum criterion, and if
           eliminating either the high or the low-point of the curve does not restore the %RSD to less
           than or equal to the required maximum:

           i.   Qualify detects for that compound(s) with a "J".

           ii.  Qualify non-detected pesticide target compounds using professional judgment.

       b.  If the high-point of the curve is outside of the linearity criteria (e.g., due to saturation):
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           i.   No qualifiers are required for detects in the linear portion of the curve.

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

           iii.  No qualifiers are required for pesticide target compounds that were not detected.

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

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

           ii.  Qualify low-level detects in the area of non-linearity with a "J".

           iii.  For non-detected pesticide compounds, use the lowest point of the linear portion of the
               curve to determine the new quantitation limit.

    8.  Note in the Data Review Narrative potential effects on the sample data due to problems with
       calibration. Notify the CLP PO if the laboratory has repeatedly failed to comply with the
       requirements for frequency, linearity, RT, or resolution.

    9.  Qualify data for Toxaphene sharing the same RT Window with  any SCP in any Individual
       Standard Mixture using professional judgment.

                   Table 49. Initial Calibration Action for Pesticide Analyses
Criteria
Initial calibration is not performed or not
performed in the proper sequence
%RSD exceeds allowable limits*
%RSD within allowable limits*
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
Use professional judgment
J
Use professional judgment
No qualification
    * %RSD < 20.0% for single component target compounds except alpha-BHC and delta-BHC.
     %RSD < 25.0% for alpha-BHC and delta-BHC.
     %RSD < 30.0% for Toxaphene peaks.
     %RSD < 30.0% for surrogates (tetrachloro-m-xylene and decachlorobiphenyl).
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                        IV.  Continuing Calibration Verification (CCV)

A.  Review Items:

    Form VII PEST-1, Form VII PEST-2, Form VII PEST-3, Form VII PEST-4, chromatograms, and
    data system printouts.

B.  Objective:

    Compliance requirements for satisfactory instrument calibration are established to ensure that the
    instrument is capable of producing acceptable qualitative and quantitative data. CCV checks and
    documents satisfactory performance of the instrument over specific time periods during sample
    analysis.  To confirm the calibration and evaluate instrument performance, continuing calibration
    verification is performed, consisting of the analyses of instrument blanks, the Performance Evaluation
    Mixture (PEM), and the mid-point concentration of Individual Standard Mixtures (A and B) or (C).
    A CCV must be performed at the beginning (opening CCV) and end (closing CCV) of the analytical
    sequence. The opening and closing CCVs consist of an injection of an instrument blank followed by
    either an injection of an PEM or mid-point concentration of Individual Standard Mixtures (A and B)
    or (C) in an alternating fashion [i.e. if the PEM is part of the opening CCV, the mid-point
    concentration of Individual  Standard Mixtures (A and B) or (C) must be part of the closing CCV].  A
    continuing calibration verification for Toxaphene is only required if Toxaphene is detected in a
    sample.

C.  Criteria:

    1.  The Absolute Retention Time (RT) for  each Single Component Pesticide (SCP) and surrogate in
       the PEM and the mid-point concentration of Individual Standard Mixtures (A and B) or (C) used
       for continuing calibration verification must be within the RT Windows determined from the
       initial calibration. If a continuing calibration verification is required for Toxaphene because of its
       detection in a sample, the Absolute RT  for each Toxaphene peak must be within the RT Windows
       determined from the initial calibration.

    2.  The Percent Difference  (%D) between the calculated amount and the nominal amount (amount
       added) for each of the SCP and surrogates in the PEM used for continuing calibration verification
       must be greater than or equal to -25.0% and less than or equal to 25.0%.

    3.  The Percent Difference  between the Calibration Factor (CF) for each of the SCP and surrogates in
       the Calibration Verification Standard (CSS) and the Mean Calibration Factor (CF) from the initial
       calibration must be greater than or equal to -20.0% and less than or equal to 20.0%.  If a
       continuing calibration verification is required for Toxaphene because of its detection in a sample,
       the Percent Difference between the CF  for each of the peaks used to identify Toxaphene in the
       Calibration Verification Standard (CSS) and the CF from the initial calibration must be greater
       than or equal to -20.0% and less than or equal to 20.0%.

    4.  No more than 14 hours may elapse from the injection of the instrument blank that begins an
       analytical sequence (opening CCV)  and the  injection of either a PEM or mid-point concentration
       of the Individual Standard Mixtures (A and B) or (C) that ends an analytical sequence (closing
       CCV).
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    5.  No more than 12 hours may elapse from the injection of the instrument blank that begins an
       analytical sequence (opening CCV) and the injection of the last sample or blank that is part of the
       same analytical sequence.

    6.  No more than 72 hours may elapse from the injection of the sample with a Toxaphene detection
       and the Toxaphene Calibration Verification Standard (CSS).

D.  Evaluation:

    1.  Check the data for each of the SCPs and surrogates in the PEM, the mid-point concentration of
       Individual Standard Mixtures (A and B) or (C), Form VII PEST-1, and Form VII PEST-2, Form
       VII PEST-3, to verify that the Absolute RTs are within the RT Windows. If a Toxaphene
       Calibration Verification is required, check the data for each Toxaphene peak and surrogates in the
       Toxaphene Calibration Verification Standard (CSS) and Form VII PEST-4 to verify that the
       Absolute RTs are within the RT Windows.

    2.  Check the data from the PEM, Form VII PEST-1, to verify that the Percent Difference between
       the calculated amount and the true amount for each of the pesticides and surrogates are within
       ±25.0%.

    3.  Check the data from the mid-point concentration of Individual Standard Mixtures (A and B) or
       (C), Form VII PEST-2, and Form VII PEST-3 to verify that the Percent Difference between the
       CF for each of the SCP and surrogates in the Calibration Verification Standard (CS3) and the  CF
       from the initial calibration are within the inclusive range of ±20.0%. If a continuing calibration
       verification is required for Toxaphene because of its detection in a sample, check the data from
       the mid-point concentration of Toxaphenes, Form VII PEST-4 and verify that the Percent
       Difference between the CF for each of the peaks used to identify Toxaphene in the Calibration
       Verification Standard (CS3) and the CF from the initial calibration are within the inclusive range
       of ±20.0%.

    4.  Check the length of time that has elapsed  from the beginning injection of the opening CCV
       (instrument blank) and the ending injection of the closing CCV [PEM or Individual Standard
       Mixtures (A and B) or (C)] to verify that no more than  14 hours has elapsed.

    5.  Check the length of time that has elapsed  from the beginning injection of the opening CCV
       (instrument blank) and the injection of the last sample or method blank to verify that no  more
       than 12 hours has elapsed.

    6.  If a continuing calibration verification is required for Toxaphene because of its detection in a
       sample, check the length of time that has elapsed from the injection of the sample with a
       Toxaphene detection and the Toxaphene Calibration Verification Standard (CS3) to verify that no
       more than 72 hours has elapsed.

       NOTE:    For data obtained from the  Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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E.  Action:

    1.  The RT Windows are used in qualitative identification.  If the standards do not fall within the RT
       Windows, carefully evaluate the associated sample results (see Table 50). All samples injected
       after the last in-control standard are potentially affected.

       a.  For non-detected target compounds in the affected samples, check to see if the sample
           chromatograms contain any peaks that are close to the expected RT Window of the pesticide
           of interest.

           i.   If no peaks are present, consider non-detected values to be valid and no qualification of
               the data is necessary.

           ii.  If any peaks are present close to the expected RT Window of the pesticide of interest, use
               professional judgment to qualify the non-detects as presumptively present "NJ".

       b.  For detected compounds in the affected samples, if the peaks are  within the RT Window, no
           qualification of the data is necessary.  However, if the peaks are close to the expected RT
           Window of the pesticide of interest, the reviewer may take additional  effort to determine if
           sample peaks represent the compounds of interest.

           For example, the reviewer can examine the data package for the presence of three or more
           standards containing the pesticide of interest that were run within the analytical sequence
           during which the sample was analyzed. If three or more such standards are present, the RT
           Window can be re-evaluated using the Mean Retention Times (RTs) of the standards.

           i.   If the peaks in the affected sample fall within the revised window, qualify detects as
               "NJ".

           ii.  If the reviewer cannot do anything with the data to resolve the problem of concern,
               qualify all non-detects as unusable "R".

    2.  For the PEM, if the Percent Difference is not within ±25.0% as defined in Pesticides  Organic
       Analysis, Section IV.C.2, qualify associated detects with a "J" and non-detects with an
       approximated "UJ".

    3.  For the Calibration Verification Standard (CSS), if the Percent Difference is not within ±20.0% as
       defined in Pesticides Organic Analysis, Section IV.C.3,  qualify associated detects with a "J" and
       non-detects  with an approximated "UJ".

    4.  If more than 14 hours has elapsed as defined in Pesticides Organic Analysis, Section IV.C.4,
       qualify all data as unusable "R".

    5.  If more than 12 hours has elapsed as defined in Pesticides Organic Analysis, Section IV.C.5,
       qualify all data as unusable "R".

    6.  If more than 72 hours has elapsed as defined in Pesticides Organic Analysis, Section IV.C.6,
       qualify all data as unusable "R".

    7.  If the Percent Difference, time elapsed, and RTs are within acceptable limits, no qualification of
       the data is necessary.
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    8.  Note in the Data Review Narrative potential effects on the sample data due to problems with
       calibration.
        Table 50.  Continuing Calibration Verification (CCV) Action for Pesticide Analyses
Criteria
RT out of RT window
Percent Difference not within limits as defined in
Pesticides, Sections IV. C. 2 and C.3
Time elapsed is greater than acceptable limits, as
defined in Pesticides, Sections IV.C.4, C.5, and C.6
Percent Difference, time elapsed, and RT are within
acceptable limits
Action
Detected
Associated
Compounds
Non-Detected
Associated
Compounds
Use professional judgment
(see Pesticides, Section IV.E.l)
J
UJ
R
No qualification
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                                                                     Pesticides Organic Analysis
                                           V. Blanks

A.  Review Items:

    Form I PEST, Form IV PEST, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.  Method Blanks

       A method blank must be extracted each time samples are extracted.  The number of samples
       extracted with each method blank shall not exceed 20 field samples  [excluding Matrix
       Spike/Matrix Spike Duplicate (MS/MSDs), Performance Evaluation (PE) samples, and
       Laboratory Control Samples (LCSs)].  In addition, a method blank shall be extracted by the same
       procedure used to extract samples and be analyzed on the same Gas Chromatograph/Electron
       Capture Detector (GC/ECD) system used to analyze associated samples.

    2.  Instrument Blanks

       An acceptable instrument blank must be run at the beginning and ending of an analytical
       sequence in which samples are  analyzed, immediately prior to the analysis of the Performance
       Evaluation Mixture (PEM) or mid-point Individual  Standard Mixtures (A and B) or (C), used for
       continuing calibration verification. All groups of acceptable sample analyses are to be preceded
       and followed by  acceptable instrument blanks.

    3.  Sulfur Cleanup Blanks

       A sulfur cleanup blank must be analyzed whenever part of a set of samples extracted together
       requires sulfur cleanup. If the entire set of samples associated with a method blank requires
       sulfur cleanup, the method blank also serves the purpose of a sulfur blank and no separate sulfur
       blank is required.

       The concentration of each target analyte in the method, sulfur cleanup, instrument, or field blanks
       must be less than its Contract Required Quantitation Limits (CRQL) listed in the method.
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D.  Evaluation:

    1.  Review the results of all associated blanks, Form I PEST, Form IV PEST, and raw data
       (chromatograms and data system printouts) to evaluate the presence of target or non-target
       analytes in the blanks.

    2.  Verify that a method blank analysis has been reported per Sample Delivery Group (SDG), per
       extraction batch, and per extraction procedure. The reviewer can use Form IV PEST to identify
       samples associated with each blank.

    3.  Verify that the method blank analysis(es) contains less than the CRQL of any target SCP or
       Toxaphene,  or any interfering peak.

    4.  Verify that the instrument blank analysis has been performed every 12 hours as the first analysis
       of the continuing calibration verification sequence. Evaluate the results from the various
       instrument blanks to verify that target analyte concentrations are less than the CRQL (assuming a
       1 L extraction of a aqueous sample).

    5.  Verify that the sulfur cleanup blanks were analyzed at the required frequency and the sulfur
       blanks do not contain any target compounds greater than or equal to the CRQL (assuming a 1 L
       extraction of an aqueous sample). If a separate sulfur cleanup blank was prepared, one version of
       Form IV PEST should be completed associating all the samples with the method blank, and a
       second version of Form IV PEST should be completed listing only those samples associated with
       the separate  sulfur cleanup blank.

       NOTE:     For data obtained from the Contract Laboratory Program (CLP), the preceding
                   criteria are evaluated as part of the Contract Compliance Screening  (CCS) process.
                   Information regarding the laboratory's compliance with these criteria can be obtained
                   from the Data Assessment Tool (DAT) reports, and may be used as part of the
                   evaluation process. Data concerning the field blanks are not evaluated as part of the
                   CCS process. If field blanks  are present, evaluate this data in a similar fashion as the
                   method blanks.

E.  Action:

    Action regarding unsuitable blank results depends on the circumstances and the origin of the blank.
    In instances where more than one of the same type of blank is associated with a given sample, base
    qualification  upon a comparison with the associated blank having the highest concentration of a
    contaminant.  Do not correct the results by subtracting the blank value.

    1.  If a target SCP or Toxaphene is found in the blank but not found in the sample, no qualification is
       required  (see Table 51).

    2.  If a target SCP or Toxaphene concentration in a blank is less than the CRQL, and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    3.  If a target SCP or Toxaphene concentration in a blank is greater than the CRQL, and:


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       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b   the sample concentration is greater than or equal to the CRQL, and less than the blank
           concentration, report the concentration of the compound in the sample at the same
           concentration found in the blank with a "U", or the reviewer may elect to qualify the data as
           unusable "R".

       c.  the sample concentration is greater than or equal to the CRQL, and greater than or equal to
           the blank concentration, use professional judgment to qualify the data.

    4.  If a target pesticide compound or Toxaphene concentration in a blank is equal to the CRQL, and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    5.  If gross contamination exists (e.g., saturated peaks, "hump-o-grams"," junk" peaks), all affected
       compounds in the associated samples should be qualified as unusable  "R", due to interference.
       Note, for Contract Laboratory Program Project Officer (CLP PO) action, if the contamination is
       suspected of having an effect on the sample results.

    6.  There may be instances where little or no contamination was present in the associated blanks, but
       qualification of the sample is deemed necessary. If the reviewer determines that the
       contamination is from a source other than the sample, they should qualify the data.
       Contamination introduced through dilution is one example.  Although it is not always possible to
       determine, instances of this occurring can be detected when contaminants are found in the diluted
       sample result, but absent in the undiluted sample result.

    7.  If contaminants are found in the field blanks, the following is recommended:

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

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

       b.  If the field blank contains a pesticide Target Compound List (TCL) compound(s) at a
           concentration greater than or equal to the CRQL, and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii. the sample concentration is greater than or equal to the CRQL, but less than the blank
              concentration, report the concentration of the compound in the sample at the same
              concentration found in the blank and qualify with a "U", or use professional judgment to
              qualify the data as unusable "R".

           iii. the sample concentration is greater than the CRQL and greater than or equal to the blank
              concentration, use professional judgment to qualify the data.
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       c.   If gross contamination (e.g., saturated, "hump-o-grams", "junk" peaks) exists in the field
           blank, positive sample results may require rejection.  Qualify as unusable "R". Non-detected
           pesticide target compounds do not require qualification unless the contamination is so high
           that it interferes with the analyses of non-detected compounds.

       d.   If the field blank contains a pesticide TCL compound(s) at a concentration less than the
           CRQL and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, use professional judgment
              to qualify the data.

       e.   If the field blank contains a pesticide TCL compound(s) at a concentration equal to the CRQL
           and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, use professional judgment
              to qualify the data.

                         Table 51.  Blank Actions for Pesticide Analyses
Blank Type




Method,
Sulfur Cleanup,
Instrument
Field



Blank Result
Detects

< CRQL

>CRQL


- CRQL
Gross
contamination
Sample Result
Not detected
 CRQL
 CRQL and
< blank concentration
> CRQL and
> blank concentration
CRQL
Detects
Action for Samples
No qualification
Report CRQL value with a U
Use professional judgment
Report CRQL value with a U
Report the concentration for the
sample with a U, or qualify the data
as unusable R
Use professional judgment
Report CRQL values with a U
Use professional judgment
Qualify results as unusable R
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                                     VI. Surrogate Spikes

A.  Review Items:

    Form II PEST-1, Form II PEST-2, Form VIII PEST, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.  Two surrogate spikes, tetrachloro-m-xylene (TCX) and decachlorobiphenyl (DCB), are added to
       all samples, including Matrix Spike/Matrix Spike Duplicates (MS/MSDs), Laboratory Control
       Samples (LCSs) and blanks to measure their recovery.  The surrogates  are also added to all the
       standards to monitor Retention Times (RTs).

    2.  The recovery limits for the surrogates TCX and DCB are 30-150% for  all samples, including MS
       and MSDs, LCSs and all blanks.

    3.  The RTs of the  surrogates in each Performance Evaluation Mixture (PEM), mid-point Individual
       Standard Mixtures (A and B) or (C) used for continuing calibration verification, all samples
       (including MS and MSD, LCS), and all blanks must be within the calculated RT Windows. TCX
       must be within  ±0.05 minutes, and DCB must be within ±0.10 minutes of the Mean Retention
       Time (RT) determined from the initial calibration.

D.  Evaluation:

    1.  Check the raw data (e.g., chromatograms and data system printouts) to verify the recoveries on
       the Surrogate Recovery Form (Form II PEST).

       Check for any calculation or transcription errors; verify that the surrogate recoveries were
       calculated correctly using the equation in the method.

    2.  Check the raw data (e.g., chromatograms and data system printouts) to verify that the RTs on
       Form VIII PEST are accurate and within the RT Windows determined  from the initial calibration.

    3.  Whenever there are two or more analyses for a particular sample, the reviewer must determine
       which are the most accurate data to report. Considerations include, but are not limited to:

       a.   Surrogate recovery (marginal versus gross deviation).

       b.   Technical holding times.
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       c.  Comparison of the values of the target compounds reported in each sample analysis.

       d.  Other Quality Control (QC) information, such as surrogate recoveries and/or RTs in blanks
           and standards.

           NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the Contract Compliance Screening (CCS)
                      process.  Information regarding the laboratory's compliance with these criteria
                      can be obtained from the Data Assessment Tool (DAT) reports, and may be used
                      as part of the evaluation process.

E.  Action:

    If either surrogate spike recovery is outside the acceptance limits, the reviewer must consider the
    existence of coelution and interference in the raw data and use professional judgment to qualify data,
    as surrogate recovery problems may not directly apply to target analytes.

    1.  For any surrogate recovery greater than  200% (see Table 52):

       a.  Qualify detected target compounds as "J".

       b.  Use professional judgment to qualify non-detected target compounds.

    2.  For any surrogate recovery greater than  150% and less than or equal to 200%:

       a.  Qualify detected target compounds as a " J".

       b.  Do not qualify non-detected target compounds.

    3.  If both surrogate recoveries are greater than or equal to 30%, and less than or equal to 150%, no
       qualification of the data is necessary.

    4.  For any surrogate recovery greater than  or equal to 10%, and less than 30%:

       a.  Qualify detected target compounds as a " J".

       b.  Qualify non-detected target compounds as an approximated "UJ".

    5.  For any surrogate recovery less than 10%, the reviewer should examine the sample chromatogram
       to assess the qualitative validity  of the analysis. If low surrogate recoveries are from sample
       dilution, professional judgment should be used to determine if the resulting data should be
       qualified. If sample dilution  is not a factor:

       a.  Qualify detected target compounds as a " J".

       b.  Qualify non-detected target compounds as unusable "R".

    6.  In the special case of a blank analysis with surrogates out of specification, the reviewer must give
       special consideration to the validity of associated sample data. The basic concern is whether the
       blank problems represent an isolated problem with the blank alone, or whether there is  a
       fundamental problem with the analytical process. For example, if one or more samples in the


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       batch show acceptable surrogate recoveries, the reviewer may choose to consider the blank
       problem to be an isolated occurrence. Note, for Contract Laboratory Program Project Officer
       (CLP PO) action, analytical problems even if this judgment allows some use of the affected data.

    7.  If surrogate RTs in PEMs, Individual Standard Mixtures, samples, and blanks are outside of the
       RT Windows, the reviewer must use professional judgment to qualify data.

    8.  If surrogate RTs are within RT windows, no qualification of the data is necessary.
                       Table 52. Surrogate Actions for Pesticide Analyses
Criteria
%R > 200%
150%<%R<200%
30% < %R < 150%
10%< %R<30%
%R < 10% (sample dilution not a factor)
%R < 10% (sample dilution is a factor)
RT out of RT window
RT within RT window
Action*
Detected
Target Compounds
J
J
Non-detected
Target Compounds
Use professional judgment
No qualification
No qualification
J
J
UJ
R
Use professional judgment
Use professional judgment
No qualification
    Use professional judgment in qualifying data as surrogate recovery problems may not directly apply
    to target analytes.
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                                                                   Pesticides Organic Analysis
                     VII. Matrix Spike/Matrix Spike Duplicates (MS/MSDs)

A.  Review Items:

    Form III PEST-1, Form III PEST-2, chromatograms, and data system printouts.

    NOTE:    Data for MS and MSDs will not be present unless requested by the Region.

B.  Objective:

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

C.  Criteria:

    1.  If requested, MS and MSD samples are extracted and analyzed at a frequency of one MS and
       MSD per 20 or fewer field samples per sample matrix.

    2.  MS and MSD recoveries should be within the advisory limits provided on Form III PEST-1,
       Form III PEST-2.

    3.  Relative Percent Differences (RPDs) between MS and MSD recoveries must be within the
       advisory limits provided on Form III PEST-1 and Form III PEST-2.

D.  Evaluation:

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

    2.  Check the raw data and Form III PEST-1 and Form III PEST-2 to verify that the results for MS
       and MSD recoveries were calculated and transcribed correctly.

    3.  Check that the RPDs were calculated correctly.

       NOTE:    For data obtained from the Contract Laboratory Program  (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.
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E .  Action:

    1.  No qualification of the data is necessary on MS and MSB data alone. However, using informed
       professional judgment, the data reviewer may use the MS and MSB results in conjunction with
       other QC criteria to determine the need for some qualification of the data. Table 54 lists the
       pesticide target compounds that are spiked into samples to test for matrix effects. If any MS and
       MSB Percent Recovery or RPB in the pesticides fraction is out of specification, qualify data to
       include the consideration of the existence of interference  in the raw data. Considerations include,
       but are not limited to (see Table 53):

       a.  For any recovery or RPB greater than the upper acceptance limit:

           i.  Qualify detected spiked Single Component Pesticide (SCP) target compounds as a "J".

           ii.  Bo not qualify non-detected spiked SCP target compounds.

       b.  For any recovery greater than or equal to 20% and less than the lower acceptance limit:

           i.  Qualify detected spiked SCP target compounds as a "J".

           ii.  Qualify the sample quantitation limit for non-detected spiked SCP target compounds as
              approximated "UJ".

       c.  For any recovery less than 20%:

           i.  Qualify detected spiked SCP target compounds as a "J".

           ii.  Use professional judgment to qualify non-detected spiked SCP target compounds.

    2.  If recoveries and RPB are within acceptance limits, no qualification of the data is necessary.

    3.  The data reviewer should first try to determine to what extent the results of the MS and MSB
       affect the associated sample data. This determination should be made with regard to the MS and
       MSB sample itself, as well as specific analytes for all samples associated with the MS and MSB.

    4.  In those instances where it can be determined that the results of the MS and MSB affect only the
       sample spiked, limit qualification to this sample only. However, it may be determined through
       the MS and MSB results, that a laboratory is having a systematic problem in the analysis of one
       or more analytes that affects all associated samples. Use  professional judgment to qualify the
       data from all associated samples.

    5.  Use professional judgment to determine the need for qualification of detects of non-spiked
       compounds.

       NOTE:    Notify the Contract Laboratory Program Project Officer (CLP PO) if a field blank
                  was used for the MS and MSB, unless designated as such by the Region.
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     Table 53. Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Pesticide Analysis
Criteria
%R or RPD > Upper Acceptance Limit
20% <%R < Lower Acceptance Limit
%R < 20%
Lower Acceptance Limit <%R; RPD <
Upper Acceptance Limit
Action
Detected
Spiked Compounds
J
J
J
Non-detected
Spiked Compounds
No qualification
UJ
Use professional judgment
No qualification
          Table 54. Matrix Spike (MS) Recovery and Relative Percent Difference (RPD)
Compound
gamma-BHC (Lindane)
Heptachlor
Aldrin
Dieldrin
Endrin
4,4'-DDT
Percent
Recovery
Water
56- 123
40- 131
40 - 120
52 - 126
56- 121
38 - 127
RPD
Water
0- 15
0-20
0-22
0- 18
0-21
0-27
Percent
Recovery Soil
46 - 127
35- 130
34- 132
31- 134
42- 139
23 - 134
RPD
Soil
0-50
0-31
0-43
0-38
0-45
0-50
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                                                                  Pesticides Organic Analysis
                          VIII. Laboratory Control Samples (LCSs)
A.  Review Items:
    Form I PEST, Form II PEST-1, Form II PEST-2, Form III PEST-3, Form III PEST-4, LCS
    chromatograms, and data system printouts.

B.  Objective:

    Data for LCSs are generated to provide information on the accuracy of the analytical method and
    laboratory performance.

C.  Criteria:

    The LCS contains the pesticides target compounds and surrogates listed in Table 55.


  Table 55. Pesticides Laboratory Control Sample (LCS) Spike Compounds and Recovery Limits
LCS Spike Compound
gamma-BHC
Heptachlor epoxide
Dieldrin
4,4'-DDE
Endrin
Recovery
Limits (%)
50- 120
50- 150
30- 130
50- 150
50- 120
LCS Spike Compound
Endosulfan sulfate
gamma-Chlordane
Tetrachloro-m-xylene (surrogate)
Decachlorobiphenyl (surrogate)
Recovery
Limits (%)
50- 120
30-130
30- 150
30- 150

NOTES:   The recovery limits for any of the compounds in the LCS may be expanded at any time
           during the period of performance is USEPA determines that the limits are too restrictive.

           All samples prepared and analyzed with an LCS that does not meet the technical acceptance
           criteria in the method will require re-extraction and re-analysis.

D.  Evaluation:

    Check the raw data (e.g., chromatograms and data system printouts) to verify the recoveries on the
    Laboratory Control Sample Recovery Forms (Form III PEST-3, Form III PEST-4). For surrogate
    recoveries check the Surrogate Recovery Forms (Form II PEST-1, Form II PEST-2).

    Check for any calculation or transcription errors; verify that the LCS recoveries reported on Form II
    PEST-1, Form II PEST-2, Form III PEST-3, and Form III PEST-4 are within the Quality Control
    (QC) limits.
January 2005
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                                                                   Pesticides Organic Analysis
    NOTE:
For data obtained from the Contract Laboratory Program (CLP), the preceding criteria are
evaluated as part of the Contract Compliance Screening (CCS) process. Information
regarding the laboratory's compliance with these criteria can be obtained from the Data
Assessment Tool (DAT) reports, and may be used as part of the evaluation process.
E.  Action:
    If the LCS criteria are not met, laboratory performance and method accuracy are in question. Use
    professional judgment to determine if the data should be qualified or rejected.  The following
    guidance is suggested for qualifying sample data for which the associated LCS does not meet the
    required criteria.

    1.  If the  LCS recovery criteria are not met, use the LCS results to qualify sample data for the
       specific compounds that are included in the LCS solution (see Table 56).

       a.   If the LCS recovery exceeds the upper acceptance limit, qualify detected target compounds as
           a  "J". Do not qualify non-detected target compounds.

       b.   If the LCS recovery is less than the lower acceptance limit, qualify detected target
           compounds as a "J" and non-detects as unusable "R".

       c.   Use professional judgment to qualify data for compounds other than those compounds that
           are included in the LCS. Use professional judgment to qualify non-LCS compounds.  Take
           into account the compound class, compound recovery efficiency, analytical problems
           associated with each compound, and comparability in the performance of the LCS compound
           to the non-LCS compound.

    2.  If the  LCS recovery is within allowable limits, no qualification of the data is necessary.

    3.  Note,  for Contract Laboratory Program Project Officer (CLP PO) action, if a laboratory fails to
       analyze an LCS with each Sample Delivery Group (SDG), or if the reviewer has knowledge that a
       laboratory consistently fails to generate acceptable LCS recoveries.

                 Table 56.  Laboratory Control Sample (LCS) Recovery Actions
Criteria
%R > Upper Acceptance Limit
%R < Lower Acceptance Limit
Lower Acceptance Limit < %R < Upper
Acceptance Limit
Action
Detected
Associated Compounds
J
J
Non-Detected
Associated Compounds
No qualification
R
No qualification
January 2005
                               188
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                                                                   Pesticides Organic Analysis
                IX.  Regional Quality Assurance (OA) and Quality Control (OC)

A.  Review Items:

    Form I PEST, chromatograms, data system printouts, Traffic Report/Chain of Custody Record
    (TR/COC), quantitation reports and other raw data from Regional QA/QC samples.

B.  Objective:

    Regional QA/QC refers to any QA and/or QC samples initiated by the Region, including field
    duplicates, Performance Evaluation (PE) samples, blind spikes, and blind blanks.  The use of these
    QA/QC samples are highly recommended (e.g., the use of field duplicates can provide information on
    sampling precision and sample homogeneity).

C.  Criteria:

    Criteria are determined by each Region.

    1.  PE sample frequency may vary.

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

D.  Evaluation:

    1.  Evaluation procedures must follow the Region's Standard Operating Procedure (SOP) for data
       review.  Each Region will handle the evaluation of PE samples on an individual basis.  Compare
       results for PE samples to the acceptance criteria for the specific PE samples, if available.

    2.  Calculate Relative Percent Difference (RPD) between field duplicates. Provide this information
       in the Data Review Narrative.

E.  Action:

    Any action must be in accordance with Regional specifications and the criteria for acceptable PE
    sample results. Note, for Contract Laboratory Program Project Officer (CLP PO) action,
    unacceptable results for PE samples.
January 2005                                189                                   Draft Final

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                                                                     Pesticides Organic Analysis
                            X. Florisil Cartridge Performance Check

A.  Review Items:

    Form IX PEST-1, Florisil raw data, chromatograms, and data system printouts.

B.  Objective:

    The Florisil cartridge cleanup procedure is used to remove matrix interferences from sample extracts
    prior to analysis.  The use of the Florisil cartridge cleanup procedure significantly reduces matrix
    interferences caused by polar compounds. The performance of each lot of Florisil cartridges used for
    sample cleanup is checked by running a spiked reagent through a cartridge, and calculating the
    recoveries of the spiked compounds through the cartridge.

C.  Criteria:

    1.  The performance of each lot of Florisil cartridges used for sample cleanup must be checked at
       least once, or every six months, whichever is most frequent. The performance of the Florisil
       cartridges is checked with a spiking solution contain 2.4.5-trichlorophenol and the mid-point
       concentration of Individual Standard Mixture (A). If calibration with one standard mixture is
       used, the mid-point concentration of Individual Standard Mixture (C) may also be used.

    2.  The limits for recovery of the target pesticide compounds and surrogates in the Individual
       Standard Mixture (A) are 80-120%, and the recovery limit for 2,4,5-trichlorophenol is less than
       5%. If Individual Standard Mixture (C) is used, check the limits for recovery for the target
       compounds and surrogates present in the Individual Standard Mixture (A) only.

D.  Evaluation:

    1.  Check the raw data for the Florisil cartridge performance check analysis and the results on Form
       IX PEST-1.  Verify that  there are no calculation or transcription errors.

    2.  Verify that the percent recoveries of the target pesticides and surrogates in the performance check
       solution are within 80-120%, and the recovery of 2,4,5-trichlorophenol is less than 5%.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the  Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  If the Florisil Cartridge Performance Check criteria are not met, examine the raw data for the
       presence of polar interferences and  use professional judgment in qualifying the data as follows
       (see Table 57):

       a.   If the Percent Recovery is greater than 120% for any of the pesticide target compounds in the
           Florisil Cartridge Performance Check, use professional judgment to qualify detected target
           compounds. Do not qualify non-detected target compounds.
January 2005                                 190                                   Draft Final

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                                                                    Pesticides Organic Analysis
       b.  If the Percent Recovery is greater than or equal to 80% and less than or equal to 120% for all
           the pesticide target compounds, no qualification of the data is necessary.

       c.  If the Percent Recovery is greater than or equal to 10% and less than 80% for any of the
           pesticide target compounds in the Florisil Cartridge Performance Check, qualify detected
           target compounds with a "J" and non-detected target compounds with an approximated "UJ".

       d.  If the Percent Recovery is less than 10% for any of the pesticide target compounds in the
           Florisil Cartridge Performance Check, use professional judgment to qualify detected target
           compounds and qualify non-detected target compounds as unusable "R".

       e.  If the Percent Recovery of 2,4,5-trichlorophenol in the Florisil Cartridge Performance Check
           is greater than or equal to 5%, use professional judgment to qualify detected and non-detected
           target compounds, considering interference on the sample chromatogram.

    2.  Note in the Data Review Narrative potential effects on the sample data resulting from the Florisil
       Cartridge Performance Check analysis not yielding acceptable results.

                    Table 57. Florisil Cartridge Performance Check Actions
Criteria
%R > 120% (pesticide target compounds)
80% < %R < 120%
10% < %R< 80% (pesticide target compounds)
%R < 10% (pesticide target compounds)
%R> 5% (2,4,5-trichlorophenol)
Action
Detected
Associated
Compounds
Use professional
judgment
Non-Detected
Associated
Compounds
No qualification
No qualification
J
Use professional
judgment
UJ
R
Use professional judgment
January 2005
191
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                                                                    Pesticides Organic Analysis
                XL Gel Permeation Chromatography (GPC) Performance Check

A.  Review Items:

    Form IX PEST-2, GPC raw data, chromatograms, and data system printouts.

B.  Objective:

    GPC is used to remove high molecular weight contaminants that can interfere with the analysis of
    target analytes. GPC cleanup procedures are checked by adding the GPC calibration mixture to the
    GPC cleanup columns and setting the appropriate elution window, and verifying the recovery of
    target compounds through the cleanup procedure by the analysis of a cleanup blank.

C.  Criteria:

    1.  GPC is a mandatory cleanup method for non-aqueous samples and is an optional cleanup method
       for aqueous samples and sample extracts that contain high molecular weight components that
       interfere with the analysis of the target analytes.

    2.  At least once every seven (7) days, the calibration of the GPC unit must be checked by injecting
       with the GPC continuing calibration verification solution.

    3.  The GPC calibration is acceptable if the recovery of the pesticides in the GPC continuing
       calibration verification solution are within 80 to 110%.

       a.   Peaks must be observed and symmetrical for all compounds in the calibration solution.

       b.   Corn oil and the phthalate peaks exhibit greater than 85% resolution.

       c.   The phthalate and methoxychlor peaks exhibit greater than 85% resolution.

       d.   Methoxychlor and perylene peaks exhibit greater than 85% resolution.

       e.   Perylene and sulfur peaks must not be saturated and should exhibit greater than 90% baseline
           resolution.

       f   The Retention Time (RT) shift is less than 5% between  ultraviolet (UV) traces for bis (2-
           ethylhexyl) phthalate and perylene.

    4.  A GPC blank must be analyzed after each GPC calibration and is acceptable if the blank does not
       exceed the Contract Required Quantitation Limit (CRQL) for any target analytes listed in
       SOM01.0. Exhibit C - Pesticides, Target Component List and Contract Required Quantitation
       Limits, available at:

                       http://www.epa.gov/superfund/programs/clp/soml.htm.
January 2005                                 192                                   Draft Final

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                                                                    Pesticides Organic Analysis
D.  Evaluation:

    1.  Verify that there are two UV traces present and that the RT shift for bis(2-ethylhexyl) phthalate
       and perylene is less than 5%.

    2.  Verify that the compounds listed in Pesticides Organic Analysis, Section XI.C.3, are present and
       symmetrical in both UV traces and that the compound pairs meet the minimum resolution
       requirements.

    3.  Verify that no target compound in the GPC blank exceeds the CRQL.

    4.  Check the data from the GPC calibration check analyses and the Form IX PEST-2, and
       recalculate some of the  percent recoveries to verify that the percent recoveries of the pesticides in
       the matrix spike solution are within 80 to 110%.  The Region may devise other means to
       compare this information. Check to make sure that no transcription errors have occurred.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are  evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  If GPC criteria are not met, examine the raw data for the presence of high molecular weight
       contaminants. Examine the subsequent sample data for unusual peaks, and use professional
       judgment  in qualifying the data. Notify the Contract Laboratory Program Project Officer (CLP
       PO) if a laboratory chooses to analyze samples under unacceptable GPC criteria.

    2.  If the Percent Recovery is less than 10% for the pesticide compounds and surrogates during the
       GPC calibration check,  the non-detected target compounds may be suspect.  Use professional
       judgment to qualify the detected target compounds (see Table 58).  Qualify all non-detected
       target compounds as unusable "R".

    3.  If the Percent Recovery is greater than or equal to 10% and is less than 80% for any of the
       pesticide target compounds in the GPC calibration, qualify detected target compounds with a "J"
       and non-detected target compounds with an approximated  "UJ".

    4.  If the Percent Recovery is greater than or equal to 80% and less than or equal to 110% for all the
       pesticide target compounds, no qualification of the data is necessary.

    5.  If high recoveries (i.e., greater than 110%) were obtained forthe pesticides and surrogates during
       the GPC calibration check, use professional judgment to qualify detected target compounds. Do
       not qualify non-detected target compounds.

    6.  Note in the Data Review Narrative potential effects on the  sample data resulting from the GPC
       cleanup analyses not yielding acceptable results.
January 2005                                193                                  Draft Final

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                                                             Pesticides Organic Analysis
        Table 58. Gel Permeation Chromatography (GPC) Performance Check Actions
Criteria
%R < 10% (pesticide target compounds)
10%< %R<80%
80%< %R< 110%
%R > 110% (pesticide target compounds)
Action
Detected
Associated Compounds
Use professional judgment
J
Non-Detected
Associated Compounds
R
UJ
No qualification
Use professional judgment
No qualification
January 2005
194
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                                                                   Pesticides Organic Analysis
                             XII. Target Compound Identification

A.  Review Items:

    Form I PEST, Form X PEST-1, Form X PEST-2, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.  The Retention Times (RTs) of both of the surrogates and reported target compounds in each
       sample must be within the calculated RT Windows on both columns. Tetrachloro-m-xylene
       (TCX) must be within ±0.05 minutes of the Mean RT (RT) determined from the initial calibration
       and Decachlorobiphenyl (DCB) must be within ±0.10 minutes of the RT determined from the
       initial calibration.

    2.  The Percent Difference for the detected mean concentrations of a pesticide target compound
       between the two Gas Chromatograph (GC) columns must be within the inclusive range of ±25.0.

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

    4.  Chromatograms must display Single Component Pesticides (SCPs) detected in the sample and the
       largest peak of any multi-component analyte detected in the sample at less than full scale.

    5.  If an extract must be diluted, chromatograms must display SCPs peaks between 10-100% of full
       scale, and multi-component analytes between 25-100% of full scale.

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

    7.  If a chromatogram is replotted electronically to meet these requirements, the scaling factor used
       must be displayed on the chromatogram, and both the initial chromatogram and the replotted
       chromatogram must be submitted in the data package.

D.  Evaluation:

    1.  Review Form I PEST, the associated raw data (chromatograms and data system printouts) and
       Form X PEST-1 and Form X PEST-2. Confirm reported detected analytes by comparing the
       sample chromatograms to the tabulated results and verifying peak measurements and RTs.
       Confirm reported non-detected analytes by a review of the sample chromatograms. Check the
       associated blank data for potential interferences (to evaluate sample data for false positives) and
       check the calibration data for adequate RT Windows (to evaluate sample data for false positives
       and false negatives).
January 2005                                195                                   Draft Final

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                                                                    Pesticides Organic Analysis
    2.  For Toxaphene, compare the RTs and relative peak height ratios of major component peaks the
       appropriate standard chromatograms.

    3.  Compare the Toxaphene peaks identified in the sample to determine that the RTs do not overlap
       with the RTs of any SCPs or with chromatographic interferences from the sample matrix.

    4.  Check that the Percent Difference results were calculated correctly.

E.  Action:

    1.  If the qualitative criteria for both columns were not met, all target compounds that are reported as
       detected should be considered non-detected. The reviewer should use professional judgment to
       assign an appropriate quantitation limit using the following guidance:

       a.  If the detected target compound peak was sufficiently outside the pesticide RT Window, the
           reported values may be a false positive and should be replaced with the sample Contract
           Required Quantitation Limits (CRQL) value.

       b.  If the detected target compound peak poses an interference with potential detection of another
           target peak, the reported value should be considered and qualified as unusable "R".

    2.  If the data reviewer identifies a peak in both GC column analyses that falls within the appropriate
       RT Windows, but was reported as a non-detect, the compound may be a false negative. Use
       professional judgment to decide if the compound should be included. Note in the Data Review
       Narrative all conclusions made regarding target compound identification.

    3.  If the Toxaphene peak RT windows determined from the calibration overlap with SCPs or
       chromatographic interferences, use professional judgment to qualify the data.

    4.  If target compounds were detected on both GC columns, and the Percent Difference between the
       two results is greater than 25.0%, consider the potential for coelution and use professional
       judgment to decide whether a much larger concentration obtained on one column versus the other
       indicates the presence of an interfering  compound. If an interfering compound is indicated, use
       professional judgment to determine how best to report, and if necessary, qualify the  data.

    5.  If Toxaphene exhibits a marginal pattern-matching quality, use professional judgment to establish
       whether the differences are due to environmental "weathering" (i.e., degradation of the earlier
       eluting peaks relative to the later eluting peaks). If the presence of Toxaphene is strongly
       suggested, report results as presumptively present "N".
January 2005                                 196                                   Draft Final

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                                                                   Pesticides Organic Analysis
             XIII. Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation

A.  Review Items:

    Form I PEST, Form X PEST-1, Form X PEST-2, chromatograms, and data system printouts.

B.  Objective:

    If GC/MS confirmation is required by the Region for all detected Single Component Pesticides
    (SCPs) and Toxaphene that have at least one individual peak with a sufficient on-column
    concentration on both columns (greater than or equal to 5.0 ng/(iL for SCPs and 125 ng/(iL for
    Toxaphene), GC/MS confirmation for purposes of qualitative identification is required. GC/MS
    confirmation may be accomplished by one of three general means:

    1.  Examination of the semivolatile GC/MS library search results [i.e., Tentatively Identified
       Compound (TIC) data]

    2.  A second analysis of the semivolatile  extract; or

    3.  Analysis of the Aroclor extract, following  any solvent exchange and concentration steps that may
       be necessary.

C.  Criteria:

    The on-column concentration for any individual peak must be greater than or equal to 5.0 ng/(iL for
    SCPs and greater than or equal to 125 ng/(iL for Toxaphene on both GC columns.

D.  Evaluation:

    1.  Review Form I PEST, the  associated raw data (chromatograms and data system printouts) and
       Form X PEST-1 and Form X PEST-2. Confirm that GC/MS confirmation was required by
       ensuring that an individual peak has an on-column concentration greater than or equal to 5.0
       ng/(iL for a SCP and greater than or equal  to 125 ng/(iL for Toxaphene on both GC columns by
       looking at the quantitation reports.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool  (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  If the quantitative criteria for both columns were met (>5.0 ng/(iL for SCPs and > 125 ng/(iL for
       Toxaphene), determine whether GC/MS confirmation was performed.  If it was performed,
       qualify the data using the following guidance (see Table 59):

       a.  If GC/MS confirmation was not required because the quantitative criteria for both columns
           was not met, but it was still performed, use professional judgment when evaluating the data to
           decide whether the detect should be qualified with "C".
January 2005                                197                                   Draft Final

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                                                                Pesticides Organic Analysis
       b.  If GC/MS confirmation was performed, but unsuccessful for a target compound detected by
          GC/ECD analysis, qualify those detects as "X".

       Table 59.  Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation Actions
Criteria
SCP/Toxaphene was confirmed by GC/MS
SCP/Toxaphene was not confirmed by GC/MS
Action
Detects C
Detects X
January 2005
198
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                                                                     Pesticides Organic Analysis
  XIV. Compound Ouantitation and Reported Contract Required Ouantitation Limits (CRQLs)

A.  Review Items:

    Form I PEST, Form X PEST-1, Form X PEST-2, sample preparation log sheets, chromatograms,
    Sample Delivery Group (SDG) Narrative, and data system printouts.

B.  Objective:

    The objective is to ensure that the reported quantitative results, CRQLs, and Percent Moisture
    determination (for non-aqueous samples) are accurate.

C.  Criteria:

    Compound quantitation, as well as the adjustment of the CRQL, must be calculated according to the
    equations provided in the method.

D.  Evaluation:

    1.  Examine raw data to verify the correct calculation of all sample results reported by the laboratory.
       Compare data system printouts, chromatograms, and sample preparation log sheets to the reported
       detects and non-detects sample results. Verify that the sample values are reported correctly.

    2.  Verify that the CRQLs have been adjusted to reflect all sample dilutions, cleanup activities, dry
       weight factors (for non-aqueous samples) and other factors that are not accounted for by the
       method.

E.  Action:

    1.  Qualify non-detect results affected by large, off-scale peaks as unusable "R". If the interference
       is  on-scale, the reviewer can provide an approximated quantitation  limit "UJ" for each affected
       compound.

    2.  For non-aqueous samples, if the Percent Moisture is less than 70.0%, no qualification of the data
       is  necessary (see Table 60). If the Percent Moisture is greater than or equal to 70.0% and less
       than 90.0%, qualify detects as "J" and non-detects as "UJ". If the Percent Moisture is greater than
       or equal to 90.0%, qualify detects as "J" and non-detects as unusable "R".

    3.  If there are any discrepancies found, the Region's designated representative may contact the
       laboratory to obtain additional information that could resolve any differences. If a discrepancy
       remains unresolved, the reviewer must decide which value is the best value. Under these
       circumstances, the reviewer may determine if qualification of the data is warranted.  Note in the
       Data Review Narrative a description of the reasons for data qualification and the qualification that
       is  applied to the data.
January 2005                                 199                                   Draft Final

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                                                                Pesticides Organic Analysis
      Table 60. Percent Moisture Actions for Pesticides Analyses for Non-Aqueous Samples
Criteria
%Moisture < 70.0%
70.0% < %Moisture < 90.0%
%Moisture > 90.0%
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
No qualification
J
J
UJ
R
January 2005
200
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                                                                     Pesticides Organic Analysis
                                XV. Overall Assessment of Data

A.  Review Items:

    Entire data package, data review results, and (if available) Quality Assurance Project Plan (QAPP),
    and Sampling and Analysis Plan (SAP).

B.  Objective:

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

C.  Criteria:

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

D.  Evaluation:

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

    2.   If appropriate information is available, the reviewer may assess the usability of the data to assist
        the data user in avoiding inappropriate use of the data.  Review all available information,
        including the QAPP (specifically the acceptance or performance criteria), SAP, and
        communication with data user that concerns the intended use and desired quality of these data.

E.  Action:

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

    2.   Write a brief narrative to give the user an indication of the analytical limitations of the data.
        Note, for Contract Laboratory Program Project Officer (CLP PO) action, any inconsistency of
        that data with the Sample Delivery Group (SDG) Narrative. If sufficient information on the
        intended use and required quality of the data are available, include an assessment of the usability
        of the data within the given context. This may be used as part of a formal Data Quality
        Assessment (DQA).
January 2005                                 201                                    Draft Final

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                                                                  Aroclors Organic Analysis
                                AROCLOR DATA REVIEW




The Aroclor data requirements to be checked are:




I.      Preservation




II.     Initial Calibration




III.     Continuing Calibration Verification (CCV)




IV.     Blanks




V.     Surrogate Spikes




VI.     Matrix Spike/Matrix Spike Duplicates (MS/MSDs)




VII.    Laboratory Control Samples (LCSs)




VIII.   Regional Quality Assurance (QA) and Quality Control (QC)




IX.     Gel Permeation Chromatography (GPC) Performance Check




X.     Target Compound Identification




XI.     Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation




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




XIII.   Overall Assessment of Data
January 2005                               202                                 Draft Final

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                                                                     Aroclors Organic Analysis
                                        I. Preservation

A.  Review Items:

    Form IARO, Traffic Report/Chain of Custody Record (TR/COC), raw data, sample extraction sheets,
    and Sample Delivery Group (SDG) Narrative checking for:

    1.  pH
    2.  Sample temperature
    3.  Holding time
    4.  Other sample conditions

B.  Objective:

    The objective is to ascertain the validity of the analytical results based on sample condition (e.g.,
    preservation and temperature) and the holding time of the sample from time of collection to time of
    sample extraction and analysis.

C.  Criteria:

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

       For Aroclors in properly cooled (4°C ± 2°C) aqueous samples, the maximum holding time for
       extraction is seven (7) days from sample collection, and the maximum holding time for analysis is
       forty (40) days from sample extraction.

    The technical holding time criteria for non-aqueous samples are as follows:

       For Aroclors in properly cooled (4°C ± 2°C) non-aqueous samples, the maximum holding time is
       fourteen (14) days from sample collection, and the maximum holding time for analysis is forty
       (40) days from sample extraction.

D.  Evaluation:

    Technical holding times for sample extraction are established by comparing the sample collection
    dates on the TR/COC Record with the dates of extraction on Form I ARO and the sample extraction
    sheets. Information contained in the Complete SDG File (CSF) should also be considered in the
    determination of holding times. To determine if the samples were analyzed within the holding time
    after extraction, compare the dates of extraction on the sample extraction sheets with the dates of
    analysis on Form I ARO. Verify that the analysis dates on Form I(s) and the raw data/SDG File are
    identical.

    Review the  SDG Narrative and the TR/COC Record to determine if the samples were received intact
    and iced. If there is no indication in the SDG Narrative, the TR/COC Record, or the sample records
    that there was a problem with the samples, assume the integrity of the samples to be acceptable. If it
    is indicated that there were problems with the samples, the integrity of the  sample may have been
    compromised; use professional judgment to evaluate the effect of the problem on the sample results.
January 2005                                203                                   Draft Final

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                                                                       Aroclors Organic Analysis
E.  Action:

    1.  Qualify aqueous sample results using preservation and technical holding time information as
       follows (see Table 61):

       a.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed within the technical holding times
           [seven (7) days from sample collection for extraction; forty (40) days from sample collection
           for analysis], use professional judgment to qualify the data.

       b.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed outside the technical holding
           times [seven (7) days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       c.  If the samples were properly preserved, and were  extracted and analyzed within the technical
           holding times  [seven (7) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were  extracted or analyzed outside the technical
           holding times  [seven (7) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], qualify detects with a "J" and non-detects as estimated with
           an approximated "UJ" or unusable "R".  Note in the Data Review Narrative that holding times
           were exceeded and the effect of exceeding the holding time on the resulting data.

    2.  Qualify non-aqueous sample results using preservation and technical holding time  information as
       follows (see Table 61):

       a.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed within the technical holding times
           [fourteen (14)  days from collection for extraction; forty (40) days from sample collection for
           analysis], use professional judgment to qualify the data.

       b.  If there is no evidence that the samples were properly preserved (e.g., if the sample
           temperature has exceeded the allowable limits or if the integrity of the sample has been
           compromised), and the samples were extracted or analyzed outside the technical holding
           times [fourteen (14) days from sample collection for extraction; forty (40) days from sample
           collection for analysis], use professional judgment to qualify the data.

       c.  If the samples were properly preserved, and were  extracted and analyzed within the technical
           holding times  [fourteen (14) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], no qualification of the data is necessary.

       d.  If the samples were properly preserved, and were  extracted or analyzed outside the technical
           holding times  [fourteen (14) days from sample collection for extraction; forty (40) days from
           sample collection for analysis], qualify detects with a "J" and non-detects as estimated with
           an approximated "UJ" or unusable "R".  Note in the Data Review Narrative that holding times
           were exceeded and the effect of exceeding the holding time on the resulting data.
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    3.  If technical holding times are grossly exceeded, qualify all detects as estimated with a "J" and use
       professional judgment to qualify sample non-detects.

    4.  Note in the Data Review Narrative, whenever possible, the effect of exceeding the holding time
       on the resulting data.

    5.  Note, for Contract Laboratory Program Project Officer (CLP PO) action, when technical holding
       times are grossly exceeded.

                          Table 61. Holding Time Actions for Aroclor
Matrix
Aqueous
Non-aqueous
Preserved
No
No
Yes
Yes
Yes/No
No
No
Yes
Yes
Yes/No
Criteria
< 7 days (for extraction) and
< 40 days (for analysis)
> 7 days (for extraction) and
> 14 days (for analysis)
< 7 days (for extraction) and
< 40 days (for analysis)
> 7 days (for extraction) and
> 40 days (for analysis)
Grossly Exceeded
< 14 days (for extraction) and
< 40 days (for analysis)
> 14 days (for extraction) and
> 40 days (for analysis)
< 14 days (for extraction) and
< 40 days (for analysis)
> 14 days (for extraction) and
> 40 days (for analysis)
Grossly Exceeded
Action
Detected
Associated
Compounds
Non-Detected
Associated
Compounds
Use professional judgment
Use professional judgment
No qualification
J
J
UJ
UJorR
Use professional judgment
Use professional judgment
No qualification
J
J
UJ
UJorR
January 2005
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                                                                      Aroclors Organic Analysis
                                     II. Initial Calibration

A.  Review Items:

    Form VI ARO-1, Form VIARO-2, Form VIARO-3, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.  An initial five-point calibration is performed using Aroclors 1016 and 1260 to demonstrate the
       linearity  of the detector response. These Aroclors may be analyzed in a single standard mixture.
       The other seven Aroclors, 1221, 1232,  1242, 1248,  1254, 1262 or 1268, are calibrated at a single
       mid-point for pattern recognition. If Aroclors 1221, 1232, 1242, 1248, 1254, 1262 or 1268 are
       detected  in a sample, a five-point initial calibration is required for the detected Aroclor.

       a.   The Mean Retention Times (RTs) of each of the three to five major peaks of Aroclors 1016
           and 1260 and the Retention Time (RT) of the surrogates are determined from the five-point
           initial_calibration. For the other seven Aroclors, 1221, 1232,  1242, 1248, 1254, 1262 or 1268,
           the RTs  of each of the three to five major peaks and the RT of the surrogates are determined
           from the single-point standard initial calibration. If Aroclors 1221, 1232, 1242, 1248, 1254,
           1262 or  1268, are detected in a sample, the RTs of each of the three to five major peaks and
           the RT of the surrogates are determined from the five-point initial calibration.

       b.   An RT Window must be calculated as ±0.07 for each of the three to five Aroclor peaks and
           ±0.05 and ±0.10 for the surrogates tetrachloro-m-xylene (TCX) and decachlorobiphenyl
           (DCB) respectively.

       c.   At least  one chromatogram from each of the Aroclor Standards must yield peaks that give
           recorder deflections between 50-100% of full scale.

       d.   The concentrations of the five concentration level standards containing the Aroclors should
           be prepared at the following concentrations 100; 200; 400; 800; and 1600 ng/mL and
           surrogates at 5.0, 10, 20, 40 and 80 ng/mL for TCX and 10, 20, 40, 80 and 160 ng/mL for
           DCB.

       e.   Mean Calibration Factor (CF) must be calculated for the three to five major peaks of each
           Aroclor, as well as for the surrogates, over the initial calibration range.

       f   The Percent Relative Standard Deviation (%RSD) of the Calibration Factors (CFs) for the
           three to  five major peaks of each of the Aroclor compounds must be less than or equal to
           20.0%.  The Percent RSD of the CFs for the two surrogates must be less than or equal to
           20.0%.
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           NOTE:    Either peak area or peak height may be used to calculate the CFs that are, in turn,
                      used to calculate %RSD. However, the type of peak measurement used to
                      calculate each CF for a given compound must be consistent. For example, if
                      peak area is used to calculate the CS1 CF for a given peak of a certain Aroclor,
                      the remaining CFs for the same peak in the remaining standards (CS2-CS5)  for
                      that Aroclor must also be calculated using peak area.

    2.  Initial Calibration Sequence

       The initial calibration must be performed following a specific sequence (see Table 62).

                             Table 62.  Initial Calibration Sequence
Initial Calibration Sequence
1.
2.
3.
4.
5.
6.
7.
Aroclor 1221 CS3
Aroclor 1232 CS3
Aroclor 1242 CS3
Aroclor 1248 CS3
Aroclor 1254 CS3
Aroclor 1262 CS3
Aroclor 1268 CS3
8. Aroclor 1016/1260 (100 ng/mL)CSl
9.
10.
11.
12.
13.
Aroclor 1016/1260 (200 ng/mL) CS2
Aroclor 1016/1260 (400 ng/mL) CS3
Aroclor 1016/1260 (800 ng/mL) CS4
Aroclor 1016/1260 (1600 ng/mL) CSS
Instrument blank
D.  Evaluation:

    1.  Check the raw data (chromatograms and data system printouts) for each standard to verify that
       each of the standards was analyzed at the required concentration levels.

    2.  Check the Aroclor Standards data and Form VIARO-1 and Form VIARO-3 and review the
       calculated RT Windows for calculation and transcription errors.

    3.  Check the chromatograms and verify that at least one chromatogram from each of the Aroclor
       Standards yields peaks registering recorder/printer deflections between 25-100% of full scale.

    4.  Verify that the concentrations of the Aroclor Standards meet the criteria defined in Aroclors
       Organic Analysis, Section Il.C.l.d.
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    5.  Check the Aroclor Standards data and Form VIARO-2 to verify that the %RSD for the CFs are in
       compliance with the criteria defined in Aroclors Organic Analysis, Section II.C.

    6.  Check and recalculate the CFs and %RSD for one or more Aroclors. Verify that the recalculated
       values agree with the reported values. If errors are detected, more comprehensive recalculation
       and review should be performed.

    7.  Verify that if Aroclors 1221, 1232, 1242, 1248,  1254, 1262, or 1268 were detected in a sample, a
       valid 5-point calibration for that Aroclor using proper concentrations was performed.

    8.  Verify that the steps of initial calibration are followed in the proper sequence defined in Table 62.

E .  Action:

    1.  If the proper initial calibration sequence is not performed or the steps of the initial calibration are
       not followed in the proper sequence, use professional judgment to evaluate the effect on the data
       and notify the Contract Laboratory Program Project Officer (CLP PO) (see Table 63).  This is
       especially critical for the low-level standards and non-detects.

    2.  If RT Windows are not calculated correctly, recalculate the windows and use the corrected values
       for all evaluations.

    3.  If the chromatogram display (recorder deflection) criteria are not met, use professional judgment
       to evaluate the effect on the data.

    4.  If the standard concentration criteria are not met, use professional judgment to evaluate the effect
       on the data and notify the CLP PO. This is especially critical for the low-level standards and  non-
       detects.

    5.  If the %RSD criteria are not met, qualify detects with a "J"  and non-detected target compounds
       with an approximated "UJ".

    6.  If the %RSD criteria are within allowable limits, no qualification of the data is necessary.

    7.  At the reviewer's discretion, and based on the  project-specific data quality objectives, consider a
       more in-depth review using the following guidelines:

       a.  If any Aroclor peak has a %RSD greater than the maximum criterion, and if eliminating
           either the high or the low-point of the curve does not restore the %RSD to less than or equal
           to the required maximum:

           i.   Qualify detects for that Aroclor with a " J".

           ii.  Qualify non-detected Aroclor using professional judgment.

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

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

           ii.  Qualify detects outside of the linear portion of the curve with a "J".
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                                                                       Aroclors Organic Analysis
           iii.  No qualifiers are needed for Aroclors that were not detected.

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

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

           ii.  Qualify low-level detects in the area of non-linearity with a "J".

           iii.  For non-detected Aroclors, use the lowest point of the valid curve to determine the new
               quantitation limit.

    8.  Note in the Data Review Narrative potential effects on the sample data due to problems with
       calibration. Notify the CLP PO if the laboratory has repeatedly failed to comply with the
       requirements for frequency, linearity, RT, or resolution.

                    Table 63.  Initial Calibration Action for Aroclor Analyses
Criteria
Initial calibration is not performed or
not performed in the proper sequence
%RSD exceeds allowable limits*
%RSD within allowable limits*
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
Use professional judgment
J
UJ
No qualification
    *   %RSD < 20.0% for Aroclors.
        %RSD < 20.0% for surrogates (tetrachloro-m-xylene and decachlorobiphenyl).
January 2005
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                                                                     Aroclors Organic Analysis
                        III.  Continuing Calibration Verification (CCV)

A.  Review Items:

    Form VII ARO-1, chromatograms, and data system printouts.

B.  Objective:

    Compliance requirements for satisfactory instrument calibration are established to ensure that the
    instrument is capable of producing acceptable qualitative and quantitative data.  CCV checks and
    documents satisfactory performance of the instrument over specific time periods during sample
    analysis.  To confirm the calibration and evaluate instrument performance, CCV is performed,
    consisting of the analyses of instrument blanks, and the mid-point concentration (CSS) of Aroclor
    standards. A CCV must be performed at the beginning (opening CCV) and end (closing CCV) of the
    analytical sequence. The opening and closing CCVs consist of an injection of an instrument blank
    followed by an injection of mid-point concentration (CSS) of Aroclor 1016/1260 Standard Mixture.
    If an Aroclor other than 1016 or 1260 is detected in any samples, that Aroclor must have a mid-point
    concentration (CSS) standard analyzed as part of the opening and closing CCV.

C.  Criteria:

    1.  The Absolute Retention Time (RT) for each Aroclor and surrogate in the mid-point concentration
       (CSS) of the Aroclor Standards used for CCV must be within the RT Windows determined from
       the initial calibration.

    2.  For the opening CCV, or closing CCV that is used as an opening CCV for the next 12-hour
       period, the Percent Difference (%D) between the CF of each of the three to five peaks used to
       identify an Aroclor and surrogates in the mid-point concentration (CSS) of the Aroclor Standards
       and the CF from the initial calibration must be within ±15.0%.

    3.  For a closing CCV, the Percent Difference between the CF of each of the three to five peaks used
       to identify an Aroclor and surrogates in the mid-point concentration (CSS) of the Aroclor
       Standards and the CF from the initial calibration must be within ±50.0%.

    4.  No more than 14 hours may elapse from the injection of the instrument blank that begins an
       analytical sequence (opening CCV) and the injection of the last mid-point concentration (CSS) of
       the Aroclor Standards that ends an analytical sequence (closing CCV).

    5.  No more than 12 hours may elapse from the injection of the instrument blank that begins an
       analytical sequence (opening CCV) and the injection of the last sample or blank that is part of the
       same analytical sequence.

D .  Evaluation:

    1.  Check the data for each of the Aroclors and surrogates in the mid-point concentration (CSS) of
       the Aroclor Standards on Form VII ARO-1 to verify that the Absolute RTs are within the RT
       Windows.
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                                                                      Aroclors Organic Analysis
    2.  For an opening CCV, or closing CCV that is used as an opening CCV for the next analytical
       sequence, check the data for each of the Aroclors and surrogates in the mid-point concentration
       (CSS) of the Aroclor Standards on Form VIIARO-1 to verify that the Percent Difference between
       the CF of each of the three to five peaks used to identify an Aroclor and surrogates in the mid-
       point concentration (CSS) of the Aroclor Standards and the CF from the initial calibration is
       within ±15.0%.

    3.  For a closing CCV, check the data for each of the Aroclors and surrogates in the mid-point
       concentration (CSS) of the Aroclor Standards on Form VII ARO-1 to verify that the Percent
       Difference between the CF of each of the three to five peaks used to identify an Aroclor and
       surrogates in the mid-point concentration (CSS) of the Aroclor Standards and the CF from the
       initial calibration is within ±50.0%.

    4.  Check the length of time that has elapsed from  the beginning injection of the instrument that
       belongs to the opening CCV and the ending injection of the last Aroclor Standard that is part of
       the closing CCV to verify that no more than  14 hours has elapsed.

    5.  Check the length of time that has elapsed from  the beginning injection of the instrument blank
       that belongs to the  opening CCV (instrument blank) and the injection of the last sample or
       method blank to verify that no more than 12  hours has elapsed.

E.  Action:

    1.  RT Windows are used in qualitative identification.  If the standards do not fall within the RT
       Windows, use professional judgment to evaluate the associated sample results (see Table 64). All
       samples injected after the last in-control standard are potentially affected.

       a.  For non-detected target compounds in  the affected samples, check to see if the sample
           chromatograms contain any peaks that are close to the expected RT Window of the Aroclor
           of interest.

           i.   If no peaks are present, consider the non-detected values to be valid and no qualification
               of the data is necessary.

           ii.   If any peaks are present close to the expected RT Window of the Aroclor of interest,
               qualify the non-detected values as  presumptively present "N".

       b.  For detected compounds in the affected samples, if the peaks are within the RT Window, no
           qualification of the  data is necessary.  If the peaks are close to the expected RT Window of
           the Aroclor of interest, the reviewer may take additional effort to determine if sample peaks
           represent the compounds of interest.

           For example, the reviewer can examine the data package for the presence of three or more
           standards containing the Aroclor of interest that were run within the analytical sequence
           during which the sample was analyzed. If three or more such standards are present, the RT
           Window can be re-evaluated using the Mean Retention Times (RTs) of the standards.

           i.   If the peaks in the affected sample fall  within the revised window, qualify the detected
               target compounds as "NJ".
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                                                                       Aroclors Organic Analysis
           ii.  If the reviewer cannot do anything with the data to resolve the problem of concern,
               qualify all non-detects as unusable "R".

    2.  If the Percent Difference is not within ±15% as specified in Aroclors Organic Analysis, Section
       III.C.2, qualify associated detects with a "J" and non-detects with an approximated "UJ".

    3.  If the Percent Difference is not within ±50% as specified in Aroclors Organic Analysis, Section
       III.C.3, qualify associated detects with a "J" and non-detects with an approximated "UJ".

    4.  If more than 14 hours has elapsed as defined in Aroclors Organic Analysis, Section III.C.4,
       qualify associated as unusable "R".

    5.  If more than 12 hours has elapsed as defined in Aroclors Organic Analysis, Section III.C.5,
       qualify associated data as unusable "R".

    6.  If RT, Percent Difference, and time elapsed are within acceptable limits, no qualification of the
       data is necessary.

    7.  Note in the Data Review Narrative potential effects on the sample data due to problems with
       calibration.

         Table 64.  Continuing Calibration Verification (CCV) Action for Aroclor Analyses
Criteria
RT out of RT window
Percent Difference not within ±15%
as specified in Aroclors, Section IV. C. 2
Percent Difference not within ±50%
as specified in Aroclors, Section IV. C. 3
Time elapsed is greater than acceptable limits as
defined in Aroclors, Sections IV.C.4, and C.5
RT, Percent Difference, time elapsed are within
acceptable limits
Action
Detected
Associated
Compounds
Non-Detected
Associated
Compounds
Use professional judgment
(see Aroclors, Section III. E.I)
J
J
UJ
UJ
R
No qualification
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                                                                      Aroclors Organic Analysis
                                          IV. Blanks

A.  Review Items:

    Form I ARO, Form IV ARO, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.   Method Blanks

        A method blank must be extracted each time samples are extracted.  The number of samples
        extracted with each method blank shall not exceed 20 field samples [excluding Matrix
        Spike/Matrix Spike Duplicate (MS/MSDs), Performance Evaluation (PE) samples, and
        Laboratory Control Samples (LCSs)]. In addition, a method blank shall be extracted by the same
        procedure used to extract samples and be analyzed on the same Gas Chromatograph/Electron
        Capture Detector (GC/ECD) system used to analyze associated samples.

    2.   Instrument Blanks

        An acceptable instrument blank must be run at the end of the initial calibration sequence. An
        acceptable instrument blank must be run at the beginning and ending of an analytical sequence in
        which samples are analyzed, immediately prior to the analysis of the mid-point concentration
        (CSS) Aroclor Standard 1016/1260 Mixture, used for continuing calibration verification.  All
        groups of acceptable sample analyses are to be preceded and followed by  acceptable instrument
        blanks.

    3.   Sulfur Cleanup Blanks

        A sulfur cleanup blank must be analyzed whenever part of a set of samples extracted together
        requires sulfur cleanup.  If the entire set of samples associated with a method blank requires
        sulfur cleanup, the method blank also serves the purpose of a sulfur blank and no separate sulfur
        blank is required.

        The concentration of each target analyte in the method, sulfur cleanup, instrument blanks, and
        field blanks must be less than its Contract Required Quantitation Limits (CRQL) listed in the
        method.
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D.  Evaluation:

    1.  Review the results of all associated blanks, Form IARO, Form IV ARO, and raw data
       (chromatograms and data system printouts) to evaluate the presence of target or non-target
       analytes in the blanks.

    2.  Verify that a method blank analysis has been reported per Sample Delivery Group (SDG), per
       extraction batch, and per extraction procedure. The reviewer can use Form IV ARO to identify
       samples associated with each blank.

    3.  Verify that the method blank analysis(es) contains less than the CRQL of any target Aroclor or
       any interfering peak.

    4.  Verify that the instrument blank analysis has been performed at the beginning and end of every
       12-hour period in  which samples were analyzed, immediately before the analysis of the mid-point
       concentration (CSS) Aroclor Standard 1016/1260 Mixture  or Aroclor of interest detected in a
       sample. Evaluate  the results from the various instrument blanks to verify that target analyte
       concentrations are less than the CRQL (assuming a 1 L extraction of an aqueous sample).

    5.  Verify that the sulfur cleanup blanks  were analyzed at the required frequency and the sulfur
       blanks do not contain any target compounds greater than or equal to the CRQL (assuming a 1 L
       extraction of an aqueous sample and  30g of a non-aqueous sample). If a separate sulfur cleanup
       blank was prepared, one version of Form IV ARO should be completed associating all the
       samples with the method blank, and a second version of Form IV ARO should be completed
       listing only those  samples associated  with the separate sulfur cleanup blank.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are  evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process. Data concerning the field blanks are not evaluated as part of the
                  CCS process. If field blanks are present, the data reviewer should evaluate this data
                  in a similar fashion as the method blanks.

E.  Action:

    Action regarding unsuitable blank results depends on the circumstances and the origin of the blank.
    In instances where more than one of the same type of blank is associated with a given sample, base
    qualification upon a comparison with the  associated blank having the highest concentration of a
    contaminant.  Do not correct the results by subtracting the blank value.

    1.  If a target Aroclor compound is found in the blank but not  found in the sample, no qualification is
       required (see Table 65).

    2.  If a target Aroclor compound concentration in a blank is less than the CRQL, and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.
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                                                                     Aroclors Organic Analysis
    3.  If a target Aroclor compound concentration in a blank is greater than the CRQL, and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b   the sample concentration is greater than or equal to the CRQL, and less than the blank
           concentration, report the concentration of the compound in the sample at the same
           concentration found in the blank with a "U", or the reviewer may elect to qualify the data as
           unusable "R".

       c.  the sample concentration is greater than or equal to the CRQL, and greater than or equal to
           the blank concentration, use professional judgment to qualify the data.

    4.  If a target Aroclor compound concentration in a blank is equal to the CRQL, and:

       a.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

       b.  the sample concentration is greater than or equal to the CRQL, use professional judgment to
           qualify the data.

    5.  If gross contamination exists (e.g., saturated peaks, "hump-o-grams", "junk" peaks), all affected
       compounds in the associated samples should be qualified as unusable "R", due to interference.
       Note, for Contract Laboratory Program Project Officer (CLP PO) action, if the contamination is
       suspected of having an effect on the sample results.

    6.  There may be instances where little or no contamination was present in the associated blanks, but
       qualification of the sample is deemed necessary. If the reviewer determines that the
       contamination is from a source other than the sample, they should qualify the data.
       Contamination introduced through dilution is one example. Although it is not always possible to
       determine, instances of this occurring can be detected when contaminants are found in the diluted
       sample result, but absent in the undiluted sample result.

    7.  If contaminants are found in the field blanks, the following is recommended:

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

           If the analyte was not present in the method blank, the source of contamination may have
           occurred in the field or during sample transport. Consider all associated samples for possible
           cross-contamination.

       b.  If the field blank contains an Aroclor Target Compound List (TCL) compound(s) at a
           concentration greater than the CRQL and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii. the sample concentration is greater than or equal to the CRQL, and less than the blank
              concentration, report the concentration of the compound in the sample at the same
              concentration found in the blank and qualify with a "U", or use professional judgment to
              qualify the data as unusable "R".
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           iii. the sample concentration is greater than the CRQL and greater than or equal to the blank
              concentration, use professional judgment to qualify the data.

       c.   If gross contamination (e.g., saturated peaks, "hump-o-grams", "junk" peaks) exists in the
           storage or field blank, positive sample results may require rejection.  Qualify as unusable "R".
           Non-detected Aroclor target compounds do not require qualification unless the contamination
           is so high that it interferes with the analyses of non-detected compounds.

       d.   If the field blank contains an Aroclor volatile TCL compound(s) at a concentration less than
           the CRQL  and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, use professional judgment
              to qualify the data.

       e.   If the field blank contains an Aroclor TCL compound(s) at a concentration equal to the
           CRQL and:

           i.  the sample concentration is less than the CRQL, report the CRQL value with a "U".

           ii.  the sample concentration is greater than or equal to the CRQL, use professional judgment
              to qualify the data.

                         Table 65.  Blank Actions for Aroclor Analyses
Blank Type




Method,
Sulfur Cleanup,
Instrument
Field



Blank Result
Detects
<- ppr\T
*- V^KV^ij

>CRQL

ppr\T
V^KV^ij
Gross
contamination
Sample Result
Not detected
 CRQL
 CRQL and
< blank concentration
> CRQL and
> blank concentration
CRQL
Detects
Action for Samples
No qualification
Report CRQL value with a U
Use professional judgment
Report CRQL value with a U
Report the concentration for the
sample with a U, or qualify the data
as unusable R
Use professional judgment
Report CRQL values with a U
Use professional judgment
Qualify results as unusable R
January 2005
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                                      V. Surrogate Spikes

A.  Review Items:

    Form IIARO-1, Form II ARO-2, Form VIIIARO, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.  Two surrogate spikes, tetrachloro-m-xylene (TCX) and decachlorobiphenyl (DCB), are added to
       all samples, including Matrix Spike/Matrix Spike Duplicates (MS/MSDs), Laboratory Control
       Samples (LCSs) and blanks to measure their recovery. The surrogates are also added to all the
       standards to monitor Retention Times (RTs).

    2.  The recovery limits for the surrogates TCX and DCB are 30-150% for all samples, including  MS
       and MSDs, LCSs and all blanks.

    3.  The RTs of the  surrogates in each Performance Evaluation Mixture (PEM), mid-point Aroclor
       standards used for continuing calibration verification, all samples (including MS and MSD, LCS,
       and PE samples) and all blanks must be within the calculated RT Windows.  TCX must be within
       ±0.05 minutes, and DCB must be within ±0.10 minutes of the Mean Retention Time (RT)
       determined from the initial calibration.

D.  Evaluation:

    1.  Check the raw data (e.g., chromatograms and data system printouts) to verify the recoveries on
       the Surrogate Recovery Form (Form II ARO).

       Check for any calculation or transcription errors; verify that the surrogate recoveries were
       calculated correctly using the equation in the method.

    2.  Check the raw data (e.g., chromatograms and data system printouts) to verify that the RTs on
       Form VIII ARO are accurate and within the RT Windows determined from the initial calibration.

    3.  Whenever there are two or more analyses for a particular sample, the reviewer must determine
       which are the most accurate data to report. Considerations include, but are not limited to:

       a.   Surrogate recovery (marginal versus gross deviation).

       b.   Technical holding times.
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                                                                      Aroclors Organic Analysis
       c.  Comparison of the values of the target compounds reported in each sample analysis.

       d.  Other Quality Control (QC) information, such as surrogate recoveries and/or RTs in blanks
           and standards.

           NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                      criteria are evaluated as part of the Contract Compliance Screening (CCS)
                      process.  Information regarding the laboratory's compliance with these criteria
                      can be obtained from the Data Assessment Tool (DAT) reports, and may be used
                      as  part of the evaluation process.

E.  Action:

    If either surrogate spike recovery is outside the acceptance limits, consider the existence of coelution
    and interference in the  raw data and use professional judgment to qualify data, as surrogate recovery
    problems may not directly apply  to target analytes.

    1.  For any surrogate recovery greater than  200% (see Table 66):

       a.  Qualify detected target compounds are qualified as "J".

       b.  Use professional judgment to qualify non-detected target compounds.

    2.  For any surrogate recovery greater than  150%, and less than or equal to 200%:

       a.  Qualify detected target compounds are qualified as a "J".

       b.  Do not qualify non-detected target compounds.

    3.  If both surrogate recoveries are greater than or equal to 30% and less than or equal to 150%, no
       qualification of the data is necessary.

    4.  For any surrogate recovery greater than  or equal to 10% and less than 30%:

       a.  Qualify detected target compounds as a " J".

       b.  Qualify non-detected target compounds as an approximated "UJ".

    5.  For any surrogate recovery less than 10%, the reviewer should examine the sample chromatogram
       to assess the qualitative validity of the analysis. If low surrogate recoveries are from sample
       dilution, use professional judgment to determine if the resulting data should be qualified. If
       sample dilution is not a factor:

       a.  Qualify detected target compounds as a " J".

       b.  Qualify non-detected target compounds as unusable "R".

    6.  In the special case  of a blank analysis with surrogates out of specification, the reviewer must give
       special consideration to the validity of associated sample data. The basic concern is whether the
       blank problems represent an isolated problem with the blank alone, or whether there is a
       fundamental problem with the analytical process.  For example, if one or more samples in the


January 2005                                 218                                  Draft Final

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       batch show acceptable surrogate recoveries, the reviewer may choose to consider the blank
       problem to be an isolated occurrence. Note, for Contract Laboratory Program Project Officer
       (CLP PO) action, analytical problems even if this judgment allows some use of the affected data.

    7.  If surrogate RTs in PEMs, mid-point Aroclor standards used for Continuing Calibration
       Verification (CCV), samples, and blanks are outside of the RT Windows, use professional
       judgment to qualify data.

    8.  If surrogate RTs are within the RT windows, no qualification is necessary.

                       Table 66. Surrogate Actions for Aroclor Analyses
Criteria
%R > 200%
150%<%R<200%
30% < %R < 150%
10%< %R<30%
%R < 10% (sample dilution not a factor)
%R < 10% (sample dilution is a factor)
RT out of RT window
RT within RT window
Action*
Detected
Target Compounds
J
J
Non-detected
Target Compounds
Use professional judgment
No qualification
No qualification
J
J
UJ
R
Use professional judgment
Use professional judgment
No qualification
    *   Use professional judgment in qualifying data as surrogate recovery problems may not directly
       apply to target analytes.
January 2005
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                     VI. Matrix Spike/Matrix Spike Duplicates (MS/MSDs)

A.  Review Items:

    Form III ARO-1, Form III ARO-2, chromatograms, and data system printouts.

    NOTE:     Data for MS and MSDs will not be present unless requested by the Region.

B.  Objective:

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

C.  Criteria:

    1.   If requested, MS and MSD samples are extracted and analyzed at a frequency of one MS and
        MSD per 20 or fewer field samples.

    2.   MS and MSD recoveries should be within the advisory limits provided on Form III ARO-1.

    3.   Relative Percent Difference (RPD) between MS and MSD recoveries should not exceed the
        advisory limits provided on Form III ARO-1.

D.  Evaluation:

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

    2.   Check the raw data and Form III ARO-1 to verify that the results for MS and MSD recoveries
        were calculated and transcribed correctly.

    3.   Check that the RPD was calculated correctly.

        NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance Screening (CCS) process.
                  Information regarding the laboratory's compliance with this criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E .  Action:

    1.   No qualification of the data is necessary on MS and MSD data alone.  Use professional judgment
        to use the MS and MSD results in conjunction with other QC criteria to determine the need for
        some qualification of the data.  Table 68 lists the Aroclor target analytes that are spiked into
        samples to test for matrix effects.  If any MS and MSD, Percent Recovery, or RPD in the Aroclor
        fraction is out of specification, qualify data to include the consideration of the existence of
        interference in the raw data.  Considerations include, but are not limited to (see Table  67):
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                                                                      Aroclors Organic Analysis
       a.  For any recovery or RPD greater than the upper acceptance limit:

           i.   Qualify detected spiked Aroclor target compounds as a "J".

           ii.  Do not qualify non-detected Aroclor target compounds.

       b.  For any recovery greater than or equal to 20% and less than the lower acceptance limit:

           i.   Qualify detected spiked Aroclor target compounds as a " J".

           ii.  Qualify the sample quantitation limit for non-detected spiked Aroclor target compounds
               as approximated "UJ".

       c.  For any recovery less than 20%:

           i.   Qualify detected spiked Aroclor target compounds as a "J".

           ii.  Use professional judgment to qualify non-detected spiked Aroclor target compounds.

       d.  If recoveries are within the acceptance limits, no qualification of the data is required.

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

    3.  In those instances where it can be determined that the results of the MS and MSB affect only the
       sample spiked, limit qualification to this sample only. However, it may be determined through
       the MS and MSB results, that a laboratory is having a systematic problem in the analysis of one
       or more analytes that affects all associated samples; use professional judgment to qualify the data
       from all associated samples.

    4.  Use professional judgment to determine the need for qualification of detects of non-spiked
       compounds.

       NOTE:    Notify the Contract Laboratory Program Project Officer (CLP PO) if a field blank
                  was used for the MS and MSB, unless designated as such by the Region.
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     Table 67. Matrix Spike/Matrix Spike Duplicate (MS/MSD) Actions for Aroclor Analysis
Criteria
%R or RPD > Upper Acceptance Limit
20% <%R < Lower Acceptance Limit
%R < 20%
Lower Acceptance Limit < %R < Upper
Acceptance Limit
Action
Detected
Spiked Compounds
J
J
J
Non-detected
Spiked Compounds
No qualification
UJ
Use professional judgment
No qualification
      Table 68.  Matrix Spike (MS) Recovery and Relative Percent Difference (RPD) Limits
Compound
AR1016
AR1260
Percent Recovery QC Limits
29- 135
29- 135
RPD
0- 15
0-20
January 2005
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                                                                   Aroclors Organic Analysis
                           VII.  Laboratory Control Samples (LCSs)

A.  Review Items:

    Form I ARO, Form II ARO-1, Form II ARO-2, Form III ARO-3, Form III ARO-4, LCS
    chromatograms, and data system printouts.

B.  Objective:

    Data for LCSs are generated to provide information on the accuracy of the analytical method and
    laboratory performance.

C.  Criteria:

    1.  The LCS contains the Aroclors target compounds and surrogates listed in Table 69.

                     Table 69. Aroclor Laboratory Control Sample (LCS)
                            Recovery - Aqueous and Non-Aqueous
Compound
Aroclor 1016
Aroclor 1260
Tetrachloro-m-xylene (surrogate)
decachlorobiphenyl (surrogate)
% Recovery QC Limits
50- 150
50- 150
30- 150
30- 150
    2.  The Percent Recoveries (%R) for the LCS compounds must be within the limits specified in
       Table 69.

       NOTE:   All samples prepared and analyzed with an LCS that does not meet the technical
                 acceptance criteria in the method will require re-extraction and re-analysis.

D.  Evaluation:

    Check the raw data (e.g., chromatograms and data system printouts) to verify the recoveries on the
    Laboratory Control Sample Recovery Form (Form III ARO-3, Form III ARO-4).  Check the raw data
    to verify the recoveries on the Surrogate Recovery Forms (Form II ARO-1, Form II ARO-2).

    Check for any calculation or transcription errors; verify that the LCS recoveries reported on Form II
    ARO-1, Form II ARO-2, Form III ARO-3, and Form III ARO-4 are within the QC limits.

    NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding criteria are
              evaluated as part of the Contract Compliance Screening (CCS) process. Information
              regarding the laboratory's compliance with these criteria can be obtained from the Data
              Assessment Tool (DAT) reports, and may be used as part of the evaluation process.
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E.  Action:

    If the LCS criteria are not met, laboratory performance and method accuracy are in question. Use
    professional judgment to determine if the data should be qualified or rejected. The following
    guidance is suggested for qualifying sample data for which the associated LCS does not meet the
    required criteria (see Table 70).

    1.  If the  LCS recovery criteria are not met, use the LCS results to qualify sample data for the
       specific compounds that are included in the LCS solution.

       a.   If the LCS recovery exceeds the upper acceptance limit, qualify detected target compounds as
           a  "J". Do not qualify non-detected target compounds.

       b.   If the LCS recovery is less than the lower acceptance limit, qualify detected target
           compounds as a "J" and non-detects as unusable "R".

       c.   Use professional judgment to qualify data for compounds other than those compounds that
           are included in  the LCS.

       d.   Use professional judgment to qualify non-LCS compounds. Take into account the compound
           class, compound recovery efficiency, analytical problems associated with each compound,
           and comparability in the performance of the LCS compound to the non-LCS compound.

    2.  If the  LCS recovery criteria are within the acceptance limit, no qualification of the data is
       necessary.

    3.  Note,  for Contract Laboratory Program Project Officer (CLP PO) action, if a laboratory fails to
       analyze an LCS with each Sample Delivery Group (SDG), or if a laboratory consistently fails to
       generate acceptable LCS recoveries.

                 Table 70.  Laboratory Control Sample (LCS) Recovery Actions
Criteria
%R > Upper Acceptance Limit
%R < Lower Acceptance Limit
Lower Acceptance Limit < %R < Upper
Acceptance Limit
Action
Detected
Associated Compounds
J
J
Non-Detected
Associated Compounds
No qualification
R
No qualification
January 2005
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                                                                    Aroclors Organic Analysis
                VIII. Regional Quality Assurance (OA) and Quality Control (OC)

A.  Review Items:

    Form I ARO, chromatograms, data system printouts, Traffic Report/Chain of Custody Record
    (TR/COC), quantitation reports, and other raw data from Regional QA/QC samples.

B.  Objective:

    Regional QA/QC refers to any QA and/or QC samples initiated by the Region, including field
    duplicates, Performance Evaluation (PE) samples, blind spikes, and blind blanks. The use of these
    QA/QC samples are highly recommended (e.g., the use of field duplicates can provide information on
    sampling precision and sample homogeneity).

C.  Criteria:

    Criteria are determined by each Region.

    1.  PE sample frequency may vary.

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

D.  Evaluation:

    1.  Evaluation procedures must follow the Region's Standard Operating Procedure (SOP) for data
       review.  Each Region will handle the evaluation of PE samples on an individual basis. Compare
       results for PE samples to the acceptance criteria for the specific PE samples, if available.

    2.  Calculate Relative Percent Difference (RPD) between field duplicates. Provide this information
       in the Data Review Narrative.

E.  Action:

    Any action must be in accordance with Regional specifications and the criteria for acceptable PE
    sample results. Note, for Contract Laboratory Program Project Officer (CLP PO) action, any
    unacceptable results for PE samples.
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                                                                     Aroclors Organic Analysis
                IX. Gel Permeation Chromatography (GPC) Performance Check

A,  Review Items:

    Two Ultraviolet (UV) traces, GPC cleanup blank quantitation reports, and chromatograms.

B.  Objective:

    GPC is used to remove high molecular weight contaminants that can interfere with the analysis of
    target analytes. GPC cleanup procedures are checked by adding the GPC calibration mixture to the
    GPC cleanup columns and setting the appropriate elution window, and verifying the recovery of
    target compounds through the cleanup procedure by the analysis of a cleanup blank.

C.  Criteria:

    1.  GPC is an optional cleanup method for both aqueous and non-aqueous samples and is used for
       the cleanup of all non-aqueous and aqueous sample extracts that contain high molecular weight
       components that interfere with the analysis of the target analytes.

    2.  At least once every seven (7) days, the calibration of the GPC unit must be checked by injecting
       with the GPC calibration verification solution.

    3.  The GPC calibration is acceptable if the two UV traces meet the following requirements:

       a.   Peaks must be observed and should be symmetrical for all compounds in the calibration
           solution.

       b.   Corn oil and the phthalate peaks should exhibit greater than 85% resolution.

       c.   The phthalate and methoxychlor peaks should exhibit greater than  85% resolution.

       d.   Methoxychlor and perylene peaks should exhibit greater than 85% resolution.

       e.   Perylene and sulfur peaks must not be saturated and should exhibit greater than 90% baseline
           resolution.

       f   The Retention Time (RT) shift is less than 5% between  UV traces for bis (2-ethylhexyl)
           phthalate and perylene.

    4.  A GPC blank must be analyzed after each GPC calibration and it is acceptable if the blank does
       not exceed the Contract Required Quantitation Limit (CRQL) for any target analytes listed in
       SOM01.0. Exhibit C - Aroclors, Target Compound List and  Contract Required Quantitation
       Limits, available at:

                       http://www.epa.gov/superfund/programs/clp/soml.htm
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                                                                     Aroclors Organic Analysis
D.  Evaluation

    1.  Verify that there are two UV traces present and that the RT shift for bis(2-ethylhexyl) phthalate
       and perylene is less than 5%.

    2.  Verify that the compounds listed in IX.C.3 are present and symmetrical in both UV traces and
       that the compound pairs meet the minimum resolution requirements.

    3.  Verify that no target compound exceeds the CRQL.

       NOTE:    For data obtained from the Contract Laboratory Program (CLP), the preceding
                  criteria are evaluated as part of the Contract Compliance  Screening (CCS) process.
                  Information regarding the laboratory's compliance with these criteria can be obtained
                  from the Data Assessment Tool (DAT) reports, and may be used as part of the
                  evaluation process.

E.  Action:

    1.  If GPC criteria are not met, examine the raw data for the presence of high molecular weight
       contaminants. Examine the subsequent sample data for unusual peaks and use professional
       judgment in qualifying the data. Notify the Contract Laboratory Program Project Officer (CLP
       PO) if a laboratory chooses to analyze samples under unacceptable GPC criteria.

    2.  Note in the Data Review Narrative potential effects on the sample data resulting from the GPC
       cleanup analyses not yielding acceptable results.
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                                                                     Aroclors Organic Analysis
                              X. Target Compound Identification

A.  Review Items:

    Form I ARO, Form X ARO, chromatograms, and data system printouts.

B.  Objective:

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

C.  Criteria:

    1.  The Retention Times (RTs) of both of the surrogates and reported target compounds in each
       sample must be within the calculated RT Windows on both columns. Tetrachloro-m-xylene
       (TCX) must be within ±0.05 minutes of the Mean Retention Time (RT) determined from the
       initial calibration and decachlorobiphenyl (DCB) must be within ±0.10 minutes of the RT
       determined from the initial calibration.

    2.  The Percent Difference (%D) for the detected mean concentrations of an Aroclor target
       compound between the two Gas Chromatograph (GC) columns must be within the inclusive
       range of ±25.0.

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

    4.  Chromatograms must display the largest peak of any Aroclors detected in the sample at less than
       full scale.

    5.  If an extract must be diluted, chromatograms must display Aroclors peaks between 25-100% of
       full scale.

    6.  If a chromatogram is replotted electronically to meet these requirements, the scaling factor used
       must be displayed on the chromatogram,  and both the initial chromatogram and the replotted
       chromatogram must be submitted in the data package.

D.  Evaluation:

    1.  Review Form I ARO, the associated raw  data (chromatograms and data system printouts) and
       Form X ARO. Confirm reported detected analytes  by comparing the sample chromatograms to
       the tabulated results and verifying peak measurements and RTs. Confirm reported non-detected
       analytes by a review of the sample chromatograms. Check the associated blank data for potential
       interferences (to evaluate sample data for false positives) and check the calibration data for
       adequate RT Windows (to evaluate sample data for false positives and false negatives).
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                                                                      Aroclors Organic Analysis
    2.  Compare the Aroclor peaks identified in the sample to determine that the RTs do not overlap with
       the RTs of any chromatographic interferences from the sample matrix.

    3.  Check that the Percent Difference results were calculated correctly.

E.  Action:

    1.  If the qualitative criteria for both columns were not met, all target compounds that are reported as
       detected should be considered non-detected. The reviewer should use professional judgment to
       assign an appropriate quantitation limit using the following guidance:

       a.  If the detected target compound peak was sufficiently outside the Aroclor RT Window, the
           reported values may be a false positive  and should be replaced with the sample Contract
           Required Quantitation Limits (CRQL) value.

       b.  If the detected target compound peak poses an interference with potential detection of another
           target peak, the reported value should be considered and qualified as unusable "R".

    2.  If the data reviewer identifies a peak in both GC column analyses that falls within the appropriate
       RT Windows, but was reported as a non-detect, the compound may be a false negative. Use
       professional judgment to decide if the compound should be included. Note in the Data Review
       Narrative all conclusions made regarding target compound identification.

    3.  If the Aroclor peak RT Windows determined from the calibration overlap with chromatographic
       interferences, use professional judgment to  qualify the data.

    4.  If Aroclors were detected on both GC columns, and the Percent Difference between the two
       results is greater than 25.0%, consider the potential for coelution and use professional judgment
       to decide whether a much larger concentration obtained on one column versus the other indicates
       the presence of an interfering compound. If an interfering compound is indicated, use
       professional judgment to determine how best to report, and if necessary, qualify the data.

    5.  If Aroclors exhibit marginal pattern-matching quality, use professional judgment to establish
       whether the  differences are due to environmental "weathering" (i.e., degradation of the earlier
       eluting peaks relative to  the later eluting peaks). If the presence of an Aroclor is strongly
       suggested, report results as presumptively present "N".
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              XL Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation

A.  Review Items:

    Form I ARO, Form X ARO, chromatograms, and data system printouts.

B.  Objective:

    If GC/MS confirmation is required by the Region for all detected Aroclors that have at least one
    individual peak with a sufficient on-column concentration on both columns (greater than or equal to
    10 ng/(iL), GC/MS confirmation for purposes of qualitative identification is required.  GC/MS
    confirmation may be accomplished by one of three general means:

    1.  Examination of the semivolatile GC/MS library search results [i.e., Tentatively Identified
       Compound (TIC) data];

    2.  A second analysis of the semivolatile extract; or

    3.  Analysis of the Aroclor extract, following any solvent exchange and concentration steps that may
       be necessary.

C.  Criteria:

    The on-column concentration for any individual peak belonging to an Aroclor must be greater than or
    equal to  10 ng/(iL on both GC columns.  If the on-column concentration to run GC/MS confirmation
    is adequate, the laboratory must have permission from the Region before GC/MS performing
    confirmation.

D.  Evaluation:

    1.  Review Form I ARO, the associated raw data (chromatograms and data system printouts) and
       Form X ARO-1 and Form X ARO-2. Confirm that GC/MS confirmation was required by
       ensuring that an individual peak belonging to an Aroclor has an on-column concentration greater
       than or equal to 10 ng/(iL on both GC columns by looking at the quantitation reports.

E.  Action:

    1.  If the quantitative criteria for both columns were met (> 10 ng/(iL), determine whether GC/MS
       confirmation was requested. If it was requested and performed, qualify the data using the
       following guidance (see Table 71):

       a.  If GC/MS  confirmation was not required because the quantitative criteria for both columns
           was not met, but it was still performed, the reviewer should use professional judgment when
           evaluating the data to decide whether the detect should be qualified with "C".

       b.  If GC/MS  confirmation was requested and performed, but not successful for a target
           compound detected by GC/ECD analyses, qualify those detects as "X".
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                                                               Aroclors Organic Analysis
       Table 71. Gas Chromatograph/Mass Spectrometer (GC/MS) Confirmation Actions
Criteria
Aroclor peak was confirmed by GC/MS
Aroclor peak was not confirmed by GC/MS
Action
Detects C
Detects X
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                                                                      Aroclors Organic Analysis
   XII. Compound Ouantitation and Reported Contract Required Ouantitation Limits (CRQLs)

A.  Review Items:

    Form I ARO, Form X ARO-1, sample preparation log sheets, chromatograms, Sample Delivery
    Group (SDG) Narrative, and data system printouts.

B.  Objective:

    The objective is to ensure that the reported quantitative results and CRQLs are accurate.

C.  Criteria:

    Compound quantitation, as well as the adjustment of the CRQL, must be calculated according to the
    equations provided in the method.

D.  Evaluation:

    1.   Examine raw data to verify the correct calculation of all sample results reported by the laboratory.
        Compare data system printouts, chromatograms, and sample preparation log sheets to the reported
        detects and non-detects sample results. Verify that the sample values are reported correctly.

    2.   Verify that the CRQLs have been adjusted to reflect all sample dilutions, cleanup activities,
        Percent Moisture determination (for non-aqueous samples) and other factors that are not
        accounted for by the method.

E.  Action:

    1.   Qualify non-detect results affected by large, off-scale peaks as unusable  "R". If the interference
        is on-scale, provide an approximated quantitation limit "UJ" for each affected compound.

    2.   For non-aqueous samples, if the Percent Moisture is less than 70.0%, no qualification of the data
        is necessary (see Table 72). If the Percent Moisture is greater than or equal to 70.0% and less
        than 90.0%, qualify detects as "J" and non-detects as "UJ". If the Percent Moisture is greater than
        or equal to 90.0%, qualify detects as "J" and non-detects as unusable "R".

    3.   If there  are any discrepancies found, the Region's designated representative may contact the
        laboratory to obtain additional information that could resolve any differences. If a discrepancy
        remains unresolved, the reviewer must decide which value is the best value. Under these
        circumstances, determine if qualification of the data is warranted. Note in the Data Review
        Narrative a description of the reasons for data qualification and the qualification that is applied to
        the data.
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                                                                Aroclors Organic Analysis
       Table 72.  Percent Moisture Actions for Aroclors Analyses for Non-Aqueous Samples
Criteria
%Moisture < 70.0%
70.0% < %Moisture < 90.0%
%Moisture > 90.0%
Action
Detected
Associated Compounds
Non-Detected
Associated Compounds
No qualification
J
J
UJ
R
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                                                                      Aroclors Organic Analysis
                                XIII.  Overall Assessment of Data

A.  Review Items:

    Entire data package, data review results, and (if available) Quality Assurance Project Plan (QAPP),
    and Sampling and Analysis Plan (SAP).

B.  Objective:

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

C.  Criteria:

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

D.  Evaluation:

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

    2.   If appropriate information is available, assess the usability of the data to assist the data user in
        avoiding inappropriate use of the data. Review all available information, including the QAPP
        (specifically the acceptance or performance criteria), SAP, and communication with data user that
        concerns the  intended use and desired quality of these data.

E.  Action:
    1.  Use professional judgment to determine if there is any need to qualify data which were not
       qualified based on the Quality Control (QC) criteria previously discussed.

    2.  Write a brief narrative to give the user an indication of the analytical limitations of the data.
       Note, for Contract Laboratory Program Project Officer (CLP PO) action, any inconsistency of
       that data with the Sample Delivery Group (SDG) Narrative. If sufficient information on the
       intended use and required quality of the data are available, include an assessment of the usability
       of the data within the given context.  This may be used as part of a formal Data Quality
       Assessment (DQA).
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                                                                                 Appendix A

                                 APPENDIX A: GLOSSARY

Analysis Date/Time - The date and military time (24-hour clock) of the injection of the sample, standard,
or blank into the Gas Chromatograph/Mass Spectrometer (GC/MS) or Gas Chromatograph (GC) system.

Aroclor - A trademarked name for a mixture of poly chlorinated biphenyls (PCBs) used in a variety of
applications including additives in lubricants, heat transfer dielectric fluids, adhesives, etc.

Blank - An analytical sample designed to assess specific sources of contamination. See individual
definitions for types of blanks.

Breakdown - A measure of the decomposition of certain analytes (DDT and Endrin) into by-products.

4-Bromofluorobenzene (BFB) - The compound chosen to establish mass spectrometer instrument
performance for volatile analyses.

Calibration Factor (CF) - A measure of the Gas Chromatographic response of a target analyte to the
mass injected.

Case - A finite, usually predetermined number of samples collected over a given time period from a
particular site. Case Numbers are assigned by the Sample Management Office (SMO).  A Case consists
of one or more Sample Delivery Groups (SDGs).

Contract Compliance Screening (CCS) - A screening of electronic and hardcopy data deliverables for
completeness and compliance with the contract.  This screening is performed under USEPA direction by
the Sample Management Office (SMO) Contractor.

Contamination - A component of a sample or an extract that is not representative of the environmental
source of the sample.  Contamination may stem from other samples, sampling equipment, while in transit,
from laboratory reagents, laboratory environment, or analytical instruments.

Continuing Calibration Verification (CCV) - Analytical standard run every 12 hours to verify that the
instrument response at the concentration of the standard is within acceptable limits.

Contract Laboratory Program (CLP) - Supports the USEPA's Superfund effort by providing a range
of state-of-the-art chemical analytical services of known and documented quality.  This program is
directed by the Analytical Services Branch (ASB) of the Office of Superfund Remediation and
Technology Innovation (OSRTI) of USEPA.

Contract Laboratory Program Project Officer (CLP PO) - The Regional USEPA official responsible
for monitoring laboratory performance and/or requesting analytical data or services from a Contract
Laboratory Program (CLP) laboratory.

Decafluorotriphenylphosphine (DFTPP) - Compound chosen to establish mass spectrometer
instrument performance for semivolatile analysis.

Deuterated Monitoring Compounds (DMCs) - Compounds added to every volatile  and semivolatile
calibration standard, blank, and sample used to evaluate the efficiency of the extraction/purge and trap
procedures, and the performance of the Gas Chromatograph/Mass Spectrometer (GC/MS) systems.
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                                                                                   Appendix A

DMCs are isotopically labeled (deuterated) analogs of native target compounds. DMCs are not expected
to be naturally detected in the environmental media.

Field Blank - A blank used to provide information about contaminants that may be introduced during
sample collection.

Field Sample - A portion of material to be analyzed that is contained in single or multiple containers and
identified by a unique sample Number.

Fourteen (14)-Hour Time Period - For pesticide and Aroclor analyses, the fourteen-hour time period
begins at the injection of the beginning of the sequence for an opening Continuing Calibration
Verification (CCV) (instrument blank) and must end with the injection of the closing sequence of the
closing CCV [Individual standard A, B, or C or Performance Evaluation Mixture (PEM)]. The time
period ends after 14 hours have elapsed according to the system clock.

Gas Chromatograph (GC)  - The instrument used to separate analytes on a stationary phase within a
chromatographic column.  The analytes are volatized directly from the sample (volatile), or injected as
extracts (semivolatile, pesticides, and Aroclors). In volatile and semivolatile analyses, the compounds
are detected by a Mass Spectrometer. In pesticide and Aroclors analyses, the compounds are detected by
an Electron Capture Detector (ECD).

Gas Chromatograph/Electron Capture Detector (GC/ECD) - A Gas Chromatograph (GC) equipped
with an Electron Capture Detector (ECD). This is one of the most sensitive gas chromatographic
detectors or halon-containing compounds such as organochlorine pesticides and polychlorinated
biphenyls.

Initial Calibration - Analysis of analytical standards at different concentrations to define the linear range
of an analytical instrument [e.g., Gas Chromatograph/Mass Spectrometer (GC/MS), Gas
Chromatograph/Electron Capture Detector (GC/ECD)].

Internal Standards - Compounds added to every volatile and semivolatile standard, blank, sample, or
sample extract, including the Laboratory Control Sample (LCS), at a known concentration, prior to
analysis. Internal standards are used to monitor instrument performance and quantitation of target
compounds.

Instrument Blank - A blank designed to determine the level of contamination either associated with the
analytical instruments, or resulting from carryover.

Laboratory Control Sample (LCS) - The LCS is an internal laboratory Quality Control (QC) sample
designed to assess [on an Sample Delivery Group (SDG)-by-SDG basis] the capability of the contractor
to perform the analytical method.

m/z -  Mass to charge ratio, synonymous with "m/e".

Matrix - The predominant material of which the sample to be analyzed is composed. For the purpose of
this document, the sample matrix is either aqueous or non-aqueous.

Matrix Effect - In general, the effect of a particular matrix on the constituents with which it contacts.
Matrix effects may prevent efficient purging/extraction of target analytes, and may affect DMC and
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                                                                                   Appendix A

surrogate recoveries.  In addition, non-target analytes may be extracted from the matrix causing
interferences.

Matrix Spike (MS) - Aliquot of the sample fortified (spiked) with known quantities of specific
compounds and subjected to the entire analytical procedure in order to indicate the appropriateness of the
method for the matrix by measuring recovery.

Matrix Spike Duplicate (MSD) - A second aliquot of the same sample that is fortified (spiked) with
known quantities of specific compounds and subjected to the entire analytical procedure in order to
determine precision of the method.

Method Blank - A reagent aqueous sample spiked with internal standards, and surrogate standards (or
DMCs for volatile and semivolatile), that is carried throughout the entire analytical procedure. The
method blank is used to define the level of contamination associated with the processing and analysis of
samples.

Narrative (SDG Narrative) - Portion of the data package which includes laboratory, contract, Case and
sample Number identification, and descriptive documentation of any problems encountered in processing
the samples, along with corrective action taken and problem resolution

Percent Difference (%D) - The difference between two values (usually a true value and a found value),
calculated as a percentage of the true value. The Percent Difference indicates both the direction and the
magnitude of the difference (i.e., the Percent Difference may be either negative, positive, or zero).

Performance Evaluation Mixture (PEM) - A calibration solution of specific analytes used to evaluate
both recovery and Percent Breakdown as measures of performance.

Polychlorinated Biphenyls (PCBs) - A group of toxic, persistent chemicals used in electrical
transformers and capacitors for insulating purposes, and in gas pipeline systems as a lubricant. The sale
and new use of PCBs were banned by law in 1979.

Purge-and-Trap (Device) - Analytical technique (device) used to isolate volatile (purgeable) organics by
stripping the compounds from aqueous by a stream of inert gas, trapping the compounds on an adsorbent
such as a porous polymer trap, and thermally desorbing the trapped compounds onto the Gas
Chromatographic column.

Reconstructed Ion Chromatogram (RIC) - A mass spectral graphical representation of the separation
achieved by a Gas Chromatograph; a plot of total ion current versus Retention Time (RT).

Relative Percent Difference (RPD) - The difference between two values, calculated as a percent relative
to the mean of the two values.

Relative Response Factor (RRF) - A measure of the mass spectral response of an analyte relative to its
associated internal standard.  RRFs are determined by analysis of standards and are used in the calculation
of concentrations of analytes in samples.

Relative Retention Time (RRT) - The ratio of the Retention Time (RT) of a compound to that of a
standard (such as an internal standard).
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                                                                                 Appendix A

Resolution - Also termed separation or percent resolution, the separation between peaks on a
chromatogram, calculated by dividing the depth of the valley between the peaks by the peak height of the
smaller peak being resolved, multiplied by 100.

Resolution Check Mixture - A solution of specific analytes used to determine resolution of adjacent
peaks; used to assess instrumental performance.

Retention Time (RT) - The time a target analyte is  retained on a Gas Chromatograph (GC) column
before elution.  The identification of a target analyte is dependent on a target compound's RT falling
within the specified RT Window established for that compound.  The RT is dependent on the nature of
the column's stationary phase, column diameter, temperature, flow rate, and other parameters.

Sample Delivery Group (SDG) - A unit within a sample Case that is used to identify a group of samples
for delivery. An SDG is defined by the following, whichever is most frequent:

    •   Each Case of field samples received, or;

    •   Each twenty (20) field samples (excluding Performance Evaluation (PE) samples) within a Case,
       or;

    •   Each seven (7) calendar day period [three (3) calender day period for seven (7) day turnaround]
       during which field samples in a Case are received (said period beginning with the receipt of the
       first sample in the SDG).

    In addition, all samples and/or sample fractions  assigned to an SDG must have been scheduled under
    the same contractual turnaround time.  Preliminary Results have no impact on defining the SDG.

Sample Management Office (SMO) - A contractor-operated facility operated under the Contract
Laboratory Analytical Services Support (CLASS) contract, awarded and administered by USEPA.

Sample Number (USEPA Sample Number) - A unique identification number designated by USEPA to
each sample. USEPA Sample Number appears on the Traffic Report/Chain of Custody Record
(TR/COC) which documents information on that sample.

Semivolatile Compounds - Compounds amenable to analysis by extraction of the sample with an organic
solvent. Used synonymously with Base/Neutral/Acid (BNA) compounds.

Statement of Work (SOW) - A document which specifies how laboratories analyze samples under a
particular Contract Laboratory Program (CLP) analytical program.

Storage Blank - Reagent water (two 40.0 mL aliquots) or clean sand stored with volatile samples in a
Sample Delivery Group (SDG).  It is analyzed after all samples in that SDG have been analyzed; and it is
used to determine the level of contamination acquired during storage.

Sulfur Cleanup Blank - A modified method blank that is prepared only when some of the samples in a
batch are subjected to sulfur cleanup.  It is used to determine the  level of contamination associated with
the sulfur cleanup procedure. When all of the samples are subjected to sulfur cleanup, the method blank
serves this purpose. When none of the samples are subjected to sulfur cleanup, no sulfur cleanup blank is
required.
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                                                                                 Appendix A

Surrogates (Surrogate Standard) - For pesticides and Aroclors, compounds added to every blank,
sample [including Laboratory Control Sample (LCS)], Matrix Spike/Matrix Spike Duplicate (MS/MSD),
and standard; used to evaluate analytical efficiency by measuring recovery. Surrogates are not expected
to be detected in environmental media.

Target Compound List (TCL) - A list of compounds designated by the Statement of Work (SOW) for
analysis.

Technical Holding Time - The maximum length of time that a sample may be held from the collection
date until extraction and/or analysis.

Tentatively Identified Compounds (TIC) - Compounds detected in samples that are not target
compounds, internal standards, Deuterated Monitoring Compounds (DMCs), or surrogates.  Up to thirty
(30) peaks, not including those identified as alkanes (those greater than 10% of the peak area or height of
the nearest internal standard), are subjected to mass spectral library searches for tentative identification.

Traffic Report/Chain of Custody Record (TR/COC) - A USEPA sample identification form filled out
by the sampler, which accompanies the sample during shipment to the laboratory and which documents
sample condition and receipt by the laboratory.

Trip Blank - A blank used to provide information about contaminants that may be introduced during
sample transport.

Twelve-hour Time Period - The twelve (12)-hour time period for Gas Chromatograph/Mass
Spectrometer (GC/MS) system instrument performance check, standards calibration [initial or Continuing
Calibration Verification (CCV)], and method blank analysis begins at the moment of injection of the
Decafluorotriphenylphosphine (DFTPP) or 4-Bromofluorobenzene (BFB) analysis that the laboratory
submits as documentation of instrument performance. The time period ends after 12 hours have elapsed
according to the system clock. For pesticide analyses performed by Gas Chromatograph/Electron  Capture
Detector (GC/ECD), the 12-hour time period in the analytical sequence begins at the moment of injection
of the instrument blank that precedes sample analyses, and ends after twelve hours have elapsed
according to the system clock.

Validated Time of Sample Receipt (VTSR) - The date on which a sample is received at the Contractor's
facility, as recorded on the shipper's delivery receipt and Traffic Report/Chain of Custody Record
(TR/COC).

Volatile Compounds - Compounds amenable to analysis by the purge-and-trap technique. Used
synonymously with purgeable compounds.
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                                                                   Appendix B
                APPENDIX B: ORGANIC DATA REVIEW SUMMARY
CASE NO.
LABORATORY
SDGNO.
RE VIEWER NAME
CLP PO: ACTION
SITE
NO. OF SAMPLES/MATRIX
SOWNO. REGION
COMPLETION DATE
FYI
Review Criteria
Preservation
GC/MS or GC/ECD Instrument
Performance Check
Initial Calibration
Continuing Calibration
Verification
Blanks
Deuterated Monitoring
Compound Surrogate Spikes
Matrix Spike/Matrix Spike
Duplicate
Laboratory Control Sample
Regional QA/QC
Internal Standards
GPC Performance Check
Florisil Cartridge Performance
Check
Target Compound Identification
GC/MS Confirmation
Compound Quantitation and
Reported CRQLS
Tentatively Identified
Compounds
System Performance
Overall Assessment of Data
Fraction
TRACE


















LOW/MED


















SVGA


















PEST


















AROCLOR


















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