EPA Region 10 SOP For the Validation of
Polychlorinated Dibenzodioxin (PCDD)
and Polychlorinated Dibenzofuran (PCDF) Data

EPA Region 10
Environmental Services Division
12 00 Sixth Avenue
Seattle, WA 98101

Revision 2.0
January 31, 19 96

APPROVAL:

Quality Assurance Manager:

Barry Towns	Date:

Region 10 Chemists:

Peggy Knight	Date:

Robert Melton

Date:


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TABLE OF CONTENTS

1.0 HOLDING TIME AND PRESERVATION OF SAMPLES 		1

1.1	Objective	1

1.2	Criteria	1

1.3	Action	2

2.0 GC/MS PERFORMANCE CHECK 		3

2.1	Objective	3

2.2	Criteria	3

2.3	Action	3

3.0 INITIAL CALIBRATION 		3

3.1	Objective	4

3.2	Criteria	4

3.3	Action	4

4.0 CALIBRATION VERIFICATION MEASUREMENTS 		4

4.1	Objective	4

4.2	Criteria	4

4.3	Action	5

5.0 SYSTEM PERFORMANCE 		5

5.1	Objective	5

5.2	Criteria	5

5.3	Action	6

6.0 METHOD BLANKS 		6

6.1	Objective	6

6.2	Criteria	6

6.3	Action	6

7.0 RECOVERY OF C-13 LABELED ISOTOPE DILUTION INTERNAL STANDARDS
	6

7.1	Objective	7

7.2	Criteria	7

7.3	Action	7

8.0 INSTRUMENT RECOVERY INTERNAL STANDARDS 		7

8.1	Objective	7

8.2	Criteria	7

8.3	Action	7

9.0 PROJECT AND REGIONAL QUALITY ASSURANCE SAMPLES 		8

9.1	Objective	8

9.2	Criteria	8

9.3	Action	8

10.0 COMPOUND IDENTIFICATION 		8

10.1 Objective	8


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10.2	Criteria	8

10.3	Action		10

11.0 LABORATORY CONTACTS 		10

12.0 OVERALL ASSESSMENT OF THE QUALITY OF THE DATA		11

12.1	Objective		11

12.2	Criteria		11

12.3	Action		11

DATA QUALIFIER DEFINITIONS 		12


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EPA Region 10 SOP For the Validation of
Polychlorinated Dibenzodioxin (PCDD)
and Polychlorinated Dibenzofuran (PCDF) Data

The Office of Quality Assurance (OQA) of EPA Region 10 has
developed the following guidelines which should be used to access
the quality of PCDD and PCDF data from samples originating from
Region 10 sampling sites. This SOP is based upon the data
validation principles specified in National Functional Guidelines
For Organic Data Review. December, 1990, and the quality control
(QC) requirements of EPA Method 1613B, October, 1994, and EPA
Method 8290, Revision 0, 9/94.

The EPA Analytical Operations Branch (AOB) of the Hazardous Site
Evaluation Division in EPA Headquarters recently prepared a draft
SOP for the validation of dioxin/furan data using low resolution
GC/MS and Contract Laboratory Program (CLP) protocol, DFLM01.1.
The title of this AOB SOP is, National Functional Guidelines For
Dioxin/Furan Data Validation. January, 1996. This draft SOP does
not apply for the validation of high resolution GC/MS data from
EPA Methods 1613B and 8290, because CLP protocol DFLM01.1 uses a
different procedure to calibrate the GC/MS system, and because
the quality control requirements of CLP protocol DFLM01.1 are
very different from the QC approach in high resolution methods
1613B and 8290. Therefore, National Functional Guidelines For
Dioxin/Furan Data Validation. January, 1996, will not be used as
the basis for the validation of Method 1613B and Method 8290 high
resolution GC/MS data in EPA Region 10.

The validator of PCDD and PCDF data should obtain a copy of the
site-specific Quality Assurance Project Plan (QAPP) and use the
Data Quality Objectives and QA requirements of the QAPP to assess
the data. This SOP requires that the following criteria be
evaluated when determining the quality of high resolution PCDD
and PCDF data:

1.0	HOLDING TIME AND PRESERVATION OF SAMPLES

1.1	Objective. To determine the validity of the measurement
results based upon EPA requirements for preservation and holding
time of the samples from day of collection to day of extraction.
EPA also has holding time requirements for extracts which is the
time from extraction of the samples to injection of the sample
extracts.

1.2	Criteria. Holding time and preservation requirements for
the measurement of 2,3,7,8-TCDD in water samples under the CWA


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(40CFR Part 136), SDWA, and RCRA have been promulgated and
codified under 40CFR. These regulations require that water
samples be preserved by neutralizing any chlorine residual with
0.008% sodium thiosulfate, and cooling to 4°C using a holding
time of 7 days from day of collection to day of extraction of the
sample. In addition, the maximum holding time of extracts is 40
days from day of extraction to day of injection of the extract.

The holding time and preservation requirements of 2,3,7,8-TCDD
and of other measured PCDD and PCDF isomers in non-water matrixes
have not been promulgated by EPA. Therefore, the data validator
should use the holding time specified in the EPA approved site-
specific Quality Assurance Project Plan (QAPP).

Method 8290, Revision 9/94 specifies that all samples,
except fish and adipose tissue samples, must be stored at
4°C in the dark, extracted within 30 days, and completely
analyzed within 45 days of extraction. Fish and adipose
samples must be stored at -20°C in the dark, extracted
within 30 days, and completely analyzed within 45 days of
collection (see Section 6.4 of Method 8290).

Method 1613B does not set holding times for PCDD or PCDF
isomers. The Method does state that water samples which
contain a chlorine residual should be treated with 80-mg of
sodium thiosulfate per liter of water, samples should be
maintained at 4°C in the dark, and extracts should be
analyzed within 40 days of extraction.

Method 1613B, October, 1994, has recommended a holding time
of one year for tissue samples which are frozen at < -10°C.
Once frozen tissue samples are thawed, tissue samples must
be extracted within 24 hours.

It should be noted that the above reference data validation SOP,
National Functional Guidelines For Dioxin/Furan Data Validation.
January, 1996, does not address either holding time or
preservation requirements for environmental samples which are
measured for PCDDs/PCDFs.

1.3 Action. If 40CFR Part 136 and the QAPP for the samples do
not specify a holding time, then the holding time which is
recommended by applicable EPA method -- Method 1613B or EPA
Method 82 90, Revision 9/94, should be used. Whenever samples or
extracts are analyzed after holding time expiration date, the
results should be considered to be minimum concentrations and
must be qualified with a "J3". Samples which are not preserved
correctly should be qualified with a "J" flag.


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2.0	GC/MS PERFORMANCE CHECK

2.1	Objective. Gas chromatograph/mass spectrometer (GC/MS)
instrument performance checks are performed to ensure mass
resolution, identification, and to some degree, sensitivity.

These criteria are not sample specific. Conformance is
determined using standard materials, therefore, these criteria
should be met in all circumstances.

2.2	Criteria. For the PFK molecular leak, the resolution must
be greater than or equal to 10,000. The deviation between the
exact mass and the theoretical mass (Table 3 in 1613B) for each
of the three to five ions monitored must be less than 5 ppm. If
the mass spectrometer is adjusted the resolution must be tested
again and the resolution documented. (1613B/7.1.2 . 2;

8290/7.6.2.2)

The mass spectrometer shall be operated in a mass-drift
correction mode using PFK to provide lock-masses. Each lock-mass
shall be monitored and shall not vary by more than +/-2 0%
throughout each respective time window. (1613B/7.2.1.2)

Ion abundance ratios. All labeled and unlabeled PCDDs and PCDFs
in the CS1 standard shall be within the QC limits in 1613B Table
3A or 8290 Table 8 for their respective ion abundance ratios.
(1613B/7.2.2; 8290/7.7.2.3)

The HRGC/HRMS must meet the minimum levels in 1613B Table 2. All
labeled and unlabeled analytes in the CS1 calibration standard
must have signal to noise ratios greater than or equal to 10.0.
(1613B/7.2 .3)

The absolute retention time of 13C12-1, 2 , 3 , 4-TCDD shall exceed 25.0
minutes on the DB-5 column, and the retention time of 13C12-
1,2,3,4-TCDD shall exceed 15.0 minutes on the DB-225 column.
(1613B/7.2.4)

The compound pairs in the window defining mixtures shall be
determined. (1613B/7.3)

The height of the valley between the most closely eluted isomers
and the 2,3,7,8 - substituted isomers shall be less than 25%
(1613B/7.4.2)

2.3	Action. Failure to meet either the resolution or the
retention window criteria invalidates all calibration or sample
data collected during the 12 hour time window.

3.0 INITIAL CALIBRATION


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3.1	Objective. Compliance requirements for satisfactory
instrument calibration are established to ensure that the
instrument is capable of producing acceptable qualitative and
quantitative data for PCDDs and PCDFs. Initial calibration
demonstrates that the instrument is capable of producing a linear
calibration curve.

3.2	Criteria. There shall be an initial calibration curve
consisting of five points for each analyte. The initial
calibration curve shall be determined less than 30 days from the
time the first samples of a Sample Delivery Group (SDG) are
measured by the lab. The lab shall use the same calibration
standards with the same lot number, for all internal standards,
and labeled standards used in measuring the initial calibration
curve, verification standards, field samples, and method blanks
on both the primary GC column and on the secondary confirmation
GC column. If an analyte is calculated by the isotope dilution
method, an averaged response factor may be used if the RSD is
less than 20% For analytes calculated by the internal standard
method, an averaged response factor may be used if the RSD is
less than 35%. Otherwise, for either calculation method, the
complete curve must be used (1613B/7.5.4). [There is a variance
with 8290 which requires 20% and 30% respectively and also
requires the use of the average RF.]

3.3	Action. If the Initial Calibration Curve is older that 30
days, or if internal standards or labeled standards used in
measuring of the initial calibration curve, verification
standards, field samples, and method blanks on both the primary
GC column and on the secondary confirmation GC column or not from
the same lot number, then all measurement data should be
qualified with a "J" qualifier and non-detects qualified "UJ".

If the RSD exceeds 20% for those analytes analyzed by isotope
dilution or 35% for those analytes analyzed by the internal
standard method qualify positive results with "J", and non-
detects qualified "UJ". At the reviewer's discretion, a more in-
depth review may be conducted to minimize data qualification by
examining the entire curve and the quantitation method used.

4.0	CALIBRATION VERIFICATION MEASUREMENTS

4.1	Objective. Compliance requirements for satisfactory
instrument calibration are established to ensure that the
instrument remains capable of producing acceptable qualitative
and quantitative data.

4.2	Criteria. The individual analytes shall meet the acceptance
criteria in Table 7 of 1613B. [Method 8290 requires that the


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RRFs of the unlabeled analytes to be within 20% and the labeled
analytes to be within 30%.

It shold be noted that CLP protocol DFLM01.1 require that the
GC/MS system must be calibrated based upon a daily Calibration
Check Standard, whereas, EPA Methods 1613B and 8290 required that
the GC/MS system

4.3 Action. The reviewer should use professional judgement to
determine if it is necessary to qualify the data. The following
are guidelines:

If the %D for an analyte is outside the acceptance window
qualify positive results "J" and non-detected "UJ" for that
analyte. If the ion abundance criteria are not met results
qualify all results for that analyte "R".

5.0	SYSTEM PERFORMANCE

5.1	Objective. The performance of the method by the laboratory
is examined by determination of their initial ability to perform
the method (Initial Precision and Recovery (IPR) study) and
demonstration of continuing ability to perform the analysis
(PAR). See Section 8.2 of Method 1613B for requirements of IPR
data.

As part of measuring system performance, Methods 1613B and 8290
require that samples and standards be measured within require QC
limits. QC criteria such as required relative retention times of
labeled and native isomers, theoretical ion abundance ratios,
recovery limits for OPR and VER standards, and recovery limits
for spiked labeled target compounds must be met in order to
demonstrate that the measurement system is within control limits.

5.2	Criteria. Initial precision and accuracy. All cleanup
steps used in processing samples shall be included in the IPR
study. All analytes shall be within the IPR limits in Table 7 of
1613B. Note that Method 8290 does not require a IPR study.

Ongoing Precision and recovery (PAR). There will be one PAR
sample for each sample set analyzed. All analytes must meet the
PAR limits in Table 7. [There are no requirements for PAR
samples in Method 8290.]

QC limits such as required relative retention times of labeled
and native isomers, theoretical ion abundance ratios, recovery
limits for OPR and VER standards, and recovery limits for spiked
labeled target compounds must be within control limits of the
method.


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5.3 Action. Results for analytes which do not meet either IPR
or PAR requirements should be qualified with either "J" or "UJ".
If an analyte is not recovered for an PAR sample, results must be
qualified with an "R" for that analyte. Failure to meet QC
limits of the method may result in measurement values to be
qualified with a "J" or "UJ". In specific cases where major QC
limits are exceeded, the data validator may determine that the
measurement system is out of control, which would require that
measurement results be qualified with a "J", "UJ", or "R" flag.

6.0	METHOD BLANKS

6.1	Objective. To determine the existence and magnitude of
contamination of samples resulting from laboratory activities.
The criteria for evaluation of blanks will apply to any blank
associated with the samples, including any method blanks,
instrument blanks, field equipment blanks, transfer blanks, trip
blanks, or solvent blanks.

6.2	Criteria.

1.	The criteria for the frequency of extraction and
analysis of method blanks as stated in section 8.5 of Method
1613B shall be followed and demonstrated in the documented
data. The maximum amount of PCDD and PCDF isomer
contamination in method blanks is stated in Table 2 of
Method 1613B.

2.	The method blank must be measured on each GC/MS system
which is used to measure a group of samples. This
requirement includes measuring method blanks on a second GC
column if confirmatory analysis of sample extracts on a
second column is required by the method or by the Lab SOW.

6.3	Action. If the maximum contamination requirements of
specific TCDD and TCDF isomers stated in Table 2 of Method 1613B
are not met, then all isomers in all samples associated with a
method blanks shall be qualified with a "Jl" flag. If the
frequency of measuring method blanks is not met by the laboratory
in the data submitted, then the results of all samples which do
not meet the frequency of extraction and measurement of method
blanks shall be qualified with a "R" flag. Any PCDD or PCDF
measurement in a sample that is also measured in any associated
blank, is qualified with a "U" flag if the sample concentration
is less than 5 times the blank concentration.

7.0 RECOVERY OF C-13 LABELED ISOTOPE DILUTION INTERNAL STANDARDS


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7.1	Objective. Labeled PCDDs and PCDFs are added to each sample
and method blank prior to extraction. The role of these C-13
labeled spiked compounds is to be an internal standard for the
quantitation of native PCDD and PCDF isomers, and to serve as
surrogates for the assessment of method performance in the sample
matrix.

7.2	Criteria. The recovery of each C-13 labeled PCDD and PCDF
isomer using Method 1613B must be within 25-150%. The acceptable
recovery limits for Method 8290 data must be between 40 and 135%.

7.3	Action. If any of the 15 labeled percent recoveries are
outside the guideline windows for individual analytes, the
individual isomer for that sample will be qualified with a "J"
flag. For non-detected PCDD and PCDF compounds whose percent
recoveries are outside the guideline windows for individual
analytes, these will be qualified with a "UJ" flag.

8.0	INSTRUMENT RECOVERY INTERNAL STANDARDS

8.1	Objective. The purpose of adding the two instrument
recovery internal standards (13C12-1, 2 , 3 , 4-TCDD and 13C12-

1,2,3,7,8,9-HxCDD) prior to injecting sample extracts and
standards into the GC/MS is to determine the recovery efficiency
of the extraction and cleanup procedures, to determine if the
GC/MS sensitivity and response are stable during every analytical
run, and to determine if the same amount of extract was injected
into the GC/MS.

8.2	Criteria. The sum of the area counts of two masses for each
of the two instrument recovery internal standards for samples,
blanks, and standards must not vary by more than a factor of four
(-25% to +400%) from the sum of the associated average areas from
the five initial calibration standards.

8.3	Action. The reviewer should use professional judgement to
determine if it is necessary to qualify the data. The following
are guidelines:

1.	If the sum of the two quantitation area counts of either
of the two instrument recovery standards in the samples or
blanks are outside the -25% to +400% window, then positive
results for compounds measured should be qualified with a

" J" .

2.	If the sum of the two quantitation area counts is
greater that 400%, then non-detected compounds should not be
qualified.


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3.	If the sum of the two area counts is less than 25%, then
non-detect compounds should be qualified with a "UJ".

4.	If the sum of the area counts is less than 10%, then
non-detect target compounds should be qualified with a "R".

9.0	PROJECT AND REGIONAL QUALITY ASSURANCE SAMPLES

9.1	Objective: The data validator should consider the data of
samples which are identified as field duplicates, transfer
blanks, trip blanks, blind spikes, blind blanks, and performance
evaluation (PE) samples.

9.2	Criteria. If QA samples are included among the field
samples for measurement by the laboratory, then the data
validator should refer to the applicable QAPP for any QA
requirements regarding QA samples. Results from the measurement
of project and regional QA samples will reflect upon the ability
of the laboratory to report analytical results of known and
documented quality which meet the PARCC requirements of the QAPP.

9.3	Action. The data validator should recommend action in
accordance with Regional specifications and the criteria for
acceptable PE sample results. Poor performance by the laboratory
on blind PE samples may indicate that the laboratory analytical
system is out of control, or that the amount of PCDD and PCDF
isomers reported by the laboratory is an estimated quantity. The
data validator should use her/his professional judgement to
assess if "J" or "R" qualifiers should be placed upon the data
due to the measurement of QA or PE samples.

10.0	COMPOUND IDENTIFICATION

10.1	Objective. The qualitative criteria for target compound
identification have been established by EPA Method 1613B and EPA
Method 8290 to minimize the number of erroneous identifications.
An erroneous identification can be either a false-positive

(reporting a target compound when it is not present in the
sample), or false-negative (not reporting a compound that is
present in the sample). The addition of single or double blind
PE samples among field samples provides ancillary data to support
the laboratory's ability to meet QAPP objectives.

10.2	Criteria. EPA Method 1613B and EPA Method 8290 specify
certain requirements and guidelines for the positive
identification of certain PCDD and PCDF isomers. The most
frequently encountered interfering compounds to the measurement
of PCDDs and PCDFs are chlorinated substances such as


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polychlorinated diphenyl ethers (PCDPEs), polychlorinated
biphenyls (PCBs), polychlorinated alkyldibenzofurans, and
polychlorinated napthalenes that may be found at concentrations
several orders of magnitude higher than the analytes of interest.
Interferences are such a major problem to Methods 1613B and 8290,
that each method requires that PCDPE interference ions be scanned
at the same time that PCDD and PCDF mass ions are measured. Both
methods require that certain PCDF isomers such as 2,3,7,8-TCDF be
measured on a second dissimilar GC column before specific TCDF
identifications can be made.

In this part of the SOP for the validation of PCDD and PCDF data,
the following criteria must be met for a GC peak to be identified
as a PCDD or PCDF (either unlabeled or labeled compound):

1.	The signals for the two exact m/z's being monitored must
be present, and must maximize within plus or minus 2 seconds
of one another (see 1613B/Section 15.1; 8290/Section
7.8.4.1.4).

2.	The signal-to-noise ratio (S/N) of each of the two exact
m/z's must be greater than or equal to 2.5 for a sample
extract, and greater than or equal to 10 for a calibration
standard (see 1613B/Section 15.2; 8290/Section 7.8.4.3).

3.	The ratio of the integrated ion currents (EICPs) of both
the exact m/z's monitored must be within the limits of the
method (see 1613B/Section 15.3; 8290/Section 7.8.4.2).

4.	The relative retention time (RRT) of the peaks
representing a unlabeled 2,3,7,8 substituted PCDD or PCDF
must be within the limits given in the method. The
retention time (RT) of peaks representing non-2,3,7,8-
substituted PCDDs or PCDFs must be within the RT windows
established in the method (see 1613B/Section 15.4;
8290/Section 7.8.4.1.1).

5.	The measurement of 2,3,7,8-TCDF on the primary DB-5 GC
column must be confirmed by analysis on a confirmatory
column such as DB-225, SP-2330, DB-DIOXIN, or equivalent.
All QC requirements of the method must be met on both the
primary and secondary GC columns (see 1613B/Section 15.5;
8290/Section 3.4). If a PCDPE interference peak to the
measurement of 2,3,7,8-TCDF is detected on the secondary GC
column, then the laboratory should remove PCDPE
interferences by additional cleanup procedures such as is
described in one of the following references:

a) Method 1613B. October, 1994, Section 13.1.2 and
Section 13.4 (Alumina column cleanup).


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b) J. R. Ryan, R. Lizotte, and W. H. Newsome, J. of
Chromatography. 303 (1984) 351-360 (Activated
Florisil column cleanup.

6.	If non-PCDPE interferences to the measurement of
2,3,7,8-TCDF on the secondary GC column are present, then
the laboratory should measure 2,3,7,8-TCDF on a third
dissimilar GC column in order to separate the 2,3,7,8-TCDF
peak from the non-PCDPE interference peak. Measurement of
2,3,7,8-TCDF on a third dissimilar GC column requires full
calibration (both initial and calibration verification) on
the third GC column.

7.	The identification of a GC peak (on either primary or
confirmatory GC column) as a PCDF can only be made if no
signal having a S/N > 2.5 is detected at the same retention
time (± 2 seconds) in the corresponding polychlorinated
diphenyl ether (PCDPE) channel. This criteria requires that
the laboratory document the EICP of all PCDPE m/z's which
are scanned (see 8290/Section 7.8.4.4).

8.	The retention times of target compounds must be verified
using reference standards before identifications can be
determined (see 8290/Section 3.3).

9.	The valley height between 2,3,7,8-TCDD and the other
TCDD isomers at m/z 319.8965, and between 2,3,7,8-TCDF and
the other TCDF isomers at m/z 303.9016 shall not exceed 25%
on their respective columns (see 1613B/Section 14.4.2.2;
8290/Section 7.9.7.1.1 and 7.9.7.1.2).

10.3 Action. The validator of the data must use his/her
professional judgement in evaluating the data using the above
identification criteria. Generally, if all of the above criteria
for the identification of PCDD and PCDF isomers are not met, then
each reported positive measurement of a PCDD or PCDF isomer
should be considered a non-detect, and therefore flagged with a
"R" flag. The "R" flag in this case is based upon the fact that
the presence of the isomer in the sample can not be corroborated
by the laboratory data.

11.0 LABORATORY CONTACTS

Provide and attached to the validation memo a copy of all
telephone logs and correspondence with the laboratory concerning
the quality of data submitted by the laboratory.


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12.0	OVERALL ASSESSMENT OF THE QUALITY OF THE DATA

12.1	Objective. The overall assessment of a data package is a
brief narrative in which the data reviewer expresses concerns and
comments of the quality of the data. The overall assessment of
the data should be made after the data validator considers the
DQOs and other QA requirements of the site-specific QAPP. It
should be noted that the data reviewer does not determine or
report the useability of the data. This determination is made by
the Site Manager and by the other users of the data.

12.2	Criteria. The criteria for overall assessment is the QA
and DQO criteria of the QAPP and the criteria listed above in
this data validation SOP.

12.3	Action. Use professional judgement to determine if there
is a need to further qualify the data. Write a brief narrative
to give the user an indication of any analytical limitations of
the data. Note if there are any inconsistencies observed between
the raw data and the laboratory reported sample results.


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DATA QUALIFIER DEFINITIONS

U - The analyte was analyzed for, but was not detected above
the sample quantitation limit. The associated numerical value
indicates the approximate concentration necessary to detect the
analyte in this sample.

If a decision requires quantitation of the analyte below the
associated numerical level, reanalysis or alternative
analytical methods should be considered.

J - The analyte was analyzed for and was positively identified,
but the associated numerical value may not be consistent with the
amount actually present in the environmental sample.

A subscript may be appended to the "J" that indicates which
of the following quality control criteria were not met:

J1 Blank Contamination: indicates possible high bias
and/or false positives.

J2 Calibration range exceeded: indicates possible low
bias.

J3 Holding times not met: indicates low bias for most
analytes with the exception of common laboratory
contaminants and chlorinated ethenes (i.e.:
trichloroethene, 1,1-dichloroethene, vinyl chloride).

J4 Other QC parameter outside control limits: bias
not readily determined.

J5 Other QC parameter outside control limits. The
reported results appear to be biased high. The actual
value of target compound in the sample may be lower
than the value reported by the laboratory.

J6 Other QC parameter outside control limits. The
reported results appear to be biased low. The actual
value of target compound in the sample may be higher
than the value reported by the laboratory.

J7 2,3,7,8-TCDF is reported from the value measured on
the primary GC Column, DB-5. The reported value on the
primary GC column may be biased high because other TCDF
isomers may elute at this same retention time. The
actual value of 2,3,7,8-TCDF in the sample may be lower
than the value reported by the laboratory due to


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possible co-elution of other TCDF isomers on the primary GC
column.

J8 The measurement of 2,3,7,8-TCDF on the secondary GC
column used by the Laboratory appears to have chemical
interferences which co-elute with the native 2,3,7,8-
TCDF GC peak. Therefore, the value of 2,3,7,8-TCDF on
the secondary GC column is rejected and is qualified
with a "R" flag. Consequently, the measured value of
2,3,7,8-TCDF on the primary GC column should be used as
the measured value of 2,3,7,8-TCDF in the sample. The
reported value of 2,3,7,8-TCDF on the primary GC column
is qualified with a "J8", and may be biased high
because other TCDF isomers may elute at this same
retention time. The actual value of 2,3,7,8-TCDF on
the primary GC column may be lower than the value
reported by the laboratory due to possible co-elution
of other TCDF isomers.

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

Resampling and reanalysis are necessary to confirm or
deny the presence of the analyte.

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

If a decision requires quantitation of the analyte
close to the associated numerical level, reanalysis or
alternative analytical methods should be considered.

13


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