[Meeting Minute Index] [RL74 TIM #1 Minutes]
|
Date: |
March 11, 1999 |
|
Time: |
10:30 A.M. - 12:00 P.M. |
|
Place: |
Parsons Engineering Science, Austin office |
|
Subjects: |
Laboratory Status |
Participants:
|
Participant |
Organization |
|
Brian K. Murphy |
CSSA ENV |
|
Jo Jean Mullen |
AFCEE/ERD |
|
Rene G. Hefner |
AFCEE/ERC |
|
Nancy Stine |
AMC CONF |
|
Dave McCollough |
AMC CONF |
|
Ma Thong |
AMC CONF |
|
Beth Shively |
AFCEE/ERC |
|
Garry Earls |
Parsons ES, St. Louis |
|
Greg Jones |
Parsons ES, Atlanta |
|
Peter Holland |
Parsons ES, Austin |
|
Julie Burdey |
Parsons ES, Austin |
|
Susan Roberts |
Parsons ES, Austin |
|
Karuna Mirchandani |
Parsons ES, Austin |
|
Tammy Chang |
Parsons ES, Austin |
Minutes prepared by Julie Burdey, Parsons ES.
Prior to conferencing in participants from the contracting office of Air Mobility Command (AMC CONF), Parsons ES-St. Louis, and Parsons ES-Atlanta, there was some discussion regarding the U.S. Environmental Protection Agency’s (EPA’s) investigation of ITS Laboratory. This discussion is summarized in the following paragraphs:
Brian Murphy, CSSA, indicated that he recently spoke with Guy Tidmore at EPA regarding their investigation of ITS. Mr. Tidmore told Brian that at least four, and up to eight, people may be indicted at ITS. Mr. Tidmore also told Brian that EPA plans to not accept any VOC or SVOC data from ITS, but they haven’t found a problem with metals data from ITS. Jo Jean Mullen, AFCEE/ERD, said that, during AFCEE’s audit of ITS, ITS personnel reported that they weren’t following their standard operating procedures (SOP). However, Mr. Murphy responded, we cannot prove that they weren’t. He added that legally, we can’t not accept the metals data. Ms. Mullen responded that, if ITS personnel say in court that they didn’t follow the SOP or the project required procedures, then metals data can be thrown out.
Mr. Murphy said that the U.S. Army Corps of Engineers (USACE) is going to have to spend $200 million to fix their problem associated with the fraudulent ITS data. He added that most contractors don’t know the extent of the problem. Ms. Mullen said that Earth Tech and Rust are now going through what Parsons ES did. When they request information from ITS, ITS only sends part of it, then they have to ask for it again, etc. Ms. Mullen said that Earth Tech’s lawyers are going to say that ITS is in breach of contract.
Mr. Murphy added that he mentioned to Mr. Tidmore at EPA that ITS was trying to get CSSA, AFCEE, and Parsons ES to change data quality objectives (DQOs). Mr. Tidmore said that EPA is going to come out with a position on ITS. The position letter will be sent to ITS, but Mr. Tidmore will send a copy to Mr. Murphy, who will send a copy to AFCEE and Parsons ES. Mr. Murphy also said that Mr. Tidmore told him that EPA has audited other labs to make sure they are not following the same fraudulent practices that ITS was, and they haven’t found any labs doing that.
The conference call was initiated with Ms. Mullen’s description of her concerns regarding the February 26 letter from Garry Earls, Parsons ES Program Manager, to Nancy Stine, AMC Contracting Officer. The letter addressed Parsons ES’ proposal to resolve the ITS data problem at CSSA. Ms. Mullen has concerns regarding the second paragraph on page 2 of the letter which implies that AFCEE’s QAPP requirements are too stringent. Ms. Mullen feels that this statement is inappropriate and that the Parsons ES Program Manager does not have a technical understanding as to why the DQOs are set as they are.
Ms. Mullen added that she would like to allow laboratories to follow EPA contract laboratory program (CLP) requirements, but CSSA can’t use CLP data. Ms. Stine then stated that Parsons is having difficulty finding a laboratory that can meet the AFCEE QAPP requirements. Ms. Mullen responded that she did not think that is necessarily accurate. She said she has not seen all of the variances from all of the laboratories. AFCEE will consider variances, as long as they aren’t outlandish. She added that final approval of variances would ultimately have to come from the regulatory agencies. After EPA comes on board, AFCEE won’t be able to allow any variances without approval from EPA.
At this point, the group agreed to discuss one laboratory (O’Brien & Gere) that is being considered for work under DO23 of the AFCEE contract. Susan Roberts noted that, although this laboratory was not currently being considered for work under orders RL33 and RL53 of the AMC contract, this discussion would serve as a “case study” for the types of problems Parsons ES is experiencing regarding laboratory subcontracting. Requests for proposal (RFPs) for RL33 and RL53 were sent to four additional laboratories on March 4 based on input from AFCEE. Bids and variances were received on March 10, which did not allow sufficient time for Parsons chemists to review the packages prior to this conference call.
Regarding the O’Brien & Gere package, Ms. Mullen said that the preliminary data package that the laboratory sent was basically a CLP package. O’Brien & Gere’s variances said that they would use CLP-like forms, and also included text which implied use of CLP procedures.
Ms. Roberts then introduced tables that Parsons ES prepared to summarize all of the major variances received by labs proposing on the CSSA analytical work. These tables are provided as Attachment A. Karuna Mirchandani indicated that the O’Brien & Gere package submitted to AFCEE was CLP-like, but that the format is still under discussion. O’Brien & Gere is currently trying to work through AFCEE’s concerns regarding the format. She added that technical issues associated with O’Brien & Gere include elevated reporting limits (RLs) and wider quality control (QC) acceptance criteria.
Ms. Mullen responded that those analytes for which O’Brien & Gere have requested elevated RLs, are the same analytes for which they want wider QC acceptance criteria. Ms. Mullen said that they can have one or the other. She added that, if you look at the CLP program and compare the reporting limits and acceptance criteria allowed by that program, you’ll notice the numbers that O’Brien & Gere has requested in their variances are the same as the CLP numbers, assuming they are even following CLP.
Ms. Mirchandani indicated that Parsons could request O’Brien & Gere’s SOPs and control charts for each of the parameters we are reviewing. Parsons could review each of the SOPs to make sure that O’Brien & Gere is not just following CLP requirements, and that they have a history of needing the wider QC acceptance criteria. Ms. Mullen responded that this effort would take a lot of time for Parsons, and that it would be difficult to schedule around this. Ms. Mirchandani clarified that Parsons would only review each compound for which a variance has been requested. Ms. Roberts added that Parsons wouldn’t know how long this would take until Parsons received the SOPs.
Greg Jones, Parsons ES-Atlanta, added that Parsons ES needs to determine if O’Brien & Gere is just providing a CLP-like package, or if they are following CLP procedures. He added that CLP procedures have side limits designed for pushing through a lot of data of known quality, not necessarily of high quality. Parsons would have to verify that O’Brien & Gere’s SOPs follow SW-846. Mr. Jones said that lab’s SOPs are usually based on SW-846, but they can also be based on CLP requirements. O’Brien & Gere has told Parsons that they are following SW-846 but Parsons has not reviewed their SOPs to verify this.
Ms. Mullen added that SW-846 provides guidelines. Laboratories say that they are using SW-846, but in reality they are mixing SW-846 and CLP, and taking the loosest requirements from each. Some examples include using the practical quantitation limit (PQL) as the nondetect (ND) value; not using the AFCEE “U” or “F” flag; applying the “U” flag where AFCEE would have none; and adjusting method detection limits (MDLs) and reporting limits (RLs) for dry weight. Ms. Mullen added that these are very basic differences that go to the heart of reporting, and that AFCEE does not allow CLP reporting, period.
Mr. Earls noted that it sounded like O’Brien & Gere is not a viable laboratory for the CSSA project. Ms. Mullen responded that she didn’t know. O’Brien & Gere is in Dames & Moore’s contract laboratory program and they say O’Brien & Gere can do AFCEE QAPP analytical testing. O’Brien & Gere has said themselves that they can do it. However, by looking at the variances, Ms. Mullen said she can’t tell.
Mr. Jones indicated that, from the standpoint of a laboratory manager, if the laboratory has requested variances, that means that if they don’t get the variances approved, they can’t do it. Ms. Mullen responded that that isn’t necessarily true. AFCEE has seen other labs revise their variance requests based on specific project needs. Mr. McCollough then asked if O’Brien & Gere might be acceptable based on a more rigorous demonstration of their need for these variances.
Ms. Mullen responded that some variances would not be
accepted by AFCEE. AFCEE will not
accept CLP reporting, CLP flagging, nor CLP QA/QC. At this point, all agreed to discuss each variance requested
by O’Brien & Gere, summarized in Tables 2, 3, and 4 in
Attachment
4-A. The results of these
discussions regarding specific O’Brien & Gere variances are summarized
in Attachment 4-B.
After each of the variances were discussed as noted in Attachment 4-B, Ms. Roberts said that Parsons ES would move forward to try to get O’Brien & Gere on board for the CSSA project. Ms. Mullen added that she felt that Parsons could handle whatever O’Brien & Gere can’t do, and that CSSA is willing to pay the additional costs. Parsons just needs to notify AFCEE of the additional effort involved.
Ms. Stine then asked what the Parsons plan is regarding the rework for RL17 and RL33, and when AMC can expect a schedule for the rework. Ms. Roberts responded that Parsons can put together a general schedule, but it is difficult to estimate how long actions will take. Our prior experience cannot be used to estimate how long it will take to get these laboratory issues resolved. Parsons can provide a schedule which includes assumptions about how long it will take for each step, but prefers not to give specific dates, if that is acceptable to AMC and AFCEE. Ms. Mullen agreed that would be adequate for CSSA’s needs.
Ms. Stine also asked if AFCEE, CSSA, and Parsons all agree on the level of effort required for the resampling (i.e. is Parsons going to resample everything?). Ms. Mullen responded that complete resampling may not be necessary. She indicated that input from the regulators would be required. Ms. Roberts indicated that Parsons would likely propose no resampling at locations which had high levels of contaminants detected, since ITS’ problem affects non-detects and low level detects. Ms. Mullen agreed, and reiterated that approval for the reduced resampling effort must be obtained from the regulatory agencies.
Ms. Roberts indicated that the schedule for the ressampling effort will be provided on March 31, 1999, and AFCEE and AMC agreed to this date.
Mr. Murphy indicated that CSSA would like to get two labs on board for soils, for a total of three laboratories. Mr. Earls noted that there would be additional expense involved with that. Mr. Murphy agreed, and asked that Parsons ES submit a cost estimate for additional lab procurement along with the schedule.
Ms. Stine asked how the rework is being charged. Mr. Earls responded that Parsons has set up its own internal job number for these efforts. Parsons is trying to pursue ITS, ITS’ insurance company, and ITS’ parent company for compensation.
Mr. Murphy repeated some of the information that was discussed during the pre-conference discussion. He noted that EPA will be indicting 4 to 8 people at ITS; that EPA has found the VOC and SVOC data to be invalid; and that EPA has not found anything wrong with the metals data. Mr. Earls noted that Parsons would like to use the maximum amount of ITS data that meets CSSA’s requirements.
Attachment 4-A
Table 1. List of Labs Responding to RFP for DO23
|
Project |
Laboratory Name and Date Submitted |
General Comments |
Proposed Cost |
Report Forms |
||
|
Format |
Electronic Deliverable |
Flag |
||||
|
DO23 |
Savannah (Feb 98) |
Declined to bid. |
No Bid |
|
|
|
|
DO23 |
Ceimic (Feb 98) |
Has never done AFCEE work according, to Ceimic contact. |
$50,770 |
CLP - like |
|
|
|
DO23 |
DHL Analytical (Feb 98) |
Declined to bid. |
No Bid |
|
|
|
|
DO23 |
Ecology (Sept 98) |
Can’t provide results for full AFCEE list of compounds. |
$25,840 |
Reporting unit for soil: µg/kg, for water: µg/L |
|
|
|
DO23 |
EMAX (Sept 98) |
Can’t do AFCEE flags, did not meet variances requested on another AFCEE project. |
$34,036 |
In-house reporting formats |
|
Different flags |
|
DO23 |
O’Brien & Gere (Sept 98) |
In Dames & Moore contract lab program (CLP), currently doing AFCEE work, cooperative in providing information. Consider to use. |
$33,474 |
All positive results with 2 sig. fig. In-house report formats |
Does not include TICs |
|
|
DO23 |
Parsons ES Lab (Feb 98) |
Declined to bid. |
No Bid |
|
|
|
Note: Shaded line represents laboratory preferred by Parsons ES for project analyses.
Attachment 4-A (continued)
Table 1. List of Labs Responding to RFP for RL33 and RL53
Project |
Laboratory Name and Date Submitted |
General Comments |
Proposed Cost |
Report Forms |
||
|
Format |
Electronic Deliverable |
Flag |
||||
|
RL33/RL53 |
Accutest (Dec 98) |
Following SW-846 instead of AFCEE QAPP 3.0. No attempt to meet AFCEE QAPP requirements. |
$49,195 |
CLP - like |
|
CLP - flag |
|
RL33/RL53 |
APPL (Mar 99) |
Consider for use based on latest preliminary response to RFP received March 10, 1999. |
NA |
|
|
|
|
RL33/RL53 |
Chemron (July 98) |
Missed holding times and misreported results to CSSA. |
$44,760 |
|
|
|
|
RL33/RL53 |
Columbia (Dec 98) |
Declined to bid. |
No Bid |
|
|
|
|
RL33/RL53 |
Data Chem Lab (Feb 98, Mar 99) |
Declined to bid on first round. Consider for use based on latest preliminary response to RFP received March 10, 1999. |
$56,230 |
|
|
|
|
RL33/RL53 |
EA (Dec 98) |
Declined to report AFACEE format unless variances were granted, poor customer service, no historical control charts. |
$41,304 + 20% (to manage additional AFCEE QA/QC issues) |
CLP–like Currently the lab is working on the development of AFCEE QAPP 3.0 report formats. |
|
|
|
RL33/RL53 |
Kemron (Mar 99) |
Consider for use based on latest preliminary response to RFP received March 10, 1999. |
NA |
|
|
|
|
RL33/RL53 |
Paragon (Dec 98) |
Poor reference. |
$45,058 |
Level IV CLP - like |
|
|
|
RL33/RL53 |
PDP (Mar 99) |
Submitted inadequate variances. |
$50,230 |
PDP does not have QAPP 3.0 forms. Currently under development. |
|
|
|
RL33/RL53 |
QA (July 98) |
No longer exists. |
$40,383 |
|
|
|
|
RL33/RL53 |
Quanterra (July 98) |
Missed holding times and turn-around times, poor customer service on other Parsons projects. |
$43,623 |
AFCEE QAPP 2.0 |
|
|
Note: Shaded line represents laboratory preferred by Parsons ES for project analyses. Since RFPs were recently sent to labs and responses are not completely in, final determination of recommended laboratory is not yet possible.
Attachment 4-A (continued)
Table 2. Summary of Variances for Metals and Explosives
|
|
|
SW-7000 Metals |
SW7470A/7471A |
SW-8330 |
||||||||
|
|
Reporting Limits |
Lab Control Sample |
Calibration |
Reporting Limits |
Substitute with ICP method |
Reporting Limits |
Post-spike & Method of Standard Addition (MSA) |
Reporting Limits |
Surrogates |
Calibrations |
Lab Control Sample |
Confirmation |
|
Accutest |
Follows SW-846, use the lowest calibration concentration as the RL |
Only use to determine method compliance if MS/MSD fails |
Use one standard and one blank |
Higher RLs |
|
|
No MSA, no matrix check dilutions |
Based on SW 846 |
|
|
|
|
|
APPL |
Zn: 0.05 ppm for water and 5.0 ppm for soil |
|
|
|
Cd |
|
|
|
|
|
|
|
|
Ceimic |
W: 7 elements with higher RL |
|
|
|
|
|
|
|
|
|
|
|
|
Chemron |
|
Do not reanalyze sample when LCS is high but sample shows ND |
|
No MDL study for Cd |
|
|
|
|
|
|
|
|
|
Columbia (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
Data Chem |
|
|
|
|
|
|
|
Higher RL for 3 nitrotoluene isomers, reports o- and p-nitrotoluene together |
|
|
Allow one of 7 compds with 75% as LCL to be lowered to 50% |
|
|
DHL Analytical (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
EA |
RL verification: %R 50%-150% |
Different corrective action |
|
W: 2 compds with higher RL S: 1 compd with higher RL RL and LCS have same variances as 6010B |
|
W: higher RL |
|
|
Only reanalyze when LCS, MB and sample failed |
Follow SW8000B Sec. 7.7 |
80% of analytes meet acceptance criteria |
2nd column confirmation does not have to meet the acceptance criteria |
|
Ecology |
S: Zn is missing from the list |
|
|
|
Pb, As, Cd |
|
|
|
|
|
|
|
|
EMAX |
W: 6 elements with higher RL S: 3 elements with higher RL |
|
|
|
|
|
|
|
|
|
|
|
|
Kemron (bid not yet available) |
|
|
|
|
|
|
|
|
|
|
|
|
Attachment 4-A (continued)
Table 2. Summary of Variances for Metals and Explosives
|
|
|
SW-7000 Metals |
SW7470A/7471A |
SW-8330 |
||||||||
|
|
Reporting Limits |
Lab Control Sample |
Calibration |
Reporting Limits |
Substitute with ICP method |
Reporting Limits |
Post-spike & Method of Standard Addition (MSA) |
Reporting Limits |
Surrogates |
Calibrations |
Lab Control Sample |
Confirmation |
|
O’Brien & Gere |
1: Zn has higher RL than AFCEE |
|
|
|
|
2: MDL> half of AFCEE’s RL |
|
|
|
|
|
|
|
Paragon |
W: 3 elements with higher RL S: 2 elements with higher RL |
|
|
|
|
|
|
|
|
|
|
|
|
Parsons ES Lab (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
PDP |
|
|
|
|
|
|
|
|
|
|
|
|
|
QA (closed) |
|
|
|
|
|
|
|
|
|
|
|
|
|
Quanterra |
|
|
|
|
|
|
|
|
|
|
|
|
|
Savannah (declined) |
-- |
-- |
-- |
-- |
-- |
|
|
-- |
-- |
-- |
-- |
-- |
Attachment 4-A (continued)
Table 3. Summary of Variances for Volatile Organic Compounds
|
|
SW 8260B |
|||||||||||
|
Reporting Limits |
Laboratory Control Sample |
Initial Calibration Verification |
Continuing Calibration Verification |
Internal Standards |
2nd
source Calibration Verification |
Surrogates |
Method
Blank |
Retention
Time |
System
Performance Check Compounds |
Instrument
Tuning |
Accuracy |
|
|
Accutest |
Follows SW-846, use the lowest calibration concentration as the RL |
Only use to determine method compliance if MS/MSD fails |
|
Different acceptance criteria |
|
|
Do not automatically
re-extract when surrogate fails |
|
Follow criteria for RT in
the SW 846 |
|
|
|
|
APPL |
W: 20 compds with higher RL
S: 4 compds with higher RL |
|
|
|
|
|
|
|
|
|
|
|
|
Ceimic |
1 ppb for water;
5 ppb for soil |
Only reanalyze sample when
%R is higher than the UCL and analyte is found in the sample |
If %RSD>15%, use cc of
linear regression or avg.
RF to check |
1 ppb as the lowest cal std
and 2 ppb for 1,2-dibromo-3-chloropropane (w); no corrective action if
%Drift<30% and samples do not contain target analytes |
|
|
|
Increase limit for MeCl2
to 5 ppb |
|
|
|
Many variances based on
historically developed control limits |
|
Chemron |
Report m- & p-Xylene
together |
Only reanalyze when sample
> RL |
|
|
|
|
|
Only reanalyze when MB >
RL |
|
|
|
|
|
Columbia
(declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
Attachment 4-A (continued)
Table 3. Summary of Variances for Volatile Organic Compounds
|
|
SW 8260B |
|||||||||||
|
|
Reporting
Limits |
Laboratory
Control Sample |
Initial
Calibration Verification |
Continuing
Calibration Verification |
Internal
Standards |
2nd
source Calibration Verification |
Surrogates |
Method
Blank |
Retention
Time |
System
Performance Check Compounds |
Instrument
Tuning |
Accuracy |
|
DHL Analytical (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
Data Chem |
|
|
0.5 ppb is the lowest
calibration point, includes a 0.3 ppb RL check |
0.5 ppb is the lowest
calibration point; includes a 0.3 ppb RL check; uses mean RF instead
of mean RSD; allows up to 4 analytes >20% but <30% |
|
|
Uses 3 surrogates |
Higher RL for MeCl2 |
|
|
|
|
|
EA |
W: 29 compds with higher RL;
S: 10 compds with higher RL |
80% of analytes meet
acceptance criteria |
|
Follow SW8000B
Sec 7.7 |
Wider EICP area |
Follow SW8000B Sec 7.7 |
Only reanalyze when MB, LCS
and sample are failed |
Wider range for MeCl2
and acetone |
|
Dec. 1 mini. RF
requirement; Follow
SW8000B Sec. 7.5 |
Alternative tuning criteria |
|
|
Ecology |
Report
m-, p-Xylene together; Higher
RL for 3 compds; 15 compds are missing from the list
modified
MDL procedure |
No
reanalyze when LCS is high |
|
Lowest
cal pt. for water is 1 ppb and for soil is 5 ppb except ketones |
|
|
|
Higher
limits for acetone and MeCl2 |
|
|
|
|
Attachment 4-A (continued)
Table 3. Summary of Variances for Volatile Organic Compounds
|
|
SW 8260B |
|||||||||||
|
|
Reporting
Limits |
Laboratory
Control Sample |
Initial
Calibration Verification |
Continuing
Calibration Verification |
Internal
Standards |
2nd
source Calibration Verification |
Surrogates |
Method
Blank |
Retention
Time |
System
Performance Check Compounds |
Instrument
Tuning |
Accuracy |
|
EMAX |
Report m- and p-Xylene
together;
W: 14 compds with higher RL |
|
|
Only apply to analytes of
concern |
Uses 4 IS instead of 3 |
Only apply to analytes of
concern |
Uses 3 surrogates instead
of 4 |
|
|
|
|
|
|
Kemron (bid not yet
evaluated) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
O’Brien & Gere |
3a: W: 4 compds with
higher RL
3b:
S: 4 compds with higher RL
3C:
report m-, p-Xylene together
3d:
adjusted by dry wt. |
|
|
|
|
4:
50-150%R for dichlorodi-fluoromethane |
5:
No reextraction for med-level soil samples with one surrogate
failed |
6:
Inc limit for MeCl2 to 1 ppb |
|
|
|
7:
50 - 150%R for dichloro-difluoro-methane |
|
Paragon |
Higher limit for MeCl3 |
Wider range for MeCl3 |
%RSD<50% for MeCl3 |
MeCl3 +/- 30% |
Use different IS |
MeCl3 +/- 30% |
|
|
|
|
|
|
|
Parsons ES Lab (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
PDP |
Uses
the lowest calibration point as the RL;
Report m-&p-Xylene together |
|
|
|
|
|
|
|
|
|
|
|
Attachment 4-A (continued)
Table 3. Summary of Variances for Volatile Organic Compounds
|
|
SW 8260B |
|||||||||||
|
|
Reporting
Limits |
Laboratory
Control Sample |
Initial
Calibration Verification |
Continuing
Calibration Verification |
Internal
Standards |
2nd
source Calibration Verification |
Surrogates |
Method
Blank |
Retention
Time |
System
Performance Check Compounds |
Instrument
Tuning |
Accuracy |
|
QA |
|
|
|
|
|
|
|
|
|
|
|
|
|
Quanterra |
Report m- & p-Xylene
together;
W: 19 compds with higher RL;
S: 2 compds with higher RL |
|
|
|
|
|
|
|
|
|
|
|
|
Savannah (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
Attachment 4-A (continued)
Table 4. Summary of Variances for Semivolatile Organic Compounds
|
Laboratories |
SW-8270C |
||||||||||
|
Reporting
Limits |
Initial
Calibration Verification |
Continuing
Calibration Verification |
Surrogates |
Retention
Time |
2nd
Source Calibration Verification |
Internal
Standards |
Method
Blank |
Laboratory
Control Sample |
Instrument
Tuning |
Accuracy |
|
|
Accutest |
Follows
SW-846, use the lowest calibration concentration as the RL |
|
20%D of ICV |
|
Follow the RT criteria in
SW 846 |
|
|
|
Only be used to determine
method compliance if MS/MSD failed |
|
|
|
APPL |
|
|
|
|
|
|
|
|
|
|
|
|
Ceimic |
|
|
|
|
|
|
|
|
|
|
|
|
Chemron |
Report 3- & 4-Methyl
phenol together |
|
|
|
|
|
|
|
Do not reanalyze sample
when LCS is high but sample shows ND |
|
|
|
Columbia (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
DHL Analytical (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
Data Chem |
|
|
|
|
|
|
|
|
|
|
|
|
EA |
|
Follow SW8000B Sec. 7.7 |
Follow SW8000B Sec. 7.7 |
Only reanalyze when MB, LCS
and sample failed |
|
Follow SW8000B Sec. 7.7 |
Wider EICP acceptance range |
exception for all common
phthalates |
80% of analytes meet
acceptance criteria |
Alternative tuning |
W: 5 compounds
S: 5 compounds |
|
Ecology |
3 compounds with higher RL |
|
|
|
|
|
|
|
|
|
|
Attachment 4-A (continued)
Table 4. Summary of Variances for Semivolatile Organic Compounds
|
|
SW-8270C |
||||||||||
|
Laboratories |
Reporting
Limits |
Initial
Calibration Verification |
Continuing
Calibration Verification |
Surrogates |
Retention
Time |
2nd
Source Calibration Verification |
Internal
Standards |
Method
Blank |
Laboratory
Control Sample |
Instrument
Tuning |
Accuracy |
|
EMAX |
|
Only apply to analytes of
concern |
Only apply to analytes of
concern |
|
|
Only apply to analytes of
concern |
|
|
Only apply to analytes of
concern |
|
|
|
Kemron (bid not yet
available) |
|
|
|
|
|
|
|
|
|
|
|
|
O’Brien & Gere |
8:
Adjusted by dry wt. |
|
|
|
|
|
|
|
|
|
|
|
Paragon |
W: 2 compounds with higher
RL |
|
30%D of ICV for 6 compounds |
|
Eliminated |
|
Compare to CCV instead of
ICAL |
|
|
|
Wider ranges for 6
compounds (both w and s) |
|
Parsons ES Lab (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
PDP |
|
|
|
|
|
|
|
|
|
|
|
|
QA (closed) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
|
Quanterra |
|
|
Higher %R for
11 poor performers |
|
|
+/-30% for 11 poor
performers |
|
|
|
|
Wider range for
hexachlorocyclo-pentadiene |
|
Savannah (declined) |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
Attachment 4-B
O’Brien & Gere Variances and Conference Call Agreements
|
Cross-Reference
No. from Att. A |
Section and Page in AFCEE QAPP 3.0 |
Variance |
O’Brien & Gere Justification |
Conference Call Discussion |
Final Decision from AFCEE |
|
Detection
Limits: |
|||||
|
2 |
4.3.2 Reporting Limits,
page 4-6 |
The following MDL is more
than one-half of the RL: mercury
(soil) |
The MDL (0.06 mg/kg) does
not support the requirement of one half the RL (0.1 mg/kg).
However, the AFCEE RL can still be met. |
This comment addresses soil
reporting limits, but the contract currently planned under DO23 is
only for analysis of groundwater samples; therefore, this variance
does not apply. Furthermore,
there are no established background levels for groundwater at CSSA.
For soil analyses, the established background “PQL” is 0.1
mg/kg. O’Brien and
Gere’s required MDL of 0.06 mg/kg is only slightly above the AFCEE
requirement of 0.05 mg/kg. |
Approved. |
|
1 |
7.2.15-1 Reporting Limits
for Method SW6010B, page 7‑106 |
Lab can meet the required
soil RL’s, with the following exception:
Zinc 2.0 mg/kg |
Based on the MDL study
submitted, RLs must be elevated slightly to achieve AFCEE’s
requirement of MDLs one half of the RLs. |
The RL listed in AFCEE QAPP
3.0 for zinc (method 6010B) is 1.0 mg/kg. However, the background “PQL” value is 2.0 mg/kg, the
value that O’Brien & Gere is proposing.
Although this does not apply to the analyses planned under
DO23, this variance is acceptable to AFCEE. |
Approved. |
|
3a |
7.2.9-1 Reporting Limits
for Method SW8260B, page 7‑59, 60 |
Lab can meet the required aqueous RL’s, with the following exceptions: 1,1,2,2-Tetrachloroethane 0.5 ug/l Methylene chloride 2.0 ug/l Naphthalene 1.0 ug/l
Styrene
0.5 ug/l |
1,1,2,2-Tetrachloroethane: A reactive compound and the low standards can have poor response, affecting the linearity. Methylene chloride: A common laboratory contaminant. If the RL is too low, laboratory background may elevate the low standard response and result in poor linearity.
Naphthalene:
Moderate concentrations in analytical samples and standards are
prone to cross-contamination in ensuing samples.
Higher RL reduces the possibility of a false positive being
reported. |
AFCEE RLs and TNRCC risk reduction standards for the four compounds are as follows: 1,1,2,2-Tetrachloroethane: RL-0.4 ug/l, RRS-4.3 ug/l Methylene chloride: RL-0.3 ug/l, RRS-5 ug/l Naphthalene: RL-0.4 ug/l, RRS-730 ug/l Styrene: RL-0.4 ug/l, RRS-100 ug/l
Ms. Mullen indicated that, since methylene chloride, naphthalene, and
styrene are not contaminants of concern, the elevated RLs for these
compounds would be acceptable.
The
requested RL for 1,1,2,2-tetrachloroethane is only 0.1 ug/l above the
AFCEE RL; therefore, it is also acceptable.
Furthermore, all of the requested RLs are below the TNRCC risk
reduction standards. |
Approved. |
Attachment 4-B
O’Brien & Gere Variances and Conference Call Agreements
|
Cross-Reference
No. from Att. A |
Section and Page in AFCEE QAPP 3.0 |
Variance |
O’Brien & Gere Justification |
Conference Call Discussion |
Final Decision from AFCEE |
|
Detection
Limits: |
|||||
|
3b |
7.2.9-1 Reporting Limits
for Method SW8260B, page 7‑59, 60 |
Lab can meet the required soil RL’s, with the following exceptions: 1,1,2,2-Tetrachloroethane 0.0025 mg/kg Methylene chloride 0.005 mg/kg Naphthalene 0.005 mg/kg
Styrene
0.0025
mg/kg |
1,1,2,2-Tetrachloroethane: A reactive compound and the low standards can have poor response, affecting the linearity. Methylene chloride: A common laboratory contaminant. If the RL is too low, laboratory background may elevate the low standard response and result in poor linearity. Naphthalene: Moderate concentrations in analytical samples and standards are prone to cross-contamination in ensuing samples. Higher RL reduces the possibility of a false positive being reported.
Styrene: A reactive compound and the low standards can have poor
response, affecting the linearity. |
AFCEE RLs and the TNRCC risk reduction standards (most conservative value from GWP and SAI res. and ind. listed) for the four compounds are as follows: 1,1,2,2-Tetrachloroethane: RL-0.002 mg/kg, RRS-0.43 mg/kg Methylene chloride: RL-0.002 mg/kg, RRS-0.5 mg/kg Naphthalene: RL-0.002 mg/kg, RRS-73 mg/kg Styrene: RL- 0.002 mg/kg, RRS-10 mg/kg
Ms. Mullen indicated that, since methylene chloride, naphthalene, and
styrene are not contaminants of concern, the elevated RLs for these
compounds would be acceptable.
The
requested RL for 1,1,2,2-tetrachloroethane is only 0.1 ug/l above the
AFCEE RL; therefore, it is also acceptable. Furthermore, all of the
requested RLs are below the TNRCC risk reduction standards. |
Approved. |
|
Method
QC Procedures: Method 8260B |
|||||
|
3c |
Table 7.2.9-1.
RLs for Method SW8260B, page 7-60 |
m and p-Xylene will be
reported together as (m+p)-Xylene with an RL of: |
m and p-Xylene cannot be
resolved on capillary columns commonly utilized for SW8260 methods. |
Approved without
discussion. |
Approved. |
|
7 |
Table 7.2.9-2.
QC Acceptance Criteria for Method SW8260B, page 7-61 |
Use
water and soil control limits of 50-150 (%R) for accuracy for
dichlorodifluoromethane. |
This analyte has been
historically very difficult to purchase from two separate vendors and
meet criteria of 75-125 %R. |
AFCEE’s required control
limits are |
Approved. |
Attachment 4-B
O’Brien & Gere Variances and Conference Call Agreements
|
Cross-Reference
No. from Att. A |
Section and Page in AFCEE QAPP 3.0 |
Variance |
O’Brien & Gere Justification |
Conference Call Discussion |
Final Decision from AFCEE |
|
Method
QC Procedures: Method 8260B |
|||||
|
4 |
Table 7.2.9-3.
Summary of Calibration and QC Procedures for Method SW8260B:
Second source calibration verification page 7‑63 |
Use water and soil control
limits of 50-150 (%R) for dichlorodifluoromethane. |
This analyte has been
historically very difficult to purchase from two separate vendors and
meet criteria of 75-125 %R. |
AFCEE’s required control
limits are
65-135 for soils
75-125 for water
Parsons noted that 50-150% is not unusual for a lab because
dichlorodifluoromethane (freon) is a gaseous compound of which trace
amounts can be found in air.
Ms.
Shively, AFCEE, also noted that it probably is not an analyte of
concern at CSSA. |
Approved.
Parsons will request O’Brien and Gere to provide control charts for
this analyte. |
|
6 |
Table 7.2.9-3.
Summary of Calibration and QC Procedures for Method SW8260B:
method blank page 7‑65 |
Increase the method blank
acceptance criteria of methylene chloride to 1.0 ppb. |
This is a common laboratory
contaminant. |
Approved without
discussion. |
Approved. |
|
5 |
Table 7.2.9-3.
Summary of Calibration and QC Procedures for Method SW8260B:
Surrogate Spike page 7‑67 |
Medium-level soil samples
will not be re-extracted for the failure of one surrogate.
The sample extract will be re-injected only. |
The failure of one
surrogate is an indication of matrix effects. The sample extract will be re-injected and flagged
according to the AFCEE flags. |
Ms. Shively at AFCEE noted
that this variance is a request to allow O’Brien & Gere to do
something differently than what other labs are allowed to do. Mr. Jones noted that really only the analyst sitting at the
bench can tell if there is a matrix effect.
CONDITION:
Ms. Shively indicated that the surrogate should be flagged as
required by the QAPP, but that an explanation be given in the case
narrative.
|
Approved with condition.
Follow AFCEE QAPP requirements then note in case narrative.
Parsons ES to request that O’Brien & Gere clarify their
variance. |
|
Reporting Requirements: |
|||||
|
3d, 8 |
8.2
Data Review, Validation, and Reporting Requirements for
Definitive Data, p. 8‑2 |
The AFCEE QAPP requires
that MDLs and results be reported to one decimal place more than the
corresponding RL. O’Brien
& Gere request a variance to report all positive results to two
significant figures. |
All of our LIMS data is
formatted in this manner. Results
are reported to 2 significant figures or the RL.
The results are not significant past the RL. (e.g., RL=10, result reported as 11 not 11.1).
MDLs will be reported electronically to the calculated MDL as
defined in section 4, 4.3.1 (p. 4-5). |
Not discussed during
conference call. |
None. |
Attachment 4-B
O’Brien & Gere Variances and Conference Call Agreements
|
Cross-Reference
No. from Att. A |
Section and Page in AFCEE QAPP 3.0 |
Variance |
O’Brien & Gere Justification |
Conference Call Discussion |
Final Decision from AFCEE |
|
Reporting Requirements |
|||||
|
|
8.2
Data Review, Validation, and Reporting Requirements for
Definitive Data, p. 8‑2 |
The AFCEE QAPP requires that RLs and MDLs not be adjusted for dry weight. O’Brien & Gere request a variance to report MDLs and RLs which have been adjusted for dry weight. A wet weight aliquot of sample, as specified by the method, will be used for analysis then dry weight converted based on the percent solids. RLs and MDLs are then dry weight converted. RLs and MDLs are provided electonically only. |
The industry stsandard is
to take a wet weight aliquot of soil sample. |
Ms. Mullen indicated that AFCEE is not having a problem with the numbers, but with the adjustment. Ms. Mirchandani noted that labs typically adjust MDLs and RLs. Labs’ LIMS systems are set up to flag prior to correction, then to report the adjusted limits on the reporting form. Ms. Roberts asked that if O’Brien & Gere can’t report unadjusted limits, should Parsons ES consider them to be unacceptable? Ms. Mullen responded that then they just don’t want to try. She added that O’Brien & Gere will have to report unadjusted results for Dames & Moore. Ms. Mullen stated that she would not accept an adjustment for dry weight; the adjustment is allowed by CLP. |
Denied. Ms. Mullen indicated that CSSA is willing to pay to get the data right the first time. She suggested that Parsons provide O’Brien & Gere with a program to make the conversion back to unadjusted limits. If the lab can’t do it, and it is something that Parsons can do, Parsons should do it for them. Parsons should notify AFCEE of additional costs. |
|
|
8.2 Data Review, Validation, and Reporting Requirements for Definitive Data, p. 8‑2 |
The AFCEE QAPP requires that TICs be flagged with a “T.” O’Brien & Gere requests a variance to allow the following: TICs, when required, will be provided by hardcopy only on a separate result form from the “TCL” results. |
Currently our instrument software does not electronically transfer this information into our LIMS system. |
Not discussed during conference call. |
None. |
|
|
8.8, Hardcopy data reports for screening and definitive data, p. 8‑9 |
The AFCEE QAPP requires that hardcopy data reports conform to the formats identified in the referenced section. O’Brien & Gere requests approval for in-house report forms be substituted for the required forms. The results form that would be provided will include all required flags as specifed in the tables in section 7.2, Table 8.2-1, 8.2-2, 8.2-3, and 8.2-4. See attached “Example Report Forms.” |
We currently do not have the ability to provide the forms in the requested format. However, all of the information is available on our in-house report forms. See attached “Example Report Forms.” |
Parsons ES will generate forms following AFCEE requirements in-house if O’Brien and Gere cannot do it. Parsons ES will provide AFCEE with a cost estimate for additional effort associated with providing AFCEE forms. Ms. Mirchandani asked if AFCEE 2.0 forms would be acceptable if the lab cannot do AFCEE 3.0 forms. Ms. Mullen and Ms. Shively agreed that AFCEE 2.0 forms would be acceptable. Parsons ES will get back to AFCEE on specific plan of action and associated costs. |
Denied. Either laboratory or Parsons ES must provide AFCEE forms. |