Section and Page in AFCEE QAPP-3.0

Variance

APPL Inc.'s Justification

Parsons ES" Justification

(April 1999)

7.2.15-1 Reporting Limits (RLs) for Method SW6010B, page 7-106

Zinc 0.01 mg/L

Lab can meet the required aqueous Reporting Limits (RLs), with the following exception:

Zinc 0.05 mg.L

In order to meet the requirement in Sec. 4.3.2 of AFCEE QAPP 3.0, "The Method Detection Limit (MDL) may not be more than one-half the corresponding RL", APPL proposed a higher RL for zinc. The proposed RL is two times the MDL.

The proposed RL is five times the AFCEE required RL for zinc.

Zinc is a naturally occurring element. Parsons ES does not feel that this elevated RL will impact the project objectives. Parsons ES accepts the proposed RL.

7.2.15-1 Reporting Limits (RLs) for Method SW6010B, page 7-106

Zinc 1.0 mg/kg

Lab can meet the required soil RLs, with the following exception:

Zinc 5.0 mg/kg

In order to meet the requirement in Sec. 4.3.2 of AFCEE QAPP 3.0, "The method Detection Limit (MDL) may not be more than one-half the corresponding RL", APPL proposed a higher RL for zinc. The proposed RL is two times of respective MDL.

The proposed RL is five times the AFCEE required RL for zinc.

Zince is a naturally occurring element and has been detected in every background sample collected at CSSA; therefore, Parsons ES does not feel that this elevated RL will impact the project objectives. Parsons ES accepts the proposed RLs.

Section and Page in AFCEE QAPP-3.0

Variance

APPL Inc.'s Justifiction

Parsons ES' Justification

(April 1999)

7.2.9-1 RLs for Method SW8260B, page 7-59, 60

1,2,3-Trichlorobenzene: 0.3 mg/L

1,2,4-Trichlorobenzene: 0.4 mg/L

1-Chlorohexane: 0.5 mg/L

Methylene chloride: 0.3 mg/L

Naphthalene: 0.4 mg/L

Lab can meet the required aqueous RLs, with the following exceptions:

1,2,3-Trichlorobenzene: 0.5 mg/L

1,2,4-Trichlorobenzene: 0.5 mg/L

1-Chlorohexane: 0.6 mg/L

Methylene chloride: 1 mg/L

Naphthalene: 0.8 mg/L

Methylene chloride: A common spurious laboratory contaminant.

For the rest of compounds: In order to meet the requirement in Sec. 4.3.2 of AFCEE QAPP 3.0, "The Method Detection Limit (MDL) May not be more than one-half the corresponding RL", APPL proposed higher RLs for 1,2,3-trichlorobenzene, 1,2,4-trichlorobenzene, 1-chlorohexane and naphthalene.

The proposed RLs for listed compounds are generally within two times the AFCEE's RLs except methylene chloride which is within four times AFCEE's RL.

Considering the popular usage of methylene chloride in the lab and the volatility of the compound, Parsons ES accepts the variance.

Parsons ES does not feel that elevated RLs of other listed compounds will impact the project objectives. Parsons ES accepts the proposed RLs.

7.2.9-1 RLs for Method SW8260B, page 7-59, 60

1,2,3-Trichlorobenzene: 0.002 mg/kg

1,2,4-Trichlorobenzene: 0.002 mg/kg

Methylene chloride: 0.002 mg/kg

Naphthalene: 0.002 mg/kg

Lab can meet the required soil RLs, with the following exception:

1,2,3-Trichlorobenzene: 0.004 mg/kg

1,2,4-Trichlorobenzene: 0.004 mg/kg

Methylene chloride: 0.005 mg/kg

Naphthalene: 0.02 mg/kg

Methylene chloride: A common spurious laboratory contaminant.

For the rest of compounds: In order to meet the requirement in Sec. 4.3.2 of AFCEE QAPP 3.0, "The Method Detection Limit (MDL) may not be more than one-half the corresponding RL", APPL proposed higher RLs for 1,2,3-trichlorobenzene, 1,2,4-trichlorobenzene, 1-chlorohexane and naphthalene.

The proposed RLs for listed compounds are generally within three times the AFCEE's RLs except naphthlane which is ten times AFCEE's RL.

Considering that naphthalene is a poor purger and unstable compound, Parsons ES accepts the variance.

Parsons ES does not feel that elevated RLs of other listed compounds will impact the project objectives. Parsons ES accepts the proposed RLs.

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:

waters: 1.3 mg/L

soils: 0.007 mg/kg

m and p-Xylene can not be resolved on capillary columns commonly utilized for 8260 methods.

Parsons ES agrees that these two isomers cannot be separated by 8260B. Reporting m-Xylene and p-Xylene together will still provide for adequate technical information. Parsons ES accepts the variance.

7.2.9-2. QC Acceptance Criteria for Method SW8260B, page 7-61.

1,1-Dichloroethene: 75% - 125%

Bromomethand: 72% - 125%

Chloromethand: 75% - 125%

Lab can meet the required aqueous accuracy limits with the following exception:

1,1-Dichloroethene: 75% - 130%

Bromomethane: 65% - 125%

Chloromethane: 65% - 125%

This is based on historical performance of these compounds and is documented in the control chart.

Parsons ES has reviewed and approved APPL's Standard Operation Procedure (SOP) for method 8260B, historical data and control limits.

The proposed variance still meets data objectives of this project. Parsons ES accepts this variance.

7.2.9-3. Summary of Calibration and QC Procedures for Method SW8260B: Second source calibration verification page 7-63.

Lab can meet the required �25% of expected value for all analytes except the following:

1,1-Dichloroethene: �30%

Bromomethane: �30%

Chloromethane: �30%

This is based on historical performance of these compounds and is documented in the control chart.

Parsons ES has reviewed and approved APPL's Standard Operation Procedure (SOP) for method 8260B, historical data and control limits.

The proposed variance still meets data objectives of this project. Parsons ES accepts this variance.