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

Lab can meet the required soil RLs, 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 �SQL� value is 2.0 mg/kg, the value that O�Brien & Gere is proposing.

The proposed RL for zinc is two times that of AFCEE�s RL. However, the lowest background level of zinc is 5.2 ppm and the SQL is 2.0 ppm. Since background value is higher than 2 ppm, Parsons ES accepts the proposed RL of 2 ppm.

Approved

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

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

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.

Styrene: A reactive compound and the low standards can have poor response, affecting the linearity.

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.

The proposed RLs for listed compounds are generally within one to four times range of AFCEE RLs except methylene chloride. The proposed numbers are reasonable to Parsons ES.

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

Approved

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

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

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.

The proposed RLs for listed compounds are generally within one to four times range of AFCEE RLs except methylene chloride. The proposed numbers are reasonable to Parsons ES.

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

Approved

Section and Page in AFCEE QAPP-3.0

Variance

O�Brien & Gere Laboratories� Justification

Conference Call Discussion

(March 1999)

Parsons ES� Justification

(April 1999)

Action taken by AFCEE during the teleconference meeting on March 11, 99.

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:

waters 0.6 ug/l.

soils 0.004 mg/kg

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

Approved without discussion.

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.

Approved

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 criteria for dichlorodifluoromethane.

This analyte has been historically very difficult to purchase from two separate vendors and meet criteria of 75-125 %R for water and 65-135%R for soil.

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.

Parsons ES has reviewed and approved O�Brien & Gere�s Standard Operation Procedure (SOP) for method 8260B, historical data and control limits.

Agree to approve after Parsons ES review and approval of O�Brien & Gere�s SOP and historical data.

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 second source calibration criteria for dichlorodifluoromethane.

This analyte has been historically very difficult to purchase from two separate vendors and meet criteria of 75-125 %R for water and 65-135%R for soil..

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.

Parsons ES has reviewed and approved O�Brien & Gere�s Standard Operation Procedure (SOP) for method 8260B, historical data and control limits.

Agree to approve after Parsons ES review and approval of O�Brien & Gere�s SOP and historical data.

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 for water matrix.

This is a common laboratory contaminant.

Not discussed.

Considering the popular usage of this compound as solvent, Parsons ES agrees with this variance.

Not discussed.

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 reextracted for the failure of one (1) surrogate. The sample extract will be re-injected only.

The failure of one (1) 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.

Parsons ES approves this variance as long as it is clearly defined and noted in the case narrative, when appropriate.

AFCEE will approve the variance if the case narrative details the exception.

Section and Page in AFCEE QAPP-3.0

Variance

O�Brien & Gere Laboratories� Justification

Conference Call Discussion

(March 1999)

Parsons ES� Justification

(April 1999)

Action taken by AFCEE during the teleconference meeting on March 11, 99.

8.2 Data Review, Validation, and Reporting Requirements for Definitive Data, p. 8-2

MDLs and results shall be reported to one decimal place more than the corresponding RL, p. 8-2

The MDL may be reported to more than one decimal place beyond the corresponding RL.

Some MDLs may be a factor of a hundred times or more, more sensitive than the requested RL thus requiring to report an additional digit to be significant.

Not discussed during conference call.

Since this variance leads to more accurate reporting of significant figures, Parsons ES approves the variance.

Not discussed.

TICs will be flagged with a "T",

p. 8-2

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.

TICs have not been reported over the past 8 years of ground water monitoring and therefore are not considered necessary for future monitoring. Parsons ES approves the variance.

Not discussed.

8.8 Hardcopy data reports for screening and definitive data. The hardcopy data reports shall conform to the formats identified in the section, p. 8-9

All results and QA/QC will be reported on AFCEE-like report forms. Calibrations will be provided by calibration summary forms with the AFCEE header attached. The following forms will be in-house forms: I-3, I-3A, I-3B, O-3A, O-3,
O-5A, O-5, W-3. See attached "Example Report Forms"

We currently do not have the ability to provide instrument calibration data on the AFCEE requested report format. However, all the calibration data will be summarized with the header information attached. See attached "Example Report 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 has reviewed the sample data package provided by O�Brien & Gere. The required AFCEE information will be properly linked and provided in the data package. Parsons ES approves the variance.

AFCEE required all necessary information to be properly linked and provided in the data package.