Quality Assurance and Quality Control Requirements For For The Massachusetts Contingency Plan (MCP)
Quality Assurance and Quality Control Requirements For For The Massachusetts Contingency Plan (MCP)
Quality Assurance and Quality Control Requirements For For The Massachusetts Contingency Plan (MCP)
WSC – CAM – VI B
Donald Muldoon
Department of Environmental Protection
One Winter Street
Boston, MA 02108
[email protected]
Document Chronology
Regulatory Limits for Total Chromium, Chromium (VI) and Chromium (III)
Table VI B-3 16
under 310 CMR 40.0000
Sample Preservation, Container and Analytical Holding Time
Specifications for Surface Water, Groundwater, Soil and Sediment
Appendix VI B-1 17
Samples Analyzed for Chromium (VI) in Support of MCP Decision
Making
Appendix VI B-2 Eh/pH Phase Diagram 18
Quality Control Flow Diagram SW-846 Method 3060A Alkaline
Appendix VI B-3 19-20
Digestion for Hexavalent Chromium, Including Figure 1 and 2
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Protection Bureau of Waste Site Cleanup 20 August 2004 Revision No. 3
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Reporting Limits (RL), sensitivity, and/or the optimum linear concentration range can vary with
sample matrix and laboratory operating conditions.
SW-846 Method 7196A may be used directly to determine dissolved hexavalent chromium
(VI) in aqueous samples containing concentrations from 0.005 œ 50 mg/L. This method may
also be used in combination with the SW-846 Method 3060A alkaline digestion procedure for
the analysis of hexavalent chromium in soils, sludges, sediments and similar waste materials
containing concentrations from 1.0 œ 2000 mg/kg on a dry weight basis.
Sample preservation, container and analytical holding time specifications for surface water,
groundwater, soil, and sediment matrices for hexavalent chromium analyzed in support of
MCP decision-making are presented in Appendix VI Bœ1 of this document and Appendix VII-A,
WSC-CAM-VII A, —Quality Assurance and Quality Control Guidelines for the Acquisition and
Reporting of Analytical Data in Support of Response Actions Conducted Under the
Massachusetts Contingency Plan (MCP)".
Each laboratory that uses SW-846 Method 7196A are required to operate a formal quality
assurance program to demonstrate the precision and bias of the method as performed by the
laboratory and procedures for determining the method reporting limit (RL). The minimum
requirements of this program consist of an initial demonstration of laboratory capability, ongoing
analysis of standards and blanks as a test of continued performance, and the analysis of
laboratory control samples (LCSs), and LCS duplicates to assess accuracy and/or precision.
Project-specific matrix duplicates or matrix spike duplicates (MSDs) may be used in lieu of LCS
duplicates to evaluate precision when such samples are analyzed either at discretion of
laboratory or at request of data-user. Refer to SW-846 Methods 7196A, and 3060A Sections
8.0 and 9.0 for general quality control guidelines for these chromium determinative methods.
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Laboratories must document and have on file an Initial Demonstration of Capability for each
combination of sample preparation and determinative chromium methods being used. These
data must meet or exceed the performance standards as presented in Section 1.4 and Table VI
B-1 of this method. Procedural requirements for performing the Initial Demonstration of
Laboratory Capability can be found in SW-846, Chapter One, Section 4.4.1. The data
associated with the Initial Demonstration of Laboratory Capability for hexavalent chromium
analyses must be kept on file at the laboratory and made available to potential data-users on
request and must include the following:
Laboratories are encouraged to continually strive to minimize variability and improve the
accuracy and precision of their analytical results. . In some cases, the standard laboratory
acceptance criteria for the various QC elements may have to be modified to accommodate
more rigorous project-specific data quality objectives prescribed by the data user. The
laboratory may be required to modify routine sample introduction and/or analytical conditions to
accommodate project-specific data quality objectives.
Use of this method is restricted to use by, or under the supervision of, analysts who are knowledgeable of
UV-Visible spectrophotometry as a quantitative tool, and the correction of the chemical, and physical
interferences described in this method.
SW-846 Method 7196A may be used to determine the concentration of dissolved hexavalent
chromium (Cr (VI)) from 0.5 to 50 mg per liter (PPM) in EP/TCLP characteristic extracts,
surface water and groundwater. Dissolved Hexavalent Chromium, in the absence of
interfering amounts of substances such as molybdenum, vanadium, and mercury, may be
determined spectrophotometrically. Cr (VI) is determined by the addition of an excess of
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SW-846 Method 3060 is an alkaline digestion procedure for extracting hexavalent chromium
(Cr (VI) from soluble, adsorbed, and precipitated forms of chromium compounds in soils,
sludges, sediments, and similar waste materials. The pH of the digestate must be carefully
adjusted and monitored during the digestion procedure. Failure to meet the pH
specifications of the method will necessitate re-digestion of the samples.
To quantify all Cr (VI) species contained in a solid matrix, three criteria must be satisfied:
SW-846 Method 3060A meets these criteria for most solid matrices. Under the alkaline
conditions of the extraction, minimal reduction of Cr (VI) or oxidation of native Cr (III) occurs.
The addition of Mg+2 in a phosphate buffer to the alkaline solution has been shown to suppress
oxidation. The efficiency (as % Recovery) of the extraction procedure is assessed using spike
recovery data for soluble and insoluble forms of Cr (VI) (e.g., K2Cr2O7 and PbCrO4), coupled
with the measurement of other soil properties, such as oxidation reduction potential (ORP),
pH, organic matter content, ferrous iron, and sulfides as indicators that oxidative conditions will
be maintained during digestion of the Cr (VI) spike.
Recovery of an insoluble Cr (VI) spike is used to assess efficiency and maintenance of non-
reductive conditions during the solubilization process. Method-induced oxidation (Cr (III)
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converted to Cr (VI)) is usually not observed except in soils high in manganese and amended
with soluble Cr (III) salts or freshly precipitated Cr (OH) 3.
Alkaline digestion is the required preparative step for the analysis soils, sludges, sediments
and similar waste materials under the MCP.
The quantification of Cr (VI) in Method 3060A digestates may be performed using any
analytical technique with suitable accuracy and precision. The following summary table
presents the recommended alternative SW-846 methods that may be used in conjunction with
the alkaline digestion procedure for the analysis of Hexavalent Chromium in soils, sludges,
sediments, and similar waste materials. Other less commercially-available analytical
techniques such as ion chromatography (IC) coupled with inductively coupled plasma œ mass
spectrometric (ICP-MS) detection, high performance liquid chromatography (HPLC) with ICP-
MS detection, capillary electrophoresis (CE) with ICP-MS detection, etc. may be considered
once their performance effectiveness has been validated.
Total Chromium may be determined by flame or flameless atomic absorption methods, ICP-
AES or by ICP-MS. Refer to the appropriate MADEP Analytical Method (WSC-CAM III A, III C
or III D) for specific analytical and reporting details. Chromium (III) is defined as the difference
between the Total Chromium concentration and the Chromium (VI) concentration.
Samples submitted to a laboratory for trace metal analysis may be subject to contamination
during both sampling and analysis. Potential sources of contamination may include:
The chromium reaction with diphenylcarbazide is usually free from interferences. However,
certain substances may interfere if the chromium concentration is relatively low. Hexavalent
molybdenum and mercury salts also react to form color with the reagent; however, the red-
violet intensities produced are much lower than those for chromium at the specified pH.
Under the MCP, determination of the reducing/oxidizing tendency of each soil type and/or
sediment matrix for each analytical batch is required when measuring hexavalent chromium.
This is accomplished by characterization of each sample for two (2) additional analytical
parameters:
Section 7.2 of SW-846 Method 9045C should be referenced as the preparatory method for
solid samples for ORP. The ORP and pH probes are inserted directly into the soil slurry. The
displayed ORP and pH values are allowed to equilibrate and the resulting measurements are
recorded. Additional optional parameters include:
Analysis of these parameters establishes the tendency of Cr (VI) to exist or not exist in the
unspiked sample(s) and assists in the interpretation of QC data for matrix spike recoveries
outside of the acceptance criteria.
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Cr (VI) results obtained using this method may be biased high due to method-induced
oxidation for waste materials or solid samples containing soluble Cr (III) concentrations
greater than four times the laboratory Cr (VI) reporting limit. The addition of Mg2+ in a
phosphate buffer to the alkaline extraction solution has been shown to suppress this
oxidation. The presence of soluble Cr (III) can be approximated by extracting the solid
sample with deionized water (ASTM methods D4646-87, D5233-92, or D3987-85) and
analyzing the resultant leachate for both Cr (VI) and total chromium. The difference between
these two values approximates the concentration of soluble Cr (III).
1.4 Specific QA/QC Requirements and Performance Standards for SW-846 Methods 7196A
and 3060A
Specific QA/QC requirements and performance standards for SW-846 Methods 7196A are
presented below in Tables VI B-1. Strict compliance with the QA/QC requirements and
performance standards for this method, as well as satisfying other analytical and reporting
requirements will provide a data user with —Presumptive Certainty“ regarding the usability of
analytical data to support MCP decisions. The concept of —Presumptive Certainty“ is explained
in detail in Section 2.0 of WSC-CAM-VII A.
While optional, parties electing to utilize these protocols will be assured of —Presumptive
Certainty“ of data acceptance by agency reviewers. In order to achieve —Presumptive
Certainty“, parties must:
(b) Comply with the applicable QC analytical requirements prescribed in Table VI B-1 for this
test procedure;
(c) Evaluate, and narrate, as necessary, compliance with performance standards prescribed
in Table VI B-1 for this test method; and
(d) Adopt the reporting formats and elements specified in the CAM.
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In achieving the status of —Presumptive Certainty“, parties will be assured that analytical data
sets:
V Will satisfy the broad QA/QC requirements of 310 CMR 40.0017 and 40.0191
regarding the scientific defensibility, precision and accuracy, and reporting of
analytical data;
V May be used in a data usability assessment, and if in compliance with all MCP
Analytical Method standards, laboratory QC requirements, and field QC
recommended limits and action levels, the data set will be considered useable
data to support site characterization decisions made pursuant to the MCP; and
Laboratory Analytical
Continuing Sensitivity (1) Frequency - Every 10 samples and at end Re-calibrate/re-analyze all
Narrate non-
Calibration (instrument drift and of run immediately after CCV No samples since last compliant
compliance.
Blank (CCB) contamination (2) Cr (VI) must be < RL CCB.
evaluation)
WSC-CAM Table: VI B-1
Massachusetts Department of Environmental
Protection Bureau of Waste Site Cleanup 20 August 2004 Revision No. 3
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Quality Assurance and Quality Control Requirements and Performance Standards for SW-846 Method 7196A
Hexavalent Chromium by UV-Visible Spectrophotometry
Narrate non-
(1) Frequency - One per digestion batch of < compliance.
20 field samples.
Laboratory (2) LCS must be media-matched (aqueous or Note: MADEP
Laboratory solid) to field samples and digested with Re-digest/reanalyze all
Control Sample Yes modification to
Method Accuracy the samples. associated samples.
(LCS) frequency of
(3) LCS percent recovery for Cr (VI) must be LCS for
within 80-120% or certified acceptance consistency with
limits, whichever is applicable. other methods.
(1) Locate and
rectify source of
(1) Frequency - One per digestion batch of < non-
20 field samples. conformance
(2) LCS Duplicate must be media-matched before
(aqueous or solid) to field samples; proceeding with
prepared using the standard source and the analyses of
concentration as the LCS, and digested subsequent
with the samples. sample batches.
Laboratory (3) Recommended to be run immediately after Re-digest/reanalyze all
LCS Duplicate Yes (2) Narrate non-
Method Precision LCS in analytical sequence. associated samples.
compliance.
(4) Laboratoryœdetermined Relative
Percent Difference (RPD) must be ≤ 20 Note: MADEP
(aqueous) and ≤ 35 (soils/sediments), modification
and to frequency
(5) A project-specific MD or MSD may be of LCS for
substituted to evaluate precision in lieu of consistency
an LCS duplicate. with other
methods.
WSC-CAM Table: VI B-1
Massachusetts Department of Environmental
Protection Bureau of Waste Site Cleanup 20 August 2004 Revision No. 3
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Quality Assurance and Quality Control Requirements and Performance Standards for SW-846 Method 7196A
Hexavalent Chromium by UV-Visible Spectrophotometry
* It is recommended that a matrix spike duplicate analysis be performed if analytes are not suspected to be detected. A matrix duplicate
analysis should be performed if analytes are suspected to be detected.
WSC-CAM Table: VI B-1
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Quality Assurance and Quality Control Requirements and Performance Standards for SW-846 Method 7196A
Hexavalent Chromium by UV-Visible Spectrophotometry
Overall data usability is influenced by uncertainties associated with both sampling and
analytical activities. This document provides detailed quality control requirements and
performance standards for SW-846 Methods 7196A and 3060A which may be used to assess
the analytical component of data usability. The sampling component of data usability, an
independent assessment of the effectiveness of sampling activities to meet data quality
objectives, is not substantively addressed in this document.
Specific Quality Control Requirements and Performance Standards for SW-846 Method
7196A are presented in Table VI B-1. Specific QA/QC Requirements and Performance
Standards for SW-846 Method 7196A are summarized below in Table VI B-2 as —Required
Analytical Deliverables (YES)“. These routine reporting requirements should always be
included as part of the laboratory deliverable for this method. It should be noted that
although certain items are not specified as —Required Analytical Deliverables (NO)“, these
data are to be available for review during an audit and may also be requested on a client-
specific basis.
WSC-CAM Section: VI B
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Protection Bureau of Waste Site Cleanup 20 August 2004 Revision No. 3
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Table VI B-2 Routine Analytical Reporting Requirements for SW-846 Method 7196A
4.0 Regulatory Limits for Total Chromium, Chromium (VI) and Chromium (III) under
310 CMR 40.0000
The Reportable Quantity (RQ) together with the most stringent (lowest) MCP Reportable
Concentrations (RCs) and Method 1 Standards for Chromium (VI), Chromium (III) and Total
(or undifferentiated) Chromium are listed below in Table VI B-3:
Table VI B-3 Regulatory Limits for Total Chromium, Chromium (VI) and Chromium
(III) under 310 CMR 40.0000
Total Chromium
Chromium (VI)
Chromium (III)
Title: for Surface Water, Groundwater, Soil and Sediment Samples Analyzed for
Sample preservation, container and analytical holding time specifications for surface
water, groundwater, soil, and sediment matrices for Chromium (VI) conducted in
support of MCP decision-making are summarized below and presented in Appendix VII-
A of WSC-CAM-VII A, —Quality Assurance and Quality Control Guidelines for Sampling,
Data Evaluation, and Reporting Activities for the Massachusetts Contingency Plan
(MCP)“. Additional guidance may be found in SW-846, Chapter Three.
Soil/Sediment
Ferrous iron and (1) 4-ounce glass jar
Cool, 4 ± 2o °C 7 days
Sulfide with teflon-lined cap
(optional analyses)
1. Holding time begins from time of sample collection.
WSC-CAM Appendix: VI B-2
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