TAGM SW-96-09 Development And Review Of Site Analytical Plans

TAGM SW-96-09 Development and Review of Site Analytical Plans content

Effective Date: May 3, 2001 (supersedes TAGM DMM-96-03)

I. Purpose

The purpose of this TAGM is to provide Department staff with guidance to review Site Analytical Plans (SAPs) submitted by owners and/or operators of landfills in satisfaction of the requirements of 6 NYCRR Part 360 Solid Waste Management Facilities (Part 360). This TAGM can also provide technical guidance to the regulated community when preparing a SAP. The environmental monitoring, performed in accordance with Part 360, is designed to protect public health, safety and the environment, and conserve the State's natural resources. Therefore, it is essential that the analytical data obtained during the site development, operation, closure and post-closure periods of a landfill be of a quality sufficient for its intended use. The data used as a result of environmental monitoring is provided by analytical laboratories and assessed by data validators performing under contract to the landfill owner and/or operator. The responsibility for determining the capability of the laboratory and the data validator remains with the landfill owner and/or operator.

II. Background

Section 502 of the Public Health Law (PHL) authorizes the Commissioner of the New York State Department of Health (NYSDOH) to issue certificates of approval covering laboratory examinations including, but not limited to, specific procedures or specialties within such categories as the examination of non-potable water, potable water, sediment, solid waste and air. Section 502 of the PHL states: "No environmental laboratory may perform any examination on samples collected in the state of New York for which the commissioner issues a certificate of approval for such examination unless the laboratory has been issued such certificate of approval. Such laboratory examinations shall conform to any conditions under which the approval is granted."

"No state agency, authority, county, city, including the city of New York, town, village, water district, sewer district or other political subdivision of the state shall contract with any laboratory for laboratory examinations for which the commissioner issues certificates of approval pursuant to subdivision three of this section, unless such laboratory has been issued such certificate."

Approved laboratories must use appropriate methods for all tests performed in areas for which they have approval. Environmental Conservation Law (ECL) requires facilities to comply with all applicable laws, rules and regulations.

Subdivision 360-2.11(c) states: "The environmental monitoring plan must describe all proposed on-site and off-site monitoring, including the location of all environmental, facility, and other monitoring points, sampling schedule, analyses to be performed, statistical methods, and reporting requirements. The plan must also include a schedule for construction of the groundwater monitoring wells based on site-specific hydrogeology and the sequencing of construction of landfill cells; a schedule for initiation of the existing water quality and operational water quality monitoring programs and a contingency water quality monitoring plan which specifies trigger mechanisms for its initiation."

Further, paragraph 360-2.11(c)(5) states: "A water quality monitoring program must be implemented for all environmental monitoring points specified in the environmental monitoring plan. This program must be tailored to the site to establish existing water quality for the site prior to landfilling, operational water quality during operation of the site and the post-closure period, and contingency water quality, if contamination is detected at the site."

Title 40 CFR Part 258 Criteria for Municipal Solid Waste Landfills (Part 258 Criteria), more specifically section 258.53, states: "The ground-water monitoring program must include consistent sampling and analysis procedures that are designed to ensure monitoring results that provide an accurate representation of ground-water quality at the background and downgradient wells...." Section 258.53 also places a considerable emphasis on statistical analysis of all data to identify statistically significant evidence of contamination.

Department staff recognized that the Part 258 Criteria emphasized reliance on statistics to show significant increases in leachate contaminants in groundwater to indicate landfill-derived contamination was not as crucial in New York State as it may be in other parts of the country. Part 360 places greater reliance upon landfill siting, monitoring the performance of the double composite liner system, and construction quality assurance/ construction quality control criteria. In section 360-2.11, the Department developed an equivalent approach to the Part 258 Criteria that requires detailed sampling and laboratory analysis. The SAP process is intended to ensure quality data when used to evaluate regulatory compliance with Part 360.

III. Guidance

1. General Criteria

   The SAP is intended to be an orderly set of standard operating procedures beginning with the planning of sample collection procedures and ending with the usability analysis of the generated analytical data. The predefinition of these activities is intended to ensure consistent, comparable data for all sampling events occurring throughout the life of the landfill. As part of the hydrogeologic report, a SAP is developed to describe the reporting data quality objectives, method of sample collection, sample preservation, chain-of-custody documentation, analyses to be performed, analytical methods and procedures for corrective actions. Additionally, the SAP will describe procedures for data reduction, data validation and data usability. SAPs pertain to existing, operational, contingency, post-closure and corrective measures, water quality monitoring categories and leachate monitoring.

   Before conducting any sampling and analysis, the landfill owner and/or operator should coordinate and plan all field and laboratory activities. The SAP should be fully developed and approved by the Department prior to the first sampling event for characterization of the groundwater at the site. Additional uses, such as waste stream studies, may utilize the SAP format. Any revisions to the approved SAP must be submitted to the Department for review and approval prior to implementation in the sampling event.

2. Specific Criteria

   The SAP should define the following principal elements:

   1. Data Quality Objectives. The Data Quality Objectives (DQOs) section is fundamental to the SAP. DQOs are qualitative and quantitative statements of the data required to support specific decisions or regulatory actions. DQOs should take into account sampling considerations as well as analytical protocols.

      The DQOs should define who the data users are for each sampling media within each of the appropriate monitoring categories (e.g., existing, operational or contingency). Data user identification includes the landfill owner and/or operator, the regulator such as the DSHM and other Department Divisions or State agencies, and the public (i.e., interested parties and environmental professionals).

      DQOs include both qualitative and quantitative data performance specifications necessary to support the data validation and usability determination process and are designed to ensure the data will indicate the concentration of chemicals as they actually occur in the media. These specifications include the appropriate analytical level, contaminants of concern, sampling media types, determination of required detection levels and achievability of their detection levels in the actual sample matrices. Additionally, these specifications should include identification of data quantity needs as defined in terms of data characteristics (e.g., precision, accuracy, representativeness, completeness, comparability and defensibility).

      The DQOs should discuss the implementation mechanisms of sampling for routine, baseline and expanded parameters and explain how the data will be used. Because each category of monitoring has a specific purpose, it may be necessary to develop DQOs for each category.

      The DQOs should define the action levels (levels of concern) or applicable groundwater, surface water or sediment protection standards (i.e., 6 NYCRR Part 700-705 Water Quality Regulations for Surface Waters and Groundwaters, maximum contaminant levels (MCLs) of 40 CFR Part 141 National Primary Drinking Water Regulations) and the regulatory requirements to which they apply. The DQOs should specify the appropriate detection levels for each analyte for each category of environmental monitoring. The appropriate detection levels with associated analytical methods and reporting levels are found in the New York State Department of Environmental Conservation Analytical Services Protocol (NYSDEC ASP).

      The DQOs will be used as a guide to develop the field and laboratory operations to provide reliable and representative data. This will result in sound and technically justifiable decisions being made during the development, operation and post-closure periods of the facility.

      For a more detailed discussion of the DQO process, refer to the following USEPA documents: Data Quality Objectives for Remedial Response Activities, Development Process, and Data Quality Objectives for Remedial Response Activities, Example Scenario: RI/FS Activities at a Site with Contaminated Soils and Ground Water.

   2. Analytical Quality Assurance/Analytical Quality Control. Analytical Quality Assurance/Analytical Quality Control (AQA/AQC) is the assessment of features and characteristics of a product or service that bears on the ability to satisfy present or future quality objectives of environmental monitoring at the site.

      AQA is an integrated program for assuring the integrity of sample collection and measurement processes. The system allows for integration of the quality planning, assessment and improvement efforts to meet users defined requirements. AQA provides systematic specifications and establishes the features and characteristics of data quality. AQA will provide data users a degree of assurance that the results of the environmental monitoring program depict actual field conditions.

      AQC is the application of procedures for obtaining prescribed standards of performance in the monitoring and measurement processes. AQC checks are the mechanisms by which all the components of the AQA objectives are monitored. The AQC process should be integrated throughout the analytical program from the sampling plan design through the data usability review.

      The AQA/AQC section of the SAP should include the project's organization chart and designate a project AQA officer. The AQA officer should be determined by the landfill owner and/or operator to be proficient in SAP development, analytical methodology, data quality interpretation, quality control procedures and auditing techniques. To verify this, the SAP should contain a copy of the AQA officer's qualifications and experience and include the AQA officer's signature indicating approval and concurrence with the SAP.

      The AQA/AQC section of the SAP should include a discussion of the quality assurance reports that will be provided to the landfill owner and/or operator. These reports should include periodic assessment of data characteristics, results of system audits, identification of AQA/AQC problems and recommended solutions and resolutions of problems.

      In addition, the SAP should also include the laboratory-specific AQA/AQC plan or quality assurance program plan that defines:

      1. key laboratory staff and management, and each individual's responsibilities within the organization;
      2. procedures used to demonstrate proficiency with each analytical method used in the laboratory;
      3. laboratory control procedures and limits;
      4. methods of determining matrix effects;
      5. equipment calibration procedures and frequencies;
      6. internal quality control checks;
      7. performance and system audits;
      8. preventative maintenance;
      9. historical performance of the laboratory and how this relates to the expected quality of data for this project;
      10. AQA reporting to project management; and
      11. corrective action quality assurance reporting.

      It should be noted there is the possibility that some portions of the laboratory-specific AQA/AQC plans will overlap the site-specific AQA/AQC elements within the SAP. If this is the case, cross-reference to the laboratory AQA/AQC plan may be used. However, it may not be appropriate to duplicate the laboratory-specific AQA/AQC plan and submit it as the SAP's AQA/AQC program.

      Table I provides AQA/AQC sample recommendations. For a more detailed discussion of the AQA/AQC components with a sample quality assurance project plan outline, refer to the following documents: RCRA Quality Assurance Project Plan Guidance, and Guidance for Preparation of Combined Work/Quality Assurance Project Plans for Environmental Monitoring.

   3. Field Sampling Procedures. All field sampling procedures in the SAP that take into account actual site conditions should be approved by the Department prior to initiation of any sampling activities. Consideration should be given to the nature of the geological strata being monitored and the expected recharge rates for the monitoring wells. In addition, the method of obtaining samples should be integrated into the sampling procedures section. The SAP should include a description of the pre-sampling activities including:

      1. identifying all sampling and measuring equipment;
      2. frequency of calibration of equipment;
      3. examination of the monitoring wells and stations;
      4. taking field measurements;
      5. checking for, documenting, and sampling immiscible fluids;
      6. checking the wellhead space and documenting for organic and explosive vapors;
      7. procedures for well purging; and
      8. procedures for decontaminating the sampling equipment.

      A table reflecting the number of samples to be collected should be provided which includes: matrices, holding times, and analytical protocols to be used; and the anticipated number and frequency of AQA/AQC samples to be collected or analyzed. For the actual sampling events, the SAP should include determinations such as:

      • Will a phased approach be used?
      • Will a grid system be used?
      • What sample types: grab or composite, filtered or unfiltered?
      • Which wells are upgradient and should be sampled first?

      The sampling procedures should detail the sampling team's organization and staffing and designate which members will be responsible for recording field measurements, and who is responsible for sample chain-of-custody, preservation and transport to the laboratory. Simple identification of activities is not sufficient. The SAP should identify the type and frequency of activities depending on the media and the DQOs. Standard operating procedures describing how each of the media will be sampled and any special procedures necessary for the conduct of activities at individual monitoring points should be included.

      Examples of laboratory information forms and chain-of-custody sheets should be provided. The SAP should assure that the field personnel keep and maintain a written log for each sampling event. Sample packaging and delivery procedures should be fully described. The SAP should include procedures for identifying and documenting changes in the field sampling procedures. Possible changes may include samples not taken due to a damaged well, insufficient volume of water in the well, or a change from the standard operating procedure on how the samples were taken.

   4. Laboratory Procedures. The SAP should identify the laboratory to be used for analyzing the environmental samples. The laboratory must provide verification of current certification by the NYSDOH Environmental Laboratory Approval Program (ELAP). The ELAP certification must be in the NYSDEC ASP (Contract Laboratory Protocol) category when the laboratory is performing analytical services for sampling events which require data validation to be performed. For all other sampling events, the laboratory must have ELAP certification in either the Solid and Hazardous Waste or NYSDEC ASP (Contract Laboratory Protocol) category. These categories include the following subcategories: inorganics, PCBs and pesticides, volatiles and semi-volatiles. The laboratory must be certified in the subcategories that are necessary to meet the analytical requirements of the environmental monitoring program. For information and a list of laboratories currently certified, refer to the following NYSDOH document: Commercial Laboratories with New York State Approval to Perform Environmental Analyses.

      The SAP should describe the laboratory's standard operating procedures for identifying and correcting any deficiencies that can cause an error in the identification or quantification of any analyte. Procedures for sample receipt, verification, examination for damage, preservation, scheduling and holding times, storage, and the maintenance of the internal chain-of-custody as a continuation of the field chain-of-custody procedures should be fully detailed.

      A listing of each analyte, analytical protocols and methods, levels of concern, and the target detection limits for each analyte listed in the monitoring category should be included. The target detection limit should be in the range of one-half to one-fifth of the level of concern, if possible. Where either the action level or standard cannot be achieved, the method chosen should be as close to the action level or standard as possible. A requirement that the data reportables and deliverables package are in compliance with the NYSDEC ASP Category B for use during data validation should be included in the SAP. The data package submitted to the Department should be the data summaries that include the validator's data qualifications.

   5. Data Quality Assessment. The assessment of environmental data occurs in two phases. The first phase consists of reviewing and determining the validity of the analytical data. The second phase consists of interpreting the data to determine its usability. The information from the assessment is included in the data quality assessment report with the results from each sampling event. Only the routine sampling event can be validated by the laboratory performing the analysis. All other validation activities must be performed by a validator independent of the laboratory performing the analyses.

      1. Data Validation. Data validation is the process by which the quality of the data is determined with respect to data quality criteria that are defined in facility and laboratory quality control programs and in the referenced analytical methods. Data validation must be performed on a minimum of one in 20 samples (five percent) for every Baseline and Expanded Parameter sampling event.

         The process consists of data editing, screening, checking, auditing, certification, reviewing and interpretation. The goal of the process is to define and document data quality and determine if it is sufficient for the intended use. Ideally, data validation evaluates the data quality in terms of the DQOs. The validator should have experience evaluating data packages for NYSDEC ASP or USEPA Contract Laboratory Program (CLP) compliance. A full description of the data validation to be performed after each sampling event should be part of the SAP. The following is a description of the tasks that should be performed during data validation:

         Task I: Completeness-the validator should review the data package to determine completeness. A complete data package should contain the following components:

         1. sample chain-of-custody forms;
         2. case narratives including sample analysis summaries;
         3. AQA/AQC summary forms and supporting documentation;
         4. relevant calibration data and supporting documentation;
         5. instrument and method performance data;
         6. documentation showing the laboratory's ability to attain the method detection limits for analytes in the required matrices;
         7. data report forms, including sample preparation logs, analytical run logs and examples of the calculations used in determining final concentrations; and
         8. raw data used in the identification and quantification of the contract-specified analytes

         Deficiencies in completeness should be reported to the AQA officer. The laboratory should be contacted by the AQA officer and should be given a reasonable time (ten calendar days) to produce the documentation necessary to remove the deficiencies.

         Task II: Compliance-the validator should review the submitted data package to determine compliance with those portions of the SAP that pertain to the production of laboratory data. Compliance is defined by, but not limited to, the following criteria:

         1. the data package is complete as defined in Task 1 above;
         2. the data has been produced and reported in a manner consistent with the requirements of the SAP;
         3. SAP-defined AQA/AQC criteria have been met;
         4. instrument calibration requirements have been met for the time frame during which the analyses were completed;
         5. SAP-defined initial and continuing calibration data is present and documented;
         6. data reporting forms are complete for all samples submitted, including sample dilution and concentration factors and remeasurement sample clean-up procedures; and
         7. problems encountered during the analytical process have been reported in the case narrative.

         The data validation task requires that the validator conduct a detailed comparison of the reported data with the raw data submitted as part of the supporting documentation package. It is the responsibility of the validator to determine if the reported data can be substantiated by applying protocol-defined procedures for the identification and quantification of the individual analytes. To assist the validator in this determination, the following documents are recommended:

         1. the particular protocols under which the data was generated (i.e., NYSDEC ASP, EPA SW-846); and
         2. data validation guidance documents such as: USEPA Contract Laboratory Program National Functional Guidelines for Organic Data Review; USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review; and USEPA Contract Laboratory Program National Functional Guidelines for Polychlorinated Dibenzodioxins/Polychlorinated Dibenzofurans.

         NOTE: The site-specific requirements in the SAP take precedent if different than those noted in the functional guidelines. The referenced USEPA Contract Laboratory Program National Functional Guidelines for Organic and Inorganic Data Review will be used for format only.

         Task III: Report Submittal-the validator must submit a final report to the Department. The final report should discuss the results of the data review process that includes:

         1. a general assessment of the data package as determined by the accomplishment of Tasks I and II above;
         2. detailed descriptions of any deviations from the required protocols. These descriptions should include references to the portions of the protocols involved in the alleged deviations. Accuracy and defensibility issues should also be addressed;
         3. failures in the validator's attempt to reconcile the reported data with the raw data from which it was derived. Documentation of pertinent telephone conversations and meeting minutes;
         4. a detailed assessment by the validator of the degree to which the data may have been compromised by any deviations from protocol, AQA/AQC breakdowns, lack of analytical control, etc., that occurred during the sampling acquisition and analytical processes;
         5. a copy of the laboratory's case narrative and field notes, if applicable;
         6. data summary forms with validator qualifiers; and
         7. a chart, consisting of the site name, sample numbers, date submitted to the laboratory, methodologies, matrix, and fractions analyzed (i.e., volatiles, semi-volatiles, pesticides, metals).
      2. Data Usability Analysis. Data review for usability is a process that evaluates the validated data in context to the original DQO's. The formal process of usability determination involves a complex series of editing, screening, auditing, verifying and reviewing the validated data. The analysis should evaluate the following items:
         1. determination of whether or not the DQO's were met;
         2. consistency of the data with the site history;
         3. consistency of the data with regard to previous data rounds;
         4. evaluation of blanks for potential field or laboratory contamination;
         5. evaluation of duplicates for representativeness;
         6. evaluation of the matrix effect for high or low bias tracking;
         7. evaluation of the data characteristics (i.e., precision, accuracy, representativeness, comparability, completeness and defensibility) and justification for the use of both compliant and non-compliant data; and
         8. integration of field and laboratory data with hydrogeological, geological, and meteorological data to provide information for the intended use of the data.

NOTE: This table is provided to serve as a guide only; AQA/AQC sample requirements should be developed on a site-specific basis. Laboratory blanks and surrogate spikes are method specific and are not included in this table (see NYSDEC ASP). For information on sampling refer to the NYSDEC, Division of Water Sampling Manual.

References

Ambient Water Quality Standards and Guidance Values, TOGS (1.1.1), NYSDEC, Division of Water, Albany, NY 12233-3500, October 1993.

40 CFR Part 141 -- National Primary Drinking Water Regulations, MCLs, Protection of Environment, Office of the Federal Register, National Archives and Records Administration, Washington, DC 20408.

40 CFR Part 258 -- Criteria for Municipal Solid Waste Landfills, Protection of Environment, Office of the Federal Register, National Archives and Records Administration, Washington, DC 20408.

New York State Department of Environmental Conservation Analytical Services Protocol, NYSDEC, Division of Water, Albany, NY 12233-3500, October 1995.

USEPA Contract Laboratory Program National Functional Guidelines for Organic Data Review, Publication 9240.1-05, EPA-540/R-94/012, OSWER, USEPA, Washington, DC 20460, February 1993.

USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, Publication 9240.1-05-01, EPA-540/R-94/013, PB94-963502, OSWER, USEPA, Washington, DC 20460, February 1994.

USEPA Contract Laboratory Program National Functional Guidelines for Polychlorinated Dibenzodioxins/Polychlorinated Dibenzofurans, OSWER, USEPA, Washington, DC 20460, August 1990.

Guidance for Data Useability in Risk Assessment (Part A), Publication 9285.7-09A, PB92-963356, Office of Emergency and Remedial Response, USEPA, Washington, DC 20460, April 1992.

Guidance for Data Useability in Risk Assessment (Part B), Publication 9285.7-09B, PB92-963362, Office of Emergency and Remedial Response, USEPA, Washington, DC 20460, May 1992.

Sampling Guidelines and Protocols: Technological Background and Quality Control Quality Assurance for NYSDEC Spill Response Program, NYSDEC, Division of Spills Management, Albany, NY 12233-3750, September 1992.

Guidance for Preparation of Combined Work/Quality Assurance Project Plans for Environmental Monitoring, Office of Water Regulations and Standards, USEPA, Washington, DC 20460, May 1984.

Data Quality Objectives for Remedial Response Activities, Development Process, EPA/540/G-87/003, Office of Emergency and Remedial Response and Office of Waste Programs Enforcement, OSWER, USEPA, Washington, DC 20460, March 1987.

Data Quality Objectives for Remedial Response Activities, Example Scenario: RI/FS Activities at a Site with Contaminated Soils and Ground Water, EPA/540/G-87/004, Office of Emergency and Remedial Response and Office of Waste Programs Enforcement, OSWER, USEPA, Washington, DC 20460, March 1987.

RCRA Quality Assurance Project Plan Guidance, Division of Hazardous Substances Regulation, NYSDEC, Albany, NY 12233, March 1991.

Commercial Laboratories with New York State Approval to Perform Environmental Analyses, NYSDOH, Wadsworth Center for Laboratories and Research, Empire State Plaza, Albany, NY 12201-0509, May 22, 1995.

Emergency Standard Practice for Generation of Environmental Data Related to Waste Management Activities, ES 16-90, American Society for Testing and Materials, Philadelphia, PA 19103, June 1990.

USEPA Requirements for Quality Assurance Project Plans for Environmental Data Operations, EPA QA/R-5, USEPA Quality Assurance Management Staff, USEPA, Washington, DC 20460, July 1993.

Sampling Manual, NYSDEC, Division of Water, Albany, NY 12233, March 1989.

USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Data Review, Publication 9240.1-05-01, EPA-540/R-94/013, PB94-963502, OSWER, USEPA, Washington, DC 20460, February 1994.

USEPA Contract Laboratory Program National Functional Guidelines for Polychlorinated Dibenzodioxins/Polychlorinated Dibenzofurans, OSWER, USEPA, Washington, DC 20460, August 1990.

Guidance for Data Useability in Risk Assessment (Part A), Publication 9285.7-09A, PB92-963356, Office of Emergency and Remedial Response, USEPA, Washington, DC 20460, April 1992.

Guidance for Data Useability in Risk Assessment (Part B), Publication 9285.7-09B, PB92-963362, Office of Emergency and Remedial Response, USEPA, Washington, DC 20460, May 1992.

Sampling Guidelines and Protocols: Technological Background and Quality Control Quality Assurance for NYSDEC Spill Response Program, NYSDEC, Division of Spills Management, Albany, NY 12233-3750, September 1992.

Guidance for Preparation of Combined Work/Quality Assurance Project Plans for Environmental Monitoring, Office of Water Regulations and Standards, USEPA, Washington, DC 20460, May 1984.

Data Quality Objectives for Remedial Response Activities, Development Process, EPA/540/G-87/003, Office of Emergency and Remedial Response and Office of Waste Programs Enforcement, OSWER, USEPA, Washington, DC 20460, March 1987.

Data Quality Objectives for Remedial Response Activities, Example Scenario: RI/FS Activities at a Site with Contaminated Soils and Ground Water, EPA/540/G-87/004, Office of Emergency and Remedial Response and Office of Waste Programs Enforcement, OSWER, USEPA, Washington, DC 20460, March 1987.

RCRA Quality Assurance Project Plan Guidance, Division of Hazardous Substances Regulation, NYSDEC, Albany, NY 12233, March 1991.

Commercial Laboratories with New York State Approval to Perform Environmental Analyses, NYSDOH, Wadsworth Center for Laboratories and Research, Empire State Plaza, Albany, NY 12201-0509, May 22, 1995.

Emergency Standard Practice for Generation of Environmental Data Related to Waste Management Activities, ES 16-90, American Society for Testing and Materials, Philadelphia, PA 19103, June 1990.

Emergency Standard Practice for Generation of Environmental Data Related to Waste Management Activities, ES 16-90, American Society for Testing and Materials, Philadelphia, PA 19103, June 1990.

USEPA Requirements for Quality Assurance Project Plans for Environmental Data Operations, EPA QA/R-5, USEPA Quality Assurance Management Staff, USEPA, Washington, DC 20460, July 1993.

Sampling Manual, NYSDEC, Division of Water, Albany, NY 12233, March 1989.

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