United States
           Environmental Protection
           Agency
&EPA
            Office of Research and
            Development
            Washington DC 20460
EPA/540/R-95/515
August 1995
HNU-Hanby PCP
Immunoassay Test Kit
           Innovative
           Evaluation
            Technology
             Report
                SUPERFUND
                TECHNOLOGY
            INNOVATIVE
            EVALUATION

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                                           CONTACT
Jeanette Van Emon and Steve Rock are the EPA contacts for this report. Jeanette Van Emon is presently
with the new Characterization Research Division (formerly the Environmental Monitoring Systems
Laboratory) in Las Vegas, NV, which is under the direction of the National Exposure Research Laboratory
with headquarters in Research Triangle Park, NC.

 Steve Rock is presently with the new Land Remediation and Pollution Control Division (formerly the Risk
Reduction Engineering Laboratory) in the newly organized National Risk Management Research Laboratory
in Cincinnati, OH.


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                                             EPA/540/R-95/515
                                             August 1995
HNU-HANBY PCP IMMUNOASSAY TEST KIT

      INNOVATIVE TECHNOLOGY EVALUATION REPORT
  NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
         OFFICE OF RESEARCH AND DEVELOPMENT
        U.S. ENVIRONMENTAL PROTECTION AGENCY
                CINCINNATI, OHIO 45268
      NATIONAL EXPOSURE RESEARCH LABORATORY
        OFFICE OF RESEARCH AND DEVELOPMENT
        U.S. ENVIRONMENTAL PROTECTION AGENCY
               LAS VEGAS, NEVADA 89193
                                             Printed on Recycled Paper

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                                             Notice
The information in this document has been funded wholly or in part by the U.S. Environmental Protection
Agency (EPA) in partial fulfillment of Contract No. 68-CO-0047, Work Assignment No. 0-40, to PRC
Environmental Management, me. It has been subject to the Agency's peer and administrative review, and it
has been approved for publication as an EPA document. The opinions, findings, and conclusions expressed
herein are those of the contractor and not necessarily those of the EPA or other cooperating agencies.
Mention of company or product names is not to be construed as an endorsement by the agency.
                                                11


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                                            Foreword
        The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's land,
air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate and
implement actions leading to a compatible balance between human activities and the ability of natural systems
to support and nurture life. To meet this mandate, EPA's research program is providing data and technical
support for solving environmental problems today and building a science knowledge base necessary to manage
our ecological resources wisely, understand how pollutan s affect our health, and prevent or reduce environmental
risks in the future.

        The National Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and the environment.
The focus of the Laboratory's research program is on methods for the prevention and control of pollution to air,
land,  water  and subsurface resources; protection of water quality in public water systems ; remediation of
contaminated sites and ground water; and prevention and control of indoor air pollution. The goal of this research
effort is to catalyze development and implementation of innovative, cost-effective environmental technologies;
develop scientific and engineering information needed, by EPA to support regulatory and policy decisions; and
provide technical  support  and information transfer
regulations and strategies.
        This publication has been produced as part of the Laboratory
published and made available by EPA's Office of Research
to link researchers with their clients.
to ensure effective implementation  of environmental
             's strategic long-term research plan. It is
    and Development to assist the user community and
                                              E. Timothy Oppelt, Director
                                              National Risk Management Research Laboratory
                                                 111

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                                                Abstract
This innovative technology evaluation report describes a demonstration of the HNU-Hanby Environmental Test Kit for
determining pentachlorophenol (PCP) contamination hi soil. This kit was demonstrated in Morrisville, North Carolina,
in August 1993. The objective of this demonstration was to evaluate the technology by comparing its results to those from
a confirmatory laboratory that used standard EPA-approved analytical methods. The HNU-Hanby test kit can provide
PCP results only in samples that also contain a petroleum hydrocarbon carrier such as gasoline, kerosene, diesel fuel,
or fuel oil. The test kit uses the Friedel-Crafts alkylation reaction to detect the petroleum hydrocarbons.  This reaction
is colorimetric. A reflective photometer is used to quantitatively measure the reaction color.  A site-specific calibration
is needed to determine the ratio of PCP to carrier solvent.  This ratio is then used to correct the results from the reflective
photometer.

Hie detection limit reported by the test kit's developer is 1.0 part per million (ppm) for soil samples. A 5.0 ppm detection
limit was used for this demonstration.  The elevated detection limit was  the result of reducing the sample mass used for
extraction.  During the demonstration, 47 soil samples  were extracted and analyzed.  The precision of the test kit was
determined to be statistically the same as the precision of the confirmatory laboratory.  The accuracy of the kit's data set
was evaluated as a whole and by concentrations less than and greater than 100 ppm PCP.  When the entire data set was
evaluated, the test kit's results were determined to be statistically different from the confirmatory results.  This was also
the case for samples in which the PCP concentrations were greater than 100 ppm. The test kit's  data for samples
containing less than 100 ppm PCP was shown to be statistically similar to the corresponding confirmatory data. Based
on this evaluation, the test kit produced Level 1 data for samples containing greater than 100 ppm PCP and Level 2 data
for samples containing less than 100 ppm PCP.  This  indicates that there was a concentration effect oh the test kit's
accuracy. The test kit showed greater comparability to the confirmatory data when PCP concentrations in samples were
below 100 ppm.

This report  was submitted hi partial fulfillment of 68-CO-0047 WA 0-40 by PRC Environmental Management, Inc.
(PRC), under sponsorship of the U.S. Environmental Protection Agency.  This report covers a period from July 1, 1993,
to August 31, 1993, and work was completed as of February  1, 1994.
                                                     IV

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                                     Table of Contents
Section
Notice	
Foreword 	
Abstract 	
List of Figures	
List of Tables  	
List of Abbreviations and Acronyms
Acknowledgments  	
1   Executive Summary
2  Introduction	
       EPA's Site Program and MMTP: An Overview
               The Role of Monitoring and Measu
               Defining the Process 	
               Components of a Demonstration
       Rationale for this Demonstration	
       Demonstration Purpose, Goals, and Objec
ives
3  Predemonstration Activities  	
       Identifying Developers	
       Selecting the Sites	
       Selecting the Confirmatory Laboratory and
       Training Technology Operators	
       Predemonstration Sampling and Analysis .
Analytical Methods
    Demonstration Design and Description	
       Implementation of the Demonstration Plan
       Field Modifications to the Demonstration PI
       Data Collection	
       Statistical Analysis of Results	
an
   Confirmatory Analysis Results	
       Confirmatory Laboratory Procedures  . . .
              Sample Holding Times	'.
              Sample Extraction  	
              Detection Limits and Initial and Continuing Calibrations
•ement Technologies
..ii
.  iii
.  iv
. vii
. vii
 viii
.  ix

.  1

.  3
.  3
.  3
.  3
.  4
.  4
.  5

.  6
.  6
. .6
.  7
.  7
.  7

.  8
.  8
.  8
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.  9

11
11
11
11
11

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                            Table of Contents (Continued)
Section
Page
              Sample Analysis	  12
              Quality Control Procedures  	  12
              Data Reporting	  12
       Data Quality Assessment	'•	  13
       Confirmatory Laboratory Costs and Turnaround Times	  14

6  HNU-Hanby Environmental Test Kit	  15
       Operational Characteristics	  16
       Performance Factors	  17
       Intramethod Assessment	  17
       Comparison of Results to Confirmatory Laboratory Results	  18

7  Applications Assessment	  21

8  References	  22
                                            VI

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                                      List of
Figure

6-1  Regression of Data
                                      List of Tables
5-1  Matrix Spike and Matrix Spike Duplicate Resu
6-1  Calibration Data  	
6-2  Laboratory Duplicate Results	
6-3  Field Duplicate Results	
6-4  Summary of Demonstration Data	
6-5  Summary of Regression and Residual Results
                                              Figures
                                                                                       Page

                                                                                       ..  20
                                                                                       Page
                                             ts
13
15
18
18
19
20

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                            List of Abbreviations and Acronyms
DCAA         2,4-dichlorophenylacetic acid
EMSL-LV      Environmental Monitoring Systems Laboratory-Las Vegas
EPA           Environmental Protection Agency
ERA           Environmental Research Associates
GC            gas chromatograph
GC/MS         gas chromatograph/mass spectrograph
IDW           investigation-derived waste
ITER          Innovative Technology Evaluation Report
Koppers        Koppers Company
fig/kg          micrograms per kilogram
mg/kg          milligrams per kilogram
MMTP         Monitoring and Measurement Technologies Program
NRMRL        National Risk Management Research Laboratory
ORD           Office of Research and Development
OSWER        Office of Solid Waste and Emergency Response
PCP           pentachlorophenol
PE            performance evaluation
ppm           part per million
PRC           PRC Environmental Management, Inc.
QADE         Quality Assurance and Data Evaluation
QA/QC         quality assurance/quality control
QAPjP         quality assurance project plan
p              correlation of determination
RCRA         Resource Conservation and Recovery Act
RECAP        Region 7 Environmental Collection and Analysis Program
RPD           relative percent difference
SARA          Superfund Amendments and Reauthorization Act of 1986
SITE           Superfund Innovative Technology Evaluation
SMO          Sample Management Office
SVOC          Semivolatile Organic Compound
                                                VIII

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                                        Acknowledgments
This demonstration and the subsequent preparation of this report required the services of numerous personnel from the
Environmental Protection Agency, Envkonmental Monitoring Systems Laboratory (Las Vegas, Nevada); Environmental
Protection Agency, Region 7 (Kansas City, Kansas); HNU-Hanby Systems (Houston, Texas); HNU Systems (Boston,
Massachusetts);  Beazer  East, Inc. (Pittsburgh,  Pennsylvania); Winona Post,  Inc. (Winona, Missouri);  and PRO
Environmental Management, Inc. (Kansas City, Kansas; Cincinnati, Ohio; and Chicago, Illinois).  The cooperation and
efforts of these organizations and personnel are gratefully acknowledged.
                                                  IX

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                                               Section 1
                                        Executive Summary
     This innovative technology evaluation report (ITER)
 presents information on the demonstration of the HNU-
 Hanby Environmental Test Kit for determining penta-
 chlorophenol (PCP) contamination in soil. This screen-
 ing kit was demonstrated in Morrisville, North Carolina,
 in August 1993.  The demonstration was conducted by
 PRC Environmental Management,  Inc. (PRC), under
 contract with the Environmental Protection Agency's
 (EPA)  Environmental  Monitoring Systems  Labora-
 tory—Las Vegas  (EMSL-LV).  The demonstration was
 developed  under the  Monitoring  and Measurement
 Technologies Program  (MMTP)  of the  Superfund
 Innovative Technology Evaluation (SITE) Program.

     This technology was demonstrated in conjunction
 with four other  field  screening technologies:  (1)  the
 Penta RISc Test System developed by EnSys Incorpor-
 ated, (2) the EnviroGard PCP Test Kit developed by the
 Millipore Corporation, (3) the Penta  RaPID Assay
 developed by Ohmicron Corporation, and (4) the Field
 Analytical Screening Program PCP Method developed
 by EPA's Region  7 through its Superfund Program.  The
 results of the demonstrations of these other technologies
 are presented in separate reports similar to this  one.

     The objective of this demonstration was to evaluate
 the HNU-Hanby  test kit for accuracy  and precision at
 detecting high and low levels of PCP in soil samples by
 comparing  its  results  to  those from a confirmatory
 laboratory that used standard EPA-approved analytical
 methods.  These EPA-approved methods are  used to
 provide legally defensible analytical data for the purpose
 of monitoring or  for the enforcement of environmental
 regulations.   Because these EPA-approved methods are
 used by the regulatory community, they also were used
 for this demonstration for comparison of results.  While
 these methods may include inherent tendencies which
 may bias data or may include procedures with which
 developers  disagree,  they are  the  best methods for
providing legally defensible  data  as  defined  by the
regulatory community.  To remove as much of these
 inherent tendencies as possible, PRC used post  hoc
residual analysis  to remove data outliers.  The HNU-
 Hanby test kit also was qualitatively evaluated for the
 length of time required for analysis, ease of use, porta-
 bility, and operating cost.

     The site selected for demonstrating this technology
 was the former Koppers  Company (Koppers) site hi
 Morrisville, North Carolina.   This site was  selected
 because  a  Risk Reduction  Engineering Laboratory
 (RREL)  SITE demonstration was planned for  this site
 allowing  for a  conjunction of logistical and  support
 efforts between RREL and EMSL-LV.  However the
 PCP at the former Koppers site was not introduced using
 a petroleum hydrocarbon carrier.  Because the HNU-
 Hanby test kit provides results only for soil hi  which a
 petroleum hydrocarbon carrier is present, samples were
 collected from the  Winona Post site in Missouri and
 shipped  to the former Koppers site for inclusion as
 demonstration  samples.   PCP contamination at  the
 Winona Post site had been introduced using a diesel fuel
 carrier solvent.

     The  HNU-Hanby test kit is designed to  provide
 quick, semiquantitative and quantitative results for PCP
 concentrations in soil samples.  The test kit can  provide
 PCP results only hi samples which also contain  a petro-
 leum hydrocarbon carrier  such as gasoline, kerosene,
 diesel fuel, or fuel oil. It cannot be used to determine
 PCP results for samples in which no petroleum hydro-
 carbon carriers are  present.  The HNU-Hanby test kit
 measures PCP  indirectly by measuring the petroleum
 hydrocarbons carrier solvent remaining hi the soil.  The
 ratio of PCP hi a petroleum hydrocarbon carrier may
 vary due  to manufacturing processes, dilution variances,
 and  the  volatility  and weathering of  the  petroleum
 hydrocarbon carrier.  Therefore, site samples must be
 obtained  so that site-specific calibration data  can be
prepared. This can be done by analyzing the samples
both by EPA-approved methods and using the test kit.
 Calibration data can then be generated by correlating the
PCP confirmatory results against the kit's corresponding
response.  The test kit uses the Friedel-Crafts alkylation
reaction  to detect the petroleum hydrocarbons.  This
reaction is colorimetric. A reflective photometer is used
                                                   1

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to quantitatively measure the reaction color.  A site-
specific calibration is needed to determine the ratio of
PCP to carrier solvent. This ratio is then used to correct
the results from the reflective photometer.

    The HNU-Hanby test kit is portable and can be
operated outdoors.  Temperature extremes and humidity
do not seem to affect its performance.  The reagents
used with the test kit do not require refrigeration.  The
reflective photometer requires electricity but can be
operated using a rechargeable battery pack. The test kit
was  found to be easy to operate by individuals with no
prior environmental testing experience.

    The test kit costs $1,195.  This test kit provides
enough reagent and glassware to perform 30 soil sample
analyses.  The reflective photometer used  to provide
quantitative data costs $3,500.  Other equipment, such as
extraction vials and pipettes, may need to be purchased
when using the test kit.   The cost of these items will
vary depending upon the number of samples that will be
analyzed.  The detection limits reported by the test kit's
developer is 1.0 part per million (ppm) for soil samples.
A 5.0 ppm detection limit was used for this demonstra-
tion.  The  elevated detection limit was the result of
reducing the sample mass used for extraction.
    During  the demonstration, 47 soil samples were
extracted and analyzed hi two 8-hour days.  The average
time to analyze one soil sample was about 21 minutes.
The precision of the test  kit was determined  to  be
statistically the same as the precision of the,confirmatory
laboratory.  The kit's data set was evaluated for accur-
acy as a whole  and by concentrations less than and
greater than 100 ppm PCP.  When the entire data  set
was evaluated, the test kit's results were determined to
be statistically different from the confirmatory results.
This was also the case for samples in which the PCP
concentrations were greater than 100 ppm. The test kit's
data for samples containing less than 100 ppm PCP was
shown to be statistically similar to the corresponding
confirmatory data.  Based on this evaluation, the test  kit
produced Level  1 data for samples containing greater
than 100  ppm PCP and Level 2 data for samples contain-
ing less  than 100 ppm PCP.  This indicates that there
was a concentration effect on the test kit's accuracy.
The test kit showed greater comparability to the confir-
matory data when PCP concentrations in samples were
below 100 ppm.

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                                                Section 2
                                              Introduction
     This HER presents information on the demonstratio: i
 of the  HNU-Hanby Environmental Test Kit, a field
 screening technology designed to detect PCP in soil.  The
 demonstration was conducted by PRC under the EPA's
 SITE  Program.    The test  kit was demonstrated
 conjunction with the demonstrations of four other fieli
 screening technologies:  (1) the Penta PJSc Test Sys
 developed by EnSys Incorporated,  (2) the EnviroGa:
 PCP Test Kit developed by the Millipore Corporation, (3J)
 the  Penta RaPID  Assay  developed by the Ohmicron
 Corporation,  and  (4) the Field Analytical Screening
 Program PCP Method  developed by EPA's Region 7
 through its Superfund Program.  The results of these other
 demonstrations are presented in reports similar to  this one

 EPA's Site Program and MMTP: an Overview

     At  the time  of the  Superfimd Amendments  anc
 Reauthorization  Act of  1986  (SARA),  it was we!
 recognized that the environmental cleanup problem needec
 new and better methods.  The SITE Program, therefore.
 was created to fulfill a requirement.of SARA that  the EPA]
 address  the   potential  of  alternative  or  innovative
 technologies.  The EPA made this program a joint effort
 between the  Office of Solid  Waste and Emergency
 Response (OSWER)  and  the  Office of Research and
 Development (ORD). The SITE Program includes four
 parts:

 •   The Demonstration Program
 •   The Emerging Technology Program
 •   The Monitoring  and  Measurement  Technologies
    Program (MMTP)
 •   The Technology Transfer Program

    The  largest   part  of the  SITE Program,  the
 Demonstration Program, is concerned with treatment
technologies and is administered by ORD's NRMRL in
Cincinnati, Ohio.  The  MMTP component, though, is
administered  by EPA's EMSL-LV.   The MMTP  is
concerned with monitoring and measurement technologies
that identify, quantify, or monitor changes in contaminants
occurring at hazardous waste sites or that are  used  to
characterize a site.
     The MMTP seeks  to  identify  and  demonstrate
 innovative technologies that may provide less expensive,
 better, faster, or safer means of completing this monitoring
 or characterization.  The  managers of hazardous waste
 sites are often reluctant to use any method, other than
 conventional ones, to generate critical data on the nature
 and extent of contamination.  It is generally understood
 that the courts recognize data generated with conventional
 laboratory methods; still,  there  is a tremendous need to
 generate data more cost effectively.  Therefore, the EPA
 must  identify innovative approaches,  and  through
 verifiable testing of the  technologies under the SITE
 Program, ensure that the innovative technologies are
 equivalent to or better than traditional technologies.

 The Role of Monitoring  and  Measurement
 Technologies

    Measurement and monitoring technologies are needed
 to assess the degree of contamination, to  determine the
 effects  of  contamination  on public  health and  the
 environment, to supply data for  selection of appropriate
 remedial action, and to monitor the success or failure of
 selected remedies. Thus,  the  MMTP is concerned with
 evaluating  screening  technologies, including  remote
 sensing, monitoring, and analytical technologies.

    Candidate technologies may come from within the
 federal government or from the private sector.  Through
 the program, developers are to  rigorously evaluate the
 performance of their technologies.  Finally, by distributing
 the results and recommendations of those evaluations, the
 market for the technologies is enhanced.

 Defining the Process

    The demonstration process begins by canvassing the
 EPA's 10 regional offices (with input from OSWER .and
 ORD) to determine their needs.  Concurrently, classes of
 technologies are identified. An ideal match is made when
there is  a clear need by EPA's regions  and a number of
technologies  that  can address  that need.     The
demonstrations are designed to  judge  each  technology
against existing standards and not against each other.

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    The demonstration is designed to provide for detailed
quality assurance and quality control (QA/QC) to ensure
that a potential user can evaluate the accuracy, precision,
representativeness, completeness, and compar-ability of
data derived from the innovative technology.  In addition,
a  description of  the necessary steps and  activities
associated with operating the innovative technology is
prepared.    Cost data,  critical  to  any environmental
activity, is generated during the demonstration and allows
a potential user to make economic comparisons. Finally,
information on practical matters such as operator training
requirements, detection levels, and ease of operation is
reported.   Thus, the  demonstration report and other
informational materials produced by the MMTP provide
a real-world comparison of that technology to conventional
technologies.  With cost and performance data,  as well as
"how to" information, users can determine whether a new
technology better meets their needs.

Components of a Demonstration

    Once a decision has been made  to demonstrate
technologies to meet a particular EPA need, the MMTP
performs a  number of activities.   First, the MMTP
identifies potential participants and determines whether
they are interested  in participating.  Each developer is
advised of the general nature of the demonstration and is
provided  with information  common  to all MMTP
demonstrations.    Information   is  sought  from  each
developer about  its  technology  to  ensure that the
technology meets the parameters of the demonstration.
Then, after evaluation of the information, all respondents
are  told whether they have been  accepted into the
demonstration or  not.   While  participants  are being
identified, potential sites also are identified, and basic site
Information is obtained.

    The next component, probably the most important, is
the  development  of plans that   describe  how the
demonstration will be conducted.  A major part of the
EPA's   responsibility  is  the  development   of  a
demonstration plan,  a  quality   assurance project plan
(QAPjP), and a health and safety plan.  While the EPA
pays for and has the primary responsibility for these plans,
each  is  developed  with   input  from  all  of the
demonstration's  participants.   The  plans  define how
activities will be conducted and how the technologies will
be evaluated. The MMTP also provides each developer
with site information and often predemonstration samples
so the developer can. maximize the field performance of its
innovative technology.  Generally, the developers train
EPA-designated personnel to operate their technologies so
that performance is not based on the special expertise of
the developers. This also ensures that potential users have
valid information on training requirements and the types of
operators who typically use a technology successfully.
    The field demonstration itself is the shortest part of
the process.  During the field demonstration,  data is
obtained on cost, technical effectiveness  (compared to
standard methods),  and limiting factors.  'In addition,
standardized field methods are developed and daily logs of
activities and observations (including photos or videotape)
are produced.   The EPA  is also  responsible for the
comparative, conventional method analytical costs and the
disposal   of  any  wastes  generated  by   the  field
demonstration.

    The final  component of an MMTP demonstration
consists of reporting the results and ensuring distribution
of demonstration information.  The primary product of the
demonstration  is  an  ITER,  like  this  one, which is
peer-reviewed and distributed as part of the technology
transfer responsibility of the MMTP.  The ITER fully
documents  the   procedures  used during  the  field
demonstration, QA/QC results, the field demonstration's
results, and its conclusions.  A separate QA/QC data
package also is made available for those 'interested hi
evaluating  the demonstration hi greater depth. Two-page
technical  briefs  are  prepared   to  summarize  the
demonstration  results and  to  ensure  rapid and  wide
distribution of the information.

    Each  developer  is responsible for providing the
equipment or technology product  to be demonstrated,
funding its own mobilization costs, and training of EPA-
designated operators.  The MMTP does not provide any
funds  to developers for costs associated with preparing
equipment for demonstration or for development, and it
does not cover the costs developers Incur to demonstrate
their products.

Rationale for this Demonstration

    PCP,  a regulated chemical used in the wood treatment
industry,  is included on the EPA Extremely Hazardous
Substances List.  Recently, PCP regulations under the
Resource  Conservation and Recovery Act (RCRA) have
been created specifically for wood treatment facilities.
PCP   is   included  as a  target  compound  of many
EPA-approved analytical methods, including EPA 500
Series Methods  515.1  and  525, EPA  600  Series
Methods  604  and  625,  and  EPA SW-846  Manual
Methods  8040, 8151, 8250, and  8270.  All  of these
methods use solvent extraction and  gas chromatograpby.
Detection and  quantitation is performed  with flame
ionization,  electron  capture,  or   mass  spectrometer
detectors.  Analyzing  samples for PCP using  these
methods  is  typically  costly  and  time  consuming.
EMSL-LV, therefore, identified the need for effective,
accurate,  low-cost screening "technologies  that could
provide  near  real-time  analytical data  for  PCP  to
Superfund and RCRA decisionmakers.

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Demonstration Purpose, Goals,
and Objectives

     The HNU-Hanby test kit was qualitatively evaluated
for the length of time required for analysis, ease of use
portability, and operating cost.  It also was evaluated fo
accuracy and precision at detecting high and low levels ox
PCP in soil samples. The test kit's accuracy and precision
were statistically compared to the accuracy and precision
of a conventional confirmatory laboratory that had used
EPA-approved analytical methods.  These comparisons
also were used to determine the highest data quality level
that the test kit could attain in field applications. For the
purpose of this demonstration the three primary data
quality levels are defined as follows (EPA 1990):
Level 1:      This data is not necessarily analyte-specific
             Technologies that  generate Level  1 dati.
             provide  only  an  indication  of contarm-
             ination.    Generally, the  use  of these
             technologies requires sample documentation
             instrument  calibration,  and performance
             checks of equipment.

Level 2:      This data is analyte-specific.  To provide at.
             accuracy check, verification analysis  for
             at least 10 percent of the samples by an
             EPA-approved  method is necessary.  The
             method's analytical error is quantified. Use
             of  QC   procedures  such   as   sample
             documentation, chain-of-custody procedures,
             sample  holding time criteria,  initial and
             continuing instrument calibration,  method
             blank analysis,  rinsate blank analysis, and
             trip blank analysis is recommended.

 Level 3:     This  data   is  considered   formal  or
             confirmatory analysis. It is analyte-specific
             and  generally   involves   second-method
             confirm-ation on 100 percent of critical
             samples.   Analytical error is quantified
             (precision,    accuracy,    coefficient   of
             variation) and monitored. The following QC
             measures are used:  sample documentation,
             chain of  custody,  sample holding time
             criteria, initial  and  continuing instrument
             calibration, rinsate blank analysis, trip blank
             analysis,   and   performance   evaluation
             samples.   Detection limits are determined
             and monitored.

    Inherent in  the concept  of data quality levels is
accuracy. Although PRC could not find a reference that
defined the expected and quantified accuracy of each data
quality  level, it imposed common accuracy criteria in
defining these data quality levels.  Data quality Level 3 is
considered the most accurate of the three levels; this data
is obtained by formal analysis using approved methods.
Data  quality  Level 2 is less accurate but does quantify
compound concentrations.  Data quality Level  1 is the
least accurate and is often considered survey data, only
identifying the presence or absence of a compound or class
of compounds.

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                                              Section 3
                                   Predemonstration Activities
    Several activities were  conducted by EMSL-LV,
PRC, and other demonstration participants before the
demonstration began. These activities included identifying
developers, selecting the demonstration sites, selecting the
confirmatory  laboratory and analytical methods, and
conducting predemonstration sampling. Predemonstration
sampling  and analysis  are normally  used to  allow
developers to refine their technologies and revise their
operating  instructions,  if  necessary,  prior  to  the
demonstration.

Identifying Developers

    EMSL-LV supplied PRC with the names  of the
immunoassay developers demonstrating technologies and
asked that PRC search for other technologies that could be
demonstrated simultaneously and  inexpensively.   PRC
identified EPA Region 7's field gas chromatograph (GC)
method and the HNU-Hariby test kit for inclusion in the
demonstration.

Selecting the Sites

To  evaluate  the  HNU-Hanby  test  kit  under  field
conditions, a hazardous  waste  site  suitable  for the
demonstration was needed.  The following criteria were
used to select the appropriate site:

•   The test, kit needed to be demonstrated on samples
    with a wide range of PCP contamination.

•   PCP  concentrations at the  site  had to be well
    characterized and documented.

•   The  site had to  be accessible  for conducting
    demonstration activities without interfering with any
    other activities being conducted on site.

•   Because the  test kit can  only be  apph'ed when  a
    petroleum product is the PCP carrier, the site used
    had to  be contaminated by  PCP  hi a petroleum
    product carrier.
    The former Koppers wood treatment site was selected
for conducting the analyses because it met the criteria for
the  other demonstrations  and because NRMRL  was
planning a SITE demonstration of the ETG Environmental,
Inc., Base-Catalyzed Decomposition technology at the site,
allowing logistical and support efforts between NRMRL
and EMSL-LV to be combined.  However, the former
Koppers  site is contaminated with PCP in  butane and
isopropyl ether carrier solvents.  Therefore, demonstration
samples were collected from the  Winona  Post site  in
Missouri and shipped to the former Koppers site.  Soils at
the  Winona Post site are contaminated with PCP  in a
diesel fuel carrier solvent.

    The Winona Post site is  located in Winona, Missouri,
on Old Highway 60 West. It has operated as a sawmilling
and wood preserving facility since at least the early 1950s.
It currently treats pine and oak lumber with a solution of
5 percent PCP in diesel fuel. The solution is stored in a
20,000-gallon aboveground storage tank located adjacent
to the treatment building.   In the past, the Winona  Post
Company mixed its own solution from concentrated PCP.
Prior to the mid-1950s, the Winona Post Company treated
wood with creosol.

    PCP is an organic chemical with an empirical formula
of C5C15OH and a molecular weight of 266 grams per
mole.  PCP has a melting point of 191 °C and a boning
point of 310  °C.   The  specific gravity  of PCP  is
1.978 grams per cubic centimeter. PCP iSjdescribed as
almost insoluble in water, with  8 milligrams  able  to
dissolve into 100 milliliters of water.  The octanol  ratio
coefficient of PCP is 6,400, which indicates that PCP is
tightly bound to the soil matrix when it is released into the
environment.

    PCP is used as a wood preservative, an insecticide, a
preharvest defoliant, a slimicide, and a defbaming agent.
The largest user of PCP is the wood treating industry.
PCP is applied to wooden utility poles, railroad ties, and
lumber to protect them from weathering and deteriorating
due to fungus and rot.  About 0.23 kilogram of PCP is
required for each cubic foot of wood treated.  For treating

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wood, PCP is usually diluted to a 5 percent solution with
solvents such as mineral spirits, kerosene, diesel fuel, or
fuel oil.  PCP  also has been applied to wood with
methylene chloride and liquified petroleum gas, such as
butane.  PCP also is used in the manufacturing of learner
and tanning products, masonry products, rope and paper
products, adhesives, and paint.
Selecting the Confirmatory Laboratory
Analytical Methods
and
    Before  the  demonstration,  the  EPA  Region
Laboratory arranged for all samples to be analyzed undsr
the Region  7 Environmental Collection and Analysis
Program (RECAP) Contract.   SW-846 protocols f>r
Level 3 data were used to analyze the samples during tt is
demonstration.   All  samples were extracted by  EPA
Method 3540A (Soxhlet Extraction) and analyzed by EP A
Method 8270A (Semivolatile Organic Compounds by G is
Chromatograph/Mass Spectrometer [GC/MS]: capillary
column).  Any samples in which PCP was not detected
using Method 8270A were reanalyzed by Method 815lk
(chlorinated   herbicides   by   GC:  capillary column)
calibrated to PCP. All of these analytical methods are
well established  and approved  by  EPA.   The  QA
procedures,  reporting requirements,  and data  quality
objectives of these methods are consistent with the goals
of the SITE Program.

Training Technology Operators

    The technology was operated by a PRC operator.
Before  the demonstration  began, this  individual  was
trained  on how to use the technology.  This training
involved a review of operating procedures and instructions
provided by the developer, and formal training by the
developer. Training was equivalent to that recommended
by the developer for those using the test kit on actual site
characterization projects.

Predemonstration Sampling and Analysis

    In August 1993, while demonstration sampling for the
other technologies was being conducted at the former
Koppers site, PRC collected five predemonstration soil
samples from areas at the  Winona Post site previously
identified  as  containing PCP.   These samples were
submitted to  HNU-Hanby.  These samples were not
analyzed by a confirmatory  laboratory.  HNU-Hanby
Systems analyzed the predemonstration samples with the
test kit and by GC/MS. The developer used this data to
calculate calibration factors  for the test kit.

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                                              Section 4
                            Demonstration Design and Description
    The primary objective of the demonstration was to
evaluate this test kit for its effectiveness at detecting
PCP  in soil when operated in field conditions.  This
objective included defining the precision, accuracy, cost,
and range of usefulness for the test kit.  A secondary
objective was to define the data quality objectives that
the test kit can be used to address.  The evaluation was
designed so that the test kit results could be compared to
those of a confirmatory laboratory that analyzed each
sample using  standard EPA-approved methods.   The
design limited, as much as possible,  those elements of
sample collection and analysis that would interfere with
a direct comparison of the results.   These elements
included heterogeneity of the samples and interference
from  other chemicals or other controllable sources.

    The design also ensured that the data was collected
in a normal field environment.  To do this, the test kit
was operated in a trailer located at the former Koppers
site.  The operator was trained by the developer and was
able to call the developer with questions when necessary.
The operator, though, obtained all results on his own and
reported the results once he believed the results were
accurate and  precise.   Standard  QC samples were
analyzed with each batch of environmental samples.
Numerous laboratory and field duplicate samples were
included among those  analyzed  to  ensure  a proper
measure of precision.  The  technology was tested  for
common interferants.  Qualitative measures, such  as
portability and ease of operation, were also noted by the
operator.  Overall, the demonstration was executed as
planned in the demonstration plan (PRC  1993), which
included the QAPjP.  The final version of that plan was
approved by all participants and developers before  the
demonstration began. Below is a discussion of selected
elements of that plan and a full discussion of deviations
from it.

Implementation of the Demonstration Plan

    Forty  soil samples and five soil field duplicates were
collected at the Winona Post site. The soil  samples were
collected in areas believed to be contaminated with high
(greater than 1,000 ppm), medium (100 to 999 ppm),
and low (less than 99 ppm) concentrations of PCP.  The
identification of these areas was based on past sampling
data and visual signs of waste disposal.   All  of the
samples were  collected, packaged, and shipped to the
former Koppers site. Each soil sample was thoroughly
homogenized and then split into six replicate samples.
One replicate from each soil sample was submitted to the
confirmatory laboratory for analysis using the methods
described in Section 3.   The remaining replicates were
analyzed in the trailer at the  former Koppers site using
the various technologies being evaluated.

Field Modifications
to the  Demonstration Plan

    Two field modifications were made to the approved
demonstration plan used to demonstrate the five technol-
ogies, but neither influenced the test kit's results.  First,
fluorescein was to be added to the soil samples from the
former Koppers site prior to homogenization. This test
kit, though, was used only on samples from the Winona
Post site, and the saturated silty nature of the Winona
Post soil samples allowed easy and thorough homogeni-
zation.  PRC, therefore, used an EPA-approved homo-
genization method and applied  it to each sample  for 10
to 15 minutes.

Data Collection

    The operator prepared a subjective evaluation of
how difficult the test kit was to use. Other qualitative
factors  included  portability, ruggedness,  instrument
reliability, and health and safety considerations.  Infor-
mation on these qualitative factors was collected both by
the operator of the test kit and by the project's lead
chemist.

    Accuracy and precision were statistically evaluated
during this  demonstration.  To evaluate accuracy and
precision, all samples collected for the demonstration
were  split between the  test  kit and the confirmatory

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 laboratory for analysis.  The results from the confirma
 tory laboratory, for the purposes of this demonstration,
 were considered the actual concentration of PCP in each
 sample. The statistical methods used for the comparison
 are detailed later hi this section. The cost of using the
 test kit also was assessed. Cost, for the purposes of this
 demonstration, includes expendable  supplies, nonexpendj-
 able equipment, labor, and investigation-derived waste
 (IDW) disposal.  These costs  were tracked during th<
 demonstration.

 Statistical Analysis of Results

    Besides looking at the data set as a whole, PRCJ
 grouped the data into results greater than 100 ppm anc
 less than 100 ppm PCP.  This grouping was intended tc
 assess potential concentration effects on the data analy
 sis.  These data sets  were prepared for  the statistica
 analysis following the approved demonstration plan
 When comparing duplicate samples or when comparing
 the results of a technology to those from the confirma-
 tory laboratory, sample pairs that contained a nondetec
 were removed from the data sets. While other statistica
 methods can be used when nondetects  are encountered.
 PRC  felt that  the  variance introduced by  eliminating
 these data pairs would be less than, or no more thai
 equal to, the variance produced by giving not detectec
 results an arbitrary value.

 Intramethod Comparisons

    Sample results from the test kit were compared to
 their  duplicate  sample  results and to other QA/QC
 sample results.   These  comparisons are called intra-
 method comparisons. Intramethod precision was as-
 sessed through the statistical analysis of relative percent
 differences (RPD) between duplicates.  First, the RPDs
 of  the results for each sample pan- hi which both the
 sample and its duplicate were found to contain PCP were
 determined.  The RPDs  then were compared to upper
 and lower control limits.  When  using  conventional
 technologies, such data is often available from analysis
 of  samples collected during previous investigations.
 Because the technology being  demonstrated was itseli
 being assessed, the control limits used were calculated
 from data provided during this investigation.  To deter-
 mine these control limits, the standard deviation of the
 RPDs was calculated.  This standard deviation was then
 multiplied by two and added to its respective mean RPD.
 This established the upper control limit for the technol-
 ogy.   Because an RPD  of zero would mean that  the
 duplicate  samples  matched  their  respective samples
perfectly, zero was used as the lower control limit. This
 resulted in  a large  range of acceptable  values.   All
 samples that fell within the control  limits  were consid-
ered  acceptable.   PRC  determined  that if at least
  90 percent of the duplicate samples fell within these
  control limits, the technology had acceptable intramethod
  precision.

  Intermethod Comparisons

     The data sets also were statistically compared to the
  results  from  the confirmatory  laboratory,  and  the
  precision of the technology was statistically compared to
  the precision  of the confirmatory  laboratory.  These
  comparisons are called intermethod comparisons.   In
  both cases, the results from the confirmatory laboratory
  were considered as accurate and precise as analytically
  possible.

     The statistical methods used to determine inter-
  method accuracy were linear regression analysis and the
  Wilcoxon Signed Ranks Test.  PRC prepared the data
  sets for  the linear regression by averaging the field
  duplicate results.  This was done to ensure that those
  samples  were not unduly weighted in the regression
  analysis.   PRC  calculated linear  regression by  the
  method of least squares. Calculating linear regression in
  this way makes it possible to determine whether two sets
  of data are reasonably  related, and  if so, how closely.
  Calculating linear regression results hi an equation that
 can be visually expressed as a line.  Three factors  are
 determined during the calculations:  the y-intercept,  the
 slope of  the line, and the  coefficient of determination,
 also called r2.  All three  of these factors had to have
 acceptable values before the technology's accuracy was
 considered to  meet Level  3 data quality requirements.
 The r2 expresses the mathematical relationship between
 two data sets.  If r2 is  equal to one, then the two data
. sets are directly related.  Lower r2 values indicate less of
 a relationship.  Because of the nature of environmental
 samples,  r2 values between 0.85 and 1 were considered
 to meet data quality Level 3 accuracy requirements; r2
 values between 0.75 and 0.85  were  considered to meet
 data quality Level 2 accuracy  requirements; and  r2
 values below 0.75 were considered not accurate, meet-
 ing,  at best,  Level  1  data quality objectives.  The
 classification of data as Level 1, 2, or 3 was implied hi
 the approved  demonstration plan;  however,  these
 specific criteria were not presented.

     If the regression analysis resulted hi an r2 between
 0.85 and 1, then the regression line's y-intercept and
 slope  were examined to determine how closely the two
 data sets matched. A slope of 1 and a y-intercept of zero
 would mean that the results  of the technology matched
 those of the confirmatory laboratory perfectly.  Theoreti-
 cally, the farther the slope and y-intercept differ from
 these expected values, the less  accurate the technology.
 Still, a slope or y-intercept can differ slightly from its
 expected value without that difference being statistically

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significant. To determine whether such differences were
statistically significant, PRC used the normal deviate test
statistic.  This test  statistic results in a value that is
compared  to  a table.   The value at  the  90 percent
confidence level was used for the comparison. To meet
data quality Level 3 requirements, both the slope  and
y-intercept had to be statistically the same as their ideal
values.  If the r2 was between 0.75 and 0.85, and one or
both of the other two regression parameters was not
equal to their ideal, the test kit's results were considered
inaccurate but to be of Level 2 quality.  Results in this
case could be mathematically corrected if 10  to  20
percent of the samples were  sent to  a confirmatory
laboratory. Analysis of a percentage of the samples by
a confirmatory laboratory  would  provide a basis for
determining a correction factor.  Only in cases where the
r2, the y-intercept,  and the slope were all found to be
acceptable did PRC determine that the test kit's results
were accurate, meeting Level  3 data quality  require-
ments.  Data placed hi the Level 1 category had r2 values
less than 0.75, the data was not statistically similar to the
confirmatory  data,  based on nonparametric  testing, or
the results did not meet the manufacturer's performance
specifications.

    A  second statistical method used  to assess inter-
method accuracy was the Wilcoxon Signed Ranks Test.
This test is a nonparametric method for  comparing
matched pairs of data.   It can be used to evaluate
whether two sets of data are significantly different.  The
test  requires  no assumption regarding the  population
distribution of the two sets of data being evaluated other
than that the distributions will occur identically.  In other
words,  when one data point deviates, its respective point
in the other set of data will deviate similarly.  Because
the only deviation expected during the demonstration was
a  difference  in  the concentrations  reported by each
technology, the two sets of data were expected to deviate
in the same way. The calculation performed in the Wil-
coxon Signed Ranks Test uses the number of samples
analyzed and a ranking of the difference between the
result obtained from a technology and the corresponding
result from the confirmatory laboratory. The rankings
can be compared to predetermined values on a standard
Wilcoxon distribution table, which indicates whether,
overall, the two methods have produced similar results.
In cases where the linear regression produced an r2 less
than 0.75 and the Wilcoxon Signed Ranks Test indicated
that the data sets were statistically similar, the regression
data was not considered correct.  Such occurrences were
due to one or both data sets not meeting the fundamental
assumption for regression analysis, normally distributed
data sets.

    Finally,  the  test kit's  precision was statistically
compared to the precision of the confirmatory laboratory
using Dunnett's Test.  This test was  used to assess
whether the precision of the test kit and that of the
confirmatory  laboratory were statistically equivalent.
First, the mean RPD for all samples and their respective
duplicates analyzed by the confirmatory laboratory was
determined. The RPDs of each duplicate pair analyzed
by the test kit was then statistically  compared to this
mean.  It should be noted that a Dunnett's Test result
showing the precisions are not similar does not mean that
the precision of the technology was not acceptable, only
that it was different from the precision of the confirma-
tory laboratory.  In particular,  Dunnett's Test has  no
way  of determining whether or not  any difference
between the two data sets actually resulted because a
technology's data was more precise than the confirma-
tory laboratory's.   Verification of the Dunnett's Test
results  was provided by  the Wilcoxon Signed Ranks
Test.

    Overall, for this demonstration, the determination of
significance   for  inferential  statistics  was   set  at
90 percent. However, regression analysis was consid-
ered to show a significant relationship if the coefficient
of determination (r2) was greater than 0.85 for Level 3
data and between 0.75 and 0.85 for Level 2 data.
                                                     10

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                                              Section 5
                                 Confirmatory
Analysis Results
     All  samples  collected during  this demonstration
 were submitted to the EPA Region 7 Laboratory for
 confirmatory analysis under the RECAP Contract.  The
 result for each sample is presented in a table near the
 end of Section 6.

 Confirmatory Laboratory Procedures

     EPA Region 7 Laboratory Quality Assurance am.
 Data Evaluation (QADE) Branch personnel conducted a
 Level II data  review on the results  provided by  the
 confirmatory laboratory.  A Level II data review does
 not include an evaluation of the raw data or a check of
 calculated sample values. A review of the raw data and
 a  check of the  calculations was performed by  QG
 personnel from  the  confirmatory  laboratory before
 submitting the data package to EPA Region 7 Laboratory
 QADE Branch. PRC was not able to  review all of the
 raw data generated  from the  analysis  of samples.
 However, PRC did review the laboratory case narrative!
 and  the  EPA Region 7  Laboratory  QADE Branch
 comments generated by the Level II data review. The
 following paragraphs discuss specific procedures used to
 identify and quantitate semivolatile organic compounds
 (SVOC), specifically PCP, using the following methods:;
 EPA Method 8270A and EPA Method 8151A.

 Sample Holding Times

    All of the analytical methods used for confirmatory
 analysis require that all sample extractions be completed
within 7 days  from the time a sample was collected.
Due to the stability of PCP,  ORD's Methods Validation
Section extended these holding tune requirements by 4
days for this demonstration.  The analysis of the sample
extracts must be completed within 40 days of validated
sample receipt. The holding tune requirements for the
samples collected during this demonstration were met.
    Sample Extraction

        The method used for the extraction of soil samples
    prior to analysis by EPA Method  8270A  was EPA
    Method 3550.  EPA Method 3550 involves  sonication
    extraction of the soil using methylene chloride.  The
    confirmatory laboratory used both the low concentration
    extraction method and the high concentration extraction
    method discussed in EPA Method 3550. To  determine
    the appropriate extraction method to use for the analysis
    of individual soil samples, the confirmatory laboratory
    screened each sample using the screening techniques
    recommended in EPA Method 8270A.  Soil samples
    with concentrations at or near the detection limits of
    Method 8270A were reanalyzed using Method 8151A.
    EPA Method 8151A includes an acidification of the soil
    sample followed by an ultrasonic extraction with methy-
    lene chloride. This extraction is similar to EPA Method
    3550's sonication extraction.  The soil sample extract
    was then taken  through an acid-base partition.   The
    acid-base  partition  was used  to remove potentially
    interfering compounds from the sample extract.  The
    sample extract was then concentrated and taken through
    a diazomethane derivatization.  This procedure replaces
    the hydrogen atom of the alcohol group with a methyl
    anion.  This derivatization removes the polarity associ-
    ated with PCP and enables improved chromatographic
    behavior. PCP standards used for sample identification
    and  quantitation  were taken through the same  deriv-
    atization steps to allow a direct comparison of concentra-
    tion. That is, no correction factor needs to be used for
    the molecular weight of the derivatization product.

    Detection Limits and Initial
    and Continuing Calibrations

       The detection limit for samples analyzed by EPA
    Method 8270A was reported as 0.330 ppm. The  detec-
                                                 11

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tion limit for soil  samples analyzed by EPA Method
8151A was reported as 0.076 parts per billion.  Meth-
od-required initial and continuing calibration procedures
were appropriately conducted, and all method-required
criteria for these calibrations were met.

Sample Analysis

    The  confirmatory laboratory  performed sample
analysis  by  first  screening  samples   using  EPA
Method 8270A.  Based upon the screening results, the
samples were extracted with either the low concentration
method or the high concentration method discussed in
EPA Method 3550.   Samples that did not provide a
positive response for  PCP with EPA Method 8270A
were analyzed by EPA Method 8151 A.

    For EPA Method 8270A, compound identification
was required to meet two  criteria:   (1)  the sample
component relative retention time was to fall within ±
0.06 relative retention time units of the standard compo-
nent, and (2) the mass spectrum of the sample compound
was to correspond with the standard compound mass
spectrum.  If compound identification was not made,
samples were analyzed by EPA Method 8151A.   For
EPA Method 8151A, compound identification was made
if a sample peak eluted within the retention tune window
established during the  initial calibration.

Quality Control Procedures

    Method blanks are used to monitor the presence of
laboratory-induced contamination.  The EPA Region 7
Sample Management Office (SMO) provided blank soil
for use as method blank samples.  An acceptable method
blank must not provide a positive response for the target
compounds above the reported detection limit. Method
blank samples were stored, extracted, and analyzed in
exactly the same manner as the demonstration samples.
Results for  all method blank samples extracted  and
analyzed were found to be acceptable.

    Internal standards were used for the analysis of
demonstration samples by EPA Method 8270A. Internal
standards were added to all standards, blanks, samples,
and QC  samples prior to injection  into the GC/MS
system.  The internal standards were used to provide
response factors  for each of the target compounds.  Six
samples  exhibited  internal standard  responses which
were outside of the  QC limits of 50 to 150 percent
recovery. All of the affected samples provided internal
standard responses which were less  than  50 percent.
The soil samples affected were samples 060, 062, 068,
090, 091, 095. Of these samples, three - 090, 091, and
095 — were found to contain no detectable levels of
PCP, and no corrective action was taken. Instead, they
were  reanalyzed  using  EPA Method 8151 A.   The
remaining samples were reanalyzed to verify that the
internal standard response was below 50 percent recov-
ery.   The reanalysis showed  that internal standard
response was below 50 percent recovery. No corrective
action was taken by the laboratory, which attributed the
low recovery to matrix effects inherent to the samples.
The Region 7 Laboratory QADE Branch reached the
same conclusion during its review of the data.

    Surrogate standards were  used  to  evaluate  the
efficiency of the extraction and analysis processes and to
evaluate  matrix effects.  Surrogate standards used for
EPA Method 8270A include deuterated standards which
provide a different mass spectrum when compared to the
nondeuterated compound. The surrogate standard used
for EPA Method  8151A was 2,4-dichlorophenylacetic
acid  (DC A A).    The DCAA  acceptance  range was
determined by  the RECAP and Region 7  Laboratory
through a statistical analysis of 30 or more standard
surrogate recoveries.  The mean and standard deviation
were  then  calculated, and the  acceptance range was
determined by applying a ± 3 standard deviation around
the mean.   All samples analyzed with EPA  Method
8151A provided surrogate recoveries that fell within the
laboratory-generated control limits.       ;

    Matrix spike samples are aliquots of original sample
into which a known  concentration of the target com-
pounds were added.  The EPA Region 7  Laboratory
SMO designated the samples which were to be used as
matrix spike samples.  The designated soil samples were
samples  073, 087, and 098, all  analyzed  using EPA
Method 8270A, and sample 089, analyzed using EPA
Method 8151A.  The soil  matrix spike samples were
spiked with all of the  target compounds reported by the
method.  Soil matrix spike data  for PCP is shown in
Table 5-1.  The recoveries of these samples were greatly
influenced by the high concentrations of PCP present in
the original sample relative to the amount spiked. Only
one sample,  098,  resulted in recoveries for both the
matrix spike and  matrix spike duplicate sample which
could be considered acceptable.  A clear evaluation of
the effects of matrix on PCP recovery is not possible due
to the high concentrations of PCP in the sample and the
comparatively low levels of PCP added to the matrix
spike samples.

Data Reporting

    The  data report PRC received from the EPA Region
7 Laboratory included a standard EPA Region 7 Analysis
Request Report. Results were reported on a dry weight
basis, as  required in the methods.  PRC obtained data on
                                                   12

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 TABLE 5-1.  MATRIX SPIKE AND. MATRIX SPIKE DUPLICATE RESULTS.
   Sample No.
 Amount Found
In Original Sample
                                                Amount Added
                                                To Matrix Spike
                                                   Sample
             Amount Found In
               Matrix Spike
                 Sample
Percent Recovery
073
087
089
098
86.0
46.0
0.247
0.70
11.0
1.40
0.098
0.41
130
57.0
0.315
0.82
400
786
69
29
Sample No.
073
087
089
098
Amount Added Amo
To Matrix Spike M;
Duplicate Sample Dupl
(ppm)
11.0
1.40
0.098
0.41
jnt Found In
itrix Spike
icate Sample
(ppm)
93.0
64.0
0.241
0.98
Percent Recovery
(%)
64
1,285
0
68
Relative Percent
Difference
(%)
145
48
200
80
the loss-on-drying determination for each of the samples.
The loss-on-drying values were  used to convert the
confirmatory laboratory data from a dry weight basis to
a wet weight basis.

    Results were reported by the  confirmatory labora-
tory in micrograms per kilogram Otg/kg) for soil sam-
ples.  Soil sample results were converted to milligrams
per kilogram (mg/kg) so they could be compared to the
results from the technologies,  all of which  reported
results for soil samples in mg/kg.

Data Quality Assessment

    Accuracy refers  to  the  difference between the
sample result and the true  concentration of analyte in the
sample. Bias, a measure of the departure from complete
accuracy, can be caused  by such processes as loss of
analyte during the extraction process, interferences, and
systematic contamination or carryover of an analyte from
one sample to the next. Accuracy for the confirmatory
laboratory was assessed through the use of two perform-
ance evaluation (PE) samples purchased from Environ-
mental Research Associates (ERA).  These  samples
contained a known quantity of PCP. ERA supplied data
sheets  for each PE sample which  included  the true
concentration and an acceptance range for the sample
based on the 95 percent confidence interval taken from
data generated by ERA and EPA interlaboratory studies.
The true value concentration of soil PE sample 099 (the
low-level  sample) was 7.44 ppm with an acceptance
range of 1.1 to 13 ppm.  The result reported by the
confirmatory laboratory for this sample was 4.02 ppm,
which was within the acceptance range.  The percent
recovery of this sample by the confirmatory laboratory
was 54 percent.  The  true concentration of soil PE
sample 100 (the high-level sample) was 101 ppm with an
acceptance range of 15 to 177 ppm.  The result reported
for this sample by  the confirmatory laboratory was 52.4
ppm, which was  within the  acceptance  range.  The
percent  recovery  of this sample by  the confirmatory
laboratory was 52 percent.

    Precision refers to the degree of mutual agreement
among individual measurements and provides an estimate
of random error. Precision for the confirmatory labora-
tory results was determined  through the use of field
duplicate samples. Normally  laboratory duplicates are
used for this. However, no laboratory duplicates were
analyzed by the confirmatory  laboratory.  Field dupli-
cates are two samples collected together but delivered to
the laboratory with separate sample numbers. Typically,
field duplicate samples are used to measure both sam-
pling and analysis error.  PRC  established control limits
for field duplicate RPDs.  These control limits are
similar to those used to determine matrix spike recovery
acceptance  control limits.  To  establish  the control
limits, all sample pairs that did not produce two positive
results were removed from the data set.  Then the RPD
for each pair was calculated,  and the mean RPD and
standard deviation  were determined. The lower control
limit was set at zero  because  this would mean that the
                                                   13

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results from a duplicate and its sample matched per-
fectly. The upper control limit was set by multiplying
the standard deviation by two and adding it to the mean
RPD. The RPD of each sample pair was then compared
to these control  limits.  Each sample pair RPD was
expected to fall within the control limits.

    Five field duplicate samples were collected and
analyzed by the  confirmatory laboratory during this
demonstration.   RPD  values  for the duplicate pairs
ranged from 4 to 58.  The mean RPD value of the soil
field duplicate pairs was 23 percent, with  a standard
deviation of 25 percent. For the soil field duplicate pairs
the control limits were found to  be 0 to 73 RPD. All of
the five field  duplicate sample pairs  fell within this
range.  Overall,  this data shows  excellent  agreement
between the samples and their respective field duplicates,
indicating a high degree of precision by the confirmatory
laboratory.  The mean RPD  also indicated  that the
method used to homogenize the samples before splitting
them for analysis was highly effective.

    Completeness refers to the amount of data collected
from a measurement process compared to the amount
that  was expected to be obtained  (Stanley and Verner
1983).  For this demonstration, completeness referred to
the proportion of valid, acceptable data generated by the
confirmatory laboratory.  The completeness objective
for this project was 95 percent. Completeness for the
confirmatory laboratory was 100 percent.

Confirmatory Laboratory Costs
and Turnaround Times

    The  cost for performing PCP analysis by  EPA-
approved analytical methods varies from laboratory to
laboratory.  The cost of analysis depends upon the
number of samples submitted  for analysis, the matrix,
and the level of QC performed.  The following costs are
given  as  general guidelines.   EPA Method  8270A
analysis costs  range  from $250 to $400 per  sample.
EPA Method 8151A analysis costs range from $150 to
$250 per sample. Turnaround tunes for samples submit-
ted for analysis with EPA-approved analytical methods
range  from 14 to 30 days.  The turnaround time also
depends  upon the number of samples submitted for
analysis, the matrix, and the  level of QC performed.
Faster turnaround times may be available for an addi-
tional cost.
                                                   14

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                                               Section 6
                               HNU-Hanby Environmental Test Kit
     The HNU-Hanby test kit is designed to provid;
 quick, quantitative results for aromatic and petroleum
 compounds hi soil samples.   This test kit determines
 PCP concentrations in soil samples indirectly by measurl
 ing  the  carrier solvents used in wood  treating  that
 contain PCP.  This application assumes that the ratio of
 carrier solvent concentration to PCP concentration is
 constant. HNU-Hanby Systems claims that the test *'"
 can detect petroleum carrier solvents containing PCP ;
 concentrations as low as 1 to 5 ppm in soil. The test:
 uses  the Friedel-Crafts alkylation reaction  to  detect
 aromatic and petroleum hydrocarbon compounds in soil
 In the Friedel-Crafts alkylation reaction, an aromatic
 substitution occurs where the aromatic ring  attacks  a
 carbocation electrophile.  The electrophile is formed by
 the reaction of a Lewis acid catalyst, such as aluminum
 chloride, with an alkyl halide.  An excess amount of this
 catalyst  is added to act as a dehydrant  to enable, the
 Friedel-Crafts reaction to proceed.  Electrophile aro
 matic  substitution  products  are generally very larg
 molecules with a high degree of electron dislocation tha
 cause intense  coloring.  When using the test kit, th
 sample's color is then compared to site-specific colo
 standards for a semiquantitative assessment of PCI
 concentrations.

    The  standards  are produced by analyzing severa
 samples  from the site.  These samples should contain
 PCP concentrations representative  of contamination al
 the site.  The analysis  is conducted using a GC/MS tc
 determine the PCP-to-carrier solvent ratio.   Alterna-
 tively, the change hi the color can be read in millivolt:
using a reflective photometer.  In this method, a PCF
calibration chart is developed between millivolt readings
and the concentration  of PCP based on the GC/MS
analysis.   The sample  reading as obtained from  the
reflective photometer is then  cross-referenced with thi
calibration charts to obtain a  quantitative  sample  resul
for PCP. HNU-Hanby Systems has said that the test kii
is extremely sensitive due to the intense coloring thai
develops during the Friedel-Crafts reaction.
     Because the Friedel-Crafts reaction involves only
 aromatic compounds, this test kit does not work on all
 PCP carriers.  Only those carriers that have aromatic
 compounds, such as gasoline, diesel fuel, and kerosene,
 can be detected.

     Generally, PCP is added in a certain percentage to
 the carrier  solvent for application onto wood.   This
 percentage may differ from site to site.  To assess the
 ratio between the carrier solvent and PCP hi the Winona
 Post samples, HNU-Hanby Systems obtained contami-
 nated soil samples collected from Winona Post site,
 diluted these samples when required, and analyzed these
 samples for PCP.  Later, the same samples were ana-
 lyzed using the test kit, and the  corresponding reflective
photometer  readings in millivolts were obtained.  A
regression line was then calculated to allow the kit's
operator to predict PCP concentrations when millivolt
readings were known.  This type of site-specific calibra-
tion should minimize the effect of the weathering  of the
carrier solvent that  could affect the ratio.  Following the
completion of the demonstration, HNU-Hanby Systems
sent the PCP  calibration data to  PRC.  This data is
presented in Table  6-1.

TABLE 6-1.  CALIBRATION DATA.
Reflective
Photometer Reading
(millivolts)
890
826
738
670
556
434
223
111
89
79
PCP
Concentration
(ppm)
0.00 (Blank)
0.20
0.50
1.00
2.00
5.00
25.0
100
200
1,000
                                                   15

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Operational Characteristics

    The HNU-Hanby test kit weighs about 17 pounds
and comes  in  a  ragged,  plastic carrying  case.  The
carrying case is 15 inches high by 19 inches wide by 8
inches deep.   Overall, the test kit was found to  be
portable. Each test kit contains the following materials:
(1) a 10-milliliter graduated cylinder, (2) a 50-milliliter
beaker, (3)  36  screw-top test tubes, (4) 30 ampules of
extraction  solvent consisting of 20  percent carbon
tetrachloride and  80 percent heptane, (5)  30 vials of
color development reagent such  as aluminum chloride,
(6) a  500-milliliter separatory funnel, (7) a tripod ring
stand, (8) one  pair of safety glasses, (9) six pairs of
plastic gloves,  (10) an instructional video, (11) a color
chart depicting test results, and (12) a reflective photo-
meter.

    Other  materials used  by the operator during the
demonstration besides those mentioned above included:
(1) a  scale capable of measuring ± 0.05 grams, (2) a
stainless-steel spatula,  (3) laboratory wipes, (4) a stop
watch, (5) pipette bulb, and (6) marking pens.

    The test kit's logistical requirements include elec-
tricity or battery replacements. For this demonstration,
a fume hood also was used because the extraction solvent
contains carbon tetrachloride. All extraction and analy-
sis can be carried out  hi a small open area or within a
small fume hood.  The test kit requires approximately 2
square feet of work surface.  The reflective photometer
can be operated using a 110-volt or 220-volt electrical
supply.   This instrument also  is equipped with a re-
chargeable battery. This battery requires 8 to 24 hours
of charging, and when  fully charged, the battery can last
up to 8 hours.

    The operator chosen to analyze samples using the
technology was Mr. Dan Fenton, an employee of PRC.
Mr. Fenton has worked for PRC for 2 years.  He has
been primarily involved in environmental potentially
responsible  party searches and the writing of Superfund
enforcement memorandums.  He has had 6 credit hours
of college  inorganic  chemistry  and 4  credit hours of
inorganic laboratory.  Training was conducted by the
technology  developer.   Mr. Fenton received training
from HNU-Hanby Systems and reviewed a training
videotape that explained the operation of the technology.
HNU-Hanby Systems prepared the calibration factors for
the final data evaluation.

    Mr. Fenton found the test kit easy to operate. Prior
experience  in  analytical  chemistry is  useful, but  not
required.   Operation of the test kit involves  weighing
samples, carefully breaking open glass ampules, shaking
vials, adding catalyst to vials and measuring readings on
the reflective photometer.  The test kit is designed for
use either hi the field or hi a laboratory. . Some of its
instrumentation and equipment require special handling.
This instrumentation includes the reflective photometer,
the portable balance, and the pipettor.  This equipment
must be handled carefully to avoid damage.  The proto-
type reflective photometer failed  to  give consistent
results because the batteries were weak. The reflective
photometer  had no low battery indicator to warn the
operator.  When the weak battery was noted, the pho-
tometer was plugged into an available electricity outlet.
Also, highly contaminated samples turned black and
developed  gas pockets.    These samples  seemed to
interfere with the precision of the reflective photometer
readings.

     The photometer's reliability was monitored daily by
checking a white calibration  standard.  The reflective
photometer should read 1,020 millivolts when analyzing
the white calibration standard.  As  the intensity of the
color increases, the corresponding millivolt  reading
decreases.  The calibration check should give the highest
reading. During the two calibration checks conducted
during the sample analysis, the reflective photometer
read 812 and 866 millivolts. HNU-Hanby Systems said
that these readings were within the acceptable range of
a calibration check.

     The test kit uses a proprietary solvent to extract
organic compounds from  different sample matrices.
This solvent contains heptane an.d carbon tetrachloride.
The test  kit  also  uses  aluminum  chloride  in  large
amounts as a Lewis acid catalyst.  Care should be taken
when using these chemicals.  Heptane is a highly flam-
mable solvent that tends to explode in the presence of an
ignition source.   Carbon  tetrachloride  is a probable
human  carcinogen.  Aluminum chloride is a probable
teratogen that reacts violently with alkenes.  It is recom-
mended that proper personal protective wear,  such as
gloves and safety glasses, be worn when handling these
chemicals.

     The HNU-Hanby test kit is priced at $1,195. This
test kit contains color charts for color interpretation; it
does not include a reflective photometer.  Each test kit
contains enough reagents and other supplies to analyze
30 samples. The cost of HNU-Hanby  Systems' reflec-
tive photometer is $3,500. Other costs associated with
the analysis were the cost of 40-milliliter vials, the cost
of pipettes  and  a pipette bulb, and the  operator cost.
The operator  cost depends on the operator's qualifica-
tions and experience.  The total cost for quantitative
application of this test kit  , excluding operator's costs,
was about $6,000 for the 52 samples analyzed, which is
about $112 per sample.  However, as more samples are
analyzed, the cost of the reflective photometer will be
                                                     16

-------
distributed among  more  samples, reducing  the  pe:
sample cost.  When used semiquantitatively, the cost off
the reflective photometer can be deducted from the total
cost.  In the  semiquantitative analysis, the color develr
oped by each sample is  compared to the standard color
chart, which is included in the test kit for the determinaL
tion of the concentration.   In this case, the cost per
sample  for  this demonstration would be about  $48i.
Waste disposal cost is not included in the cost per sample
described above.   The waste generated during this
demonstration  filled approximately  one-half  of a
55-gallon drum. The disposal cost for this quantity of
PCP-contaminated laboratory waste  is  approximated
$1,000.

Performance Factors

    The sensitivity of the method depends on the sensi
tivity of the reflective photometer. The literature on thi >
method claims that aromatic compounds  as low  as
1.0 ppm can be detected  in soils.  In fact, the calibration
chart prepared  for the test kit shows a range from 0.2
ppm to 1,000  ppm.  During this demonstration, all
sample extracts that developed moderate to dark color
were diluted with the proprietary  solvent. This dilution
was performed by taking 0.3 milliliter of sample extract
and adding 10  milliliters of solvent.  This produced a
172-fold  dilution for a  1.0 gram soil sample.  These
dilutions  increased the detection  limits for the samples
involved.  The  modified detection limit was 5 ppm.

    HNU-Hanby Systems has stated that 50 samples can
be analyzed in an 8-hour work day.  During this demonl
stration, the average time taken to extract each sample
and prepare it for analysis was 21  minutes. The analysis
of the prepared sample in the  reflective photometer
required less than 1 minute.  Based on the average time
of 21 minutes  per sample, approximately 22 samples
were analyzed  in an 8-hour day.  This number was
influenced by factors such as the number of samples thaf:
required dilution, and the analysis of QC samples.

    The linear  range of the test kit is dependent on
linear range  of the reflective photometer.  The line,
range of the reflective  photometer was not evaluate^
during the  demonstration.   However,  HNU-Hanb;
Systems sent  the calibration data which included a PCIj
concentration range of 0.2 ppm to 1,000 ppm.  When
this data between the millivolt readings and PCP conceni
trations was plotted on a normal-scale plot, the coeffij-
cient of determination (r)  indicated that the  response
between the reflective photometer readings and corre •
spending PCP concentrations was not linear.  A natura.
logarithm transformation  of the  data  gave  a linea'
response  with an r of 0.96.
    Drift in this method was considered the instability
associated with reflective photometer readings. As noted
by the operator, whenever the battery was either fully
charged or weak, sample readings fluctuated more. This
problem was later solved by connecting the instrument
to an outlet.

Intramethod Assessment

    Reagent  blank samples were  prepared  by talcing
reagents through all extraction and reaction steps of the
analysis.  Reagent blanks were prepared with each batch
of 20 samples.  Two reagent blanks were prepared, and
analyzed during the demonstration.  The reagent blank
samples  did  show some  readings on the  reflective
photometer.  When these millivolt readings  were con-
verted  to PCP  concentrations,  they  gave  values  of
2.19 ppm and 1.8 ppm. Both of these values are below
the  technology's detection limit of 5 ppm used during
this  demonstration. Therefore,  none of the data was
rejected because of reagent blank contamination.

    Completeness refers to the amount of data collected
from a measurement process compared to the amount
that was expected to be obtained (Stanley and Verner
1983).  For this demonstration, completeness refers to
the proportion of valid, acceptable data generated using
the  technology.   The completeness objective  for this
project was 90 percent. Forty-five soil samples  includ-
ing field duplicates were analyzed during the demonstra-
tion. Two reagent blanks and five laboratory duplicates
were analyzed along with the 45 samples.  Results were
obtained from  all samples.   Completeness  for  the
samples analyzed by the kit was 100 percent.

    Intramethod precision was assessed by determining
the method's ability to reproduce its results on duplicate
samples.  These duplicate samples included five labora-
tory duplicates and five field duplicates. Usually these
duplicate samples are used to determine matrix variabil-
ity and the effects of using several operators. To use the
duplicates to measure the method's precision,  PRC both
controlled for matrix variability by thoroughly homogen-
izing the samples and controlled for operator effects by
using only one  operator for the  entire demonstration.
Laboratory duplicate  samples are two analyses per-
formed on a single sample delivered to a laboratory.
Five laboratory duplicates were analyzed by this technol-
ogy. The results of laboratory duplicate analyses  are
presented in  Table 6-2.   The  initial analysis  of  the
duplicate samples ranged from 158 to 4,590 ppm. When
the analysis was duplicated, the results ranged from 130
                                                   17

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TABLE 6-2. LABORATORY DUPLICATE RESULTS.



Sample
No.
059D
062
064
066
067

Original
Sample
Result
(ppm)
4,590
748
354
213
158
Laboratory
Duplicate
Sample
Result
(ppm)
4,320
775
395
440
130

Relative
Percent
Difference
(%)
6
4
11
70
19
TABLE 6-3. FIELD DUPLICATE RESULTS.
Sample
No.
059
073
074
086
087
Original
Sample
Result
(ppm)
3,130
8.60
40
7.54
4.94
Field
Duplicate
Sample
Result
(ppm)
4,590
7.42
32.5
5.86
4.17
Relative
Percent
Difference
(%)
38
15
21
25
17
to 4,320  ppm.   Field duplicate samples also were
analyzed during the demonstration. Field duplicates are
two  samples  collected together but brought  to  the
laboratory with separate sample  numbers.  Five field
duplicate  samples were collected and analyzed  by this
technology during the demonstration.  The results for the
field duplicate samples are included in Table 6-3. The
RPDs between original samples and their duplicates were
calculated. The RPDs for all duplicate samples ranged
from 4 to 70 percent.  Even the best technology that
determines results quantitatively  cannot reproduce  its
results every time. Therefore, PRC established  control
limits like those sometimes used to evaluate laboratory
duplicates.  These control limits were then used to
determine whether the difference between a result from
a duplicate and the result from its respective sample was
reasonable.  The RPD for each sample pair was calcu-
lated,  and the mean RPD and population standard
deviation were determined.  The lower control limit was
set at zero because this would mean that the results from
a duplicate and its sample matched perfectly. The upper
control limit was set by multiplying the standard devia-
tion by two and adding it to the mean RPD. The RPD
of each sample pak was then compared to these  control
limits.  Each was  expected to fall within them.   If
greater than 90  percent fell within this range,  the
technology's precision was considered adequate.   If
fewer than 90 percent of them fell within this range, the
data was reviewed, and if no explanation could be found,
the technology's precision was considered inadequate.

    The control limits established using the procedure
delineated above were from 0 to 61 percent.  Comparing
the RPDs to these control limits showed that only one
sample's RPD was outside the control limit. As a result,
90 percent of RPDs fell within the control limits making
the technology's precision acceptable.

Comparison  of Results  to  Confirmatory
Laboratory Results

    The quantitative results of the test kit were analyzed
by using the linear regression techniques and the inferen-
tial statistics detailed in Section 5.  All of the data used
for the analyses is presented in Table 6-4.  The  initial
linear regression analysis was based on results from 32
samples.   The concentrations  found in  eight  of  the
samples were below the test kit's detection limit and,
therefore, were not used hi the comparative  analysis.
The r2 for this regression was 0.19, indicating  that little
or  no relationship  exists between  the data  sets.   A
residual analysis of the data, though, identified samples
59 to 62, 65, 72, 75 and 76 as outliers. PRC removed
these points, recalculated the regression, and defined an
r2 of 0.31, still indicating that little or no relationship
exists between the two data sets. The parameters of this
regression line are shown on  Table 6-5.   Figure  6-1
shows the regression graphically.  The Wilcoxon Signed
Ranks Test was used to verify these results. It  indicated
at a 90  percent  confidence  level that the data was
significantly different from that of the  confirmatory
laboratory. These results indicate that this test kit is not
accurate and that it cannot be mathematically corrected
to  estimate corresponding  confirmatory data.  This
places test kit results for the combined soil data set into
the Level  1 data quality category.

    The confirmatory laboratory found that 16  of the 32
samples had concentrations less than 100 ppitn.  Of these
the test kit detected contamination above the  detection
limit hi only 10 samples.  The initial linear regression on
these  10 samples defined an r2 of 0.23, indicating that
little or no relationship exists between the two data sets.
A residual analysis of the data identified no samples as
outliers.   However, the Wilcoxon Signed Ranks Test
indicated  at  a 90 percent confidence level that  the
method's data was not significantly different from that of
the confirmatory  laboratory.    This contradicts  the
regression analysis and indicates that one or both of the
data sets do not meet the condition of normality required
for regression analysis.  Therefore, the regression data
                                                    18

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TABLE 6-4. SUMMARY OF DEMONSTRATION DATA.
Sample
No.a
059
059D
060
061
062
063
064
065
066
067
068
069
070
071
072
073
073D
074
074D
075
076
077
078
HNU-Hanby
Environmental Test
Kit
(5 ppm)b
3,130
4,590
1,030
1,400
748
445
354
1,200
213
158
218
540
435
181
5,570
8.60
7.42
40.0
32.5
303
751
508
252
Confirmatory
Laboratory
(ppm)
9,600
10,260
1,008
2,744
138.0
• 1,610
1,978
1,577
57.80
110.0
47.70
798.0
2,888
289.0
336.0
74.80
78.20
836.0
1,520
3,692
4,590
2,040
1,720
























Sample
No.a
079
080
081
082
083
084
085
086
086D
087
087D
088
089
090
091
092
093
094
095
096
097
098

HNU-Hanby
Environmental Test
Kit
(5 ppm)b
562
263
8.16
127
9.46
83.4
5.27
7.54
5.86
5.94
5.17
2.72d
2.14d
2.65d
2.55d
2.43d
2.36d
4.47d
89.4
108
7.63
2.78d

Confirmatory
Laboratory
	 (ppm)
792.0
2,550
125.0
2,400
270.0
1,140
57.70
6.59
6.88
34.00
51.80
2.58
0.21°
0.55C
0.28°
0.57C
0.1 9C
1.02C
0.088°
59.80
14.60
0.57

   All samples numbered before 059 were collected at
   the operator of this technology.
   Detection limit. When below the detection limit
   analysis..
   Sample analyzed by Method 8151 A; all other sampl
   Result is below detection limit.
thfe
he former Koppers site and, therefore, were not analyzed by

 sample's result was not considered during the regression

js were analyzed by Method 8270A.
                                                19

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TABLE 6-5. SUMMARY OF REGRESSION AND RESIDUAL STATISTICS
                                N
Y-int
Wilcoxon Probability
All Data 37 0.27 126
<100ppm 16 0.16 14
>100ppm 20 0.04 308
0.16
1.2
0.22
Significant difference
No significant difference
Significant difference
Notes:
N Number of data points
r2 Coefficient of determination adjusted for variance
Y-int Y-axis intercept of the regression line
FIGURE 6-1. REGRESSION OF DATA.
t OKtflViwn tpfMnf
i 1
»
i
I
| '

M.PMIV.
• " -•
. . € •
TnxtNogoUws
«
Tnw Positives
• *
•
• •• •
• *
•
•

FofceNegffltoj




Confkmttoty Lctxxitoty Cone«nti«ion (ppm)
 was considered suspect.  These results indicate that this
 technology produces data statistically  similar to the
 confirmatory laboratory.  This factor places this technol-
 ogy into the level 2 data quality category for the samples
 with PCP concentrations less than  100 ppm; however,
 the data cannot be mathematically corrected.

     The confirmatory laboratory found that 23 of the 32
 samples contained PCP concentrations of more than 100
 ppm.  The initial linear regression  on these samples
 defined an r2 of 0.09,  indicating  that  no relationship
 exists between the two data sets. A residual analysis of
 the  data identified samples 59, 72, and 79  as outliers.
 PRC removed  these three  points,  recalculated  the
        regression, and defined an r2 of 0.04, still indicating that
        no relationship exists between the two data sets.  The
        Wilcoxon Signed  Ranks Test verified these  results.
        These results indicate that this test kit is not accurate and
        that it cannot  be mathematically corrected to estimate
        corresponding  confirmatory data.  This factor places this
        technology for the samples with PCP concentrations
        above  100 ppm into the Level 1 data quality category.

            To compare the precision of the test kit's results to
        the precision of the confirmatory laboratory's results, a
        Dunnett's Test was performed on the RPDs determined
        from  the field duplicate samples and  their respective
        samples.  The  Dunnett's Test determines the probability
        that the data sets on which it is based are the same.  If
        the RPDs from the confirmatory laboratory and those
        from  the technology  are the same, then it can be as-
        sumed that the precisions are also similar.  A Wilcoxon
        Signed Ranks Test was used to supplement the Dunnett's
        test results.  The Wilcoxon Signed Ranks Test was used
        to test the hypothesis that no significant difference exists
        between the technology's RPDs and the:confirmatory
        laboratory's RPDs. When the Dunnett's Test compared
        the RPDs between the method's data set and the confir-
        matory laboratory data set,  it indicated the precisions
        were statistically similar. The Wilcoxon Signed Ranks
        Test confirmed this data.
                                                     20

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                                                Section 7
                                     Applications Assessment
     The principal advantage of the test kit is that it can
 analyze a large number of samples in a short period oi
 time.  Other advantages include the following:  (1) the
 test kit is inexpensive when compared to formal labora-
 tory analysis  using EPA-approved methods for PCP,
 (2) it is simple to operate even for individuals with no
 prior experience using the test kit, (3) it is portable and
 can be operated outdoors, (4) it requires electricity, but
 a rechargeable battery can be used without the need for
 an electrical hookup at the site, and (5) its reagents do
 not require refrigeration.

    The principal limitations of the test kit are (1) that
 it  can  only be used on sites  where petroleum products
 are the carrier solvent for PCP, and (2) that it provides
 only an indirect  measurement of PCP concentration.
 The test kit requires  detailed  site-specific  calibration
 prior to use.  This indirect measurement  is performed
 through a measurement of petroleum hydrocarbons in a
 sample. An estimated ratio of PCP versus the petroleum
 hydrocarbon carrier is calculated and used to  correct the
 sample results. The test kit, therefore, can only be used
 at sites where the PCP to petroleum carrier solvent ratio
 is  stable, and it cannot be used to determine PCP results
 in samples where no petroleum hydrocarbon carriers are
present.  The ratio of PCP hi a petroleum hydrocarbon
carrier  may vary due  to  manufacturing  processes,
dilution variances, and the volatility and weathering of
petroleum  hydrocarbon carriers.   This volatility and
weathering  may   change  with depth, and  thus, the
ratio-based calibration may  vary with depth.  All of
these variances can lead to errors when interpreting PCP
results.  It is essential that  samples from the site be
investigated and analyzed for the purpose  of preparing
site-specific calibration data.

    The test kit's  estimation of PCP concentrations in
samples was generally found not to agree with results
from  the  confirmatory  laboratory.   However, for
samples contaminated with less than 100 ppm of PCP,
the technology's data was statistically similar to the
 confirmatory data.  The test kit contains the hazardous
 chemicals heptane,  carbon tetrachloride, and aluminum
 chloride.  Proper safety and disposal practices need to be
 employed when using the technology.

     The test kit can be used to provide screening results
 for  PCP soil  samples.  HNU-Hanby Systems also
 markets it for use on water samples. The demonstration
 results indicate that the test kit is  most accurate with
 samples containing less than  100 ppm PCP.  Therefore,
 it should only be used to produce Level 2 data at sites
 where the PCP action level is below 100 ppm.

     Generally,  the larger the site or  the  larger  the
 number of samples  which will be collected,  the greater
 the advantage of using the test kit.  The use of the test
 kit at these  types of sites will decrease the  cost of the
 investigation by enabling more  work to be completed
 during a single sampling visit.  The use of  the test kit
 can  allow work to continue  without having  to wait for
 confirmatory laboratory results.  The results  of  the
 demonstration indicate that the test kit can be used as an
 EPA Level  1 screening tool over a wide concentration
 range.  However,  the kit will not detect PCP if the
 carrier solvent  is heavily weathered and is no  longer
 present in the sample.  This  could lead to a false deter-
 mination of no PCP present in  the sample. This failure
 to detect the presence  of a contaminant does not meet
 Level 1 criteria.  For PCP concentrations of less than
 100 ppm at a site where the PCP-to-carrier ratio appears
 stable, this demonstration indicates that  the test kit can
produce Level 2 data.  The determination of data quality
 levels will be site-specific and dependent  on the stability
of the PCP-to-carrier ratio.  Field investigators should
confirm that results obtained from the test kit correlate
with confirmatory laboratory  results. Field investigators
must realize that the  test kit is designed  only as a
screening tool to assist hi evaluating petroleum contam-
ination and  its use as a PCP screening tool is very
site-specific.
                                                    21

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                                            Section 8
                                           References
PRC  Environmental  Management, Inc.  (PRC).  1993.   "Final  Demonstration  Plan for  the  Evaluation of
    Pentachlorophenol Field Screening Technologies."  EPA Contract No. 68-CO-0047.

Stanley, T. W. and S.  S. Verner.  1983. "Interim Guidelines and Specifications for Preparing Quality Assurance
    Project Plans." U.S. Environmental Protection Agency, Washington D.C.  EPA/600/4-83/004.

U.S. Environmental Protection Agency (EPA). 1990.  "Quality Assurance/Quality Control Guidance for Removal
    Activities." EPA/540/G-90/004. April.
                                                 22

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