x°/EPA   Guidance on the Documentation and
        Evaluation of Trace Metals Data
        Collected for Clean Water Act
        Compliance Monitoring
                                   > Printed on Recycled Paper

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Acknowledgements

This guidance was prepared under the direction of William A. Telliard of the Engineering and Analysis
Division (HAD) within the U.S.  Environmental Protection Agency's (EPA) Office of Water (OW),
Engineering and Analysis Division (EAD). This guidance was prepared under EPA Contract 68-C3-0037
by the DynCorp Environmental Programs Division with assistance from Interface, Inc.
Disclaimer

This document has been reviewed and approved for publication by the Analytical Methods Staff within
the  Engineering and Analysis Division of the EPA Office of Water.  Mention of trade names  or
commercial products does not constitute endorsement or recommendation for use.
Further  Information

For further  information, contact:

       William A. Telliard,  Chief
       Analytical Methods Staff
       Engineering and Analysis Division
       U.S. Environmental Protection Agency
       401 M Street
       Washington, DC 20460
       Phone: 202-260-7134
       Fax:   202-260-7185


Requests for additional copies should be directed to:

       US  EPA NCEPI
       11029 Kenwood Road
       Cincinnati, OH 45242
       513-489-8190

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                                                                                   Chapter 1

                                                                                    Introduction

        Numerous organizations, such as  state pollution control agencies, health departments, local
 government agencies, industrial dischargers, research facilities, and federal agencies (e.g., EPA, USGS),
 collect data on effluent and ambient metal concentrations for use in a variety of applications, including:
 determining attainment status for water quality standards, discerning trends in water quality, estimating
 effluent  concentrations and variability, estimating  background  loads  for total  maximum daily loads
 (TMDLs), assessing permit compliance,  and conducting research1.   The quality of data  used is  an
 important issue,  and, in particular, the quality  of trace level metals data may be compromised due to
 contamination during sampling, filtration, storage, and analysis.  In fact, one of the  greatest  obstacles
 faced by laboratories attempting trace metals determinations is the potential for contamination of samples
 during the sampling and analytical processes.   Trace metals are ubiquitous in the  environment, and
 samples can readily become contaminated by numerous sources, including: metallic or metal-containing
 labware, metal-containing reagents,  or  metallic sampling  equipment;  improperly cleaned  and stored
 equipment;  and atmospheric inputs such as dirt, dust, or other  particulates from exhaust or  corroded
 structures.

        The measurement of trace metals at EPA water quality criteria (WQC) levels has been spurred
 by increased  emphasis  on a water quality-based approach  to the control of toxic pollutants.  Current
 ambient WQC levels2 for trace metals require measurement capabilities at levels as much as 280 times
 lower  than those levels required to support technology-based controls or achievable by routine analyses
 in environmental laboratories.  Also, recent USGS and EPA studies strongly indicate that rigorous steps
 must be taken in order to preclude  contamination during the collection and analysis of samples for trace
 metals.

        In order to ensure that the data collected for trace metals determinations at ambient water quality
 criteria levels are valid and not a result of contamination, rigorous quality control (QC) must be applied
 to all sample collection, preparation, and analysis activities. EPA has published analytical methods (1983,
 1991)  for monitoring metals  in waters  and  wastewaters,  but these  methods  are inadequate for  the
 determination of ambient concentrations of metals in ambient waters due to the lack of some or  all of the
 essential quality control and handling criteria.  This prompted the Engineering  and  Analysis  Division
 (EAD) to develop new  sampling and analytical  methods that  include the rigorous sample handling and
 quality control procedures necessary to deliver verifiable data at WQC levels.  The new sampling method
 is entitled, Method 1669:  Sampling Ambient Water for Determination of Trace Metals at EPA Water
 Quality Criteria Levels ("Method 1669").  The new analytical methods  include Methods 1631, 1632,
 1636,  1637,  1638,  1639,  and 1640 ("the  1600 Series Analysis Methods").   Many  of  these analysis
 methods were developed by supplementing existing  EPA methods with  additional quality control and
 sample handling requirements; others are new methods that are based on newly developed analytical  procedures.
        Prothro, M., Acting Assistant Administrator for Water, Memorandum to Water Management Division Directors and
        Environmental Services Division Directors, Oct. 1, 1993.

        "Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic Pollutants; States' Compliance" (also
        referred to as "The National Toxics Rule"), 40 CFR Part 131, (57 FR 60848, December 22, 1992).
April 1995

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Data Evaluation Guidance
        Appropriate quality assurance (QA) and quality control (QC) procedures are the key to producing
precise and accurate data unbiased by contamination. Examination of trace metals data without data from
blanks and other QC analyses yields little or no information on whether sample data are reliable.  Data
quality  must be documented through the use  of blanks (both  field and laboratory blanks),  standards,
matrix spike/matrix spike duplicates, and field duplicates, as well as other QC analyses.  The results of
all QC procedures must be included in the data reporting package along with the sample results if data
quality is to be known.

        The remainder of this document contains guidance that is intended to aid in the review of trace
metals data submitted for compliance monitoring purposes under the National Pollutant  Discharge
Elimination System (NPDES) when these data are collected in accordance with Method 1669 and analyzed
by the 1600 Series  Analysis Methods.  Chapter 2 of this document outlines the data elements that must
be reported by laboratories and permittees so that EPA reviewers can validate the data.   Chapter 3
provides guidance concerning the review of data collected and reported in accordance with Chapter 2.
Chapter 4  provides a  Data  Inspection Checklist that can  be used to standardize procedures for
documenting the findings of each data inspection.

        The guidance provided in these chapters is similar in principle to the data reporting and review
guidance provided  in EPA's  Guidance  on Evaluation, Resolution, and Documentation of Analytical
Problems Associated -with Compliance Monitoring (EPA 821-B-93-001), but has been specifically adapted
to reflect particular concerns related to the evaluation of data for trace metals.

        This guidance  is applicable to the examination of recently gathered trace metals data and to
historical data in  existing EPA databases.  It should be  noted,  however that some qualification of
historical data may be  required before these data can be included in current databases.  A draft User's
Guide to the Quality Assurance/Quality Control  Evaluation Scale of Historical Datasets  (12/20/90,
available from EPA EMSL-LV), provides  guidance that may be used to qualify data for inclusion into
current  databases.  This EMSL-LV guidance stipulates that at least some form of QA/QC must be
associated with the historical data for evaluation.   This QA/QC may be in the form of various types of
blanks (method, field, etc.), replicates field, analytical, etc.), spikes (matrix, surrogate internal standard,
etc.), and PE samples (certified reference materials, QC check samples etc.).  A scoring mechanism is
applied  to these QA/QC data, and the usability of the sample data is based on the resulting score.
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                                                                                Chapter 2

                                                    Checklist of Laboratory Data Required
                                      to Support Compliance Monitoring for Trace Metals
                                             Determined in Accordance  with Method  1669
                                                     and the 1600 Series Analysis Methods


        The items listed below describe the minimum data elements necessary to validate trace metals data
 collected using the Method for Sampling Ambient Water for Determination of Trace Metals at EPA Water
 Quality Criteria Levels (Method 1669) and the 1600 Series Analysis Methods.  It should be noted that
 since different instrumentation yields different data output, the specific form  of the data will vary
 according to the analytical method.

 1.      Method Number

        The method number of the EPA analytical method used in conjunction with Method 1669 must
 be provided. This information will allow a data reviewer and user to become familiar with the method,
 if necessary, prior to reviewing  the data.   It will  also assist the reviewer  and user in  making any
 necessary determinations  of the comparability of these data with previously reported data, including
 qualified historical data.  If more than one method is needed to cover a complement of analytes, then all
 method numbers must be provided.  A clear delineation of the  specific method used for each given
 analyte is required.  Also, the revision date or revision level and number/letter of the method must be
 given, so that the reviewer or user tests the results submitted against the  specific method used. Table 1
 provides a list of EPA methods for analysis of trace metals along with the corresponding water quality
 criterion published by EPA for each metal or metal species.

        In recognition of advances that are occurring in analytical technology, the 1600 Series Analysis
 Methods are performance-based.   That is, an  alternate procedure or  technique may be used if the
 performance  requirements in the reference method(s) are met.  The analyst must start with one of the
 methods as a reference, and may  improve upon this  reference method to reduce interferences or lower
 costs of measurements.  Examples include using alternate chelating or  ion exchange  resins, alternate
 matrix modifiers, additional cleanup techniques, or more sensitive detectors.  The objective of allowing
 method modifications is to improve method performance on the sample being analyzed.  At no time are
 changes that degrade method performance allowed. Each method details the tests and documentation that
 are required to  support equivalent performance.


 2.      Detailed Narrative

        A detailed narrative discussing any problems with the analysis, corrective actions taken, and
 changes made to the reference method must be included in a complete data reporting package.  Reasons
 for changes to the reference method, supporting logic behind the technical approach to the change, and
 the result of the  change must be included in the narrative.   The narrative should be written  by an
 analytical chemist in terms that another analytical chemist can understand.  The results of the review must
April 1995

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Data Evaluation Guidance
be written so that the data user can understand the reason(s) for acceptance/rejection of the data or any
changes to the reference method.
3.      Data Reporting Forms

        The complete  data reporting package must include data reporting forms that list  all samples
analyzed, the metals and metal species determined, and the concentrations found.  Analytes detected in
field samples at concentrations below the minimum level (ML) must be reported as non-detect. However,
all analyte concentrations detected in blank samples must be reported,  regardless of the level.  Results
must be listed for each sample analyzed, including any dilutions and reanalyses.  Metals should be listed
by name and CAS Registry number.

        The ML is the quantitation  level  as defined by the EPA 1600 series method used for sample
analysis.  The laboratory is  required to determine the MDL  for each analyte  in accordance with the
procedures described in 40 CFR Part 136, Appendix B- Definition and Procedure for Determination of
Method Detection Limit - Revision 1.11. That MDL multiplied by 3.18 must be  less than or equal to the
ML given in the EPA  1600 Series Analysis Method.

        The use of data qualifiers or flags by the laboratory is  discouraged. Rather, laboratories should
attempt to correct all analytical problems and provide a detailed narrative that thoroughly describes those
problems and the corrective actions taken (see item 2 above). Flags or data qualifiers should be assigned
by data users to reflect their specific data quality objectives  and uses of the  data.   If the laboratory
submits data with internally generated flags, the laboratory must provide an explanation of the meaning
of the flags used.

4.      Summary of Quality Control Results

        Results for all quality control analyses required by the  reference EPA method must be presented
in the complete data reporting package.  If more than  one method was used or if more than one set of
samples was analyzed, it must be clearly  evident which  QC corresponds to a given method and set of
samples.

        Results  for QC procedures that must be provided include, but are not limited to, the  following
(where applicable):

 •      Instrument tuning
 •      Calibration
 •      Calibration verification (initial and following every 10 analytical samples)
 •      Initial precision and recovery
 •      Ongoing precision and recovery
 •      Blanks
                Laboratory (method) blanks
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                                                                           Data Evaluation Guidance
                Field blanks
                Calibration blanks
                Equipment blanks
 •      Matrix spike/matrix spike duplicates
 •      Field duplicates
 •      Method of standard additions (MSA) results
 •      Spectral interference checks
 •      Serial dilutions
 •      Internal standard recoveries
 •      Method detection limits
 •      Quality control charts and limits

 Table 2 lists the required frequency and purpose of the QC procedures.
 5.      Raw Data

        Raw data for all analyses must be kept on  file  at the laboratory (Chapter 2, Section 7) and
 submitted for inspection to the data reviewer upon request.  The instrument output (emission intensity,
 peak height, area, or other signal intensity)  must be traceable  from the raw data to the final result
 reported. The raw data must be provided for not only the analysis of each field sample but also for all
 calibrations, verifications, blanks, matrix spike/matrix spike duplicates,  field duplicates, and other QC
 analyses required by the reference method.

        Raw data are method and instrument specific and  may include, but are not limited  to, the
 following:

 •       Sample numbers and other identifiers
 •       Digestion/preparation or extraction dates
 •       Analysis dates and times
 •       Analysis sequence/run chronology
 •       Sample weight or volume
 •       Volume prior to each extraction/concentration step
 •       Volume after each extraction/concentration step
 •       Final volume prior to analysis
 •       Injection volume
 •       Matrix modifiers
 •       Dilution data, differentiating between dilution of a sample or an extract
 •       Instrument (make, model, revision, modifications)
 •       Sample introduction system (ultrasonic nebulizer, hydride generator, flow injection system, etc.)
 •       Column (manufacturer, length, diameter, chelating or ion exchange resin, etc.)
 •       Operating conditions (char/ashing temperatures, temperature program,  incident rf power,  flow
        rates, plasma viewing height, etc.)
 •       Detector  (type, wavelength, slit, analytical mass monitored, etc.)
 •       Background correction scheme
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Data Evaluation Guidance
        Quantitation reports, data system outputs, and other data to  link the raw data to the results
        reported
        Direct instrument readouts (e.g., strip charts, mass spectra, printer tapes, and other recordings
        of raw data) and other data to support the final results
        Lab bench sheets  and copies of all pertinent  logbook pages  for  all field and QC  sample
        preparation and cleanup steps, and for all other parts of the determinations
6.     Example Calculations

       Example calculations that will allow an independent reviewer to determine how the laboratory
used the raw  data to arrive  at a final result must be provided in the data reporting  package if any
adjustments are made to the equations included in the methods.  Useful examples include both detected
and undetected compounds.  If the laboratory or the method employs a standardized reporting level for
undetected compounds,  this should be made clear in the example  calculation.  Adjustments made for
sample volume, dilution, internal standardization, etc. should be evident.
7.     Archiving Data on Magnetic Media

       It is not necessary for the  laboratory or responsible organization to submit digitized binary,
hexadecimal, or other raw  signal recordings with the  data package.   However, the  laboratory that
performs the analysis should archive these data so that the raw reduced data can be reconstructed, and
the laboratory or organization responsible for reporting the data should be prepared to submit raw data
on magnetic media, upon request by EPA. Magnetic media may be required for automated data review,
for diagnosis of data reduction problems, or for establishment of an analytical database.
8.      Names, Titles, Addresses, and Telephone Numbers of Analysts and QC Officer

        The names, titles,  addresses, and  telephone  numbers  of the analysts  who performed  the
determinations and the quality control officer who verified the results must be  included in the data
reporting package.  If the data package is being submitted by a person or organization other than the
analytical  laboratory, it  is that  person or organization's  responsibility to ensure that the laboratory
provides all the data listed above and that all method requirements are met. For example, with regards
to effluent  or  ambient monitoring  data submitted by  an NPDES permittee on a Discharge Monitoring
Report (DMR), the task of collecting and reporting quality control data falls to the permittee.

        In addition, the personnel,  titles, addresses, telephone numbers, and name  (if different from the
laboratory that analyzed the field samples) of the facility that cleaned and shipped the sampling equipment
and generated the equipment blanks, the laboratory (if different) that analyzed the equipment blanks, and
the facility responsible for the collection, filtration, and transport of the field samples  to the laboratory
must be obtained and included in the data reporting package.
                                                                                       April 1995

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                                                Table 1
 Method Numbers, Analytical Techniques, Method Detection Limits, and Minimum Levels
Method
1631
1632
1636
1637
1638
1639
1640
Technique
Oxidation/Purge &
Trap/CVAFS
Hydride AA
Ion
Chromatography
CC/STGFAA
ICP/MS
STGFAA
CC/ICP/MS
Metal
Mercury
Arsenic
Hexavalent
Chromium
Cadmium
Lead
Antimony
Cadmium
Copper
Lead
Nickel
Selenium
Silver
Thallium
Zinc
Antimony
Cadmium
Trivalent
Chromium
Nickel
Selenium
Zinc
Cadmium
Copper
Lead
Nickel
MDL Otg/L)1
0.000054
0.002
0.23
0.0074
0.036
0.0097
0.013
0.087
0.015
0.33
1.2
0.029
0.0079
0.14
1.9
0.023
0.10
0.65
0.83
0.14
0.0024
0.024
0.0081
0.029
ML
0*g/L)2
0.0002
0.005
0.5
0.02
0.1
0.02
0.1
0.2
0.05
1
5
0.1
0.02
0.5
5
0.05
0.2
2
2
0.5
0.01
0.1
0.02
0.1
Lowest EPA
Water Quality
Criterion (ug/L)3
0.012
0.018
10.5
0.32
0.14
14
0.32
2.5
0.14
7.1
5
0.31
1.7
28
14
0.32
57
7.1
5
28
0.32
2.5
0.14
7.1
Method Detection Limit as determined by 40 CFR Part 136, Appendix B

Minimum Level (ML) calculated by multiplying laboratory-determined MDL by 3.18 and rounding result to nearest multiple of 1,
2, 5,  10, 20, 50 etc., in accordance with procedures utilized by HAD and described in the EPA Draft National Guidance for the
Permitting,  Monitoring, and Enforcement of Water Quality-Based Effluent Limitations Set Below Analytical Detection/Quantitation
Levels, March 22, 1994.

Lowest of the freshwater, marine, and human health WQC promulgated by EPA for 14 states at 40 CFR Part 131 (57 FR 60848),
with hardness-dependent freshwater aquatic life criteria adjusted in accordance with 57 FR 60848 to reflect the worst case hardness
of 25  mg/L CaCO, and all aquatic life criteria adjusted in accordance with the 10/1/93 Office of Water guidance to reflect dissolved
metals criteria. A complete listing of all WQC, including total, dissolved, and levels calculated with a hardness of 25 mg/L CaCO,
is provided  in Appendix A.
MDL for Hg by Method 1631 is an estimated value based on the standard deviation of blank measurements rather than the procedure
defined in 40 CFR Part 136, Appendix B.

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                                                                                Chapter 3

                                                              Guidance for Reviewing  Data
                                                  from the Analysis of Trace Metals Using
                                     Method 1669 and the  1600 Series Analysis Methods
        Use of the guidelines provided below, or of similarly developed standardized protocols, is highly
recommended as a tool  with which  Regional and  State permitting  authorities can standardize data
inspection and acceptance procedures and minimize differences that might otherwise result between data
reviewers and/or permittees responsible for submitting data.  A Data Inspection Checklist has also been
developed and is provided in the following chapter.  This checklist provides a standardized format for
documenting the findings of each data inspection and an additional tool for standardizing the data review
process within a regulatory agency.

1.      Purity and Traceability of Reference Standards

        The accuracy of any non-absolute empirical measurement is dependent on the reference for that
measurement. In determining pollutants in water or other sample matrices, the analytical instrument and
analytical process must  be  calibrated with a known reference material  of documented  purity and
traceability.  This information need not be provided with every  sample  analysis.  Rather, it should be
maintained on file at the laboratory and provided upon request.  When analyses are  conducted in  a
contract laboratory, such documentation should be  provided to the permittee the first  time  that the
laboratory is employed for specific analyses and updated as needed.

2.      Number of Calibration Points

        The 1600 Series Analysis Methods specify that a minimum of three concentrations are to be used
when calibrating the instrument.  One of these points  must be the  Minimum Level (ML, see item 5), and
another must be near the upper end of the calibration range.  Calibration must be performed for each
target metal before any samples or blanks are analyzed.  The use  of the ML  as a point on the calibration
curve is the principal means by which to assure  that measurements made at this quantitation level are
reliable.

        The data reviewer should review the points used by the laboratory to calibrate the instrument and
make certain that the calibration range encompasses the Minimum Level and that all sample  and QC
measurements are within the  calibration range.   Samples that  produced results which  exceeded the
calibration range should have been diluted and reanalyzed in accordance  with the specifications detailed
in the  1600 Series Analysis Method that was used by the laboratory.  The  diluted sample results need
only apply to those analytes that exceeded the calibration range of the instrument. In other words, it is
acceptable  to use data for different analytes  from  different levels within the same sample.   Some
flexibility may be exercised in acceptance of data that are only  slightly  above (< 10%) the calibration
range.  Such data are generally acceptable as calculated.

        If data from an analysis of the diluted sample are not provided, limited use can be made of the
data that are  above the calibration range (>10%).   The response of the analytical  instrument to
April 1995

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 Data Evaluation Guidance
 concentrations of analytes will eventually level off at concentrations above the calibration range. While
 it is not possible to specify the concentration at which this will occur, it is generally safe to assume that
 the reported concentration  above the calibrated  range is a lower  limit of the actual concentration.
 Therefore, if the concentration above the calibration range is also above a regulatory limit, it is a virtual
 certainty that the actual concentration would also be above that limit.

 3.      Linearity of Calibration

        The relationship between the response of an analytical instrument to the concentration or amount
 of an analyte introduced into the  instrument is referred  to  as the "calibration curve".  An analytical
 instrument can be said to be calibrated in any instance in  which an instrumental response can be related
 to the concentration of an analyte.  The response factor (RF, calculated for external standard calibration)
 or  relative response factor (RRF, calculated for internal standard calibration) is the ratio of the response
 of  the instrument to the concentration of the analyte introduced  into the instrument.  Equations for
 calculating RFs and RRFs are provided in the 1600 Series Analysis Methods.

        While the shape of calibration curves can be modeled by  quadratic equations or  higher order
 mathematical functions, most analytical  methods focus  on  a  calibration range  in  which the linear
 calibration is essentially a function of the concentration  of the analyte.  The advantage of the linear
 calibration is that the RF or  RRF represents the slope of calibration curve, simplifying calculations and
 data interpretation.   The 1600 Series Analysis Methods  contain  specific criteria for determining the
 linearity of calibration curves determined by either an internal or external standard technique.  When the
 applicable criterion  is met, the calibration curve is sufficiently linear to permit the laboratory to use an
 average RF or RRF, and it is assumed that the calibration  curve is a straight line that passes through the
 zero/zero calibration point.  Linearity is determined by calculating the relative standard deviation (RSD)
 of  the  RF  or RRF for each  analyte and comparing this RSD to the specified  limit.  The specific
 acceptance criteria are listed  in the  Data Inspection Checklist (Chapter 4, Item 12) and in the 1600 Series
 Analysis Methods.  These methods  also include alternative  procedures to be used in the event the linearity
 criteria fail specifications.

        The laboratory  must provide the RSD  results by which  an independent reviewer can judge
 linearity, even in instances in which the laboratory is using a calibration curve.   In these instances, the
 data reviewer should  review each  calibration point  to  assure  that  the  response  increases as' the
 concentration increases. If it does not, the instrument is not operating properly, and the data  should not
 be considered valid.

 4.      Calibration Verification

        Calibration verification involves the analysis of a single standard, typically in the middle of the
 calibration range, at the beginning (and, in some cases, at the  end) of each  analytical shift.   The
 concentration of each analyte in a reference standard is determined using the initial calibration data and
 compared to specifications in the method.  If results are  within the specifications, the laboratory may
proceed with analysis without recalibrating.  The initial calibration data are then used to quantify sample
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                                                                          Data Evaluation Guidance
 results.  Specific criteria for acceptance of calibration verifications are provided in the Data Inspection
 Checklist (Chapter 4, Item 17) and the 1600 Series Analysis Methods.

        Calibration verification, which is used in the 1600 Series Analysis Methods, differs in concept
 and practice from "continuing calibration", which is used in the SW-846 methods and in the Superfund
 Contract Laboratory Program (CLP).  In continuing calibration, a standard is analyzed and new response
 factors are calculated  on the basis of that analysis.  If the new factors are close to the average from the
 initial calibration, all  subsequent sample  analyses are conducted using the new response factors.   The
 degree of "closeness" is generally measured as the percent difference between the old and new factors.
 The problem with continuing calibration is that it amounts to a daily single-point calibration. Information
 about the behavior of the instrument at concentrations above and below this single standard can only be
 inferred from the initial multiple-point calibration.

        The  1600  Series Analysis Methods  require calibration verification  after every ten samples.
 Calibration verification is performed by analyzing an aliquot of the mid-point calibration standard, and
 obtaining results that meet the specifications contained in the methods.  These specifications are given
 for each method and metal as a percentage of the recovery of the mid-point calibration standard. If any
 individual value falls outside the range given, system performance is considered unacceptable, and the
 laboratory may  either recalibrate the instrument or prepare a new calibration standard and make'a second
 attempt to verify calibration. The data reviewer should verify that each batch of 10 samples is associated
 with a calibration verification that meets the required performance criteria.

 5.      Method Detection Limit and Minimum Level

        The Minimum Level (ML) is defined in the 1600 Series Analysis Methods as the lowest level at
 which the entire analytical system gives a recognizable signal and acceptable calibration point. Therefore,
 each 1600 Series Analysis Method requires that the calibration line or curve for each analyte encompass
 the method-specified ML.

        The  1600 Series Analysis Methods  also require each laboratory to perform a method detection
 limit (MDL) study for each analyte in accordance with the procedures given  in 40  CFR Part  136,
 Appendix B.  The MDL studies are conducted to demonstrate that the laboratory can achieve the MDLs
 listed in the methods.  MDL determinations must be made the first time that the laboratory utilizes the
 method and each time the laboratory utilizes a new instrument or modifies the method  in any way.

        Each MDL and ML listed in the  1600 Series Analysis Methods represents the results of MDL
 studies conducted by  the EPA's Engineering and Analysis Division as  part of its effort to validate the
 methods.  The MDL studies were conducted by at least one laboratory for each method and metal in
 accordance with the procedure given in 40 CFR Part 136, Appendix B.  The MLs shown in Table 1 were
 calculated by multiplying each laboratory-determined MDL by 3.18 and rounding the result to the nearest
 multiple of 1, 2, 5, 10, 20, 50, etc.  in accordance  with the procedures described in the EPA Draft
 National Guidance for the Permitting, Monitoring, and Enforcement of Water  Quality-Based Effluent
 Limitations Set Below Analytical Detection/Quantitation Levels, March 22,  1994.
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        The 1600 Series Analysis Methods and Chapter 2 of this document require the laboratory to
report the concentration of all sample results that are at or above the ML. It should be noted that this
ML is a sample-specific ML and, therefore, reflects any sample dilutions that were performed. If sample
results are reported below the ML, the data reviewer should require the responsible party to correct and
resubmit the data, or if this course of action is not possible, the reviewer should determine the sample-
specific ML and consider results below that level to be non-detects for regulatory purposes.

        If sample results are reported above the ML, but are below the facility's regulatory compliance
level, then the data reviewer should consider the results to suggest that the pollutant has been detected
but is compliant with the facility's permit (assuming that all QC criteria are met).  If sample results are
reported above the regulatory compliance level, the data reviewer must evaluate laboratory QC samples
in order to  verify that the level of pollutant is not attributable to analytical bias.  In addition,  the data
reviewer must evaluate all blank sample results in order to determine if the level of pollutant detected may
be attributable to contamination.

        Although sample results are  to be reported only if they exceed the ML, all blank results are to
be reported, regardless of the level.  This reporting requirement allows data reviewers the opportunity
to assess the impact  of any blank contamination on sample results that are reported above the ML.

        It is important to remember  that if a change that will affect the MDL is made to a method, the
MDL procedure must  be repeated  using the modified procedure.   Changes may include  alternate
digestion,  concentration,  and  cleanup  procedures,  and  changes   in  instrumentation.   Alternate
determinative  techniques, such as the substitution of a colorimetric technique or changes that degrade
method performance are not allowed.  The data reviewer should verify that method modifications were
appropriate  and were capable of producing the desired MDLs.

        The procedures given in this  document are for  evaluation  of results  for determination  of
regulatory compliance, and not for assessment of trends, for triggering, or for other purposes.  For such
other purposes, the reporting of all results, whether negative, zero, below the MDL, above the MDL but
below the ML, or above the ML, may be of value and may be required by the permitting authority as
necessary to enforce in a  particular circumstance.   Dealing with the  multiplicity of consequences
presented by such results, either singly or in combination, is beyond the present scope of this document.

6.      Initial Precision and Recovery

        The laboratory is required to  demonstrate its ability to generate acceptable precision and accuracy
data using the techniques specified in the 1600 Series Analysis Methods. This test, which is sometimes
termed the "start-up test", must be performed by the laboratory prior to the analysis of field samples with
the specified methods and prior to the use of modified versions of the methods on field samples.  EPA's
experience has been that laboratories that have difficulty passing the  start-up test have such marginal
performance that they will have difficulty in the routine practice of the method.

        The test consists of spiking four aliquots of reagent water with the metals of interest at 2 - 3 times
the ML concentrations listed in the methods and analyzing these four aliquots.  The mean concentration
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                                                                          Data Evaluation Guidance
 (x) and the standard deviation (s) are then calculated for each analyte and compared to the specifications
 in the methods. If the mean and the standard deviation are within the limits, the laboratory can use the
 method to analyze field samples.

        If the start-up test data fail to meet the specifications in the method, none of the data produced
 by the laboratory can be considered to be valid. If the laboratory did not perform the start-up tests, the
 data cannot be valid, unless all other QC criteria have been met and the laboratory has  submitted IPR
 (and associated instrument QC) data that were generated after-the-fact by the same analyst  on the same
 instrument.   If these conditions are met, then the data reviewer may consider the data to be acceptable
 for most  purposes.  NOTE:  The inclusion  of this alternative should  not  in any  way be construed to
 sanction the practice of performing IPR analyses after the analysis of field samples.  Rather, EPA believes
 that demonstration of laboratory capability prior to sample analysis is an essential QC component; this
 alternative is provided only as a tool to permitting authorities when data  have already  been collected
 without the required IPR samples.  Once the problem has  been identified, all responsible parties are
 expected  to implement corrective action necessary to ensure that it is not repeated.

        It is  important to remember that if a change is made to a method, the IPR procedure must be
 repeated using the modified procedure.  If the start-up test is not repeated when these steps are modified
 or added, any data produced by the modified methods  cannot be considered to be valid.

 7.      Analysis of Blanks

        Because trace metals are ubiquitous in the  environment, the precautions necessary to preclude
 contamination are more extensive than those required to preclude contamination when synthetic organic
 compounds  and other non-ubiquitous substances  are  determined.   EPA  has found  that  the  greatest
 potential for  contamination of samples analyzed for trace metals has been from atmospheric input in the
 field and  laboratory  and from inadequate cleaning of sample  bottles and labware.  In order to prove that
 such contamination is avoided during sampling, sample transit, and analysis, Method 1669 and the 1600
 Series Analysis Methods specify the collection and analysis of numerous blank samples.  These include:

 •       Equipment blanks that are collected prior to the use of any sampling equipment  at  a given site
        and provide a means for detecting contamination of sampling devices and apparatus prior to
        shipment to  the field site,

 •       Field blanks that are collected for each batch  of 10 or fewer samples from the  same site and
        provide a means of  detecting contamination that arises in the field,

 •       Calibration blanks that are analyzed immediately after each calibration verification  and provide
        a  means of detecting contamination that arises from the analytical system, and

 •       Laboratory (method) blanks that are analyzed for each batch of samples analyzed on a particular
        instrument and provide a means of detecting contamination from the analytical process.
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 Data Evaluation Guidance
        While the analysis of a minimum of four blank samples per site may seem to be excessive,
 particularly when very few (e.g., <  5) samples are collected, EPA has found that the validity of entire
 studies may be suspect when pollutants are identified in samples that are not associated with each of these
 blanks.  In general, it is not necessary for a facility to report the results of equipment blank analyses
 unless contamination is identified in field blanks. Therefore, the permittee should obtain equipment blank
 results  from its cleaning facility,  maintain these results on  file,  and provide them to the permitting
 authority upon request. The data reviewer should evaluate equipment blank results only if it is necessary
 to identify potential sources of contamination present in field  blanks.

        Controlling laboratory contamination is an important aspect of the quality assurance plan for the
 equipment-cleaning facility, laboratory, and field team.  Each party should maintain records regarding
 blank contamination.  Typically, these records take the form of a paper trail for each piece of equipment
 and control charts, and they should be used to prompt corrective action by the party associated with the
 contamination. For example, if records at a single site suggest that equipment blanks, laboratory blanks,
 and calibration blanks  are consistently clean but that field blanks show consistent levels of contamination,
 then the field sampling team should re-evaluate their sample handling procedures, identify the problem,
 and institute corrective actions  before collecting additional  samples.   Similarly, equipment cleaning
 facilities and laboratories should utilize the results of blank analyses to identify and correct problems in
 their processes.

        Unfortunately, it is often too late for  corrective action if data  are  received that suggest the
 presence of uncontrolled contamination that adversely  affects the associated data.  The exception to this
 rule is the case in which the field  and equipment blanks show no discernable levels of contamination,
 contamination is detected in the  laboratory or calibration blanks, sample holding times have not expired,
 and sufficient sample  volume remains to  allow the laboratory to  identify and eliminate the  source of
 contamination and reanalyze the associated sample(s).  In all other cases, the reviewer must exercise one
 of several options listed below when  making use of the data.

 •       If a contaminant is present  in a blank but is not present in a sample, then there is little need for
        concern about  the sample result.  (It may be useful, however, to occasionally review the raw data
        for samples without the  contaminant to ensure  that the laboratory did not edit the results for this
        compound.)

 •       If the sample contains the contaminant at levels of  at  least 10 times that in the blank, then the
        likely contribution to the sample from the contaminant  in the sample is at most 10%. Since most
        of the methods in question are no more accurate than that level, the possible contamination is
        negligible, and the data  can be considered to be of acceptable quality.

 •       If the sample contains the contaminant at levels of at  least 5 times but less than 10 times the blank
        result,  the numerical result  in the sample should be considered an upper limit  of the true
        concentration,  and  data users  should be  cautioned  when using such data  for  enforcement
        purposes.
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                                                                          Data Evaluation Guidance
•      If the sample contains the contaminant at levels below 5 times the level in the blank, the sample
       data are suspect unless there  are sufficient data from analyses of multiple blanks to perform a
       statistical analysis proving the significance of the analytical result. Such statistical analyses are
       beyond the scope of this guidance.

•      If blank contamination is found in some types of QC samples but not others (e.g., only in the
       laboratory blank but not in the field blank), the data user should apply the guidelines listed above,
       but may also use this information to identify the  source of contamination and take corrective
       actions to prevent future recurrences.

       There are two difficulties in evaluating sample results relative to blank contamination.  First, the
reviewer must be able to associate the samples with the correct blanks.  Field blanks are associated with
each group of field samples collected  from the same site.  Calibration blanks are associated with samples
by the date and time of analysis on a specific instrument. Laboratory (method) blanks are associated with
each batch of 10 samples prepared and digested in accordance with a particular method during a single
shift. If the reviewer cannot associate a batch of samples with a given blank, the reviewer should request
this association from the laboratory so that the results for the samples can be validated.

       The second difficulty involves samples that have been diluted.  The dilution of the sample with
reagent water represents an additional potential source of contamination that will not be reflected in the
results for the blank unless the blank was similarly diluted.  Therefore,  in applying the 10-times rule
stated above, the concentration of the sample is  compared to the blank results multiplied by the dilution
factor of the sample. For instance, if 1.2 ppb of a contaminant is found in the blank, and the associated
sample was diluted by  a factor of six relative to the extract from the blank prior to analysis, then the
diluted sample result would have  to be greater than 1.2x6xlOor72 ppb to be acceptable.  Diluted
sample results between 36 and 72 ppb would be considered an upper  limit of the actual concentration,
and diluted sample results  that were  less than 36 ppb would be considered unacceptable in the absence
of sufficient blank data to statistically prove  the significance of the result.

       In most cases, the practice  of subtracting the concentration reported in the blank from the
concentration in the sample is not recommended  as a tool to evaluate sample results associated with blank
data. One of the most common problems with this approach is that blank concentrations are sometimes
higher than one or more associated sample results, yielding negative results.

       Nearly all of the 1600 Series  Analysis Methods are capable of producing MDLs that are at least
10 times lower than the lowest water quality criteria (WQC) published in the National Toxics Rule.  Since
most discharge permits require monitoring  at levels that are comparable to  or higher  than  the  WQC
published in the National  Toxics Rule,  EPA believes that,  in nearly all cases,  laboratories  should be
capable of producing blank data that  are at least 10 times less than the regulatory compliance level.  It
should also be noted that laboratories  cannot be held accountable for contamination that is present in field
blanks but not present in  laboratory blanks; in such cases the sampling crew  should  take corrective
measures to eliminate  the source of contamination during their sample collection and handling steps.
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 Data Evaluation Guidance
 8.     Ongoing Precision and Recovery

        The 1600  Series Analysis Methods require laboratories to prepare and analyze an  "ongoing
 precision and recovery" (OPR) sample with each batch of up to 10 samples started through the extraction
 process on the same twelve hour shift.  This OPR sample is identical to the aliquots used in the IPR
 analyses (see Item 6), and the results of the OPR are used to ensure that laboratory performance is in
 control during the analysis of the associated batch of field samples.

        The data reviewer must verify that the OPR sample has been run with each sample batch and that
 the applicable recovery criteria in the analytical method have been met.  If the recovery criteria have not
 been met, the reviewer may use the following guidelines when making use of the data:

 •      If the concentration of the OPR is above method specifications but that analyte is not detected in
        an associated sample, then it unlikely that the sample result is affected by the failure in the OPR.

 •      If the concentration of the OPR is above method specifications and that analyte is detected in the
        sample, then the numerical sample result may  represent an upper limit of the true concentration,
        and data users should be cautioned when using the data for enforcement purposes.

 •      If the concentration of the OPR is below method specification but that analyte is detected in an
        associated sample, then the sample result may  represent the lower limit of the true concentration
        for that analyte.

 •      If the concentration of the OPR is below method specification and that analyte is not detected in
        an associated sample,  then the  sample data  are  suspect and  cannot  be considered valid for
        regulatory compliance purposes.

        If the OPR standard has not been run, there is no way to verify that the laboratory processes were
 in control. In such cases, a data reviewer may be able to utilize the field sample data by examining the
 matrix spike recovery results (see  item 9), the IPR results, OPR results from previous and subsequent
 batches, and any available historical data from both the laboratory and the  sample site.  If the matrix
 spike results associated  with the sample batch do not meet  the performance criteria in the methods, then
 the results for that set of samples  cannot be considered valid.  If the laboratory's IPR results and the
 matrix spike results associated with the sample batch  in question meet the  all  applicable performance
 criteria in the methods,  then the data reviewer may be reasonably confident that laboratory performance
 was in control during field sample analysis.  This level of confidence may be further increased if there
 is a strong history of both laboratory performance with the method and method performance with the
 sample  matrix in question,  as indicated by additional OPR and matrix spike data collected from the
 laboratory and samples from the same  site.

9.      Precision and Recovery of Matrix  Spike and Matrix Spike Duplicate Compounds

        The 1600 Series Analysis Methods  require that laboratories  spike the analytes of interest into
duplicate aliquots of at least one sample from each group of ten samples collected from a single site. The


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                                                                          Data Evaluation Guidance
first of these spiked sample aliquots is known as the matrix spike sample; the second is known as the
matrix spike duplicate.  These spiked sample aliquots are used to determine if the method is applicable
to the sample matrix in question.  The 1600 Series Analysis Methods are applicable to the determination
of metals at concentrations typically found in ambient water samples and certain treated effluents (e.g.,
the  part-per-trillion to low  part-per-billion range).   These methods may not be applicable to marine
samples and many effluent and in-process samples collected from industrial dischargers. Therefore, it
is important to evaluate method performance  in the  sample matrix of interest.

       In  evaluating matrix spike sample results,  it is important  to examine both the precision and
accuracy of the  duplicate analyses.  Precision is assessed by examining the relative percent difference
(RPD) of the concentrations found in the matrix spike and matrix spike duplicate samples, and comparing
the  RPD to the acceptance criteria specified in the analytical method. If the RPD of a matrix spike/matrix
spike duplicate  pair exceeds  the  applicable criterion,  then the method cannot be  considered  to be
applicable to the sample matrix, and none  of the associated sample data can be accepted for regulatory
compliance purposes.

       If RPD criteria are met, the method is considered to be capable of producing precise data in these
samples, and the data reviewer must then verify that the method is  capable of producing accurate data.
Accuracy  is assessed by examining the  recovery of compounds in the matrix spike and matrix spike
duplicate samples.  If the recovery of the matrix spike and  duplicate  are within the method-specified
limits, then the method is judged to be applicable to that sample matrix.  If, however, the recovery of
the spike is not within the recovery range specified, either the method does not work on the sample, or
the sample preparation process is out of control.

       If the method is not appropriate for the sample matrix, then changes to the method are required.
Matrix spike results are necessary in evaluating the modified method. If the analytical process is  out of
control, the laboratory must take immediate corrective action before any more samples are analyzed.

       To  separate indications of method performance from  those  of laboratory performance,  the
laboratory  should prepare and analyze calibration verification standards and OPR samples.  If the results
for either of these analyses are not within the specified range, then the analytical system or process must
be corrected.  After the performance of the analytical system and processes have been verified (through
the successful analysis of CCV and OPR samples), the spike sample analysis should be repeated.  If the
recovery of the  matrix spike and duplicate are within the method-specified range, then the method and
laboratory  performance can be considered acceptable.  If, however, the recovery of the matrix spike does
not meet the specified range, the laboratory should attempt to further isolate the metal and repeat the test.
If recovery of the metal remains outside the acceptance criteria, the  data reviewer may  apply the
following guidelines when attempting to  make use of the data:

•      If the recovery of the matrix spike and duplicate are above  method specifications but that metal
        is not detected in an associated sample or is detected below the regulatory compliance limit, then
        it unlikely that the sample result is affected  by the failure in the matrix spike.
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 Data Evaluation Guidance
 •      If the recovery of the matrix spike and duplicate are above method specifications and that metal
        is detected in an associated sample above the regulatory compliance level, then the sample result
        may represent the upper limit of the true concentration, and the data should not be considered
        valid for regulatory compliance purposes.

 •      If the concentration of the matrix spike and duplicate are  below method specifications but that
        metal is detected in an associated sample, then the sample result may represent the lower limit
        of the true concentration for that  metal.   If the metal  was detected in the sample  at  a
        concentration higher than the regulatory compliance limit, then it is unlikely that the sample result
        is adversely affected by the matrix.  If, however, the metal was detected below the regulatory
        compliance limit, the data should not be considered valid for regulatory compliance purposes.


 10.     Statements of Data Quality for Spiked  Sample Results

        The  1600 Series Analysis Methods specify that after the analysis of five spiked samples of a given
 matrix type,  a statement of data quality is constructed for each analyte.  The statement of data quality for
 each analyte is computed as the mean percent recovery plus and minus two times the standard deviation
 of the percent recovery for the analyte.   The statements of data quality should then be updated by the
 laboratory after each five to ten subsequent spiked sample analysis.

        The  statement of data quality can be used to estimate the true value of a reported result and to
 construct confidence  bounds around the  result.   For example, if the  result reported  for analysis  of
 selenium  is  10 ppb, and the  statement of data quality for selenium is 84% + 25% (i.e.,  the mean
 recovery is 84% and the standard deviation of the  recovery is 25%), then the true value for selenium will
 be in the range of 9.4 - 14.4 ppb, with 95% confidence. This range is derived as follows:

        Lower Limit  = [(10 + .84) - (10 x .25)] = [11.9 - 2.5]  = 9.4 ppb
        Upper Limit  =  [(10 +  .84)  + (10 x .25)] =  [11.9 + 2.5]  =  14.4 ppb

        Many laboratories do not provide the data quality statements with the sample results, in which
 case the data reviewer must determine if the data quality statements  are being maintained for each analyte
 and may need to obtain the data.  If necessary, the reviewer can construct the data quality statement from
 the individual data points. The lack of a data quality statement does  not invalidate results but makes some
 compliance decisions more difficult.  If  statements of data quality are not being maintained by the
 laboratory, there may be increased concern about both specific sample results and the laboratory's overall
 quality assurance program.

 11.     Statements of Data Quality for Spiked Reagent Water Results

       In addition to statements of data quality for results of analyses of the  compounds spiked into  field
samples, the  1600 Series Analysis Methods require that statements of data  quality be constructed from
the initial and ongoing precision and recovery data.   The purpose of these statements is to  assess
laboratory  performance  in the practice  of the method, as compared  to  the assessment of method
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performance made from the results of spiked field samples.  Ideally, the two statements of data quality
would be the same. Any difference could be attributable to either random error or sample matrix effects.

12.     Field Duplicates

        Method 1669 requires the collection of at least one field duplicate for each batch of field samples
collected from the same site. The field duplicate provides an indication of the overall precision associated
with entire data gathering effort, including sample collection, preservation, transportation, storage, and
analysis procedures.  The data reviewer should examine  field duplicate results and use the following
equation to calculate the relative percent difference between the duplicate and its associated samples.
                                      RPD =
                                                   (D1+D2)
        where:
        Dl  = concentration of the analyte in the field sample
        D2  = concentration of the analyte in the duplicate field sample
        If the analyte of interest was not detected in either replicate of the field sample, then the RPD
will be zero.  If the analyte was detected in each  field sample replicate, but the results are highly
disparate (indicated by a large RSD), the reviewer should apply the following guidelines when making
use of the data:

•       If the analyte was detected in each replicate and at similarly variable concentrations in the blank
        samples, then the field sample variability may be attributable to variable contamination, and the
        data may not be valid for regulatory compliance purposes.

•       If the  analyte was detected in each replicate at a  concentration well  above the  regulatory
        compliance level, but was not detected in the associated blank samples, then it is likely that the
        sample results are not adversely affected.

        Ideally, the RPD between field duplicates and MS/MSD samples will be identical. Any difference
between the two is attributable to variability associated with the field sampling process.
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                                                                             Chapter 4

                                                                Data Inspection Checklist
       The following pages contain a data inspection checklist that may be used by data reviewers,
laboratory personnel,  and other parties to document the results of each data inspection in a standardized
format.
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                                       Data Inspection Checklist
                                          Summary Information
   1.  Name of Reviewer:
               Title:
                     Required Samples
                         Sample Results Provided
      Sample Location or Sample ID
Analyte(s)
Sample Location or Sample
           ID
Analyte(s)
   2.  Method Used:

   3.  Total No. of analytical shifts per instrument (determined from analysis run log):
           Instrument
   4.  Total No. of CCVs Required:             	
   (one for each 10 samples after the
   first 10 samples on each instrument)

   5.  Total No. of CCBs Required:             	
   (one for each CCV)

   6.  Total No. of Field Blanks Required:       	
   (one per site or per 10 samples, whichever is more
   frequent)
   7.  Total no. of Lab Blanks Required:
   (one per batch* per  method/instrument)
   8.  Total no. of OPR analyses Required:
   (one per batch per method/instrument)

   9.  Total no. of MS/MSD samples Required:
   (one per 10% per matrix per site)

   10.  Total no. Field Duplicates Required:
   (one per 10 samples per site)

   11.  Total no. of MDL results required:
   (one per method and per analyte)
                                                         No. of Shifts
              Total No. of CCVs Reported:
              Total No. of CCBs Reported:
              Total No. of Field Blanks Reported:
              Total No. of Lab Blanks Reported:
              Total No. of OPR Analyses Reported^
              Total No. of MS/MSD samples Reported:
              Total No. of Field Duplicates Reported:
              Total No. of MDL Results Reported:
22
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                                        Data Inspection Checklist
  12.                                       Initial Calibration



  a.       Was a multiple point initial calibration performed"?                          Dyes   Dno

  b.       Were all sample concentrations reported within the calibration range?         Dyes   Dno

          If no, list method and analytes for which initial calibration was not performed or which exceeded
          the calibration range.

  c.       Analvte          No ICAL (Y/N) Exceeded ICAL Range (Y/N)
  d.      Did the initial calibration meet linearity criteria?                             Dyes   Dno


  e.      If no, was a calculation curve used to calculate sample concentrations?        Dyes   Dno

  * A three point (minimum) initial calibration should be performed for each analyte; if the RSD of the mean RRF is less than 15%, or
  if the RSD of the mean RF is less than 25%, then the averaged RRF or RF, respectively, may be used for that analyte.


  13.                      Method Detection Limit (MDL)/Minimum Level (ML)



  a.      Did the laboratory demonstrate their ability to achieve the required MDL?    Dyes   Dno


  b.      Did the initial calibration range encompass the ML?                         Dyes   Dno


  c.      Were all field samples detected below the ML reported as non-detects?       Dyes   Dno


  d.      If the answer to item a, b, or c above was "no",  describe problem:
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                                       Data Inspection Checklist
    14.




    a.




    b.




    c.




    d.




    e.
          Initial Calibration Verification (ICV)/Initial Calibration Blanks (ICB):
 Was an ICV run prior to field samples?




 Were ICV results within the specified windows?




 Was the ICV followed by an ICB?




 Was the ICB free from contamination?




 If any item in a - d above was answered "no", list problems below:




 Analyte         Failed ICV Recovery    Concentration Detected in ICB    Affected Samples
Dyes   Dno




Dyes   Dno




Dyes   Dno




Dyes   Dno
   15.




   a.




   b.




   c.




   d.
                         Initial Precision and Recovery (IPR)




Were IPR data reported for each analyte?                                 Dyes   Dno




Did all IPR aliquots meet required recovery criteria (x)?                    Dyes   Dno




Did the standard deviation (s) of each IPR series meet the required criterion?  Dyes   Dno




If any item in a - c above was answered "no", document problem below.




Analvte  Ave. Result Reported (X)       RSD Reported   Affected Samples
   16.
   a.
   b.
   c.
                       Ongoing Precision and Recovery (OPR)




Were OPR data reported for each analyte, instrument, and batch?            Dyes   Dno




Did all OPR samples meet required recovery criteria (x)?                   Dyes   Dno




If item a or b above was answered "no", document problem below.




Analyte OPR Recovery (X) Reported      Shifts Missing OPR      Affected Samples
24
                                                                                           April 1995

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                                     Data Inspection Checklist
  17.          Continuing Calibration Verification (CCV)/Continuing Calibration Blank (CCB)




  a.      Were CCVs run prior to each batch of 10 samples on each instrument?       Dyes   Dno




  b.      Were all CCV results within the specified windows?                       Dyes   Dno




  c.      Was each CCV followed by a CCB?                                     Dyes   Dno




  d.      Was each CCB free from contamination?                                 Dyes   Dno




  e.      If any item in a - d above was answered "no", list problems below:




         Analvte Affected Samples        Shift Missing CCV/CCB       Failed CCV/CCB ID
  18.                                Laboratory (Method) Blanks




  a.       Was a method blank analyzed for each instrument & sample batch?




  b.       Was each method blank demonstrated to be free from contamination?




  c.       If the answer to item a or b was "no", document problems below.




          Analvte     Affected Samples        Blank Concentration Reported
   Dyes   Dno




   Dyes   Dno









Shift Missing MB
   19.                                       Field Blanks




   a.      Was a field blank analyzed for each 10 samples per site?




   b.      Was each field blank demonstrated to be free from contamination?




   c.      If the answer to item a or b was "no", document problems below.




          Analvte    Affected Samples        Blank Concentration Reported
    Dyes   Dno




    Dyes   Dno









Shift Missing FB
April 1995
                      25

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                                       Data Inspection Checklist
    20.


    a.

    b.

    c.

    d.


    e.
                                MS/MSD Results


Were appropriate number of MS/MSD pairs analyzed?

Were all MS/MSD recoveries within specified windows?

Were all RPDs within the specified window?

Was appropriate corrective action (e.g., MSA for GFAA, serial dilution
for ICP) employed on affected samples?

If the answer was "no" to items a - d above, document affected samples:
dyes   Dno

Dyes   Dno

Dyes   Dno


Dyes   Dno
           Analvte MS % R
                      MSP % R
                                                MS/MSD RPD  Affected Samples
1 21
1 a.
1 b
1 c.
1 d.
Additional Information
Were Instrument Tune Data Provided?
Were equipment blanks demonstrated to be free from contamination?
Were statements of data quality provided?
Did field duplicate demonstrate acceptable precision?

Dyes
Dyes
Dyes
Dyes

Dno
Dno 1
Dno 1
Dno 1
26
                                                                                       April 1995

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                                                                                    Glossary
Accuracy:  The degree of agreement between a measured value and the true or expected value of the
quantity of concern.

Calibration Blank:  A sample of reagent water analyzed after the calibration verification standard to
check for contamination attributable to the analytical system.

Calibration Range (Calibration Curve):  A graphical relationship between the known values for a series
of calibration standards and instrument responses, specifically the  linear  portion  of this  relationship
between calibration standards.

Dissolved Metals:  The concentration of metal(s) that will pass through a 0.45 micron filter assembly,
prior to acidification of the sample.

Equipment Blank: An aliquot of reagent water that is subjected in the laboratory to all aspects of sample
collection and analysis, including contact with all sampling devices and apparatus.  The purpose of the
equipment blank is to determine if the sampling devices and apparatus for sample collection have been
adequately cleaned prior to shipment to  the field site.  An acceptable equipment blank must be achieved
before the sampling devices and apparatus are used for sample collection.

Field Blank:  An aliquot of reagent water that is placed in a sample container in the  laboratory, shipped
to the sampling site, and treated as a sample in all respects, including contact with the sampling devices
and exposure to sampling site conditions, storage, preservation, and all analytical procedures, which may
include filtration.   The field  blank is  used to determine  if field sample handling processes, sample
transport, and sampling site environment have caused sample contamination.

Field Duplicates:  Two identical aliquots of a sample collected in separate sample containers at the same
time and place under identical circumstances and sample collection techniques, and handled in exactly
the same manner as other samples.  Field duplicates are used as a measure of the precision associated
with sample handling, preservation, and storage as well as laboratory handling, preparation, and analytical
procedures.

Initial Precision and Recovery (IPR):  A series of four consecutively analyzed aliquots of reagent water
containing the analyte(s) of interest at 2 - 3 times the ML.  IPRs are performed prior to the first time a
method is used and any time the method or instrumentation is modified. The IPR is used to demonstrate
the analyst/laboratory ability to generate acceptable precision and accuracy through the  calculated mean
(x) and standard deviation (s) for each analyte.

Laboratory Blank:  An aliquot of reagent water that is treated exactly as a sample including exposure
to all glassware,  equipment, solvents,  reagents, internal standards,  and surrogates  that are used with
samples,  the laboratory  blank is  used to determine  if  analytes or interferences  are present in  the
laboratory environment, reagents, or the apparatus.
April 1995                                                                                     27

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 Magnetic Media:  A storage medium on which all instrumentally acquired raw data may be retained.

 Matrix Spike (MS) and Matrix Spike Duplicate (MSD): Aliquots of an environmental sample to which
 known quantities of analytes are added in the laboratory. The MS and MSD are analyzed under the same
 conditions as other samples and are used to quantify the bias and precision associated with the sample
 matrix.  The background concentration of the analytes in the sample are determined and subtracted from
 the MS and MSD results.

 Method Blank:  See "laboratory blank".

 Method Detection Limit (MDL): The minimum concentration of an analyte that, in a given matrix and
 with  a specified method,  has  a 99% probability  of  being identified, qualitatively  or  quantitatively
 measured,  and reported to  be greater than zero.

 Minimum Level (ML): The lowest level at which the entire analytical system gives a recognizable signal
 and acceptable calibration point.

 Ongoing Precision and Recovery (OPR):  An aliquot of reagent water containing  the analyte(s) of
 interest.   The OPR is used to demonstrate continuing ability  of the analyst/laboratory to generate
 acceptable  results based on target and standard recoveries.

 Quality Assurance (QA):  An integrated system of activities involving planning, quality control, quality
 assessment, reporting,  and quality  improvement to ensure that a product or service  meets defined
 standards of quality with a stated level of confidence.

 Quality  Control (QC):  The overall system of technical activities designed measure and control the
 quality of a product or service so that it meets the needs of users.  The aim is to provide quality that  is
 satisfactory, adequate,  dependable, and economical.

 Precision:  The degree of mutual agreement characteristic of independent measurements as the result of
 repeated applications of the process under specified conditions.

 Reagent Water:  Water demonstrated to be free from the  metal(s) of interest at the method detection
 limit (MDL) of the analytical method to be used for determination of the metal(s) of interest.

 Reference  Standards:  A  material or substance, one or more properties of which are sufficiently well
 established to be used for the calibration of analytical  apparatus, the assessment  of a measurement
 method, or assigning of values to materials.

 Trace Metals:  Concentrations  of metals found  at or near their established water quality criteria levels.
28                                                                                    April 1995

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                                                                            Appendix A

                                                           EPA Water Quality Criteria for
                                             Priority Pollutant Metals and Metals Species
The table provided  on the following page provides the freshwater, marine,  and human health water
quality criteria published by EPA for priority pollutant metals and metals species.  This table includes
criteria for both total recoverable metals and dissolved metals.   Criteria for dissolved metals  were
calculated in accordance with an October  1, 1993 guidance memorandum transmitted by the Acting
Assistant Administrator for Water to Water Management Division Directors and Environmental Services
Division Directors.  This table also includes freshwater criteria that are based on a hardness of 100 mg/L.
These values were published by EPA in the National Toxics Rule at 57 FR 60848.  In order to provide
a worst-case scenario, the table  also  includes criteria that are based on a hardness of 25 mg/L CaCO3.
Calculations for deriving these values were published by EPA  in the National  Toxics Rule.
April 1995                                                                                  29

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