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            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             OFFICE OF WATER
                    OFFICE OF SCIENCE AND TECHNOLOGY
                    ENGINEERING AND ANALYSIS DIVISION
                  SIXTEENTH ANNUAL EPA CONFERENCE ON
               ANALYSIS OF POLLUTANTS IN THE ENVIRONMENT
                               MAY 5-6, 1993
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                                                  Recycled/Recyclable
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                                 FOREWORD
       The  Sixteenth  Annual  EPA Conference on  Analysis of  Pollutants  in the
Environment was held at the Norfolk Marriott Waterside Hotel in Norfolk, VA on May
5th and 6th, 1993.  The Conference was attended by over 300 scientists from regulated
industry, commercial environmental laboratories,  state and  Federal  regulators,  and
environmental consultants and contractors.  The Conference provided the attendees with
the opportunity  to  discuss all  aspects of environmental analytical  chemistry  with a
particular focus on analytical methods and  related regulatory issues.

       These  proceedings  document 23  technical  and policy presentations  on the
following subjects:  herbicide, dioxin, and PCB analysis, detection levels and laboratory
accreditation,  metals and organo-metallics, radiochemistry and drilling muds, unusual
matrices, matrix interferences and sample  collection, performance-based methods, and
pollutants in soil.

       We would like to thank Jan Sears Kourmadas of  Ogden  Environmental for
coordinating the conference, Dale Rushneck of Interface, Inc.  and Cindy Simbanin of
DynCorp Viar, Inc. for their assistance in arranging the technical program, the speakers
for their  outstanding efforts, and all the others who helped make the Sixteenth  Annual
Conference a  success.  We are looking forward  to your attendance at  the Seventeenth
Annual EPA Conference in May of 1994.

                                                                   W. A. Telliard

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                 SIXTEENTH ANNUAL EPA CONFERENCE ON
             ANALYSIS OF POLLUTANTS IN THE ENVIRONMENT

                             USEPA, Office of Water
                         Office of Science and Technology
                         Engineering and Analysis Division

                                 May  5-6, 1993
                                Norfolk, Virginia

                           TABLE OF  CONTENTS - 1
Wednesday, May 5, 1993

Welcome and Introduction  	
      William A. Telliard
      Engineering and Analysis Division
      Office of Science and Technology
      USEPA, Office of Water
Herbicides. Dioxin and PCBs

Development of GC/ECD Analysis Method for Herbicide
Acids and Pentachlorophenol in House Dust	  3
      Marielle Brinkman
      Battelle

Results of the Intel-laboratory Validation Study of
USEPA Method 1613 for the Analysis of Tetra- through
Octachlorinated Dioxins and Furans by Isotope
Dilution GC/MS   	   49
      Dr. Harry  B. McCarty
      Science Applications International Corporation

Determination of Coplanar and Total Homolog PCBs
by HRGC/HRMS	   87
      E. A. Marti
      Triangle Laboratories of RTP, Inc.
Detection Levels

Compliance Monitoring Detection and Quantitation Levels  	 125
      James K. Rice, Consultant

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                            TABLE OF CONTENTS - 2
Metallo-organic Compounds

Combination of SFE with Capillary GC and Atomic Emission
Detection for the Determination of Organotin Compounds
in Environmental Samples	 161
      Yan Liu
      Midwest Research Institute
Metals

Determination of Metals in Water by Ultrasonic
Nebulization, Inductively Coupled Plasma/Atomic
Emission Spectroscopy	 191
      Theodore D. Martin
      Environmental Monitoring Systems Laboratory
      US EPA, Office of Research and Development

Ultra-Clean Sampling, Storage, and Analytical
Strategies for Accurate Determination of Trace
Metals in Natural Waters  	211
      Nicolas S. Bloom
      Frontier Geosciences, Inc.

Trace Metals Analysis - Clean and Ultra-Clean
Techniques 	237
      Bob April
      Ecological Risk Assessment Branch
      US EPA, Office of Water, Office of Science and Technology
Radiochemistry and Drilling Muds

Minimization of Production Costs and Waste Generation in
Radiochemical Analysis  	247
      David L. Demorest
      Core Laboratories, A Division of Western Atlas International

Determination of Radium-226 and Radium-228 in Naturally
Occurring Radioactive Material (NORM) Solids by
High Purity Germanium Gamma Spectroscopy	277
      Richard Rivera
      Shell  Development Center

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                            TABLE OF CONTENTS - 3
Radiochemistry and Drilling Muds

Methods for the Determination of Diesel, Mineral, and Crude Oils
in Drilling Muds from Offshore Drilling Operations	307
      Joseph C. Raia, Consultant
Thursday, May 6, 1993

Unusual Matrices

Stormwater Sampling and Analysis  	335
      G. H. Stanko
      Shell Development Company

Extracts of National Sewage Sludge Samples	395
      John M. McGuire
      Environmental Research Laboratory
      US EPA, Office of Environmental Processes and Effects Research


Pollutants in Soil

Determination of Selected Organochlorine Pesticides in Soils  	415
      Ileana Rhodes, Ph.D.
      Shell Development Company


Matrix Interferences and Sample Collection

Elimination of Matrix Interferences in Solid Phase Microextraction  	487
      Zhouyao Zhang
      University of Waterloo, Department of Chemistry

A Generalized Approach  to Solving Matrix Problems	521
      Bruce N. Colby
      Pacific Analytical

Anion Exchange Resins for Collection of Phenols in Air and Water	 567
      Hazel Burkholder
      Battelle

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                            TABLE OF CONTENTS - 4
Performance-Based Methods

Performance-Based Methods:  An Opportunity for Basic Science	605
      James M. Conlon
      Drinking Water  Standards Division
      US EPA, Office of Water, Office of Ground Water and Drinking Water

Environment Canada's Approach to Performance-Based Methods	641
      Richard Turle
      Environment Canada, Chemistry Division
Laboratory Accreditation

The AIHA Environmental Lead Laboratory Accreditation Program	667
      Kenneth T. White
      Consultive Services
Pollutants in Soil

An Integrated Application of Field Screening To Environmental
Site Investigations:  A Case Study	699
      Alex Tracy
      Woodward-Clyde Federal Services
Unusual Matrices

QA/QC Guidance for Dredged Material Evaluations	741
      Mike Kravitz
      US EPA, Office of Water, Office of Science and Technology
Closing Remarks	749

List of Speakers	751

List of Attendees	753

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                               PROCEEDINGS

                                     Mav 5. 1993
                                        MR. TELLIARD: Good morning. I would like to
welcome you to the 16th annual meeting on the measurement of pollutants in the environment.
This meeting is sponsored by the Environmental Protection Agency Office of Water.

             We would like to maintain an open forum, and want you to express your opinions.
We ask you to  do  one thing:  when you come to the microphone, please identify yourself by
name and organization.

             If, for some reason, you don't want your statement kept in the proceedings, just
state that, and we will make sure that it doesn't appear. Otherwise, it is a free-flowing system,
and we want you to feel free to ask questions, express opinions and, all in all, try to feel relaxed
at this meeting.

             So, with that housekeeping information, I would like to start the program.  Our
first speaker this morning is Margaret Brinkman and she is going to be talking on herbicides and
pentachlorophenol in house dust.  This was an interesting paper when we first heard about it, and
I think you are  going to enjoy it.

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                                        MS. BRINKMAN:  Good morning.  Today I am
going to be talking about pesticides.  More specifically, I will be talking about acid herbicides,
the types of pre-emergent herbicides most often applied to  residential lawns.

              I  will  discuss  one way  these acid herbicides migrate indoors  through a
phenomenon that we call "track-in." When we enter our homes wearing the same pair of shoes
with which we just walked across our pesticide-treated lawn, do we track in these pesticides?

              In our effort to document and then quantify human track-in, we encountered some
challenging sample matrices.

              These statistics were  reported  in  the  U.S. EPA  non-occupational pesticides
exposure study:  90 percent of the people polled in that study used pesticides.  Only half of those
90 percent  read the instructions prior to use, and only 10 percent responded that they used these
pesticides with caution.

              The National  Academy  of Sciences,  in their  report  entitled,  "Urban  Pest
Management," indicated that the lawn care industry has grown to a $2.8 billion per year industry
and that homeowners apply pesticides at a rate four to ten times greater than farms.

              Battelle conducted a telephone survey of randomly selected lawn-care companies.
These companies were geographically well-distributed within the greater Columbus, Ohio  area
and represented both nationally- and locally-owned companies.

              Of the 21 lawn-care companies polled, 11 responded to our questions. As you can
see, dicamba, mecoprop, and 2,4-D were  the most popular  post-emergent herbicides applied.

              We  also surveyed 7 retailers in the greater Columbus area.  The 6 that responded
represented a variety of store types, including a nursery, a garden center, hardware store, discount
department store, and a hardware/department store hybrid. Again, 2,4-D, mecoprop, and dicamba
were the most popular post-emergent herbicides stocked by these retailers.

              What is the impact of this use on our indoor environment? The primary issue is
whether or not these  pesticides are  tracked  into the  home from  treated turf.  Then, are
dislodgeable residues or what gets picked up off of the treated lawn, related to track-in? Do the
amounts of dislodgeable residues change with time?   What is the effect of environmental
weathering? Do entry way mats, or the welcome mats that we have in front of our front doors,
limit track-in?

              To begin to  assess the  human exposure in the  indoor environment, we need to
simulate track-in under controlled conditions at various times after application and then develop
analytical methods in order to  measure the transfer of these pesticides.

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              For this study, a commercially available mixture of three herbicide acids was
applied to the turf.  The structures are shown along with their measured application rate.

              A section of residential turf that had not been treated with lawn chemicals in at
least ten years was used.  20x20-foot plots were roped off with approximately 10-foot borders
separating the plots. The application was made at time zero, and a simulation of track-in into
the home was conducted at the times shown here for each 20x20-foot plot, 4 hours, 8 hours, 1
day, 4 days, and 6 days.

              The study also included a field blank, which is shown in the lower left of the slide,
which at the conclusion of the study, actually became an evaluation of spray drift, since our field
blank levels were 3 percent  of our sprayed plot measurements.

              Collection of dislodgeable turf residues was done using a mechanical device, which
I will  refer to as the "PUF  roller", at  11 different times between 4 hours and 14 days after
application.  This was done  on the plot marked,  "PUF 4 hour-14 day."  There was no human
traffic on this plot.

              In the upper right is a weather control plot which was used to assess the effect of
a minor amount of rain that fell in the evening following application.  The lawn plot in the lower
left was  used to assess herbicide stability in the carpet after track-in.

              We will focus now on a single track-in experiment.  The treated turf is shown in
light green.  The area reserved for  collection of turf dislodgeable residues  with the PUF roller
is shown as it was marked off in the middle of the plot.  This area received no human traffic,
and collection of this sample occurred prior to human subjects walking on the plot.

              Two platforms were placed just beyond the perimeter of the treated turf. Both had
standard nylon residential carpeting, and one included a standard home entryway mat.

              The black arrows indicate the path taken by a human subject during one cycle of
walking  to simulate track-in.  Starting at the white "start here" box, the  subject would walk
across the  left side of the track-in  plot, step onto the walk-off mat, and wipe each foot once,
proceed  along across the carpeting, turning right, circling back around, and then proceeding to
walk across  the right half of the treated  lawn plot, then walking directly onto the carpeting,
circling back around to the  left to complete one cycle.

              A complete track-in experiment included 100 of these cycles. Each experiment
had five participants. Thus, each participant walked 20 cycles.

              The counters  at the  end recorded  the number of footfalls in the lawn plot and
directed participants to a specific quadrant of the carpeting.

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              Now we are looking at the platform with carpeting at the top and the entryway mat
at the bottom.  The carpeting was divided into four equal areas, as shown.  This was done so that
dislodgeable residues collected with the PUF roller could be collected from half of the carpet,
and dust- or dirt-bound residues collected using the high volume surface sampler vacuum, which
is called the HVS3, could be collected from the other half of the  carpet.

              We developed a track-in sequence to ensure that each participant walked the same
number of times  in each area to  avoid track-in bias from participants' weight, shoe size, and
stride.

              The samples collected for each track-in experiment included dislodgeable residues
from the turf which resulted in a PUF sleeve to be extracted.  Dust- or dirt-bound residues from
the carpet, one carpet with the home entryway mat preceding and one with no mat, was collected
with the HVS3 and resulted  in two containers of dust to be weighed and extracted.

              Dislodgeable residues also from both carpets also resulted in a set of PUF sleeves
to be extracted.

              The PUF roller is shown here.   A removable polyurethane  foam sleeve was
cleaned and then  mounted at the front prior to sampling.  After sampling, the PUF  sleeve was
placed in an extraction bag.

              This slide shows the PUF roller collecting turf dislodgeables on the lawn plot that
was reserved for  PUF roller measurements  only. No track-in by human subjects was done on
this lawn.  You can see that the lanes are marked off.

              This slide shows the collection of dust or  dirt-bound  residues using  the HVS3.
The dust or dirt sample container is white and is connected to the HVS3 cyclone in the middle
of the slide.

              This slide shows our human subjects simulating track-in. A new pair of shoes and
safety apparel were provided to each participant prior to every track-in experiment.

              And this slide shows the area of a track-in lawn plot reserved for the PUF roller.
It is  roped off down the middle of the plot.

              Our analytical method development effort was directed toward not only the applied
herbicide acids but other herbicides, including MCPA, 2,4,5-T, 2,4,5-TP, and pentachlorophenol.
These methods were developed not only for use in  this program but also for other programs in
which we are analyzing residential dust samples for lawn-applied pesticides.

              Pentachlorophenol  has been used extensively  in the  past  as  an insecticide,
fungicide, and herbicide; and, notably, as a wood preservative. Although pentachlorophenol is

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less acidic than the herbicide acids, we felt that it would be feasible to develop a single analysis
scheme for both herbicide acids and pentachlorophenol.

              The development of analysis methods for herbicide acids, particularly in house
dust, requires the following considerations: First, co-extractable neutral and acidic species must
be removed through clean-up steps.

              Second, detection levels for this particular study needed to cover both high and
low analyte levels.

              Third, for purposes of quality assurance and quality control, appropriate recovery
standards and internal standards must be chosen.

              The three analysis approaches considered are shown here: first, GC/MS with little
or no sample clean-up, perhaps the most costly way to go; second, GC with minimal clean-up,
derivatization, and two-dimensional chromatography; or GC  with  clean-up using  either dual
derivatization and/or dual GC  column analysis  and/or dual GC detection for confirmation of
peaks.

              Derivatization is essential  for these analytes to ensure accurate detection  and
quantification by GC  techniques.   The options considered  included:   methylation  with
diazomethane; pentafluorobenzylbromide derivatization; or derivatization  with 2-cyanoethyl-
dimethyl-diethyl-aminosilane, the  latter  derivative being detectible by  both BCD and NPD
detectors.

              Our analytical scheme shown here is scaled in volume to accommodate extraction
of either dust, soil, or PUF sleeves.  The recovery standard, 3,4-D, is spiked to the matrix prior
to extraction with an acetonitrile:phosphate buffer.

              Soil and dust samples are sonified, PUF samples are squeezed manually in the
transport bag.

              Partitioning of the extract at high pH removes neutral compounds.  Solid phase
extraction with aCl& cartridge removes acetic and humic acid interferences.

              After addition of the internal standard, the extract is split for multiple analyses,
with PFBBr derivatization possible for samples  not detectible  with methylation.

              A comparison of the general sensitivities that can be achieved with methylation
and PFBBr are  shown here for representative herbicide acids  and pentachlorophenol.  Note in
particular that for monochlorinated herbicide acids such as mecoprop and  MCPA, a 100-fold
increase in concentration over the concentration of 2,4-D, a dichlorinated herbicide  acid, still
produces a signal only one-tenth as large.  This  indicates a differential response factor of 1000.

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              However, with PFBBr derivatization, the signals for 50 pg of mecoprop, MCPA,
and 2,4,-D are approximately equal.  Relative to methylation, PFBBr derivatization provides a
40-fold increase in sensitivity for 2,4-D and a 20,000-fold increase in sensitivity for mecoprop.

              This detection issue will become increasingly important in the future as lawn-care
companies switch from using  2,4,-D  and use instead  the monochlorinated acid  herbicides,
mecoprop and MCPA.

              As shown at last year's conference, we have developed a virtually artifact-free
PFBBr derivatization procedure which allows analyses  by  GC/ECD rather  than GC/MS.  A
standard literature-reported method was applied to three herbicide acids  with the resulting top
GC/ECD chromatogram.  Our PFBBr derivatization of four herbicide acids resulted in the lower
chromatogram.

              House dust appears to be a long-term reservoir for pollutants entering the home.
Young children crawling on carpets with moist hands appear to transfer milligram quantities per
day to their mouths.

              House dust is also an extremely complex matrix but will continue in importance
as scientists recognize its significance in exposure within the home.

              In the lowest panel is shown the GC/ECD extract of a representative house dust
without any clean-up.  Above it  is that same house dust with SPE clean-up. The top panel shows
the house dust extract with both SPE and liquid partitioning clean-up steps.

              Discrete analytes are now detectible with baseline resolution and, as shown in the
following slide...they are labeled up there on the top...the internal standard 2,6-D, 2,4-D and PCP
are now identifiable.  The presence of these  analytes in the extract was confirmed using negative
chemical ionization GC/MS. No interferences were detectible by GC/MS.

              This slide  shows 1 gram dust  extracts, spiked and unspiked,  that were carried
through our analytical procedure and subsequently methylated with diazomethane. The analytes
are highlighted in pink, and the internal standard and recovery standard are highlighted in blue
and black.

              As you can see from the bottom chromatogram, the house  dust we collected had
measurable quantities of dicamba, 2,4-D,  and  PCP already in it.

              This slide shows 0.1 gram dust extracts, spiked and unspiked, that were carried
through our analytical procedure and derivitized with PFBBr.  Now we are beginning to detect
MCPA, a monochlorinated herbicide  acid, in the unspiked dust extract.

              And this slide shows our PUF extracts, spiked and unspiked.

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              Our method recoveries were, in general, quite good, greater than 80 percent.  The
method can also be used for herbicide acid salts, the form in which they are applied to turf.

              As shown for PUF, 2,4-D salt had similar extraction and recovery to the 2,4-D free
acid.  Shown at the bottom of the slide, recovery of our surrogate recovery standard, 3,4-D, in
numerous dust, soil, and PUF field samples analyzed to date is also quite good.

              Before I  show you some results, this slide is just to refresh your memory about
the different samples collected for each track-in experiment.  Dislodgeable residues are picked
up  from the turf via the  PUF roller.  Carpet dust is collected from one-half of each carpet.
Dislodgeable residues are collected via the PUF roller from one-half of each carpet.

              What is not shown here are the turf dislodgeable residue samples taken at various
times after application from the lawn plot that had no human traffic.

              This slide shows the temporal profile of 2,4-D turf dislodgeable residues that were
collected from the single lawn plot using the PUF roller. The arrow bars indicate duplicate PUF
samples and show relatively good reproducibility for the technique.

              The trace of rain that fell on the first evening after application removed about 60
percent of the dislodgeable residues. The second rain, which was 0.9 inches in 2 hours, removed
approximately 99 percent of the dislodgeable residues, but residues were  still  detectible even
without PFBBr derivatization out to 14 days after application.

              An interesting phenomenon should be noted here: 1 day after rain, dislodgeable
residues increase, suggesting that the turf herbicide acids are  retained in the top layer  of soil.
As water  displaces the herbicide  acids  from  highly  retentive sites,  more  is  available  as a
dislodgeable residue. This phenomenon has been reported by Seibert and coworkers for volatile
pesticides as well.

              The temporal profile for dicamba is also very similar to  that for 2,4-D, including
the increases after the rain.

              This slide shows the temporal profile of 2,4-D dislodgeable turf residues collected
from the lawn plots used for human track-in.  Again, the profile is very  similar to that seen in
the previous slide and is  also similar to the profile of herbicide acids in the carpet matrices as
seen in the following slides.

               These are  the levels of dust and dirt-bound 2,4-D tracked from the turf onto the
carpeting and collected with the HVS3 vacuum cleaner.  Clearly, 2,4-D is found in carpet  dust
well after the heavy rain episodes.  The entryway mat does little to remove these residues, 50
percent at most and, at later times, showing minimal effect.

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              Dislodgeable 2,4-D residues on the carpet collected with the PUF roller are shown
here.  Once again, the same temporal profile is observed with about 25 percent removed by the
entryway mat.

              We have calculated here the  relative transfer of pesticides from turf to the PUF
roller, to the dust in the carpet, and to the carpet surface. The numbers in the very top row are
listed as ppm numbers, and below them are the percentages.

              Imagine we had a million pieces  of confetti  strewn about on the  lawn, for
Dicamba,  1600 of those pieces of confetti were picked up by the PUF, 30 of them were in the
dust, and 3 of them went to the carpet surface.

              Dislodgeable turf residues appear to be about 0.1 percent of that applied.  For
industry standard application rates that are four to five times greater than what was used in this
study, residues in the home can potentially build up over the years.  Most vacuum cleaners have
a removal efficiency of about 35 percent for small particles.

              This  slide shows quite  good correlation  between the mechanical  measure of
dislodgeable residue and that amount actually tracked in by our human subjects. Correlation of
turf dislodgeables with carpet dust levels was 0.9, and with the dislodgeable carpet  surface
residues was 0.99.

              This would indicate that simple mechanical devices may be used to discern levels
that can be tracked into a home.  What are the implications for us personally?  Possibly, we
should become more like the Japanese and Scandinavians and leave our shoes outside the door.

              Any questions?

                                         MR. TELLIARD:  Thank you.

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                       QUESTION AND ANSWER SESSION

                                     MR. TELLIARD:  Questions?

                                     MR. COCHRAN: Jack Cochran, Hazardous Waste
Center.

            I was wondering if you monitored the vapor of the home at all, the air of the home
for vapors.

                                     MS. BRINKMAN: Well, the track-in experiments
were conducted outside.  So, no, we did not. That is a concern, and that is something that we
will be looking at in the future.

                                     MR. COCHRAN: And as far as the vacuum cleaner,
would you think that it would tend to throw these particles up in the air?

                                     MS. BRINKMAN:  Well, the HVS3 is designed
specifically for the experiments that we did.

                                     MR. COCHRAN:  I  am talking about a home
vacuum cleaner.

                                     MS. BRINKMAN: Yes, that is why we used the
HVS3, because a home vacuum cleaner does, in fact, throw the particles up into the air.

                                     MR. COCHRAN: I am just suggesting that maybe
they will be breathed by the occupants.

                                     MS. BRINKMAN: Yes.

                                     MR. TELLIARD: Anyone else?
(No response.)

                                     MR. TELLIARD: I have one quick question. Does
this mean my son's room is now a national hazard?

                                     MS. BRINKMAN: I think yes.

                                     MR. TELLIARD: Not to mention what four paws
will do. Thank you.
                                        10

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-------
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Battelle acknowledges financial support
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   EPA on Contract No.68-DO-0007
                                           bri2-13cdr

-------
                                        MR. TELLIARD:   Our next speaker  is Harry
McCarty.  Harry is going to be speaking on the round robin that was carried out on Method 1613
for the determination of dioxin and  furans  tetra through  octa and the  application of dirty,
dangerous, and deadly.
              Harry?
                                        MR. MCCARTY: Thanks, Bill.
              I expected to get a lot more grief from Bill.  This study was undertaken while I
was still an employee of Viar & Company at the Sample Control Center.

              We presented this work in Finland, and I am sure a large number of you in the
audience were at the dioxin meeting in Finland. The presentation from the dioxin  meeting has
been published in Chemosphere  (Vol. 27,  Nos. 1-3, pp 41-46, 1993).   I see a lot of heads
nodding off.  You have probably  heard about this study in the past, either at this meeting  or at
others.

              To give you a little bit of background very quickly, in 1990, a little over three
years ago, Bill's office started this interlaboratory validation study. The analysis was for dioxins
and furans, the tetra through octa chlorinated dioxins and furans, by high resolution GC/mass
spectometry.

              It is an international study. We got everybody we could find at the time who was
willing  to participate in the study, and ended up with 22 laboratories in  6 countries.  As Lynn
Riddick can tell you, the troubles of shipping standards and samples to 6 different countries or
5 outside of the  U.S. is not a trivial task.

              The idea was to gather data to support the promulgation of Method  1613 under
Section 304(h) of the Clean Water Act.  That is the section, as you well know, that requires the
Agency monitoring methods to be proposed and, ultimately, promulgated after public comment.

              The method was proposed for use in February of 1991. This study began before
that promulgation, and the method has not gone final yet. So, the  results of this study will be
put into the final promulgation.

              To give you a little bit of background on the method itself, it is not as exciting
as oil and grease analysis, obviously, but we extract the water samples. The focus of the method
is aqueous samples, and we extract  the water samples after filtering them first, removing the
small particles which are believed to contain most of the dioxin in any case.

              The particulates on the filter are extracted with toluene, and the remaining aqueous
filtrate is extracted with methylene chloride in a traditional separatory funnel shake-out.


                                           49

-------
              There is a solvent exchange and, ultimately, the two extracts are combined for
cleanup and analysis. So, you are only talking about one shot on the mass spec, but two different
extraction procedures are applied to the two different parts of the matrix.

              The extraction device is something that came from Nestrick and Lamparski's work
at Dow.  They have worked on this for quite some time.  There had also been some other
development prior to their working on it.

              It is a combination of a Soxhlet extraction with a  Dean-Start water trap.  It is
known now as a Soxhlet-Dean-Stark or an SDS. It is widely applicable to soils and other solid
matrices, including particulates out of a water sample.

              This is a picture of it for those of you who aren't familiar with it. It is basically
a glass dogleg which collects the water out of the sample.

              Toluene and water form an azeotrope, and when you boil the toluene up through
here into the  Soxhlet extractor, the vapor that comes off is an  azeotrope.  The boiling point is
85°C.  The water condenses out and drops back down in this dogleg.  The toluene will float on
top of it and, ultimately, be returned to the Soxhlet body.

              With a Dean-Stark trap with a  stopcock at the bottom, you can take off as much
water as you  need to for a very wet matrix.

              The advantage of using the Soxhlet-Dean-Stark is that you no longer have to add
the drying agent, sodium  sulfate, to the sample.  There  are two  concerns  with using  sodium
sulfate. The first thing that you do with reagent grade sodium sulfate is to bake it at 400 degrees
in a muffle furnace to  get rid of all the residual carbon.  That gives a grey cast to the  sodium
sulfate.

              Nestrick and Lamparski have done  a  fair amount of work to show that that grey
cast is, of course, activated carbon, which picks up dioxins and furans out of the matrix and can
absorb them.

              The other issue is that as you  hydrate the  sodium sulfate it seals off pores  in a
porous matrix such as soil or fly ash.  You seal off the cavities in the matrix, and you never get
the solvent in contact with the small pores in the solid matrix, and therefore may not extract the
analytes of interest.

              Nestrick and Lamparski have done  a fair amount of work on SDS, and we
confirmed it with samples as nice as sewage sludge to show that Soxhlet-Dean-Stark does at least
as well as using Soxhlet along with a drying  agent.

              The cleanup steps are fairly common for dioxin methods. There is an acid-base
back extraction of the extract to remove  the water extractable interferences.  Gel permeation

                                           50

-------
chromatography (GPL) can be applied. It is not essential to perform GPL on any of the cleaner
samples.

              The alumina column, silica column, and carbon columns are all fairly traditional
for dioxin analysis,  and they remove a fair number of the co-eluting interferences,  the co-
extracted materials.

              There is also a procedure in the method for doing HPLC as a cleanup step as well.

              We add a number of standards to these  samples, the first one being 37Cl-labeled
2,3,7,8-TCDD.  This compound is not found among the environmentally occurring dioxins.  It
is completely chlorine  labeled,  and it is used as, in this method,  what is  called a  cleanup
standard.  It  is added after extraction so that you can determine the efficiency of the  cleanup
steps separately from the recoveries of the other standards.

              We also used carbon-labeled 1,2,3,4-tetrachlorodibenzodioxin and 1,2,3,7,8,9-
hexachlorodioxin as what are called in this method internal standards. Other methods call them
recovery standards.  These  are  added immediately prior to injection,  and they allow you  to
measure the  recovery of the 15 carbon-labeled standards that are added immediately prior  to
extraction.

              This is an isotope dilution method.  The 15 isomers of the dioxins and furans that
have label analogs added prior to extraction are quantitated against those labels by  isotope
dilution.  The two isomers without label  analogs  are quantitated against an analog at the same
level of chlorination.

              The octafuran label produces an interference with the  native octadioxin, so it is
not added. As a result, you quantitate octafuran by comparing it to the peak areas of the labeled
octadioxin.

              One of the hexadioxins, as I showed, is used as an internal standard immediately
prior to injection.  So,  it is quantitated against the labels for the other two hexadioxins  that are
added prior to extraction.  It is a minor variation  on isotope  dilution, if you will.

              The study design, in general, was  to supply  the laboratories with concentrated
extracts derived from bulk extraction of large volumes of industrial wastewaters and sludges.
In fact,  we did not ship the sludges to the labs in this portion of the study.  They are being used
for other purposes.

              The extracts were prepared by the EPA laboratory in Bay St. Louis.  Some of them
were fortified with additional analytes.  By and large, most of the samples had some  2,3,7,8-
TCDD and some 2,3,7,8-TCDF, but many of the  other isomers were  not found or not found in
significant concentrations in those  original samples, so the extracts were fortified prior to being
ampulated.


                                           51

-------
              The extracts were submitted to the laboratory as traditional single blind samples.
In fact, they were submitted in duplicate, and each lab did not know that they had duplicate
samples at the time that they received them.

              The extracts were used to prepare what we are calling simulated effluent samples.
It is not unlike what is done during PE studies from Cincinnati.  You concentrate the extract
down a little bit and mix it with a water miscible solvent, spike it into a liter of reagent water,
let it equilibrate, and then move on from there.

              Again, each lab received  two extracts.   The statisticians tell me that the study
design was an incomplete block.  We were trying to get a large variety of information out of a
single study, so we were looking at different concentration levels across  different laboratories.

              The extracts were shipped over a period of about four months as additional people
wanted to join in the study. Again, the troubles of shipping things overseas also slowed down
the process for us a little bit.

              There  were  some  alternatives to the use of concentrated extracts that  we did
considered at first,  but given the time frame and the relative budget for the project, it was not
something that was really feasible.   We would  have  had to have obtained large  volumes of
wastewaters that we knew contained dioxins and furans, divide them into replicate aliquots using
total suspended solids as a key to whether or not there was replication amongst the aliquots, and
then ship  them to over 20  laboratories in 6 countries.

              This really wasn't feasible at the time of the study. I am not sure it would be
feasible now, the biggest issue being not the homogeneity, but coming up with a matrix you
know has the analytes of interest at the levels you are really interested in testing.

              There were a significant number of quality assurance requirements associated with
the study.  The bulk of them come out  of the method.

              Each of the  samples, again, is spiked with the 15 topically labeled standards prior
to extraction.  That  is done prior to the  filtration  as  well so that there is some  partitioning
between the water and solid phase, certainly.

              There is the cleanup standard that is spiked at the completion of the extraction step
in order to track the efficiency of the various cleanup  steps.

              Each of the labs was  requested to run what the 1600 and 600  series the  EPA
methods traditionally call the "start-up  tests," or the  initial demonstration of capability; four
reagent water aliquots spiked with all 17 of the target analytes and then run through the entire
process. Each laboratory was expected to prepare and extract method blanks. There was a single
additional spiked reagent water aliquot that extracted with each group of samples, the so-called
ongoing precision recovery standard in these methods.


                                            52

-------
              There was as 5-point initial calibration and a single-point calibration verification
carried out at the frequencies described in the method.

              We had some data requirements we put on the laboratories.  We were originally
looking for information content, not the specific presentation.  Again, we were dealing with
laboratories that weren't used to dealing with this method or with EPA programs. We didn't want
to lock them into a specific set of paperwork.

              But we wanted to get information on the concentration of each analyte that was
detected, the recoveries of all the labeled standards, and then we wanted all the supporting raw
data, including the selected ion current profiles and the quantitation reports. We wanted to  see
exactly what the lab had done and how they had done it, the idea being that anyone with a little
bit of knowledge could go back and calculate the same result that the laboratory came up with,
and if we couldn't, we were going to contact the laboratory.

              We did receive data from a large number of the  laboratories.  Of the 22 that
originally agreed to participate, 19 submitted data by August of 1991.  Again, the study started
in February of '90. So, a year and a half later overall, we had received data from 19 laboratories.

              Some of the labs received samples as late as approximately almost August of 1990.
So, it was still  taking on the order of a year for some of these laboratories  to submit data.

              One lab finally submitted their data in June of 1992.  This was after six or seven
broken promises as to when it was going to get done. They were having some severe instrument
difficulties, and we said well, we would rather you ran it on an instrument that worked, but it
was taking an inordinately long time to get moved along.

              Two labs failed to submit any data at all, and this was somewhat troublesome,
given that we had sent them a significant volume of standards for the study.

              Of the 19 labs that submitted data by August of'91, 1 lab admitted that they failed
to be able to perform the method. They had some horrendous problems.  They were not able to
dedicate the time to going back and figuring out what they were. They did give us a fair number
of useful comments on the approach in general, but their data, by their own admission and by
our review, was not terribly useful.

              Two labs submitted only summary results, a cover page saying, you know, sample
number,  analyte  result.   No labeled compound recoveries that were  particularly useful and,
certainly, no raw data.

              That was a very difficult situation for us. We made numerous attempts to get the
data from both of those  laboratories.
                                           53

-------
              We reviewed these  data laboriously.  We looked at GC resolution, mass spec
signal-to-noise ratios, the labeled compound recoveries, retention times, ion abundance ratios, and
all the other method  specifications.  All of these review parameters  are  requirements of the
method.  This is the way that we typically review all data for Bill Telliard's program, but dioxin
data in particular, given the sensitivity.

              Where  we did not have anything but summary data, we could not review the
majority of these parameters. We could look at the concentrations they found for things, but that
was  about it.

              We did use  a fair amount of these data to develop information for the revised
method performance  specifications,  looking  particularly  at  initial  calibration, calibration
verification, and the initial  precision recovery, that is, the four spiked reagent water aliquots.

              Each of the  1600 series methods has a set of specifications  for the recovery and
the scatter, the standard deviation of the recoveries for the IPR tests. There is also a specification
for ongoing precision and  recovery analyses which are  conducted with each  batch of samples
extracted on a routine basis.

              The approach was to use algorithms that had been used previously to develop 95
percent confidence intervals for each performance measure.

              By May of  1991, we had collected enough data that we made a first attempt at
what we called the "interim method performance specifications" for the IPR/OPR, and calibration
verification.  The interim specifications were put together and sent out under a memo from Bill
Telliard asking  the laboratory  community that we deal with routinely for comment on these
specifications. They were  the reality test, if you will.

              A number of the laboratories had concern that the specifications were  what they
considered too restrictive.   The existing method specifications in the method that  had been
proposed and were sent out with the study were based on data from roughly  two, almost three
laboratories, a fair number of data from two labs  and a  small amount from the third  lab.

              Those numbers had always been viewed  as preliminary, and we were  hoping to
come up with specifications that were more rational from the standpoint of the analysis itself but
also allowed the laboratory some time to run samples instead of just running calibrations or check
standards.

              When the labs responded  with their concerns, we went back and looked at the
specific data again.  It became very quickly apparent that the data set was censored.

              Laboratories had attempted to meet the specifications in the original method. They
submitted the one set of results that seemed to pass.  We heard from a number of laboratories
                                            54

-------
that they had run some of these analyses several times in order to meet the specs.  They sent in
the one that worked, thinking that was what we were looking for.

              As a result, the censoring produced very little variability in the data. They were
trying to hit a preconceived target, and the confidence intervals, the method specifications,  are
derived on the basis of the variability that exists in the overall data set.

              So, we found that the performance specs were still considerably tighter than was
deemed reasonable by most people.

              At the 11th International Dioxin Symposium in Research Triangle Park two years
ago,  we sat down with the labs and talked about the problem.  They were  asked to submit any
additional data they generated during the course of the original study.  We did not want them
going out and generating new data outside of the context of what they had done; we simply
wanted the results that they said they had generated.

              Unfortunately, no additional data showed up.  Everybody said they had it,  but it
didn't appear in Bill's office or mine at any point.

              So, then we did what we really didn't want to do, which was sit down with  the
statisticians.  Generally, when you have to sit down with statisticians, you have to starting talking
in terms of things like root mean square deviations and things like that that most of us don't
understand as just dumb  old chemists.

              But we went through and figured out that the approach that we were going to use
in dealing with the censoring problems was to expand what is  called the quantile range so that
we were rejecting fewer  data as outliers.  Outlier tests were performed on the data set prior to
developing the method specs.

              The outlier tests make an assumption about how wide you want to go in terms of
your range of what you  will and won't consider outliers.  The tests that had been used had a
relatively narrow quantile range. We expanded that in a step-wise fashion and looked at the data
after each adjustment.

              We also expanded the confidence interval from  a 95 percent confidence interval
to a  99 percent confidence interval.  On a censored data set, we felt this was still a reasonable
approach.

              Again, every time we made an adjustment, we printed it out, one or two of us sat
down and looked at the data and said this looks like a reasonable approach.  We didn't throw  out
any data a priori and say "oh, that has got to be an outlier", but we looked and said "geez, you
don't have to expand the range very far and that one data point becomes an outlier, and these
three which looked reasonable to the naked eye were  still considered as part of the normal
population."

                                           55

-------
              We really couldn't do much with the data from the two labs that didn't submit any
raw data.  We really  were concerned about  using them on the basis of good  faith in the
laboratory.

              What we did was wherever those data fell within the range that was not considered
an outlier, we kept the data point in. But, if we came up with an outlier that was from one of
these laboratories where we could not substantiate the data, we made no further attempts to see
if it could be included.

              In the process of reviewing the hard copy data from the other laboratories, we did
come up with about three calculation errors, simple things like they forgot to multiply something
by 2, so the recovery was, in fact, twice what they thought it was originally.  In one case, a value
came well within the  specifications, and we confirmed the  correction with the laboratory and
documented all of that.

              The end result was we came up with a third revision of the method specifications
and, again, we circulated these through the same laboratory  community and some other people
within  the Agency, and  the answer came back that these numbers seemed  quite  reasonable.
There were  one or two  people who said, "well, I wish this number were 17.5, not 18,"  or
something like that, but by and large, they were considered a more reasonable approach to the
specifications.

              The third revision specifications are  currently being used by Bill's office in his
contracts with commercial laboratories,  and they will be formally incorporated into the next
revision of the method.

              In terms of evaluating the data  from the sample results, we had, three different
extracts.  The first one contained relatively few analytes, just the 2,3,7,8-TCDD and TCDF and
perhaps a little bit of octadioxin at low part per quadrillion concentrations.

              Yesterday, we were talking about mg/L of oil and grease. We are now down nine
orders of magnitude lower than that.

              The second extract had been fortified with most of the 2,3,7,8-substituted isomers
that weren't already present.  The concentrations ranged from 100 to  500  ppq.  And the third
extract was fortified such that it ended up in the 250 to 1000 ppq range.

              15 labs submitted data that were considered in the study  by the time we got done.
Actually, I think that number is closer to 19 now.

              Two labs had very large differences between the results that they didn't know were
blind dupes,  and we removed some of those from consideration after we went through the raw
data.
                                           56

-------
              Basically, we classified these as low, mid, and high concentration samples.  You
will see that in the transparencies Lynn is going to put up.

              There wasn't a large number of sample data points, so we didn't try to do outlier
tests on these data. Independent of the study, there was a single laboratory out at Bay St. Louis
that had done some analyses by a completely different procedure on the large volume extracts,
and we used those as reference values, not as absolute true values, but as a reference for what
the performance ought to be.

              These are the results for what we are calling the low part per quadrillion sample.
The only two  analytes really of concern are the 2,3,7,8-TCDD and TCDF.

              The mean concentration for the tetradioxin was 49.4; the RSD  was 26.2 percent.
The 2,3,7,8-TCDF mean concentration was 268; the RSD  was considerably tighter.

              There are different numbers of samples,  the N column on the end there.  The
tetrafuran requires what is called a second  column confirmation in most dioxin methods.  It is
not completely separated from all of the tetrafurans on a DB-5 GC column.  Several of the
laboratories did not perform that second column confirmation test, so we did not throw in their
unconfirmed results into this pile and use it for statistics.

              In the mid ppq sample, all 17 analytes were present.  The  mean concentrations
were within expectations. Again, we don't believe the reference concentrations are absolute true
values necessarily. They were simply two  analyses by a completely different method.

              If you look at the relative standard deviation column on the right there, the relative
standard deviations are, by and large, below 30 percent.  Most of them are also  below 25 percent.

              The worst case overall is the octafuran at the bottom of the slide.  The relative
standard deviation of that mean concentration is 45.5 percent.   This  is one of the two analytes
that is  not quantitated by  absolute  isotope dilution.  It is  quantitated against  the labeled
octadioxin.  The lack of a true isotope dilution  analysis here, we think, is evidence in the
variability in the data.

              The hexadioxin that is also quantitated against two other labeled standards is in
the middle there.  The RSD is 10.6, with an N of 9.  That falls much more closely in line with
the other data for the other hexadioxins, again, we believe, because that is quantitated against the
response of the other two labeled hexadioxins, so it tends  to correct there.

              The concentration range for the high sample was approximately 250 ppq to about
1000 ppq.  The agreement is quite good for things like the tetradioxin, with 18.8 RSD.  Again,
we had one lab that did not confirm the tetrafuran results, so the N there is smaller.
                                           57

-------
              The pentafaran results are quite tight, 6.8 percent relative standard deviation.  If
you get down to the octafuran,  again, you have a much larger standard deviation by and large.

              Again, this is, at most, four laboratories and eight samples.

              One of the concerns we had at the time the study was started was that most of the
labs had no direct experience with the method.  We had gone beyond the existing EPA contract
laboratory community to 22 labs in 6 different countries. Most of them were not familiar with
Method 1613, although they were all versed in high resolution dioxin-furan analysis.

              One of the problems with the international labs is they are not used to quite the
level of rigid reporting requirements that EPA requires even under  a program such as Bill's.
There is still that "trust me, we know what we are doing" attitude when you contact these people.

              The labs in this country have learned painfully that that is not the best approach,
certainly.  So, the U.S.  labs gave us more data and were more cooperative in providing it in a
format we could utilize, certainly, but they also have more experience with the programs  in
general.

              For the tetradioxin, the RSD of the mean concentrations for those three samples
generally decreases as the concentration increases. This is as you would expect.  As you get to
higher concentrations above the sensitivity limits of the method, you get more precise analyses.
This isn't unexpected.

              To a certain extent, this slide goes back to  an earlier run of the data, but it still
holds true here. For the tetrafuran, the RSD is lowest at the lowest concentration level.  We are
not sure if that is due  to the second column  confirmation requirement or  if it is an artifact  of
something else in the data.

              Again, there are also some concerns about octadioxin and octafuran and one of the
heptadioxins.  There was one lab  that seemed to have high levels of background contamination.
None of these results are background corrected either by the laboratory or by us, so we believe
that some of the scatter in that data may be due to the fact that they are having some background
contamination situations.

              This, again, is not uncommon at all with octadioxin or the octa and hepta furans.
Again,  the results for one of the hexadioxins, the one that is  not  done by absolute isotope
dilution, also seem to be skewed by the results from one laboratory that seemed to be a little bit
out, but again, we did not perform any outlier tests, because this was  a relatively small data set.

              Our first conclusion is you get what you pay for.  This is a volunteer study.  It
took, as you saw, two and a half years to get all the data  back.  If we had  paid for it, we
probably would have gotten it in a year and a half in  some cases.
                                           58

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              It is very difficult to  run  a study like this with anything other than volunteer
laboratories, because you then end up with people who are willing to do it for money,  and you
are not sure that they are really the only people you want to play with as well.

              We did go through and try to summarize some of the method performance out of
this data.  If you set a data quality objective of 30 percent accuracy, plus or minus 30 percent,
then, basically, half of the analytes in all three  samples met this criterion, looking at the  RSD
results. Most of them were well within in that, and, in fact,  more than half would be within the
window if you look at something other than the octadioxin  and octafuran results.

              Certainly, the two isomers of highest toxicological concern, the 2,3,7,8-TCDD and
TCDF, met this criterion and, in fact, are under 25 percent in the majority of these samples.

              Octadioxin contamination appears to be a problem across most labs, as we had
expected.  The octafuran and heptadioxin contamination are also a concern in some cases.

              If we were to  go back and pull out outliers, we believe that the picture would
improve in general. Again, we didn't do that for this, because we didn't feel there was quite a
large  enough  data set.  If we  get  statistically more sophisticated, we may be able to do
something.

              Since this study,  EPA has used this method on hundreds of other real-world
samples.   Many of you have heard about the study that was done in the past year and a half in
cooperation with the pulp and paper industry.

              There have been a lot of results that  have  come out of that study that  may
ultimately be used to  develop method performance specifications as well.

              We are not set in concrete in terms of what numbers are going to be out of this
study necessarily.  We want to pull together as much information as possible.

              There are some other issues involved in terms of this method in particular.  You
have probably heard,  if you were here last year, about the EMMC committee that Bill sits on,
the Environmental Methods Management Council, trying to consolidate EPA methods.

              Method 1613  is the choice of that group for an Agency high resolution dioxin
method. It will presumably supplant all other Agency high resolution dioxin methods with time.

              The Office of Drinking Water and Groundwater  has adopted  it as their  high
resolution dioxin method, as  opposed to their original proposal of a Method  513, which was
going to be a single analyte high resoution method.

              There are efforts underway to get together with the Office of Solid Waste and deal
with the differences between 1613 and 8290 so there can be a consolidated version there as  well.


                                           59

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              Also, Bill's office is looking at testing method performance in other matrices, this
again focused on water samples. We could go back and look at sludges from sewage treatment
facilities.  We could look at soils.  There is interest in looking at animal tissues and things like
that.

              I would like to thank you for your attention. If there are any questions, glad to
answer them.  Thank you.
                                           60

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                       QUESTION AND ANSWER SESSION
                                      MR. TELLIARD:  Any questions? Oh, oh, he has
got a note pad.

                                      MR. NEIN: I have three questions.

                                      MR. TELLIARD:  Would you state your name and
affiliation, please?
                                      MR. NEIN: Oh, I am sorry. John Nein. I am with
Chesapeake Paper Products Company.

             Have you looked at the results of this study compared with the round robin study
done Larry LaFleur at National Council and compared any of those results?

                                      MR. MCCARTY:  We don't have Larry's round
robin study that I know of.  Maybe I am wrong, Larry, and you can correct me, but we haven't
looked at it in any formal context.

                                      MR. NEIN: And when the method is promulgated,
how will the existing data generated by NCASI 551 be incorporated as far as a data base, or do
you anticipate doing that?

                                      MR. MCCARTY:  I don't know that any data from
551 are going to be incorporated at  all.  We certainly have been working with Larry and his
people on things like...

                                      MR. NEIN: The 104 ml study? Any of that data?

                                      MR. TELLIARD:  Yes.

                                      MR. MCCARTY:  Yes, the 104-ml study, some of
that.  Certainly, the variability study data is more likely to be used in developing the final method
for promulgation.

                                      MR. NEIN: I have also been told by some labs that
the 551 methodology is acceptable for  1613, that they are basically equivalent.  Do you agree
with that?

                                      MR. MCCARTY:  They are not equivalent. Larry
and I could get into a lengthy debate as to which works and which doesn't for certain matrices.
In some regions, it is my understanding  that individual discharge permit writers  have allowed the
                                        61

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use of 551, at least for the  time being.  I know Bill's office had endorsed the possibility of
Method 551 until the final method was promulgated.

             Once 1613 is promulgated, I don't know where that is going to stand.  That is
certainly a policy question.

                                        MR.  NEIN:  Thank you.

                                        MR.  HART:  Jerry Hart, VG Analytical.

             Is there going to be any further clarification in the protocol concerning the data
processing, particularly with regard  to the effect on things like smoothing  and background
subtraction and whether that is allowable  within the program?

                                        MR.  MCCARTY:  Bill and I have chatted  only
briefly since you and I talked at the Pittsburgh conference.  The final version of the method is
in the process of being written, if you will. It does contain a lot of improvements, clarifications,
simple language changes that came out of this study  as well as other work that has been done
in the past year or so.

             One of the issues that we are still talking about is how to handle the specifications
for  what data processing is allowable and what isn't.  The  traditional approach is to limit the
amount of manipulation, post-acquisition  manipulation, of the data to a great extent.

             Right now, my personal feeling is that we are going to come up with something
that is not probably going to please everybody, but it is at least going to give an indication of
how much smoothing is going to be considered  acceptable.

             The whole issue of background subtraction is something that we are going to have
to discuss at length.

                                        MR. HART: Additionally, is there going to be some
description regarding the calculations for  the diphenylether channels?

                                        MR. MCCARTY:    Yes,  the   whole issue  of
diphenylether interferences has been  strengthened in there, and there will be a considerably
greater focus  on  it in terms  of when  you find a signal  in  the  channel  for one  of the
diphenylethers, you cannot report that result as a positive result for the dioxin or furan without
doing further work.

                                        MR. HART:  Thank you.
                                           62

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                                        MR. TELLIARD:  While he is coming up, Harry
pointed out that this was a volunteer program and, therefore, saved the taxpayers a lot of dollars.
It only cost me $100,000 for standards.

              So, when some of those labs didn't send any data, their names are on a list.

                                        MR. MCCARTY:  We also specifically did not put
up the names of the people participating in the study so we didn't have to answer the question
of who are the two that didn't and who are the ones that didn't perform well.

                                        MR. WAGNER: My name is Bruce Wagner, and
I am with IT Corporation.

              Several questions. When do you estimate the final promulgation of 1613?

                                        MR. TELLIARD:  We are planning, due to the fact
that the pulp and paper industry is insisting on having their regulations proposed by the end of
the year or end of the summer, they are feeling very left out that they don't have any regs. So,
hopefully, the final promulgation would be close to that time period, in the October window.

              One of the issues that we have to resolve is whether we are going to have to re-
propose the method because of the changes resulting from this study, resulting from the activities
of the variability study, as it is titled, which was carried out last year with the  industry.

              Also, we are  going to include into the method a number of other options, for
example, solid phase extraction which was not in the proposed method. Also, the application of
the method will probably be proposed for fish tissue.

              It was also envisioned that we would propose the method for solid phase, for,
basically, OSW-SW846 type. Due to financial problems with our budgets, the Office of Solid
Waste hasn't been able to generate the data to do that.  So, that is still in question, but we will
probably propose it for domestic sewage sludge, fish tissue, and then, hopefully, go final on it
for aqueous samples.

                                        MR. WAGNER: Okay, you answered one  of my
other questions  about solid phase extraction.  However, the method you mentioned, 513,
specifically allows solid phase extraction for  drinking water.

              Is there any consideration of 1613 for, having made a comment about most of the
dioxins and furans being bound to the particular matter in aqueous samples, of doing away with
the separately extraction, just filtering and doing the Dean-Stark on the particulates, or are you
still going to  be requiring...
                                          63

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                           MR. MCCARTY:  We had talked about that at one point. In fact,
we had tried earlier on a novel extraction technique that had been developed at Dow where you
extracted the sample in the bottle and threw away the sample and the bottle after you took the
extract off.

             That didn't fly with most of the regulatory community. From my point of view,
I suspect we are still going to have to do something with the aqueous phase.

             Last year, Sarah Barkowski, who is sitting a couple rows in front of you, had
presented her work on solid phase extraction using the disk extractors, and as Bill said, that is
something that his office is looking at extensively.

             Whether or not that ends up in the version of the method that is promulgated first
off is a timing question, I think, as much as anything else.

             This method, in particular, is not likely to be static.  Bill is certainly anxious  to
improve it as time goes along, not  only in terms of use in the laboratory but also, even lower
sensitivity where people are concerned about it so we  can write nastier and nastier regs for
people who want to be regulated.

             But I think  you are going to see several iterations of this in the next couple  of
years, and these sorts of improvements will be included  as the time and the budget permit.

                                        MR. WAGNER:  One more question. Did any  of
the laboratories report trouble with achieving adequate separation for either the 2,3,7,8-TCDD
or the 2,3,7,8-TCDF?  In particular, there are references in the literature  about the 225 column
not being isomer-specific for the TCDF. Did any of the laboratories report that problem?

                                        MR. MCCARTY:   We  didn't have any  specific
reports of it.  Again, we did go back and look at that, the resolution checks in every case where
we got raw data, and by and large,  there were no specific problems with those.

             The method, in traditional EPA language, specifies DB-225 or equivalent.  I think
there was at least one lab  that used a different column.  So, we can use that as a judgment  of
how other columns are working, but we didn't have any specific problems with that in this study
at least.

                                        MR. WAGNER:  I have one more question. There
is a  section in 1613 as it is written now that if you have a peak that meets the signal-to-noise
criteria and it is in the retention time window but the IA  ratio does not meet that you have to  go
analyze that extract on a different column. Is that going to stay?

                                        MR MCCARTY:  Well, that was an approach to
making the labs do something when things didn't meet ion abundance ratio.


                                          64

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             For those of you who aren't intimately familiar with dioxin analysis, one of the
identification parameters, in addition to retention time information, is what is called the ion
abundance ratio.  You monitor two specific masses for each of the analytes you are looking at,
and the ratio of the two peaks produced by each analyte has to meet some method-specified QC
limit.

             The limit currently is plus or minus 15 percent of a theoretical ratio. That number,
as best as I have been able to determine in the past three years, was agreed upon at a meeting
somewhere because they needed a limit.

             We presented another paper at the meeting in Finland last year with an alternative
to that approach which is being considered for inclusion in the method along with several other
possibilities.

             But I believe  that the final method will  remove that,  from the laboratory's
standpoint, onerous burden of having to re-prep and reanalyze the sample.  I think what is going
to happen is there is going to be another approach  to clarifying when something is positively
identified in terms of ion abundance ratio.

             It is going to be a little bit of extra calculation, but it shouldn't be any extra
analytical work, but that is one of the things that is being  considered.  The decision rests, to a
certain extent, on Bill's head.

                                        MR. WAGNER:  Well, you have my vote to  drop
it. Thank you.

                                        MR. TELLIARD: Thanks. Sorry, I didn't see you.
As long as it is an easy one.

                                        MR. MCCARTY:  It is Sarah.  It is never easy.

                                        MS.   BARKOWSKI:   Sarah  Barkowski, Boise
Cascade.

             Could you describe the approach that you are using to looking at lower sensitivity?

                                        MR. TELLIARD:  Can't hear you, Sarah.

                                        MS.   BARKOWSKI:   Could  you describe the
approach that you are using for your investigation of a lower sensitivity or lower reporting limit,
whatever?

                                        MR. TELLIARD:  Lower detection limits?
                                          65

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                                        MR. MCCARTY:  Yes.

                                        MR. TELLIARD: We are getting beat up by various
and sundry groups who are looking at increasing the volume of the sample again.  You know,
if you put the Missouri River through your extraction setup, you will get a lower detection limit,
and that is basically what they are doing.

             Historically, what we have found is that you increase the sample volume, you also
increase the interferences.   Surprise, surprise.  But one of the issues down the road is we are
going to probably be asked as to what will this...and it is not going to be something we are going
to do overnight.

             You know,  in other words,  how far can you push this  methodology as far as
extraction is concerned to get to what level? Is it 1 part, is it 0.01, is it 0.001? We don't know.

             But it is one of the issues that we are  looking  at, because most of the public
meetings we have had on the pulp and paper study, one of the comments we are always getting
is, you know, Fred said he  can get to  0.02.  What the hell is wrong with you?

             So, in lieu of that, what we are looking at is as this method progresses...our first
effort is to  get the method finalized as it stands with a detection limit of 10 in water and 1 in
solids, that is, 10 parts per quadrillion and 1 part per trillion, and then move on and see what the
ruggedness of the method is.

             That is something, as Harry pointed out, this isn't going to be a fixed method. It
will probably evolve as new techniques come out, and that is  going to be dependent on how well
we can clean it up in the extraction procedures.

             So, we don't have a window yet to say it is going to  be 0.0006.

                                        MR. MCCARTY: Or how we are going to get there.

                                        MR. TELLIARD:  Right.

                                        MR. MCCARTY:  As Bill pointed out, one of the
issues is to get this method promulgated, because the existing method in Section 304(h) of the
Clean Water Act for monitoring is Method 613 which is specific only to the 2,3,7,8-TCDD, and
its best guess at sensitivity  is on the order of 2000 parts per quadrillion, 2 parts per trillion.

             To groups arguing we are not sensitive enough, we keep saying, "But if we don't
get this one in place, if we keep making  it a moving target, there isn't going to be anything that
is on the books and promulgated for formal monitoring."
                                           66

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             So, our first step at this point is to get this one done once and then go through,
maybe every couple of years there will be improvements that come along.

                                      MR. TELLIARD:  We don't know where we are at,
but we are working on it.  Thanks, Harry.
                                        67

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68

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ON
\o
       Results of the Inter laboratory
           Validation Study of
     USEPA Method 1613
           for the Analysis of
Tetra- through Octachlorinated
       Dioxins and Furans
        by Isotope Dilution GC/MS

          Harry B. McCarty
  Environmental and Health Sciences Group
 Science Applications International Corporation
          Falls Church, Virginia

           Lynn S. Riddick
          Sample Control Center
            Dyncorp/Viar, Inc.
           Alexandria, Virginia
                                          474J

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           Background

February 1990—U. S. Environmental
Protection Agency, Office of Water
Regulations and Standards (now the
Office of Science and Technology) began
interlaboratory validation study of
Method 1613.
Analysis of PCDDs and PCDFs by high
resolution gas chromatography/mass
spectrometry.
       Background (cont'd)

 International study, ultimately involving:
 - 22 laboratories,
 - in 6 countries.
 Purpose was to gather data to support
 the promulgation of Method 1613 for
 compliance monitoring under the
 authority of Section 304(h) of the Clean
 Water Act (CWA).
              70

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           Study Design

 Laboratories supplied with concentrated
 extracts derived from the extraction of
 large volumes of industrial wastewaters
 and sludges.
 Some extracts were fortified with
 additional analytes.
 Extracts were submitted to the laboratory
 as traditional single blind samples.
       Study Design (cont'd)

Extracts were used to prepare the
simulated effluent samples.
Each laboratory received two extracts.
The study design formed an incomplete
block diagram.
Extracts were shipped to laboratories over
a period of four months as additional
laboratories agreed to participate.
                  71

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     Alternative to Use of Extracts

Alternative to preparing simulated effluent samples
would have involved:
- Obtaining large homogeneous wastewater samples,
- Ensuring that they contained appropriate levels of
  PCDDs/PCDFs,
- Dividing them into replicate aliquots,
- Shipping them to over twenty laboratories in 6
  countries.
Given the difficulties associated with this alternative, the
use of simulated effluent samples was judged by USEPA
to be a suitable compromise for the purpose of the study.
   Quality Assurance Requirements
                of the Study

    In the process of analyzing the simulated effluent
    samples according to the protocol, the
    participating laboratories were required to:
    -  Spike 15 isotopically labeled standards into
       the samples prior to extraction
    -  Spike one additional standard into the extract
       before cleanup.
                  72

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 Quality Assurance Requirements
         of the Study (cont'd)

  Analysis of four reagent water aliquots spiked with
  the 17 2,3,7,8-substituted PCDDs/PCDFs and 15
  isotopically labeled standards
  Method blanks
  An additional spiked reagent water aliquot
  extracted with each group of samples
  Five point initial calibration
  Single point calibration verification.
          Data requirements

For each of the sample and quality control analyses,
the laboratories were to provide:
•  Concentration of each analyte detected.
•  Recoveries of each of the labeled standards.
•  All supporting raw data, including:
  - Selected ion current profiles,
  - Quantitation reports.
                       73

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              Data received

  Of 22 laboratories agreeing to participate:
  - 19 submitted data by August 1991
  - 1 laboratory submitted data in June 1992
  - 2 failed to submit any data at all.
  Of the 19 submissions received by August 1991:
  - 1 laboratory admitted they failed to be able to
    perform the method
  - 2 laboratories submitted only summary results,
    no raw data.
               Data Review
The data from each laboratory were thoroughly
reviewed, including the evaluation of:
•  Gas chromatographic resolution,
•  Mass spectral signal-to-noise ratios,
•  Labeled compound recoveries,
•  Retention times,
•  Ion abundance ratios
•  all other method specifications.
Summary data received for 2 laboratories could not
be reviewed in this fashion.
                  74

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            Data Evaluation

Data from calibration standards and quality control
samples were used to develop revised method
performance specifications for:
• Initial calibration,
• Calibration verification (VER),
• Initial precision and recovery (IPR), and
• Ongoing precision and recovery (OPR).
Results were processed using algorithms designed
to develop confidence intervals for each
performance measure.
       Data Evaluation (cont'd)


   AH data received and reviewed by USEPA by
   May 1991 were used to generate interim
   method performance specifications.
   Interim specifications were circulated among
   the  USEPA contract laboratory community for
   comment.
   Concern expressed that specifications were
   too  restrictive.
                      75

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      Data Evaluation (cont'd)


Apparent cause was censoring of the data set.
- Laboratories attempted to meet the specifications
  in original method
- Submitted one set of QC results
- Did not submit analyses which may have come
  close, but still outside specifications.
Censoring reduced variability in data, and narrowed
confidence intervals predicted for performance
measurements.
       Data Evaluation (cont'd)

Based on comments received at the 11th
International Dioxin Symposium, laboratories were
asked to submit any additional data generated during
the course of the original study.
When no additional data were received, two aspects
of the data evaluation algorithms were adjusted.
- Expanded quantile range to reject fewer data as
  outliers.
- Expanded confidence interval to 99% from 95%.
Adjustments were made in steps, with manual
review of the results each time.
                 76

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      Data Evaluation (cont'd)

When results from two laboratories that did not
submit raw data were within the revised
specifications, they were included in the database.
If they fell outside the variability exhibited by the
other laboratories, they were not included.
Third revision of the specifications circulated again,
and generally deemed reasonable.
Third revision specifications are  currently being
employed by Office of Science and Technology for
their contracts with commercial laboratories, and
will be formally incorporated into next revision of
the method.
      Sample Data Evaluation

 Data received from the laboratories represented
 three different sample extracts.
 - One sample contained relatively few analytes at
  low part per quadrillion concentrations.
 - The second extract was fortified with most of
  the 2,3,7,8-substituted isomers not already
  present, and had concentrations in the 100 to
  500 ppq range.
 - The third extract was fortified in the 250 to 1000
  ppq range.
                      77

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 Sample Data Evaluation (cont'd)

15 laboratories submitted sample data that were
considered in the study.
Of those, two laboratories had such large differences
between the two simulated samples that their data
were removed from consideration.
Remaining 13 laboratories represented:
- 5 low ppq samples
- 5 mid ppq samples
- 3 high ppq samples.
            Sample Results

For each analyte detected in each of the three sample
types (low, mid, high), the mean concentration and
relative standard deviation were calculated.
Given the small number of results for each analyte,
no attempt was made to determine outlier values or
to exclude them.
Independent of this study, a single laboratory
analyzed the large volume extracts before they were
divided into ampules and sealed. The results from
duplicate analyses by that laboratory were used as
reference values.
                 78

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Sample Results (cont'd)
Low ppq sample

Analyte
2378-TCDD
2378-TCDF


Reference
Cone.
60
300


Mean
Cone.
50.6
277.1


RSD
{%) N
27.0 10
10.2 10
MU,I>

M;H *-*.
2378-TCDO
2378-TCDF
12378-PeCOD
12378-PeCOF
23478-PeCOF
123678-HxCDO
123678-HxCDO
123789-HxCOD
123478-HxCOF
123678-HxCDF
123789-HxCDF
1234678-HpCOO
1234678-HpCOF
1234789-HpCOF
OCOD
OCDF
n«f«r*nc« Cone.
140
480
90
120
170
70
70
150
210
150
110
120
180
110
460
120
M«*n Cone.
111.1
427.7
71 A
100.0
158.4
72.6
72.6
207.4
195.6
155.9
86.4
197.0
146.3
104.3
2325.1
189.3
R8D <%) N
22.2 10
22.1 10
17.8 9
26.1 10
23.8 9
20.4 10
20.4 10
106.1 10
24.8 10
25.2 10
405 7
122.7 10
35.3 10
23.6 10
206.8 10
114,9 9
79

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        Analyt*
IMvrwic* Cone. Mean Cone.  MO (%)
                                           N
2378-TCOO
2378-TCOF
12378-PeCDO
12378-PeCOF
23478-PaCOF
123478-HxCDD
123678-HxCDD
123789-HxCOO
123478-HxCOF
123678-HxCOF
123789-HxCDF
1234678-HpCOO
1234678-HpCDF
1234789-HpCDF
OCOO
OCDF
270
800
250
320
480
240
240
250
600
430
310
240
500
310
700
320
243.3
651.8
192.3
274.0
425.7
175.9
175.9
167.6
507.4
161.7
129.5
203.4
356.3
287.6
734.6
235.1
18.8
26.6
39.3
32.0
26.2
39.9
41.2
49.7
422
403
128.1
42.4
44.3
32.0
38.1
51.7
8
a
7
7
7
8
8
8
8
8
5
8
8
7
8
8
*«Mu 1
       Sample Results (cont'd)

Fewer than one third of the laboratories participating
in the study had direct experience with Method 1613
prior to this study.
For 2,3,7,8-TCDD, the RSD of the results from all of
the laboratories decreases as the concentration
increases.
In contrast, for 2,3,7,8-TCDF,  the RSD is lowest at the
lowest concentration tested.
                  80

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     Sample Results (cont'd)


For the mid ppq sample type, the results for
1,2,3,4,6,7,8-HpCDD, OCDD and OCDF are highly
skewed by one laboratory where background
contamination appears to be a problem.
For the same sample, the 1,2,3,7,8,9-HxCDD
results are skewed by the results from one other
laboratory.
           Conclusions
 You get what you pay for.
                 81

-------
        Sample  Data Evaluation (cont'd)

•    19 laboratories submitted sample data that were
     considered in the study, representing:

          7 low ppq samples

          7 mid ppq samples

          5 high ppq samples

•    One of the two laboratories that did not submit any
     raw data had summary results for a high ppq
     sample which were markedly different from one
     another. Without raw data to evaluate,  these data
     were dropped from further consideration.
             Sample Results (cont'd)

Low ppq sample

              Reference     Mean     BSD
 Analyte        Cone.       Cone.      (%)     N

 2378-TCDD      60         49.4    26.2     14

 2378-TCDF     300        268.0     8.9     10
                    82

-------
Mid ppq sample

Reference
Analvte
2378-TCDD
2378-TCDF
12378-PeCDD
12378-PeCDF
23478-PeCDF
123478-HxCDD
123678-HxCDD
123789-HxCDD
1 23478-HxCDF
1 23678-HxCDF
123789-HxCDF
1234678-HpCDD
1234678-HpCDF
1234789-HpCDF
OCDD
OCDF
Cone.
140
480
90
120
170
70
70
150
210
150
110
120
180
110
460
120

Mean
Cone.
108.9
453.8
64.6
93.4
157.2
76.1
77.9
146.3
203.5
161.4
99.3
110.5
144.1
111.1
757.8
125.0

RSD
(%)
22.6
18.7
31.4
32.4
22.8
14.4
7.6
10.6
12.7
15.1
9.9
14.4
4.9
7.8
31.4
45.5


N
14
8
12
13
10
11
10
9
11
11
6
10
10
11
12
10
High ppq sample

Analyte
2378-TCDD
2378-TCDF
12378-PeCDD
1 2378-PeCDF
23478-PeCDF
1 23478-HxCDD
123678-HxCDD
123789-HxCDD
123478-HxCDF
123678-HxCDF
123789-HxCDF
1234678-HpCDD
1234678-HpCDF
1234789-HpCDF
OCDD
OCDF

Reference
Cone.
270
800
250
320
480
240
240
250
600
430
310
240
500
310
700
320

Mean
Cone.
243.3
588.7
192.3
306.3
466.5
175.9
175.9
167.6
507.4
401.3
243.8
203.4
356.3
322.3
734.6
235.1

RSD
(%)
18.8
25.6
39.3
6.8
6.8
39.9
41.2
49.7
42.3
49.7
48.4
42.4
44.3
4.2
38.1
51.7


N
8
6
8
6
6
8
8
8
8
8
6
8
8
6
8
8
83

-------
        Conclusions (cont'd)

 Accepting a data quality objective for accuracy of
 +/- 30%, half of the analytes in all three samples
 meet this criterion judged by either %RSD across
 all laboratories or as a percent bias from the
 reference data set.
 2,3,7,8-TCDD and 2,3,7,8-TCDF meet this criterion
 in all samples.
 OCDD contamination appears to be a problem
 across most laboratories, with lesser problems
 with OCDF and HpCDD
        Conclusions (cont'd)

If outlying values are removed from the data set, the
precision and bias improve for all analytes.
Since this study, USEPA has undertaken studies
where this method has been applied to hundreds of
real-world samples. Data from those studies are
being evaluated relative to method performance
issues as well.
                 84

-------
              Other Issues

In response to concern that there is a proliferation of
USEPA methods for environmental contaminants,
the Agency is evaluating the consolidation of
methods from various Program Offices.
Method 1613 is one method being considered for
such consolidation. Efforts are underway to
incorporate matrices from the Office of Solid Waste
Method 8290 into Method 1613, such that the
consolidated version of Method 1613 would replace
Method 8290.
Testing of method performance in other matrices will
benefit from the lessons learned in this study.
                        85

-------
86

-------
                                        MR. TELLIARD:  Staying with high resolution
GC/MS, Mr. Marti is going to talk about looking at coplanar PCBs. If you can't find dioxins,
you have got to have something to look for.
                                        MR. MARTI: Currently, there is no move by the
EPA to either develop or promulgate a method for coplanar PCBs.  Customer demand, on the
other hand, has forced the laboratories to develop their own method which is interesting, because
we are going to end up with different types of methods.

             This is one lab's adventure into the coplanar PCB analysis.

             I find it useful to define the  terms used in PCB analysis, because there isn't any
consistency used by many people. Congeners, when I use that term, I am speaking of any one
of the 209 possible PCB compounds. They are just similar in structure.

             I have shown on this slide the biphenyl rings showing the para, meta, and ortho-
positions, along with the numbering system  used for PCBs.  Those are positions that the chlorine
can be substituted.

             PCBs with the same number of chlorines are considered a homolog group.  So,
the mono PCBs are one homolog group, and  deca PCB which is one compound comprises the
entire homolog group.

             Coplanar, on the other hand, are chlorines in the substitution in at  least the 4,4'
position  as well  as  in at  least two  other  positions, either 3  or 5, such  that a 3,3',4,4'-
tetrachlorobiphenyl is a coplanar, or a 3,3',4,4',5,5'-hexachlorobiphenyl is considered coplanar.

             PCBs  with chlorines substituted in the 2 or the  6 position are considered
substituted  in the ortho positions.

             Isomer, refers to any of the tetra PCBs or penta PCBs within a homolog group,
compounds with the same molecular formula.

             There have been a lot of methods in the literature using BCD and low resolution
mass spectrometry (LRMS).  Doug Kuehl and his group at the EPA lab in Duluth developed a
method using carbon  column isolation similar to the dioxin analysis using isotope dilution, high
resolution GC/high resolution MS  (HRGC/HRMS) for the analysis of dioxins and the coplanar
PCBs.

             The advantages  of the technique, are the sensitivity, specificity, and, more
importantly, the data would be compatible  with the historical data base  for the national dioxin
study.
                                          87

-------
             The coplanar PCBs have the same mechanism of toxicity as 2,3,7,8-TCDD.  The
relative toxicity may be a lot less, but PCBs can be present in the environment in much higher
concentrations.  So, there is an interest in quantitating coplanar PCBs in environmental matrices.

             Our objective was to evaluate EPA-Duluth's method, and what we want to do is
report the total homolog PCBs along with the coplanar PCBs.

             PCB congeners 77, 126, 169, and 105 were the original four that the EPA Duluth
lab originally included in  their method.  There are three true coplanars and one mono-ortho
substituted PCB.  Customers have asked us to add two other mono-ortho substituted, congeners
118 and 156.

             There are several reasons why a special method is  required for coplanar PCB
analysis.  The problem is, unlike the dioxins, the PCB homolog groups overlap in retention times.
You have the hexas and the pentas  eluting with the tetras and so on.

             There are GC columns out there that you can have a 4-hour temperature program
and separate all 209 congeners, but not too many of our  customers have $5000 per sample to
spend for that type of analysis.

             What we want to have is a reasonable GC temperature program, about an hour,
in order to make it cost effective. This means that congener specificity by GC, by itself, is not
sufficient.

             Even using the high resolution mass spectrometer is not sufficient. What happens
is you have a hexa PCB that co-elutes with the 3,3',4,4'-tetra PCB, and  the fragmentation of the
hexa PCB is such that the loss of two chlorines will contribute to the exact mass of the tetra
PCB.   You need to have greater than 16,000 resolution  of the mass spectrometer in order to
separate the  masses.  The normal practical operating resolution is 10,000.

             Congener specificity by high resolution mass spectrometry is not possible for some
congeners.

             This leaves us with  very simple wet chemistry.  We do this by  using carbon
column fractoration to isolate the coplanar PCBs from the other non-coplanar PCBs.

             There is an extraction step (usually Soxhlet) that can use a variety of solvents.
Carbon column cleanup is then done which is similar to the dioxin cleanup of which one fraction
is collected for the dioxin and the other is collected for the PCBs. Recovery standards are added
and two  analyses are done, one for the coplanar PCBs  and one for the dioxin.

             Basically,  for  the carbon  column  cleanup, you elute several  solvents.   The
important part is that the EPA-Duluth method elutes with 27.5 ml of methylene chloride/benzene
in a 1:1 volume to volume to get the coplanar PCB fractions.

-------
             Now, right away, one would have to ask 27.5 ml seems pretty exact, and what we
decided to do was just to do some spiking experiments, just spike the coplanar PCBs onto this
column and see how well we can recover the coplanar  PCBs

             We are unable to recover the labeled internal standard hexa-PCB.  It is just not
present. The 3,3',4,4',5,5' was staying on the carbon column, and as you can imagine, the analyte
itself, of course, also didn't show up, although the mono-ortho substituted hexa did come through
the carbon column.  We were unable to quantitate it, because we lost the internal standard.  Just
looking at peak heights, we are estimating that the recovery was around 100 percent for the
mono-ortho substituted hexa, but we lost the coplanar hexa-PCB,

             We modified the method several ways.  We took additional fractions and did more
analyses, and after several replicates, we kept on getting these same results.

             So, what I did at this point was call Brian Butterworth at EPA saying, you know,
what  is going on here?  Am I not doing something correct?  Maybe something is not in the
method.

             He explained he was finding the same problems with reproducible results.  So, as
it turns out, EPA in Duluth has abandoned this method at this point and are looking at alternative
methods which kind of left me high and dry.

             Triangle Laboratories then decided to modify the method.  We decided that since
the dioxin carbon column cleanup is designed for coplanar compounds, it wouldn't discriminate
between a coplanar dioxin and a coplanar PCB.  We spiked in the coplanar mono-orthos along
with the labeled internal standards and,  lo and behold, we got good recoveries for all of the
compounds of interest.  We  then decided to do was do an experiment on an actual matrix.

             We went to the grocery store and bought some catfish, and we ground them up,
and we added all of our standards, internal, alternate and  surrogate  standards. We then did a
Soxhlet extraction with methylene chloride.

             We like to take out our percent lipid from the extract itself.  Then we simply split
the extract, one fraction just  going through our (what we call)  the Big Fish Column (acid celite)
and adding our recovery standards and simply doing the high resolution GC/high resolution MS
for the total homolog PCB.

             Since we want to see all the PCBs for the total homolog, we don't need any fancy
cleanups.  We just need to get rid of the lipid using the Big Fish Column.

             We took the other half of the extract and  did the carbon column cleanup, and then
analysis by high resolution GC/MS for the coplanar PCBs.
                                          89

-------
              Now, to do the dioxins, you can simply split the extract yet again for the dioxins,
or since they go through practically the same cleanups, use the same extract for the coplanar
PCBs and dioxin analyses.

              Each of the congener groups has one isomer that is used for calculating a response
factor. In order to  get a response factor for the total mono PCB we use the response factor from
the 2-monochlorobiphenyl analyte.

              In the case where there is a couple of tetras and  a couple of pentas, we average
the response factor for the two tetras to get a response factor for the entire homolog group.

              The results are  reported in nanograms.  I have not reported these in ppt.  It is a
25 gram sample size if you want to do the calculation.

              Well, interestingly enough, there are PCBs present in the store-bought catfish. The
blank was essentially clean, but what is interesting is if you look at  the distribution  of those
specific PCBs in the sample, they don't look like an Aroclor.  So, very likely, if these fish were
analyzed for PCBs for any sort  of State health concern which  are normally Aroclor methods,
these would be reported as not detect as Aroclors even though there are PCBs present.

              We  also did some Aroclor spikes previous to this experiment.  We spiked some
Aroclors and measured the recovery, and we got 85 to  105 percent recovery for the Aroclors just
looking at it by total homolog concentrations.

              Of course, what we are really interested in is how well the coplanars did, and if
you look down the percent recoveries, you will  see that the 2,2',5,5'-tetra PCB was essentially
removed from the carbon column as you would expect, since it is not coplanar, and we got good
recoveries of the coplanars of interest.

              It is interesting that the mono, di, and  tri also come through the carbon column
for good recoveries.

              What is interesting is that the 2,2'-substituted octa PCB had very good recoveries
through the carbon column cleanup as well as the diortho-substituted hepta which indicates that
the carbon column may not be all that congener  specific as we had hoped in that it seems to be
pretty selective in  the PCBs it lets through but not necessarily based on the ortho substitution.

              The octa which has a 2,2',6,6' substitution was not recovered, but the octa with just
the 2,2' substitution was recovered.  So, it indicates there is some variability here in the congener
specificity, and I think the carbon column is useful, but  I don't think  it demonstrates congener
specificity for the  coplanars and the mono-ortho substituted compounds.
                                            90

-------
              Conclusions.  Well, in talking with Brian Butterworth, it is  apparent that the
Duluth method is not rugged enough.  They had problems with reproducibility with the carbon
column and getting highly variable recoveries.

              Our method shows that you can do both the total homologs and the coplanar
PCBs, but the coplanar PCBs are reported as maximum concentrations.  I  do not think any
laboratory at this point can demonstrate congener specificity by this method.

              We  estimate our detection limits at this point  would be about  1 ppt based on
method detection limit studies.  That will be somewhat variable, depending  on  the specific
congener of interest.

              Future studies. Well, Duluth is very interested  in our work right now, they sent
us their reference  fish samples such that  we could compare  our results with  their results to
determine how well we are measuring the  coplanar PCBs.

              The other issue still remains, though, and it is a question that I can't answer today,
how are we going to demonstrate congener specificity, or are we even interested in doing that?
Maybe maximum concentrations are sufficient for what we want to do.

              But if we are interested in doing congener specific analysis, we can do some things
like using carbon-labeled close eluters or try and operate your high resolution mass spectrometer
at 20,000 which may be conceivable with today's new high resolution equipment, but neither one
of these are really practical solutions at this point.

              There is one more elegant way of doing it is that we can look at the M-l,  M-2
from the molecular ion cluster to see if there is contribution from a higher homolog group into
the specific isomers we are looking at, and we have done some preliminary experiments that look
very good and that we can at  least tell  if there is  a higher homolog interfering with the
quantitation of the coplanar PCB of interest.

              So, in conclusion, the question remains,  is congener specificity important for this
analysis?  And I have got a feeling that there are going to be different answers depending on who
you talk to, but this is the state  of the art as it stands.

              I think it is a concern that we resolve this issue, because we are  already starting
to accumulate  a historical data base on coplanar PCBs, and it would be nice to  be  able to have
some data that is being generated now that is going to be comparable five years from now.
                                           91

-------
                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD:  Questions? Microphones?

             There is a PCS seminar being held next week in Washington by the Office of
Water, primarily looking at PCB, coplanar congener PCBs in tissue. The subject of this talk will
be the subject of two days of hand wringing. For those of you who are going to attend, it looks
like the party afterwards is supposed to be pretty good.

             But are there any questions?
(No response.)

                                       MR. TELLIARD:  Thank you very much for your
attention.  It is break time. There will be coffee outside.  Get your coffee and strawberry and
get back in here so we can stay on schedule.

             Oh, we have a question. I am sorry.

                                       MR. MITZEL:  Robert Mitzel from ALTA.

             When you  did  the coplanars and the  dioxin furans, we  have noticed  on the
dioxin/furan analysis you are required to run  essentially on  three columns because of the
interference with the penta dioxin C13  labeled isomer.  Did you guys find that same problem?

                                       MR. MARTI:  We haven't done the experiment yet,
but you are correct. I think what we will have to do is probably take the coplanar PCB fraction
and run it back through additional cleanups for the dioxin at this point, unless we separate the
extract, you know, split it into thirds and just pull  it through the entire thing by itself.

             It really depends on the detection limit requirements.

                                       MR. MITZEL:  Right.

                                       MR. TELLIARD:  Okay, thank you very much.
(WHEREUPON, a brief recess was taken.)
                                         92

-------
    Determination of Coplanar
               and
       Total Homolog PCBs
                by
           HRGC/HRMS
u>
        E.A. Marti, G.D. Marbury,
       N.L Bragg and B.P. Rueda
     Triangle Laboratories of RTP, Inc.
          801 Capitola Drive
          Durham, NC 27713

-------
            Definition of Terms |
         PCBs: Polychlorinated Biphenyls
                         3    ">     V  3'
                  m
Congeners:
  PCBs are composed of 209 congeners. Similar
  in structure with different levels of chlorination.

Homologs:
  PCBs with the same number of chlorines. The
  mono through deca PCBs represent 10
  homolog groups.

-------
            Definition of Terms |
         PCBs: Polychlorinated Biphenyls


Isomer:
  Any PCB compound with same molecular
  formula. All tetra-PCBs are isomers.


Coplanar:
  Compound is dimensionally flat. Substitutions
  in both para (4,4') plus at least two meta
  positions (3 or 5) but no ortho (2J2',6,6').

-------
                   Introduction]
OS
There are many methods of analysis for coplanar
PCBs including various extraction techniques and
modes of analysis (e.g., GC-ECD and LRMS). Kuehl
et. al. uses carbon column isolation with isotope
dilution HRGC/HRMS for the analysis of dioxins and
coplanar PCBs. The advantages of this technique
are sensitivity, specificity and compatible data to
the U.S. EPA National Dioxin Study.

-------
              Introduction
Coplanar PCBs are shown to have the same
mechanism of toxicity (receptor-mediated) as
2,3,7,8-TCDD. The relative toxicity of coplanar
PCBs compared to TCDD may be 10 to 1000
times less but PCBs can be found in much higher
concentrations in the environment.

-------
                 Objective]
CO
Evaluate and develop method for the analysis
of coplanar PCBs using Kuehl et. al. methodology,
The analysis will report total homolog PCB,
congener specific coplanar and mono-ortho
PCBs and dioxin.

-------
            Objective
Coplanar:
          3,3',4,4'- Tetra-CB (#77)
          3,3',4,4',5- Penta-CB (#126)
          3,3',4,4',5,5'- Hexa-CB (#169)
Mono-Ortho:
         2,3,3')4,4'- Penta-CB (#105)
         2,3',4,4',5- Penta-CB (#118)*
         2,3,3',4,4',5- Hexa-CB (#156)*

          * Added by TL-RTP

-------
Why Go Through All This Trouble?
O Unlike dioxins, the PCB homolog groups
  overlap in retention times (e.g.,
'  2,2',3,3',6,6' hexa-CB and 2,3,3',4',6
  penta-CB coelute with 3,3',4,4' tetra-CB).
  Congener specificity by GC resolution is
  not practical.

-------
Why Go Through All This Trouble?
  Even using high resolution mass
  spectrometry, the M+2 ion from the loss
  of two chlorines from the hexa-CB has an
  exact mass of 289.9038. The exact mass
  of the tetra-CB is 289.9223. A mass
  resolution of 16,000 would be needed to
  separate the two. Congener specificity
  by mass spectrometry is not possible.

-------
Why Go Through All This Trouble?
  Separation of coplanar PCBs from
  noncoplanars is possible by carbon
  column fractionation.

-------
         Duluth Method Summary |
                    Sample
                Spike ISC-labeled
               Dioxin/PCB Standards
o
U)
                       I
Extraction
                       I
                 Carbon Column
                    Cleanup
                  Spike Recovery
                    Standards
                Analyze for Coplanar
                PCBs by HRGC/HRMS
                                     Dioxin Fraction

-------
     Duluth Method Clean-Up |
350 milligrams (mg) of 10% carbon
(AX-21) / 90% silica gel (60 mesh)
Load sample extracts (0.5 mL volume in
hexane) onto column, rinsing with two
0.5 mL hexane washes
Rinse column with 18 mL hexane, discard

-------
    Duluth Method Clean-Up
Elute column with 27.5 ml of methylene
chloride/benzene (1:1, vol:vol)
(Coplanar Fraction)
Reverse column, elute with 25 ml
toluene (Dioxin Fraction)

-------

High Resolution Coplanar PCB Recovery
Duluth Method



1. Unlabled Analytes:
a.S'.-M'-tetraCB (#77)
2,3',4,4',5-pentaCB (#118)
2,3,3'I414'-pentaCB (#105)
3,3',4,4',5-pentaCB (#126)
2,3,3',4,4',5-hexaCB (#156)
3,3',4,4',5,5'-hexaCB (#169)
ii 13C)2-Labeled Internal Standards
13C- 3,3',4,4'- tetraCB
13C- 3,3',4,4',5- pentaCB
13C- 3,3',4,4',5>5'- hexaCB
Ave
Found
(ng)
ion
i y.u
46.5
40.4
18.9
NQ*
ND
•• M jf^
14.0
7.5
ND
Spike
Level
(ng)
9n n
4&u.u
20.0
20.0
20.0
20.0
20.0

10.0
10.0
10.0

Ave
% Rec.
OK
j*j
232
202
94
NA
NA

140
75
NA


RSD
0 9
w« 7
12.6
14.8
1.7
NA
NA




* NQ= Not quantitated due to loss of IS during cleanup
ND= Not detected





-------
 High Resolution Coplanar PCB Recovery
                 Duluth Method
                                 Ave   Spike
                                 Found  Level   Ave
                                 (ng)   (ng)  % Rec.   RSD

  13CI2- Labeled Alternate Standards:

  nC-2,2'A,4',5,5'- hexaCB           N/A  10.0  N/A



IV. 13C,2- Labeled Surrogate Standards:

  "C- 3,3',S,S'- tetraCB              12.2  10.0   122

  I3C- 2,2',4I5,5'- pentaCB            2.6  10.0   26

  I3C- 2I2'3,4,4'I5- hexaCB            4.5  10.0   45

-------
o
oo
High Resolution Coplanar PCB Recovery
Triangle Laboratories of RTF Method
1. Unlabled Analytes:
S.S'A^-tetraCB (#77)
2,3',4,4',5-pentaCB (#118)
2,3,3>I4,4'-pentaCB (#105)
3,3',4,4',5-pentaCB (#126)
2,3,3',4,4',5-hexaCB (#156)
3,yA,4',5,5'-hexaCQ (#169)
II. 13C12-Labeled Internal Standards
13C- 3,3',4,4'- tetraCB
I3C- 3,y,4A'£- pentaCB
I3C- 3,3',4,4',5,5'- hexaCB
Ave
Found
(ng)
20.2
17.4
17.8
19.6
19.7
20.1
5.9
6.3
5.1
Spike
Level
(ng)
20.0
20.0
20.0
20.0
20.0
20.0
10.0
10.0
10.0
Ave
% Rec.
101
87
89
98
99
101
59
63
51
RSD
2.4
2.3
2.8
3.3.
4.3s
3.7

-------
           Triangle  Laboratories of RTP
                         PCB Method
    25 grams
  tissue sample
  Spike with:
  25 ng CoPCB-IS
  25 ng CoPCB-AS
  25 ng CoPCB-SS
  Soxhlet extract
 with MeCI2l 16hrs
Concentrate extract
    to 25 mL
       t
    1
  5.0 mL for
Percent Liptd
Determination
     I
  lO.OmLfor
HR-PCB Analysis
(Total Homolog)
                                          I
               Acid Ceiite column
                   clean up
                                      Final extract
                                     volume 100 i
                     I
                                  Spike with HR-PCB
                                  Recovery Standards
                                  13C- 2,2',5>5'- Tetra
                                  13C- 2,2',3,3',4>4'- Hexa
                     I
              Analyze HRGC/HRMS
              for total Homolog PCB
       1
    lO.OmLfor
  Co-PCB Analysis
(6 Specific Congeners)
                                          I
                    Acid Ceiite column
                       clean up
                                          I
                                  Modified Carbon/Silica
                                   Gel column clean up
                                                               I
                                      Final extract
                                     volume
                          I
                                  Spike with HR-PCB
                                  Recovery Standards
                                  13C- 2,2',5,5>- Tetra
                                  13C- 2,2',3,3',4,4'- Hexa
                          I
                   Analyze HRGC/HRMS
                    for Coplanar PCB

-------
    Triangle Laboratories of RTP
         Method Clean-Up
O 350 milligrams (mg) of 10% carbon (AX-21)
   / 90% silica gel (60 mesh)

O Load sample extracts (0.5 mL volume
  in hexane) onto column, rinsing with two
  0.5 mL hexane washes

O Rinse column with 18 mL hexane, discard

O Reverse column, elute with 25 mL toluene
  (coplanar PCB and dioxin fraction)

-------
Unlabele<
andT<
2-monoCI
4,4'-diCB
2)4,4'-triCI
2,2')5,5'-t€
3,3',4,4'-te
2,3>,4,4',5-
2,3,3',4,4'-
High Resoiutioi
PCB Analysis Sumr
Total Homolog Anc
d Analytes Ave spike
~*~i. Found Level
3TCIIS (ng) (ng)
3 22.5 25.0
26.4 25.0
3 27.8 25.0
rfraCB 48.2 50.0
traCB (#77) 48.9 50.0
pentaCB(#118) 52.9 50.0
pentaCB(#105) 51.0 50.0
1
nary
slysis
••••••
Ave
% Rec.
90.0
105.6
111.2
96.4
97.8
105.8
102.0
•••••
RSD
3.4
5.1
4.4
10.6
4.3
5.0
4.8
Catfish
Blank
Level, ng
ND
1.3
2.4
1.8
0.14
2.7
0.89

-------
1. Unlabeled
and To
3,3',4,4',5-pen
2,3,3',4,4',5-hc
S.S'A^.S.S'-h*
2,2'I3I4I4',5,5'-
2,2'I3,3',414'I5)
2I2'I3I3'I4>4',5,
2,2'I3,3'14I4'I5,
High Resolutioi
PCB Analysis Sumr
Total Homolog An<
Anfllvtp<5 ^ve Spike
• »• iv*i j IN^W Found Levsl
talS (ng) (ng)
taCB(#126) 50.1 50.0
>xaCB(#156) **41.0 50.0
exaCB (#169) **48.2 50.0
heptaCB 68.4 75.0
5'-octaCB 77.6 75.0
5',6-nonaCB 133.0 125.0
5',6,6'-decaCB 117.0 125.0
1
nary
^lysis
••••••
Ave
% Rec.
100.2
82.0
96.4
91.2
103.5
106.4
93.6
••i
RSt
>
5.4
13.6
6.0
4.7
7.5
6.5
2.8
Catfish
Blank
Level, ng
*0.002
HD
NO
1.8
*0.01
0.27
0.25
**
(EMPC)
HexaCB values from 1:25 dilutions, required due to Ql

-------

High Resolution
Coplanar PCB Analysis
1. Unlabeled Analytes
and Totals
2-monoCB
4,4'-diCB
2,4,4'-triCB
2,2')5,5>-tetraCB
3,3',4,4'-tetraCB (#77)
2,3',4,4',5-pentaCB (#118)
2)3,3',4,4'-pentaCB (#105)
Ave'
Found
(ng)
23.1
24.8
26.5
2.1
47.7
45.7
46.3
Spike
Level
(ng)
25.0
25.0
25.0
50.0
50.0
50.0
50.0

Ave
% Rec.
92.4
99.2
106.0
4.2
95.4
91.4
92.6
RSD
4.2
4.9
5.1
52.5
0.75
4.3
2.2
Catfish
Blank
Level, na
*0.006
1.3
2.5
0.33
ND
2.5
0.77
EMPC

-------

High Resolution
Coplanar PCB Analysis
1. Unlabeled Analytes
and Totals
3,3',4,4',5-pentaCB (#126)
2,3,3',4,4',5-hexaCB (#156)
2!2'i3A4'!5,5'-heptaCB
2,2',3,3',4I4',5I5'-octaCB
2,2',3,3>,4,4',5,5I)6-nonaCB
2I2'I3,3',4,4',5I5',6I6I-decaCB
Found
48.2
45.4
50.1
76.9
72.5
5.1
ND
Spike
Level
(ng)
50.0
50.0
50.0
75.0
75.0
125.0
125.0

Ave
% Rec.
96.4
90.8
100.2
102.5
96.7
4.1
NA
RSD
2.5
3.4
0.88
2.2
3.6
62.7
NA
 Catfish
 Blank
Level, ng

  ND
 0.25
  ND
  2.0
  ND
  ND
  ND

-------
High Resolution PCB Recovery Summary
Coplanar PCB Analysis
'3C12-Labeled Internal Standards
13C-4-monoCB
I3C-4,4'-diCB
13C-2,4,4'-triCB
"C-3,3',4,4'- tetraCB
1SC-3,3P,4,4',5- pentaCB
nC-3,3'AA,S,5'- hexaCB
nC-2,2',3,4A',5,5'-hetfaCZ
]3C-2,2',3,yAA',5,$'-oc\aCB
'iC-2,2',313l,4I4l,5,5I,6,6I-decaCB
Ave
% Rec.
76.5
72.2
76.8
82.0
83.7
81.4
71.5
79.7
ND
%
RSD
10.6
10.5
8.3
14.8
15.9
20.0
18.0
21.5
NA

-------
  High Resolution PCB Analysis Summary
            Coplanar PCB Analysis
13

13
 C-2,2'I3>3'I5>5',6,6'-octaCB
                                  Ave

I3C12-Labeled Alternate Standards        °/0 Rec'
'3C-2)2',4)4')5(5'-hexaCB              546        29.2
 C12-Labeled Surrogate Standards
3C-3,3f,5,5J-totraCB                   AH o
l3C-2,2',4(5,5'-pentaCB                 '

-------
           Conclusions
 1. The Duluth Method is not rugged enough
 for environmental matrices. EPA- Duluth
 looking at alternatives.

 2. TL-RTP method works for the analysis
 of total homolog PCB and coplanar PCBs
 (as maximum concentrations).  Dioxin analysis
 can be done from the coplanar PCB extract.
3. Coplanar PCB detection limits around 1 ppt,
MDL study underway.

-------
           Future Studies I
  Evaluate Triangle Labs of RTP method using
  reference fish samples from U.S. EPA
  Duluth Laboratory.
oo
  Demonstrate congener specificity by:
     1. Carbon labeled close eluters
     2. HRMS resolution of 20,000

-------
                Reference]
Kuehl, D.W., B.C. Butterworth, J. Libal and P. Marquis,
"An Isotope Dilution High Resolution Gas
Chromatographic High Resolution Mass
Spectrometric Method for the Determination of
Coplanar PCBs: Application to Fish and
Marine Mammals." Chemosphere, Vol. 22, Nos 9-10,
pp 849-858. 1991.

-------
               TRIANGLE LABORATORIES OF RTF, INC
TL-RTP Project: 91085E
Client Sample:   CoPCB IPA #5
Polychlonnated Biphenyls Analysis
          Analysis File:  X930928
Sample Matrix:
Client Project:
TLRTPID:
Sample Size:
Dry Weight:
CATHSH
COPL PCB
IPA #5
25.020 g
n/a
Date Received:
Date Extracted:
Date Analyzed:
Dilution Factor:
Blank File:
Analyst:
II
04/14/93
04/22/93
n/a
X930880
WG
Spike File:
ICAL:
CONCAL:
GC Column:
% Lipid:
% Solids:
SPPCBO25
XPC4213
X930923
DB-5
6.9
n/a
["specific AnaJytes
\< :•;*$'*•*, ;.*f:%K::x:w :.--.* •• *
2-MonoCB
4,4'-DiCB
2,4,4'-TriCB
2,2',5,5'-TetraCB
S.S'^^'-TetraCB (#77)
2,3',4,4',5-PentaCB(#118)
2,3,3',4,4'-PentaCB (#105)
3,3',4,4',5-PentaCB (#126)
2,3,3',4,4',5-HexaCB (#156)
3,3',4,4',5,5'-HexaCB (#169)
2,2',3,4,4',5,5'-HeptaCB
2,Tt3,yAA',5,5'-OctnCB
2,2',3(3',4,4>,5,5>,6-NonaCB
2,2',3,3',4,4',5>5')6,6'-DecaCB
Total MonoCB
Total DiCB
Total TriCB
Total TetraCB
Total PentaCB
Total HexaCB
Total HeptaCB
Total OctaCB
Total NonaCB
Ami (ng )
23.7
23.7
25.4
2.7
47.4
44.9
46.5
48.0
45.1
50.1
75.6
71.4
7.1
ND
24.9
26.1
30.0
65.4
147
106
77.0
71.4
7.1
DL ;,, EMPC - Rati?. y':^
3.19
1.52
1.00
0.76
0.71
0.56
0.55
0.56
1.20
1.22
1.03
0.88
0.77
0.001
3.08
26.2 1.55
30.1 1.00
65.6 0.75
148 0.58
107 1.22
1.01
0.88
0.77
• - ;';4: = • -FnV :^'j':v.-:"Ffag5.>.,;
12:57 	
19:32 	
21:38 	
23:15 	
29:14 	
30:27 	
31:44 	
33:14 	
35:11 	
36:55 	
35:56 	
40:09 	
41:50 	
—

	
	
	
	
	
	
	
	
                                     Page 1 of 2
                      PCBO.PSR v:I.OO. LARS 5 06o2
Triangle Laboratories of RTF, Inc.
801 Capitola Drive • Durham, North Carolina 27713
Phone: (919) 544-5729 • Fax: (919) 544-5491
                                         120
                   Printed: 14:02 04/27/93

-------
                  TRIANGLE LABORATORIES OF RTF, INC
TL-RTP Project: 91085E
Client Sample:   CoPCB IPA #5
                                                    Polychlonnated Biphenyls Analysi
                                                                Analysis File:    X93092!
^^:«w«te^^%,.j: -^w;
13Cs-4-MonoCB
iJC,2-4,4'-DiCB
13C12-2,4,4'-TriCB
"Cu-S.S'^'-TetraCB
13Ci2-3,3' ,4,4' ,5-PentaCB
13Ci2-3,3',4,4',5,5'-HexaCB
13C12-2,2>,3,4,4',5,5'-HeptaCB
13CI2-2,2',3,3',4,4',5,5'-OctaCB
ftj»t:{«gjj
21.4
20.0
21.6
22.1
22.7
20.4
18.2
19.1
':?&v'% Recoveiy :; •:•'••/
85.6
79.8
86.3
88.4
91.0
81.5
72.9
76.3
y y •-,/'.--.- -Ratio yy
3.23
1.55
1.04
0.79
0.63
1.27
1.03
0.89
'V '£**•:;:
14:38
19:32
21:37
29:14
33:14
36:54
35:55
40:08
K Flags ; •

	





	
l3Ci2-2>2',3,3',4,4',5,5',6,6'-DecaCB   Interference
           andards {iype 8)
                                            Reisavery •
                                       ] Flags
I3C,2-3,3',5,5'-TetraCB
13Ci2-2,2'.4,5,5'-PentaCB
lsCn-2,2',3,3',5,5',6,6'-OctaCB
                              22.5
                               9.8
                               8.1
                            Interference
89.9
39.3
32.5
0.77
0.63
1.28
26:14
27:26
32:48
                                                                                     Flags:
I3Cn-2,2',4,4>,5,5>-HexaCB
                              16.6
66.5
1.30
31:29
                      Data Reviewer
                                                               04/27/93
                                          Page 2 of 2
                                                                             PC8O..PSR v: 1.00. LARS 5.06 33.
Triangle Laboratories of RTF, Inc.
801 Capitola Drive • Durham, North Carolina 27713
Phone: (919) 544-5729 • Fax: (919) 544-5491
                                                                          Printed: 14:02 04/27/93
                                       121

-------
               TRIANGLE LABORATORIES OF RTF, INC
TL-RTP Project: 91085E
Client Sample:  CoPCB IPA #5
     Polychlorinated Biphenyls Analysis
               Analysis File:   X930928
Sample Matrix:
Client Project:
TLRTP ID:
Sample Size:
Dry Weight:
CATFISH
COPL PCB
IPA #5
25.020 g
n/a
Date Received:
Date Extracted:
Date Analyzed:
Dilution Factor:
Blank File:
Analyst:
II
04/14/93
04/22793
n/a
X930880
WG
Spike File:
ICAL:
CONCAL:
GC Column:
% Lipid:
% Solids:
SPPCBO25
XPC4213
X930923
DB-5
6.9
n/a
Specific Ahaiyte* , «
3,3',4,4'-TetraCB (#77)
2,3'>4,4',5-PentaCB(#118)
3,3',4,4',5-PentaCB (#126)
2,3,3',4,4',5-HexaCB (#156)
3,3')4,4',5,5'-HexaCB (#169)
IntefhaT SlarjdardS:
''drS.S'.M'-TetraCB
13C12-3>3',4,4',5-PentaCB
13C12-3,3',4,4',5,5'-HexaCB
Samite Siahdards (Type B)
!3Ci2-3,3',5,5'-TetiaCB
I3C12-2,2',4,5,5'-PentaCB
3C12-2,2', 3,4,4' ,5-HexaCB
Amt (ng)
47.4
44.9
46.5
48.0
45.1
50.1
AmL(ng)
22.1
22.7
20.4
AmL{ng)
22.5
9.8
8.1
DL ;;-v[-:4;^awPC '.;:

.. -%^cw%yj!;,^ =;.'•;.
88.4
91.0
81.5
.% Recovery..;: _..'• •.. • :: ",.•:.
89.9
39.3
32.5
;. : Ratio
0.71
0.56
0.55
0.56
1.20
1.22
— v Ratio
0.79
0.63
1.27
\^\- Ratio
0.77
0.63
1.28
RT Flags
29:14 	
30:27 	
31:44 	
33:14 	
35:11 	
36:55 	
RT .Flags"
29:14 	
33:14 	
36:54 	
RT • Flags: ;
26:14 	
27:26 	
32:48 	
/Alternate Standard (Typ*8) AmUfns) : *>% R^i^i^x:;;^ : .. RT :::f-:( • ••FJagsg|
13C12-Z2',4,4',5,5'-HexaCB
16.6
66.5
1.30
31:29 	
                                                                   PCBO_PSR v: 1.00. LARS 5.06 ja
Triangle Laboratories of RTP, Inc.
801 Caphola Drive • Durham, North Carolina 27713
Phone: (919) 544-5729 • Fax: (919) 544-5491
122
                        Printed: 13:5604/27/93

-------
                                        MR. TELLIARD: The next session is going to deal
with a thing warm to our hearts which is detection limits, level  of quantitation, level  of
enforcement, and, of course, the reliable imprisonment level which is a number that the Agency
is developing to make sure that no one escapes their wrath.

             Our first speaker this morning is Jim Rice. Jim has been coming to these meetings
when we used to fight, old meetings. He was at the first one and has been coming every year
since, and he is going to keep coming, he says, until we get this right.

             So, I  would like to  have Jim address you on detection limits and compliance.
                                          123

-------
124

-------
               Compliance Monitoring Detection and Quantitation Levels

                                          By

                                     James K. Rice
                                Raymond F. Maddalone
                                  Ben C. Edmondson
                                     Babu R. Nott
                                    Judith W. Scott


There are many uses of detection and quantitation levels, for example, instrument evaluation,

laboratory quality control, laboratory certification and compliance monitoring.  The problem

for the chemist, and particularly the non-chemist, is that current definitions in general do not

specify their intended use and consequently are applied inappropriately.  For example, there

should be a fundamental distinction made between measurement limits that are developed for

quality control purposes in a single lab  and measurement levels that apply to compliance

monitoring.  Quality control measurement limits are used by  single laboratories to ensure that

a particular analytical procedure is in control at a particular time.  In  compliance monitoring,

measurements are made,  often over an  extended period and by  different laboratories, to

determine if enforceable standards (e.g., National Pollutant Discharge Elimination System

(NPDES) permit limits under the Clean Water Act) are being attained. The compliance

measurement level needs to reflect the greater variability inherent in this situation, as

compared to the intra-lab Quality Assurance/Quality Control  (QA/QC) situation.



In this paper, we present definitions that we have developed for a Compliance Monitoring

Detection Level (CMDL) and a Compliance Monitoring Quantitation Level (CMQL) that

properly  take into account the analytical variability associated with compliance monitoring
                                          125
                        Copyright VJ 1993 Electric Power Research Institute

-------
situations (1).  CMDLs and CMQLs derived from interlaboratory standard deviation are




shown for several analytes, along with comparisons with detection and quantitation levels




derived employing alternative definitions.








Background




Definitions for the detection limit abound.  Over the years chemists have used "2-sigma" and




"3-sigma" detection limits without precise definition or meaning.  The United States




Environmental Protection Agency (USEPA) continued this practice when they published




detection limits (DL) without definition in the Methods of Chemical Analysis of




Water and Wastes (MCAW) (2).  Unfortunately, these limits are widely used in the




regulatory environment, where they were neither intended  nor appropriate, and because




levels specific to compliance monitoring had not been  introduced (3,4,5).








If compliance standards, such as NPDES permit limitations, are set at levels at which it is




not possible to make reliable measurements, industries and  municipalities may be subjected to




harsh civil and criminal enforcement consequences entirely as a result of analytical




variability, as opposed to an unacceptable concentration of pollutants  in their effluents.  That




is because compliance is gauged solely on the basis of the analytical results of a permittee's




effluent, not on the pollution control measures employed.  Thus, unless appropriate detection




and quantitation levels are developed and applied, permittees will experience compliance




problems, notwithstanding their best efforts to select and apply effective pollution control




measures.
                                    126

-------
Numerous authors and organizations (Table 1) have defined detection and quantitation levels




(6,7,8,9,10,11,12).  Currie (6) and Kaiser (7,8) defined detection levels in the context of




confidence intervals and the probability of seeing false positive and negative errors.  The




common thread among all  the definitions was the use of a factor times the standard deviation




of the blank or of a sample containing analyte at a concentration near the expected detection




limit. The resulting definitions (Table 1) varied in their selection of the factor and




consequently in the probability of seeing  false positive and negative errors.  Some authors




acknowledged  that detection and quantitation levels would vary by matrix, while others only




mentioned using reagent water to compute the standard deviation. The USEPA in 40 CFR




Part 136, Appendix  B, acknowledges the importance of the matrix and the overall procedure




(preparation  and analysis) in their definition of the Method Detection Limit (MDL)(11.12).









The Electric Power Research Institute (EPRI)  Q3) review of the literature of definitions for




limit of quantitation (LOQ) noted two common themes:  the LOQ is equal to a factor times




the standard deviation of a well characterized blank; the factor is related to the




expected/required precision at the LOQ.  The American Chemical Society (ACS) (10) chose




± 10%  relative standard deviation (RSD) and the factor as  inversely proportional to the RSD




at the LOQ.  EPRI Q3) defined the LOQ as the lowest true concentration for which the RSD




equals 20%. Later, Kempic of the USEPA presented detailed procedures (14) using




interlaboratory studies for calculating acceptance limits (AL) and the practical quantitation




limit (PQL)  which the USEPA (15) defined as the lowest true concentration for which greater




than 75% of the laboratories can  measure within + AL.  The latter was based on the 95%




confidence limit at the maximum contaminant limit goal (MCLG) or, where the MCLG was
                                         127

-------
zero, at a concentration five times the MDL.  Britton (16) of the USEPA expressed three




years ago an alternative definition for PQL - the lowest true concentration at which one could




be confident that a single value would not be reported below a minimum level. This




definition was similar to one proposed earlier by Currie (6) except that the Kempic definition




of PQL as well as that of EPRI and the alternative expressed by Britton utilize the




interlaboratory standard deviation and interlaboratory recovery expressions for their




derivation.








Definitions of CMDL and CMOL




Our definitions for CMDL and CMQL are based on the fact that compliance monitoring




inherently involves interlaboratory performance. Previous definitions for detection levels




have been based on either single operator, single laboratory performance, or on a pooled




(average) of the former obtained by several laboratories. It is well established that single




measurements by  different laboratories using the identically same method on the same




traceable standard sample differ, and that measurements made by one laboratory on a




standard sample differ randomly over an extended  period of time.  The variation in results




between laboratories on a known standard is the interlaboratory standard deviation of the




method for the particular analyte or property in  the given matrix. The difference between




the mean of these interlaboratory measurements  on a single standard sample and the true




value of the standard is the bias of the method at that level in the given matrix (17). There




are both systematic and random components of this observed bias.  The random components




relate to random errors in the calibration  curves resulting in part from the absence of




traceable standards at concentrations near the MDL as well as from random ambient
                                   128

-------
contamination both external and internal to each laboratory.  The interlaboratory variance




reflects these random errors while the pooled single operator variance does not.








Compliance monitoring is inherently an interlaboratory issue for these reasons:








   •   Split samples - In the regulatory  environment samples can be split between




        laboratories (permittee and regulator) in situations where doubt exists about meeting




        or exceeding a discharge limit.








   •   Extended life of the permit - Permits that are issued for discharges to the




        environment cover an extended period of time (5 years for NPDES permits).




        During that time, many different qualified contract laboratories may be employed by




        the permittee or the regulatory agency to make measurements and to monitor




        compliance.








Also, we note that compliance monitoring is dominated by two types of permits:








   •   Those  written as "no-detectable" discharge, and








   •   Those  where discharge limits (pollutant concentration not to exceed a numeric




        value)  are set.








These permits require that a detection and/or quantitation level be set for compliance




monitoring.




                                         129

-------
The following definitions meet the needs that we have outlined for compliance monitoring




applications:








   •    Compliance Monitoring Detection Level (CMDL) - The lowest true concentration at




         which there is at least a 95% level of confidence that 99% of the future analyses for




         a specific analyte at that concentration in a common sample by any laboratory in




         control will be reported as greater than zero (or a blank) for a given method and




         matrix.








   •    Compliance Monitoring Quantitation Level (CMQL)  - the lowest true concentration




         at which there is at least a 95% level of confidence that 99% of the future analyses




         for a specific analyte at that concentration in a common sample by any laboratory in




         control will be reported as greater than the CMDL for a given method and matrix.








The  CMDL should be used for determining detection levels in compliance monitoring.  The




CMQL is the lowest level recommended for quantitative decisions based on a single analysis,




and it  should be used for determining quantitation levels in  compliance monitoring.








Figures 1, 2, and 3 summarize our  proposed approach.  Since the standard deviation is a




function of the concentration, our proposed definition first computes the standard deviation at




the defined level from a regression  equation of interlaboratory standard deviation versus true




value (Figure 1).  The computed  interlaboratory standard deviation is used to establish a
                                    130

-------
tolerance interval at the CMDL, such that there is 95% confidence that there will be only a




1 % chance of a false negative with respect to zero (or a blank) among all future




measurements at the CMDL (not reporting something as there when it is) (Figure 2).









We believe that the experimental designs recommended by the ASTM D2777, Standard




Practice for Determination of Precision and Bias of Applicable Methods of Committee D-19




on Water (17), for interlaboratory round-robin studies are the proper basis for determining




the standard deviation used to compute detection levels for compliance monitoring.  The




ASTM D2777 consensus  standard is well known and accepted in scientific circles. ASTM




D2777 studies provide ample safeguards for data integrity through lab performance




assessment by lab ranking and individual outlier rejection.  A round-robin study as specified




in ASTM D2777, which  1) requires several concentration  levels, 2) provides the ability to




reject data from laboratories that can't perform, and 3) screens for outlier data which might




affect precision estimates, is most appropriate for meeting compliance monitoring needs.  A




study based upon ASTM  D2777, if properly implemented, produces an experimental situation




that closely mimics that of compliance monitoring.









The Electric Power Research Institute  (EPRI) has funded extensive interlaboratory validation




studies of selected elements in aqueous matrices for graphite furnace atomic absorption




spectroscopy  (GFAAS), flame AAS, and inductively coupled plasma-atomic emission




spectroscopy  (ICP-AES) (Table 2).  The data obtained from these studies (13,18,19,20), have




led to an evaluation of the detection levels  (DL) contained in the USEPA MCAW (1) and are
                                          131

-------
the basis of our proposed approach.  It is important to note that when establishing the




performance of a given method-matrix combination, EPRI has striven to assure that all low




level observations including those at "zero" concentration are retained in the data to be




subjected to analysis by ASTM D2777.  We believe that such retention for subsequent




analysis is essential to  derive a valid estimate of "detection."  In a method performance




study, no values should be censored a priori either by instrument set-point adjustments or by




the application of arbitrary "detection limits."  Estimates of detection derived from such




censored data are artifacts of the censoring process.









We establish the CMDL by using a tolerance interval (single-sided) for the normal




distribution with high confidence:  that is, we want to be 95% confident that 99% of the




measurements of a constituent having a concentration equal to the CMDL will be greater




than zero.  In  calculating CMDLs,  it is not necessary for us to assume that the standard




deviation estimated at a spiked level is an approximation for the standard deviation that




would be obtained with a blank.  We assume, however, that measurement errors follow a




normal distribution and that the standard deviation at the CMDL is properly represented by




the regression expression employed.  The CMDL is calculated:
    CMDL = S • K
                    (0.95, 0.99, n)
where the tolerance factor K (single-sided) depends on the number of measurements that are




used to produce the estimated standard deviation.
                                    132

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Comparison of CMDL and CMOL with Recently Proposed Definitions




Recently the American Chemical Society Committee on Environmental Improvement (ACS-




CEI) (21) proposed definitions for method detection level (MDL), reliable detection level




(RDL),  and reliable quantitation level (RQL) which are based on the US EPA method




detection limit calculation defined in 1984  (12). The ACS-CEI levels are set for false




positives from zero (method detection level), for false negatives  from the MDL (reliable




detection level), and an arbitrary factor times the RDL (reliable quantitation  level). The




ACS-CEI computational approach relies on multiplying the single operator standard deviation




near zero (MDL) by different factors to set the RDL  and RQL.  The ACS-CEI MDL




definition describes the recommended MDL as being  based on the single operator standard




deviation, but mentions that published MDLs for a method should be based upon




interlaboratory (which they define as pooled single operator)  data.  In general, the RDL and




RQL are two and four times the MDL, respectively,  and the RQL is described as the




"recommended lowest level for quantitative regulatory action based on individual




measurements." The ACS-CEI acknowledges that these levels would be matrix dependent.




The ACS-CEI definitions are inappropriate, in our opinion, for compliance monitoring,




where two  parties need to agree in a legal  sense on the presence, absence or magnitude of a




toxic constituent, for the following reasons:









    •   Pooled single operator standard deviation is used incorrectly as a surrogate for




        interlaboratory standard deviation when both are defined by  ASTM D2777 as very




        different measures of method performance (see Table 3).
                                         133

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    •   Estimates of the standard deviation near zero concentration are used to compute the




        base ACS-CEI MDL from  which the RDL and RQL are computed  far upscale from




        zero.









    •   Standard deviation estimates used to derive the ACS-CEI MDL are based on too few




        observations, as few as seven, and are based on observations at a single analyte




        concentration, and do not preserve the proposed false positive or false negative rate.









Interlaboratory Standard Deviation.  It is well established that the interlaboratory standard




deviation is considerably larger than the standard deviation derived from the results of




replicate analysis by an operator within a laboratory.  As noted earlier,  the present inability




to employ for  calibration commonly available externally prepared traceable calibration




standards at concentrations near the detection level generates a laboratory bias that appears to




be normally distributed among laboratories.   The variance of this calibration bias appears to




constitute one  of the major error terms contributing to the difference between inter- and




intra-laboratory variance.  Since samples for compliance monitoring originate outside the




laboratory, random ambient contamination error also contributes to the observed difference




(field blanks allow an estimate of this component).  Within laboratory contamination error is




a component of both intralaboratory and interlaboratory standard deviation.









The foregoing points are illustrated using USEPA data from Method Study 27 for 6 trace




metals in surface waters by ICP-AES using the soft digestion preparation (Table 4).  In this
                                    134

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case the regression equations describing the relation of pooled single operator and




interlaboratory standard deviation versus the mean concentration for river water were used to




compute the standard deviation at 100 /ig/L. The results clearly show that the




interlaboratory standard deviation is larger and thus includes more error terms than the




pooled single operator standard deviation.  Previous EPRI RP1851 validation studies




(18,19,20) with 20-40 laboratories participating also consistently showed  that the




interlaboratory standard deviation was 2 to 3 times larger than the pooled single operator




standard  deviation (Table 4 and Figure 4).  Definitions for detection  and  quantitation based




on single operator standard deviation,  whether  pooled or not, are therefore too  optimistic




about the ability of equally qualified laboratories to confirm one another's results,  especially




detection, on identical samples.  In addition, such definitions  are truly inappropriate for use




in compliance monitoring as they do not take into account calibration errors at  trace levels




nor errors that originate outside the laboratory  yet influence the reported  value  of a




parameter in a sample collected for determination of compliance with a permit  limit.









Precision Estimates Near  Zero Concentration.  As the concentration increases,  the standard




deviation increases.  For any concentration selected,  the measurements will have a




distribution related to the standard deviation at that concentration (Figure 1).  The proposed




ACS-CEI definition is given in terms of a but in fact uses an estimate of the standard




deviation near zero to predict the confidence intervals at the  higher concentrations associated




with an RDL or RQL.  Since the standard deviations at the RDL and RQL, respectively, are




substantially greater than that  near zero, the confidence intervals at the RDL and RQL
                                            135

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inferred by ACS-CEI are inaccurate and, in fact, much smaller than the actual confidence




intervals.








Unsuitability of MDL-Based Definitions. The third reason that the ACS-CEI proposed




definitions are inappropriate for compliance monitoring applications is that they are based on




the estimated standard deviation of the measurement error distribution and, in addition, are




computed from too few measurements to provide any reasonable confidence in the false




positive error rate.








The ACS-CEI definitions, which have been proposed for compliance monitoring, are based




on the MDL under the erroneous assumption that the MDL provides a  1 percent false




positive rate.  This error  rate for false positives can only be maintained by referring




measurements to the  99th percentile of the measurement error distribution.  An MDL, using




an estimated standard deviation from repeated measurements within a single laboratory,




yields an "error rate" of 1 percent false positives under very restrictive and subtle conditions:




for each measurement to be compared to an MDL, the MDL must be recomputed.  That is,




to maintain a prescribed error rate of false positives, a minimum of seven measurements




must be taken to check the eighth for compliance. This, in fact, is not done in practice and




is one of the reasons  that neither the MDL nor any multiple of the MDL that purports to




maintain a false positive rate is appropriate for compliance monitoring.  Moreover,  the "error




rate" of false positives produced by using an MDL in compliance monitoring, even if eight




measurements are used to test for compliance, cannot be predicted for any particular stream,
                                   136

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effluent or outfall. Since the MDL itself is a chance or random variable, produced from a




calculation based  upon a random sample, compliance or non-compliance for any specific test




cannot be predicted.  The 1 percent error rate ascribed to the MDL is an average rate that




belongs to all MDLs computed with at least seven measurements.  This average rate is




comprised of monitoring situations yielding false positives above 1 percent and those below 1




percent.  It can be shown that more than 20 percent of all tests for compliance using an




MDL exactly as prescribed will have false positive rates much greater than 1 percent,  while




more than 70 percent of those tests will have false positive rates  below, perhaps considerably




below, 1 percent.








There is,  however, an appropriate statistical procedure for computing with confidence




tolerance  limits for the percentiles of the error measurement distribution.  Under the




assumption of normal error distribution, tolerance limits require using the factor 4.625 (not




3.143) times the estimated standard deviation (based on seven  replicates)  which gives a




detection  level that preserves a 1 percent false positive rate with  95% confidence (22).








This issue of too  few observations can be addressed by employing data from interlaboratory




studies. The USEPA and EPRI have  conducted interlaboratory method validation studies in




numerous matrices and  for many  methods and analytes. The data have been expressed as




regression equations  that can be used to compute the standard  deviation at any point in the




test range.
                                           137

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Table 5 compares the pooled single operator, single point computational approach suggested




by the ACS-CEI with our proposed CMDL/CMQL approach which uses standard deviation




regression equations to compute the interlaboratory standard deviation at the defined level.




EPRI RP1851 ICP-AES validation  data (20) were used to compute both sets of values shown




in Table 5.  For the ACS-CEI values, the pooled single operator standard deviation at the




USEPA estimated detection limit (USEPA Method 200.7) was used with a t value computed




for the number of laboratories reporting (approximately 18).  For EPRI RP1851 data given




for the six elements in Table 5, the sample sizes ranged from 48 to 72, giving single-sided K




values from 2.7529 to 2.8760.  If the true standard deviation, a, had been known exactly




instead of estimated,  we would have  used 2.326 which is the 99th percentile of the  normal




distribution.








The ACS-CEI definitions use an estimate of standard deviation at one point (at or near zero),




while our approach effectively uses the standard deviation at the defined detection and




quantitation levels.  Since our  method of computation uses  the standard deviation regression




expressions  to determine the concentration that meets the conditions of the respective




definition, the full  power of all the valid data at all concentrations by all laboratories is used




in the estimation, not just that from a single concentration, possibly far from the defined




level.








The concept behind the proposed ACS-CEI definitions might be pursued as "fall-back"




definitions for the  situation where only single laboratory and no interlaboratory performance
                                    138

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 information is available and there are neither sufficient resources or time to obtain data in




 accordance with ASTM D2777 requirements.  In developing such definitions, however, the




 ACS-CEI approach needs to be modified to satisfy the following technical criteria:









    •    The levels developed for compliance monitoring should be based on an estimate of




         interlaboratory standard deviation at an acceptable level of confidence.









    •    The computational approach should recognize the change in standard deviation with




         concentration and the effect of this change on the calculation of the confidence




         intervals.









    •    The terms and definitions for the levels to be used for compliance monitoring




         should be readily discerned by users as different from existing definitions that are




         based on single operator or pooled single operator standard deviation.









Our CMDL/CMQL computational approach using standard deviation regression equations




addresses a number of shortcomings with the ACS-CEI MDL, RDL, and RQL, as presently




proposed, as well as with other existing definitions.   In particular, using the standard




deviation calculated from the range  of concentrations regressed allows for the interpolation or




limited extrapolation needed to calculate the CMDL and CMQL.  The latter can be viewed




with much  more confidence since they are based on the demonstrated abilities of many




laboratories to perform the measurements.
                                          139

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The authors recognize that other researchers (23,24,25,26) have proposed alternative




approaches for determining detection and quantitation levels involving joint consideration of




probabilities of false positive and false negatives, including simultaneous tolerance intervals




for weighted regression. These fundamentally single operator based statistical approaches




should be evaluated to determine their applicability to interlaboratory. compliance monitoring




situations.









Of special interest for the compliance monitoring situation is the work in progress by the




ASTM Sub-committee D-19.02, Task Group on Detection and Quantitation, Chaired by




Nancy Grams. The Task Group (composed of Federal,  State, and industry representatives) is




currently conducting its first Sub-committee ballot of the Task Group's draft definition for




detection estimate that is based on interlaboratory standard deviation and is to be used in




compliance monitoring.









Summary




The compliance monitoring detection/quantitation levels,  CMDL and CMQL, presented in




this paper:









    •   Emphasize the interlaboratory nature of compliance monitoring.









    •   Benefit from the use of the full range of available statistical data (regression




        equations used to  interpolate the concentration that exactly meets the definition).
                                    140

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    •   Provide unambiguous guidance to users regarding their intended application.








    •   Compute detection and quantitation levels based on the estimated standard deviation




        associated with each level.








The alternative ACS-CEI definitions as presently proposed have limitations in that they:








    •   Use the term "interlaboratory standard deviation" when they mean "pooled single




        operator standard deviation".








    •   Use single operator based levels for compliance monitoring, a circumstance




        requiring interlaboratory based levels.








    •   Use single point estimates of standard deviation near zero to compute confidence




        intervals far up-scale from zero.








    •   Do not take full advantage of published validation  data as could be done by using




        regression expressions of standard deviation versus true concentration.








One very important problem  in the MDL and any  levels computed from it is that it is based




upon too few observations (seven) and also upon a single analyte concentration level in the




MDL's simplest form. There are, of course, multi-laboratory single operator replication
                                           141

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studies with more observations. These studies, however,  involve essentially a single




concentration level in samples prepared by the participant and do not address between




laboratory error.  Thus, the study data are not suited for addressing detection/quantitation




issues in a compliance monitoring situation.








In this paper we have sought  to explain the need to use estimates of variability derived from




the interlaboratory validation  of compliance methods.  In doing so, we have provided a




powerful and useful method to arrive at compliance detection and quantitation levels.








Acknowledgment




The authors wish to acknowledge  the support of Mr.  James Stine (Pennsylvania Power &




Light) and Mr. Steven Koorse, Esq. (Hunton and Williams) for their review and guidance.
                                    142

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REFERENCES

1.    Maddalone, R.F.; J.K. Rice, B.C. Edmondson, B.R. Nott, J.W. Scott, "Defining
     Detection and Quantitation Levels," Water Environ.. & Tech.. 5(1), 41 (1993).

2.    USEPA, "Methods for Chemical Analysis of Water and Wastes,"  USEPA-600/4-79-
     020, March 1979 (updated March 1983).

3.    Koorse, S.J., "False Positives, Detection Limits, and other Laboratory Imperfections:
     The Regulatory Implications," Environmental Law Reporter. Volume  19, 1989, 10211-
     10222.

4.    Koorse, S.J., "MCL Noncompliance:  Is the Laboratory at Fault," Journal of the
     AWWA. February 1990, pp. 53-58.

5.    Petition of James River Corporation, et. al. (IH-90-18, 90-17, 91-05).

6.    Currie, L.A., "Limits for Qualitative Detection and  Quantitative Determination:
     Application to Radiochemistry,"  Anal.  Chem.. 40(3), 586 (1968).

7.    Kaiser, H., "Quantitation in Elemental Analysis (Part 2)," Anal. Chem.  42(4) 26A
     (1970).

8.    Kaiser, H., Z. Anal. Chem.. 209. 1 (1965).

9.    Rice, J.K., "Analytical  Issues in Compliance Monitoring," Environ. Sci. Technol..
     14(12),  1455  (1980).

10.  Keith, L.H., et al.. "Guidelines for Data Acquisition and Data Quality Evaluation in
     Environmental Chemistry," Anal. Chem.. 55(14), 2210 (1983).

11.  Glaser, J.A.; D.C. Forest,  G.D. McKee, S.A. Quane, and W.L. Budde, "Trace
     Analysis for Wastewaters," Environ. Sci. Technol..  11(12), 1426 (1981).

12.  USEPA, "Appendix B to Part 136 - Definition and Procedure for the Determination of
     the Method Detection Limit - Revision 1.11," Federal Register. 49., (209), 43430,
     Friday, October 26,  1984.

13.  Maddalone, R.F., J.W. Scott, and M.D. Powers, "Aqueous Discharges  from Steam-
     Electric Power Plants:  The Precision and Bias of Methods for Chemical Analysis."
     EPRI CS-3744, November  1984.
                                         143

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14.   Kempic, J.B., "Use of Water Supply Performance Evaluation Data to Calculate
     Laboratory Certification  Criteria and Practical Quantitation Limits for Inorganic
     Contaminants," 12th Annual USEPA Conference on Analysis of Pollutants in the
     Environment, May 10-11, 1989, Norfolk, VA.

15.   USEPA, 52 FR 25690, July 8,  1987.

16.   Britton, P.W., Statistician, Development and Evaluation Branch,  Quality Assurance
     Research Division, Environmental Monitoring Systems Laboratory, U.S. Environmental
     Protection Agency, Cincinnati,  Ohio, letter to Rick Brandes, Chief, Enforcement
     Support Branch, Office of Water Enforcement and Permits, U.S. USEPA, Washington,
     DC, October 22, 1990.

17.   "Standard Practice for Determination of Precision & Bias of Applicable Methods of
     Committee D-19 on Water," D2777-86, ASTM Standards of Precision and Bias for
     Various Applications.  Third Edition, 1988, pp. 47-60.

18.   Maddalone, R.F., J.W. Scott, and J. Frank,  "Round-Robin Study of Methods for Trace
     Metal Analysis; Volume 1:  Atomic Absorption Spectroscopy - Part 1," EPRI CS-5910,
     Volume  1, August 1988.

19.   Maddalone, R.F., J.W. Scott, and J. Frank,  "Round-Robin Study of Methods for Trace
     Metal Analysis; Volume 2:  Atomic Absorption Spectroscopy - Part 2," EPRI CS-5910,
     Volume 2, August 1988.

20.   Maddalone, R.F., J.W. Scott, and N.T. Whiddon, "Round-Robin Study of Methods for
     Trace Metal Analysis; Volume 3:  Inductively Coupled Plasma-Atomic Emission
     Spectroscopy," EPRI CS-5910, May 1991.

21.   Keith, L.H., "Revising Definitions:  Low-Level Analyses," Environmental Lab,
     June/July 1992, p. 58.

22.   Natrella, M.G., "Experimental Statistics," National Bureau of Standards Handbook 91,
     October 1966, pp 2-14, 2-15 and Table A-7, p. T-15.

23.   Gibbons, R.D., F.H. Jarke, and K.P. Stoub, "Detection Limits:  For Linear Calibration
     Curves with Increasing Variance and Multiple Future Detection Decisions",  Waste
     Testing and Quality Assurance. Third Volume, ASTM STP  1075., C. E. Tatsch, Ed.,
     American Society for  Testing and Materials, Philadelphia, 1991.

24.   Hubaux, A. and G. Vos, "Decision and Detection Limits for Linear Calibration
     Curves," Anal. Chem.. 42(8),  849  (1970).
                                  144

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25.  Clayton, C.A., J.W. Mines, and P.D. Elkins,  "Detection Limits with Specified
     Assurance Probabilities," Anal. Chem.. 59(20), 2506 (1987).

26.  Grant, C.L., A.D. Hewitt, and T.F. Jenkins, "Experimental Comparison of USEPA
     and USATHAMA Detection and Quantitation Capability Estimators," American
     Laboratory. 15, February, 1991.
                                        145

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                                                 Table 1
                       Detection Level Definitions From Various  Sources
 Author
Title
Definition
    Authors' Statistical
      Interpretation
Degrees
of Freedom
Currie (5)
Decision Limit
                 Detection Limit
Kaiser (6,7)       Limit of Detection
Rice (8)*         Critical Level
                  Limit of Detection
ACS-CEI (9)      Limit of Detection
USEPA/EMSL     Method Detection
QO, il)           Limit
Lc =  1.645aB


LD = 3.290a B



LOD  = 30.

Approximately a 5% risk of         Infinite
reporting zero values as
detected for normal distri-
butions and as high as  11 %
risk of reporting zero values
as detected for asymmetric or
broad distributions.

0.5% risk of reporting zero          Infinite
value as detected or not
reporting a real  value as > 0.

0.5% risk of reporting a true         Infinite
concentration as not detected.

7% chance of reporting zero         Infinite
value as detected or not
reporting a real  value as > 0.

1 % chance of reporting zero         6
value as detected.
   Rice also suggests using overall standard deviation data from interlaboratory studies on real, spiked samples.
                                                  146

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                       Table 2

            EPRI RP 1851-1 Interlaboratory
                   Validation Studies
  PART/ROUND
 METHOD
        ELEMENT
I.  Round 1
I.  Round 2
II. Round 1
III. Round 1
GFAAS

GFAAS

GFAAS
CVAAS
Flame AAS

ICP-AES
As, Se

Ni, Pb, Cr, Cu

Cd
Hg
Fe, Zn

Al, Ba, Be, B, Cd, Cr, Cu
Fe, Pb, Mn, No, Ni, V, Zn
                           147

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                          Table 3
 Calculated Standard Deviations from Laboratory Results

Replicate #
1
2
3
Lab Mean
Lab Std. Dev.
Laboratory Results
Lab A
11
13
12
12
1
Lab B
15
14
13
14
1
LabC
17
16
18
17
1
LabD
14
15
16
15
1
Pooled Standard Deviation =  1
Overall Mean = 14.5
Interlaboratory Standard Deviation =2.1
                              148

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                     Table 4
      Comparison of Pooled Single Operator
      v. Interlaboratory Standard deviation
Standard Deviation ^tg/L*

ELEMENT

Cd
Fe
Mn
Mo
V
Zn
POOLED
SINGLE
OPERATOR
3.2
54.2
6.9
6.6
2.9
10.0

INTERLABORATORY

9.2
56
12.9
9.1
10.0
16.6
*  USEPA Method Study 27, Surface Waters, soft digestion
   standard deviation data at 100 ^g/L for ICP-AES
                         149

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                        Table 5

    Comparison of ACS-CEI Computational Approach
       with Proposed EPRI Compliance Monitoring
            Detection and Quantitation Levels
Detection and Quantitation Levels in River Water, /*g/L*


ELEMENT
Cd
Fe
Mn
Mo
V
Zn
ACS-CEI
(single operator)
MDL
15
28
12
15
15
23
RDL
30
56
24
30
30
46
RQL
60
112
48
60
60
92
EPRI
(interlaboratory)
CMDL
14
28
17
59
29
48
CMQL
31
61
36
123
61
111
ACS-CEI values computed from EPRI RP 1851-1 pooled single operator data
at the USEPA estimated DL for ICP-AES; EPRI values from the interlaboratory
data from the same study (20).
                       150

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MEASURED
VALUE
                             TYPICAL
                             DISTRIBUTION OF
                             MEASURED VALUES
                                        TO CALCULATE A CMDL AND
                                        CMQL THE PRECISION AT EACH
                                        LEVEL MUST BE KNOWN AND
                                        USED
                                TRUE CONCENTRATION
                                                          01M 92.054.02
    Figure 1. Distribution of Measured Values at Different Concentrations
                             151

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INTERLABORATORY
STANDARD
DEVIATION
DISTRIBUTION
                                                    TRUE CONCENTRATION
        EXPECTED NORMAL
        DISTRIBUTION OF
        MEASURED VALUES
                                                    TRUE CONCENTRATION
                     CMDL
CMQL
                                                           DIM 92.066.04
              Figure 2.  Illustration of CMDL and CMQL Definitions
                                     152

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         STANDARD
         DEVIATION
         (PRECISION)
     MATRIX "NOISE" i
INSTRUMENT "NOISE" J
LINEAR
FIT
,'o
              CURVILINEAR
              FIT
                                     TRUE CONCENTRATION
                                                                  O1M 92.086.03
          Figure 3.  Comparison of Linear and Curvilinear Fits to
                    Standard Deviation versus True Concentration Data
                                   153

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STANDARD
DEVIATION
(PRECISION)
           INTERLABORATORY
2X
(TYPICAL)
                                                       POOLED
                                                       SINGLE
                                                       OPERATOR
                                  TRUE CONCENTRATION
                                                                   O1M 92.066.01
          Figure 4.  Typical Relationship between Interlaboratory and
                   Pooled Single Operator Precision
                                        154

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City of Phoenix.
                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD:  Questions?

                                       MR. SCHREINER:  My name is Dave Schreiner,
             For example, let's say you are running beryllium, and your detection limit is like
500 parts per trillion. We have been going around and around with QC about rounding.  Let's
say your analysis shows you that you have got 450 ppt and your MDL is, you know, 500.  Do
you round that up and say you report a number, or do you report less than or what?

                                       MR. RICE: When one compares a number that you
get with a permitted value, you  obviously have to establish some ground rules.  In this context,
EPA is  now, and I  think we may hear in the next paper some discussions of this, trying to
establish some very real  ground rules for how you get real numbers  for compliance purposes
when you  come up with values  that are less than the detection level.

             Whatever you do may be quite arbitrary, but everybody has to play by the same
ground rules. That is all I can say.
Company.
                                       MR. SCHREINER:  Okay, thanks.

                                       MR. STANKO: George Stanko, Shell Development
             Jim, I  understand everything  you presented here,  but  would you  give  some
guidance as to how the data should be reported? Should a laboratory  report any value below
CMQL?  And what if the observation falls below that but above CMDL?

                                       MR. RICE: The first step is getting some agreement
on a rational definition for a CMDL and a CMQL.  That is all I really  addressed in my paper.

             The next stage is as I said earlier.  EPA is addressing the reporting issue,  and I
think it is going to be  out for public comment at  some point in the  near future based on a
minimum level concept.  Then the question is how do you define a minimum level (ML).

             From my viewpoint, I  think there is a strong rationale to define the ML as
equivalent to our CMQL, the quantitation level.  The minimum  level, as it appears will be
proposed together with  its proper usage, will serve  as a sort of rosetta stone - it serves  as an
acceptable way out of the box, that occurs when you come up with health or aquatic risk based
limits for a permit that are less than what can be detected by the agreed methods of measurement.
                                         155

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             How you handle a less than value on a discharge monitoring report? That is what
the convention will be about.

             How do you arrive at that convention that is your transition or transformation point
between a less than and a value?

             EPA is proposing that anything less than the ML is zero, and that is what you
report. You don't report the other numbers.  You report the zero.  Then, anything that is at the
ML or above you report as a number, and that is quantified.

             Therefore, when you make averages, or whatever statistics you are calculating, you
are using real numbers, because zero is a real number.

             But that is not what this paper of ours was addressed to.  It is first things first
which is to find out how you can come to a rational detection and a rational quantitation limit
in a compliance context where interlaboratory differences  on split  samples is a real problem.

                                        MR.  TOM:   Otoyo  Tom  from  University of
Waterloo.

             You mentioned as the concentration increases, the  standard deviation will also
increase in some cases.  Can you explain more specifically would  this happen?

                                        MR.  RICE:   Why does the standard deviation
increase with concentration?

                                        MR. TOM: Yes.

                                        MR. RICE:  I start out with the easy answer.  It
does.  The why is simply that  it is the major error terms that  make up the interlaboratory
standard deviation are in themselves a function of concentration. The method itself generally has
an ability to measure a parameter with the error of measurement a percentage of the total. Then,
as the value of the parameter increases, so does the actual standard deviation that is  involved.

             Now, that is kind of a circular argument.  I have always found,  at least in my
experience, that the standard deviation for a method increases with  the increase in concentration,
and this is true especially for interlaboratory values.

                                        MR TOM: Thanks.

                                        MS.  MOORE:  Marlene Moore with  Advanced
Systems.

              In your definitions, you refer to true concentration.  What is true  concentration?


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                                         MR. RICE:  Well, that is a good question.  I can
explain it best by example in the EPRI round robins dealing with metals what it is we had to do
to answer that question. I think we have come about as close practically as you can at this time.

              Everyone thinks his own reagent water is Simon pure, but as we know, that is not
true.  When you are measuring metals at trace levels, it is not, and it is certainly not for lots of
other parameters.

              What we did was to send everyone the best reagent water we could make, and
send  it blind.  The participants calibrated using their own reagent water and their calibration
standards that they made up. We asked them to report the answer they got - don't censor. If you
got a negative value, report it.  We got negatives, as you would expect.

              Actually, in  a real situation, if I did that and I had the true zero and I sent it out
there, I am very likely to get as many negatives as I get positives if I have enough laboratories
in my sample.

                                         MS. MOORE: Okay,  but in the calculation when
you are actually calculating true...

                                         MR. RICE: The next step is what do you do when
you are trying to deal with a real world situation?  For the reagent waters that went out, we used
the consensus value of 20 or 30 labs on that reagent water  as the true concentration of the
particular analyte.

                                         MS. MOORE: So, we  are continuing with the fact
that we are going to use a consensus value as our true concentration?

                                         MR. RICE: Well, only for the blank, in effect.

                                         MS. MOORE: What about the knowns that were
sent out when you spiked?   Do you use a true...

                                         MR. RICE:  Well, the knowns we  used were the
value of the spike, which was calculated by the control lab by weighted additions and verified
by subsequent analysis of samples that were taken randomly from lots of the split samples.  The
true value for a spiked sample was the sum of the spike and the concensus blank concentration.

                                         MS.   MOORE:    Currently,  with performance
evaluation samples, though, when they are analyzed, we don't look at what the true value is. We
just use a statistical calculation to determine what our deviations and  variances are based on what
all 600 labs or however many labs are associated with the study. Is that what you are trying to
do here with this is to just  see what everybody can get in the  same method?
                                          157

-------
             Because you do also look at method- and matrix-specific requirements.  I guess,
in looking like this, what I am trying to decide is, do you take a given method and say therefore,
if I am running the ICP-AES method, I will get a true concentration being that I have spiked at
10 parts per billion and, therefore, this is what I should get when I do that?

             How method- and matrix-specific are you?  I mean, now we can run five different
methods for cadmium, and we might get different values, but we all have to hit the same number.

                                        MR. RICE: Well, the value that-first, you have to
start out with a traceable  standard in the first place in making  up the standards that you  are
sending out.   So, you have  to view those that  you are sending...they are split  equally to
everybody...as the standards. And you have verified by one method or another alternatively and
by other control systems that you have confidence that that is, and you call it the true value.

             Now, the only  thing that is  changed that we have done is to use the consensus
value for the reagent water that we sent out, which was the matrix that was used, and then add
the spike to that and call the total the true.

             All of the standard deviations and the like and all of the reported measured values
are then reported against and analyzed with that as the true.

                                        MS. MOORE:  Okay, thank you.

                                        MR. KEITH:  Larry Keith from Radian Corporation.

             Jim, my understanding of the ACS definition is it is a definition that allows you
to expect certain parameters from the data  that you get. In that respect, it is more of a generic
kind of definition.  It  doesn't, to my understanding, specify the protocol which means that it
doesn't say that you have to use single operators.

             If you used an  interlaboratory protocol, then I think the definition would end up
being quite close to what you have proposed here.

                                         MR.  RICE:   Well,  I might  say, Larry, there is a
problem with a definition if it can have alternative bases and the same acronym describes it. It
is really not very precise, and any time you see, an RDL or an RQL, unless somebody footnotes
it, you won't know what that number really means, what the significance is.  It could be based
on one guy, one  lab.  It could be an average of a number of labs.   It could  be  a  full
interlaboratory.

              What we are trying to do is to get a clear unambiquous definition.  I don't care
what acronym you give it, but the definition is what counts, not the acronym.  The definition of
how that number was derived is clear, unequivocal, it is unambiguous, everybody understands
it.


                                           158

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             And you can't do that with the way you have divined...put up...divined, that was
a slip...with the way you have constructed your proposed RDL and RQL, because it could be any
number of things to different people.

                                        MR. KEITH: Well, I agree that is exactly correct.
The protocol would have to be specified  along with the definition which is what you have done
in this  case.

                                        MR. RICE:  But we only  have one protocol; you
have several. That is the difference.

                                        MR. KEITH:  Yes, that is true.  One could have
different protocols.

                                        MR. TELLIARD: We have one more, and then we
are calling it. It is the hard question now.

                                        MR. MCCARTY:  Yes. Harry McCarty, SAIC.

             Jim, one comment real quick.  In this day and age, is it really appropriate to talk
about a single operator precision?

             I don't know any meaningful measurement that is being made for compliance
monitoring done by one person.  There is an extraction guy for organics.   There might be a
cleanup guy, and there is an instrument operator, and the lab manager thinks he has something
to do with it as well.

             Every one of those people thinks they are the most critical in the  process, and
many lab  managers are finding out it is the guy who received the sample and forgot to put it in
the cooler who was probably the critical one.

             A comment. It might help to get away from the concept of single operator.

                                        MR. RICE:  I would love  it.

                                        MR. MCCARTY:  If you call  it  a single  lab
measurement, it  might be more meaningful.

                                        MR. RICE:  That is what  it really should be, and
that...right now,  ASTM's D2777 is in the process of revision, and some of the internal serious
discussions  go to that issue.  I think there is general consensus there now that  we ought to
abandon the word operator. It is laboratory, single laboratory.  It is intralaboratory precision that
you  are talking about.
                                          159

-------
                                        MR. MCCARTY:  One further suggestion.  You
mentioned the minimal level which is a concept that came out of Bill Telliard's methods in
general.  One of the things that would be nice to see with your definition or whichever one is
ultimately adopted is to take what, in fact, the ACS committee in 1983 suggested which is that
you don't make measurements outside of the calibration range of a methodology, that when you
establish your quantitation level that you also  specify that the method run a standard at the
concentration equivalent to that in the sample.

             Your standards are made up, you know,  in  pure  solvent  or clean water  or
something like that, but at some point, if you could then tie this concept back to  running a
standard at that level so at  least you have some concept that the instrument can see it. For mass
spec, it becomes critical in terms of evaluating the ability of the instrument to really identify that
compound.

             The quantitation aspect of it you have covered here very well, but Bill's methods
at least  specify...the minimum level is specified as that concentration in a sample equivalent to
what is  in that standard following the procedure, and if you add that to it, I think you have got
the qualitative and the quantitative pieces tied off to a great extent, and  I would like to suggest
that for  the rewrite of D2777.

                                        MR. RICE:  A very good comment.

                                        MR. TELLIARD:  Thanks, Jim.  Appreciate it.

                                        MR. RICE:  Thank you.
                                          160

-------
                                        MR. TELLIARD: I would like to introduce our next
speaker.  We are going to move into metals now, and we are going to talk about some organo-
metals.

              Our next speaker is from Midwest Research.  Yan Liu is going to talk on organo-
metal analysis. After lunch, we will continue on the metals train which, right  now, is a very
large issue for the Agency and has a lot of implications.
                                        MR. LIU: Thank you.

              I think some of us  have had enough with  MDLs.  I am  going to  talk about
determination of organotin compounds by SFE with GC and atomic emission detection. The co-
author for the paper is Dr. Viorica Lopez-Avila, MRI and Dr. Werner Beckert, EPA-Las Vegas.

              We know  that  the industrial  use  of  organotin compounds  has  increased
significantly over the last few decades.  These compounds are commonly used as stabilizers for
polymers as wood preservatives and also as agricultural fungicides.  They are also used in anti-
fouling paints.

              Lots of these compounds are  toxic.  Their increased use  and their subsequent
discharge into the environment have contributed to environmental pollution.

              A  number of analytical methods have been developed for determination and
isolation of these compounds.  A typical procedure for determination and speciation of these
compounds usually consists of these steps:

              First, the organotin compounds are extracted from the sample matrix with a solvent
extraction procedure. Because most of these organotin compounds exist as the ionic species in
the sample, a complexing agent is often used in the solvent extraction procedure.

              Then, the extracts are often derivatized with a Grignard reagent to convert the
ionic organotin compounds into tetra alkyltin compounds.  Finally, the derivatized extracts are
analyzed by GC with tin specific detectors such as AA or atomic emission detectors.

              We know that the solvent extraction procedures are  often time-consuming and
labor-intensive. Also, the use of toxic organic solvents in relatively large amounts can contribute
to environmental  pollution.

              In recent years, SFE has gained great popularity as a sample preparation technique.
SFE can be selective because the solvation power of a supercritical fluid can be controlled by
changing of pressure and temperature.
                                          161

-------
             SFE is also relatively fast and efficient, because the supercritical fluid has high
diffusivity and low viscosity, compared to the common organic solvents.

             SFE is also suitable for extraction of thermally labile  analytes,  because the
extractions can be carried out at relative low temperatures.

             In addition, SFE reduces the use of toxic organic solvents.  Carbon dioxide, the
most commonly used supercritical fluid, is nontoxic, nonflammable, non-polluting, and relatively
inexpensive.

             A number of organic pollutants have been successfully extracted from different
sample matrices by SFE. We at the Midwest Research Institute, California Operations have been
developing SFE-based sample preparation methods over the last few years under a contract with
EPA-Las Vegas.   Recently, we developed a  SFE/GC-AED  procedure for determination of
organotin compounds in environmental samples.

             In the procedure  we developed, we use supercritical carbon dioxide or carbon
dioxide modified with a small  amount of methanol, usually 5 percent, to extract  organotin
compounds from solid samples,  and then we use pentylmagnesium bromide to derivatize the
extract. Finally, we use a GC with atomic emission detector to analyze the extract.

             This slide shows  the block diagram for the  SFE system that we  used.  We used
carbon dioxide or carbon dioxide modified with 5 percent methanol as the extraction fluid. A
syringe pump operating at a flow rate of 1 to 2 ml/min was used to deliver the  extraction fluid.

             The volume the extraction vessel was 10 ml. It was kept in a vertical position,
and we used a fused silica capillary tubing as the restrictor.

             The extracted analytes were collected with 5 ml of hexane or methanol.

             For those of you who are not familiar with the atomic emission detector, I will go
through the system very briefly. It basically consists of an HP-5890 GC that is coupled to an
HP-5921A atomic emission detector (AED).   This  detector uses microwave  induced helium
plasma as the excitation source.

             The GC effluent entering into the AED cavity where the analytes are cleaving into
atoms, and their atomic emissions were monitored using a grating spectrometer with a photodiode
array sensor.

             The GC-AED conditions that we used are shown here.  We  used a HP-5 column
to separate the organotin compounds. The transfer line that interfaced the GC with the AED was
also a HP-5 column, and we monitored the atomic emission from carbon, tin, and hydrogen.  The
carbon response and tin response was monitored with one sample injection, and the hydrogen
response was monitored with another sample injection.


                                          162

-------
             This slide shows the GC-AED chromatogram of a organotin standard solution.
The concentration of these organotin compounds was 2 ug/ml. These ionic tin compounds were
pentylated before the GC-AED analysis.

             The top chromatogram shows the  carbon response, the middle one shows the
hydrogen response, and the bottom one shows the tin response.

             In this standard, we also added hexadecane and docosane.  The reponses of these
alkanes were observed with either carbon channel or hydrogen channel, but their responses were
not observed with the tin channel.

             This specific response provided by the tin channel is very useful in analysis of the
SFE extracts generated for the environmental samples, because these extracts often contain many
other  organic compounds.   The use of a tin-specific response,  will obviously facilitate the
identification and the quantitation of these organotin compounds.

             One example is shown here.  These are the chromatograms for an SFE extract.
This topsoil sample  was  spiked with seven ionic  tin compounds, and the carbon response,
hydrogen response, and tin response are shown. It is clear that we have difficulty in identifying
these  tin compounds by using either carbon or hydrogen response.   On the other hand, the
identification and quantitation can be achieved easily with the tin-specific response.

             The GC-AED calibration data are  shown here.  We found that  the calibration
curves were usually linear within this  concentration range from 10 to 2500 ng/ml. The detection
limit for these compounds was about 5  ng/ml.

             Now I am  going to show you some SFE results.  We first investigated the
extraction of tetraalkyltin  compounds from the spiked topsoil samples.  These samples were
spiked with 2 ug/g of these six tetraalkyltin compounds.

             We carried  out extractions at different pressures and temperatures, using  carbon
dioxide as  the extraction  fluid.   The  pressure  and temperature ranged  from  100 to  350
atmospheres, and the temperature ranged from 40 to 80° C.

             We carried out dynamic extraction  of 10 to 40 minutes.

             With the exception of this experimental condition: 100 atmospheres, 10 minutes,
and 80 degrees, the recovery of tetraalkyltin compounds from  spiked  topsoil samples  was
basically quantitative.

             Again,  more data are shown  in  this slide.   These  results  indicate that the
tetraalkyltin compounds can be extracted, with a relative low pressure and temperature and a
short  extraction time.  For example,  with  a 10-minute  extraction at 100 atmospheres and 40
degrees, we can get quantitative recovery of these compounds.


                                          163

-------
             We then carried out experiments to extract ionic organotin compounds. The SFE
conditions that we used are shown here. The extraction pressure was 450 atmospheres, and the
temperature was 80° C.

             We performed  a 30-minute static extraction followed by a 20-minute dynamic
extraction. Carbon dioxide or carbon dioxide modified with 5 percent methanol was used as the
extraction fluid.

             We also used a complexing agent: sodium diethyldithiocarbamate.  We added the
complexing agent to the spiked topsoil samples to complex the ionic organotin compounds to see
if the use of the complexing agent has any effect on the recovery of these compounds.

             This slide shows the recovery of ionic organotin compounds from a spiked topsoil
sample by SFE  without using the complexing agent.  We can see that the recovery for the
trialkyltin compounds, including trimethyltin chlorine, triethyltin bromide, and tributyltin iodide,
ranged from about  50  percent to about 75 percent.

             On the  other hand,  the recovery for dialkyltin compounds  and monoalkyltin
compounds like dimethyltin, dibutyltin, diphenyltin, and butyltin trichloride were very low.  They
ranged from less than  10 percent to about 20 percent.

             These results were  found with either carbon dioxide as the  extraction  fluid or
carbon dioxide modified with 5 percent methanol as the extraction fluid.

             On the  other hand, when we mixed  the spiked samples with  a small amount of
complexing  agent: sodium DDC, prior to  the SFE  extraction, we observed a significant
improvement in the recovery of these ionic  organotin compounds  from spiked topsoil samples.
These data were obtained with carbon dioxide modified with 5 percent methanol as the extraction
fluid.

             For these trialkyltin compounds, we can see that  the recovery  improved about 20
to 30 percent. For these dialkyltin compounds and also monoalkyltin compounds, we observed
significant improvements in the extraction efficiency.  For example, the dibutyltin  compounds,
the recovery improves from about 10 percent to over 90 percent.

             We also observed some  improvement in the recovery for the diphenyltin and the
butyltin.  These are somewhat less dramatic.

             This slide compares the  effect of the extraction fluid.   This  compares the
recoveries that we obtained with either carbon dioxide alone or carbon dioxide modified with 5
percent methanol. We didn't observe any significant difference using these two extraction  fluids
with the exception  of butyltin trichloride.
                                          164

-------
             In conclusion, our study indicated that the tetraalkyltin compounds can be extracted
quantitatively from spiked topsoil samples by SFE under moderate pressure and temperature
conditions.

             Secondly, the ionic organotin compounds can be extracted by complexation SFE,
that is, with the use of complexing agents.

             We believe that SFE followed by GC-AED is a promising analytical technique for
determination of organotin compounds in environmental samples.

             Finally, I would like to acknowledge the financial support from EPA-Las Vegas
for this research. Also, Marcela Alcaraz from MRI, and Joe Tehrani from Isco who provided the
SFE system that we used  in this  investigation.

             Thank you.  Any questions?

                                       MR. TELLIARD: Questions? Any questions?
(No response.)

                                       MR. TELLIARD: Thank you, Yan, very much.
                                         165

-------
COMBINATION OF SUPERCRITICAL FLUID EXTRACTION WITH
CAPILLARY GAS CHROMATOGRAPHY AND ATOMIC EMISSION
DETECTION FOR THE DETERMINATION OF ORGANOTTN
COMPOUNDS IN ENVIRONMENTAL SAMPLES

YAN LIU AND VIORICA LOPEZ-AVILA, Midwest Research Institute, California
Operations, 625-B Clyde Avenue, Mountain View,  CA 94043

WERNER F. BECKERT, U.S. Environmental Protection Agency, Environmental
Monitoring Systems Laboratory, 944 East Harmon Avenue, Las Vegas, Nevada 89119

      In the analysis of environmental samples  for organic compounds,  sample
preparation methods involving conventional solvent extraction are usually time- and
labor- intensive.  Also, the use of organic solvents, often in relatively large amounts,
is of environmental concern because of fugitive emissions and solvent waste handling
and disposal.  Supercritical fluid  extraction (SFE) has gained popularity in recent
years as a sample preparation technique.  The commonly used supercritical  fluid
carbon dioxide is nontoxic, nonflammable, nonpolluting, and relatively inexpensive.
In addition, SFE is relatively fast, when compared to conventional solvent extraction,
and  its  selectivity can  be easily controlled.  SFE  techniques  have been  used
successfully to extract a variety of organic pollutants from solid matrices.

      A number of organometallic compounds have found industrial use, and  their
releases into the environment are contributing to environmental pollution. However,
the  isolation of organometallic  compounds from environmental samples and  their
determination often present problems.  We have successfully extracted organotin
compounds from  spiked topsoil samples by SFE and analyzed the extracts by gas
chromatography  with atomic emission detection.  A  novel  approach was  used
involving the use of complexing agents in the supercritical fluid to improve the
extraction of ionic organotin compounds.   The effects of pressure,  temperature,
extraction time, and modifier on the recovery of the organotin compounds from spiked
soil samples will be discussed.
NOTICE: Although the research described in this paper has been funded wholly by
the U.S. Environmental Protection Agency through Contract No. 68-C1-0029 to
Midwest Research Institute, it has not been subjected to Agency review. Therefore,
it does not necessarily reflect the views of the Agency.  Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
                                166

-------
  Combination of Supercritical Fluid Extraction with Capillary
      Gas Chromatography and Atomic Emission Detection
         for the Determination of Organotin Compounds
                    in Environmental Samples
o\
          Yan Liu1, Viorica Lopez-Avila1, and Werner F. Beckert2
  'Midwest Research Institute, California Operation, 625-B Clyde Avenue, Mountain View, CA 94043

  2U.S. Environmental Protection Agency, 944 East Harmon Avenue, Las Vegas, Nevada 89119

-------
OO
Industrial Applications of Organotin Compounds









 •   Stabilizers for PVC Polymers (e.g., diorganotin compounds)



 •   Wood Preservatives (e.g., triethyltin hydroxide)



 •   Agricultural Fungicides (e.g., triphenyltin hydroxide)



 •   Antifouling Paints (e.g., bis(tributyltin) oxide)

-------
 Typical Procedures for Determination of Organotin
        Compounds in Environmental Samples
•   Extraction of Organotin Compounds from Sample Matrices by
    Complexation Solvent Extraction.

•   Derivatization of Extracts with Grignard Reagent (RMgX).

•   Analysis of Derivatized Extracts By GC with Atomic Absorption or
    Atomic Emission Detectors.

-------
Advantages of Supercritical Fluid Extraction
       Selective —  Controllable Solvation Power

       Fast and Efficient — High Diffusivity and Low Viscosity

       Suitable for Thermally Labile Analytes

       Reduced Use of Toxic Solvents — CO2 is Nontoxic,
       Nonflammable, Nonpolluting, and Relatively Inexpensive

-------
SFE/GC-AED Procedures for Determination of Organotin
          Compounds in Environmental Samples
      •   Extraction of Organotin Compounds from Sample Matrices by
         Supercritical CO2 or CO2 Modified With Methanol.

      •   Derivatization of Extracts with Grignard Reagent (C5HuMgBr).

      •   Analysis of Derivatized Extracts By GC with Atomic
         Emission Detection (GC-AED).

-------
             SUPERCRITICAL FLUID EXTRACTION SYSTEM BLOCK DIAGRAM
to
                        Pump
                    Syringe Pump (100 mL)

                    Flow Rate of 1 - 2 mL/min
         do
         u u
Extraction
Vessel
10 inL Vessel
(1.5-cm ID x 6-on length)

Vertical Position
                                                                   Deactiyated Fused-Silica Capillary Tubing
                                                                   (50-/im ID, 375-A»m OD, 40-cm length)
Restrictor
                                                                                5 mL Hexane
                                                                                or Methanol

-------
          reagent gas  microwave
                  ,  generator
   Injection
     port
                            spectrometer
     chromatograph
He gas
                     cavity
                  with plasma
   GC-AED Block Diagram

-------
GC-AED OPERATING CONDITIONS
               (GC Parameters)
 Injection port temperature     250°C

 Injection port              Splitless

 Injection volume            1 jiL

 Splitless time              60  sec

 Column                  HP-5, 15-m length x 530-pm ID x
                         0.88-/tm film thickness

 Carrier gas flow rate         6 .0 mL/min helium

 Temperature program        50°C  (3-min hold) to 230°C (4-
                         min hold) at 20°C/min.

-------
    GC-AED OPERATING CONDITIONS
                     (AED Parameters)
Transfer line

Transfer line temperature

Cavity temperature

Solvent vent begin

Solvent vent end

Spectrometer window purge

Helium makeup gas flow

Makeup and reagent gas pressures


Element wavelength
HP-5 column

250°C

250°C

0.01 niin

4.0 miii

2 L/min nitrogen

220 mL/iniii

70 psi helium, 65 psi hydrogen, 25 psi
oxygen

270.651 nm for carbon (reagent gases:
hydrogen and oxygen)
247.857 nm for tin (reagent gases:
hydrogen and oxygen)
656.302 nm for hydrogen (reagent gas:
oxygen)

-------
GC-AED Chromatograms of Organotin Standards
C 24
3CB-
34B-
| 32B-
33 3BB
w 2BB-
« 2CB-
^
24B-
22B-



,t

y


B of DBTR: 1 1 1892-1.0


3 * |

.2

'




•a
X
o


L- t_

56 7
1

i
1


« C-248 channel


c
rt
8 ,
o 1 „
•o 1 9
1 II /I

a IB i! u ic
Tl ni (nl n. )
H CSC of DRTS: 1 1 1892-1. 0

IBB-
17B-
U IBB-
a
53 14B-
Ui
O
< »"•
ita-
1BB-
9B-





1
Jl




. H-656 channel

c
3 f §.


2


V
•s
X
v^

56 T
HI
i
8



1
CO
1 1
5l
L_ R. \


B IB 12 14 1C
Tl «• Cn n. >
Sn 271 of ORTR: 1 11892-1 .0
IBBB-i
9BB-
MO.-
U 7BB-
I"8'
8 see-
o •*BB"
U
2BB-
1BB-
B"

3 g Sn-271 channel

i












2













4

6 T
5



1










*










9
A

B IB 12 14 1C
Tl »> C«l n. >
                                             1    Trimethyltin chloride
                                             2    Tetraethyltin
                                             3    Triethyltin bromide
                                             4    Dimethyltin dichloride
                                             5    Tetrabutyltin
                                             6    Tributyltin iodide
                                             7    Dibutyltin dichloride
                                             8    Butyltin trichloride
                                             9    Diphenyltin dichloride
                               176

-------
Chromatograms of an SFE extract of a topsoil sample
spiked with seven ionic organotin compounds
taaa-i
saa-
0 BBB-
g. 7BB-
•- 6BB-
o
"5BB-
4BB-
3BH-
c




1
241




a




III
r QflrB:




u




W
11 189




(k
2-




\.
2. a
C-248 channel



UL_^__^
B 10 12 14 1C
ft n« C n 1 n . )
1BBBT
9BB-J
BBB-
v :
3 780-^
a SMj
Q SBB1
<; 43E- .
joa-
2BB- I
SSS






at




\
u
DRTH: 1 1 1892-2. Q
H-656 channel









y





\ L:




(




LlL. . . -
B IB 12 14 It
T { n« C n 1 n . )
sza-i

sae-
S 4BB-
2.
Sx 271 «f QBTB: 111892-2.0




a 3Ba4
Q 1
U 2BB-|
1BB-
B-
U
Sn-271 channel

i
3 7
4 6
8
, 9
ill

B IB 12 14 IK
Tl f« (nl n. >
                                                1    Trimethyltin chloride
                                                2    Tetraethyltin
                                                3    Triethyltin bromide
                                                4    Dimethyltin  dichloride
                                                5    Tetrabutyltin
                                                6    Tributyltin iodide
                                                7    Dibutyltin dichloride
                                                8    Butyltin trichloride
                                                9    Diphenyltin dichloride
                            177

-------
         GC-AED CALIBRATION DATA FOR ORGANOTIN COMPOUNDS
00
Compound
no.
1
2
3
4
5
6
7
8
9
Compound name
Trimethyltin chloride
Tetraethyltin
Triethyltin bromide
Dimethyltin dichloride
Tetrabutyltin
Tributyltin iodide
Dibutyltin dichloride
Butyltin trichloride
Diphenyltin dichloride
GC retention
time
(min)
7.10
7.39
9.21
9.54
11.15
11.58
11.98
12.39
16.59
Calibration
curve linear
range
(ng/mL)
10-2,500
10-2,500
10-2,500
10-2,500
10-2,500
10-2,500
10-2,500
10-2,500
20-2,500
Calibration
curve
correlation
coefficient
0.998
0.999
0.999
0.998
0.999
1.000
0.999
0.999
0.997

-------
               Recovery of Tetraalkyltins by Supercritical Fluid
               Extraction with CO2 from Topsoil Samples
               (Topsoil Samples spiked with 2 ug/g Tetraalkyllin Compounds)
o
o
                 100 atm
                 10 min.
                 40 °C
350 aim
10 min.
40 °C
100 aim
40 min.
40 °C
350 atm
40 min.
40 °C
250 atm
20 min.
60 °C
                                                                               •  Tctracthyltln
                                                                               ®  Triclhylpentyltln
                                                                               •  Dlmcthyldipcntyit
                                                                               mi  Tctrabutyltln
                                                                               EI  Tributylpentyllin
                                                                               s  Dutyltripentyltin
                              Rxncrimental Conditions

-------
oo
o
         CU
         >
         O
         a
         a>
                       Recovery of Tetraalkyltins by Supercritical Fluid
                       Extraction with CO2 from Topsoil Samples
                       (Topsoil Samples spiked with 2 ug/g Tetraalkyltin Compounds)
                           100 atm
                           10 min.
                           80 °C
350 atm
10 min.
80 °C
100 atm
40 min.
80 °C
350 atm
40 min.
80 °C
                                                                                      • Tetraethyltln
                                                                                      ® Trlethylpcntyltin
                                                                                      • Dimethyldipentyltin
                                                                                      mi Tctrabutyltin
                                                                                      BI Tributylpcntyllin
                                                                                      Q Dutyltripcntyltin
                                       Experimental Conditions

-------
             SFE Conditions for Extraction of Ionic
                      Organotin  Compounds
00
              Pressure:
              Temperature:
              Time:
              Fluid:
450 atm

80 °C

30 min static followed by
20 min dynamic

CO2or
CO2 + 5% methanol
              Complexing Agent:   with or without sodium
                                diethyldithiocarbamate
                                (NaDDC)

-------
                      Recovery of Ionic Organotin Compounds From Spiked
                                        Topsoil Samples By SFE
00
K)
      fc
                                                                      Carbon Dioxide

                                                                      Carbon Dioxide with 5% Methanol
               Trimethyltin
                chloride
Triethyltin
 bromide
Tributyltin
  iodide
Dimethyltin
 bichloride
Dibutyltin
dichloride
Dlbhenyltin
dichloride
 Butyltin
trichloride

-------
     Effects of Adding Complexing Agent (NaDDC) on Recovery]
                 of Ionic Organotin  Compounds by SFE
                                                               With Complexing agent

                                                              •11 No Complexing agent
Trimethyltin
 chloride
Triethyltin
 bromide
Tributyltin
 iodide
Dimethyltin
 dichloride
Dibutyltin
dichloride
Diphenyltin
dichloride
 Butyltin
trichloride

-------
        Recovery of Ionic  Organotin Compounds from Spiked
                 Topsoil Samples by Complexation SFE
                                                                • Carbon Dioxide with 5% methnnol

                                                                C3 Carbon Dioxide
Trimethyltin
 chloride
Triethyltln
 bromlda
Tributyltin
 Iodide
DfmethyUin
dichlorlde
Dibutyltln
dichlorldo
Diphenyftln
dichlorldo
 Butyltln
trichloride

-------
00
                            Conclusions
•   Tetraalkyltin Compounds Can be Extracted Quantitatively from Spiked
    Soil Samples by Supercritical CO2 at Moderate Pressures and
    Temperatures (e.g., 100 atm and 40 °C).

•   Ionic Organotin Compounds Can be Extracted by Complexation SFE from
    Spiked Soil Samples with Recoveries Ranging from 70 to 90 Percent.

•   SFE Followed by GC-AED is a Promising Analytical Technique for
    Determination of Organotin Compounds in Environmental Samples.

-------
                Acknowledgement
oo
ON
.   U. S. EPA-Las Vegas (Contract 68-C1-0029)


.   Marcela Alcaraz of Midwest Research Institute


.   Joe Tehrani of Isco Inc. (Lincoln, Nebraska)

-------
                                       MR. TELLIARD: I would like to thank all of our
morning speakers.  I think we can give them a round of applause, don't you?

             It is lunch time.  Please get back here at  1:30 so we can start the afternoon
session. There are a lot of restaurants across the way and in the hotel. Thanks for your attention
this morning. See you after lunch.

(WHEREUPON, a luncheon recess was taken.)
                                         187

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188

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                                        MR. TELLIARD:   We would like to start this
afternoon's session, please, so if we could, take some seats.  It is kind of like church.  There are
a lot of open pews down front for those of you who are hanging out in the back trying to leave
early.

             We would like to start off this afternoon's program with a discussion of metals and
what we  are going to call trace determinations or low levels or ultraclean or clean or whatever
those terms mean.  I am not too sure.  Anyhow, the media is metal, and  most of the media we
are going to be talking about is water.

             Our first speaker is  Ted Martin  from EMSL-Cincinnati.  Ted has  been at this
laboratory under many names, but the present  one is the Environmental Monitoring Systems
Laboratory, and Ted has been dealing with metals analysis for, I guess, most of his career which
has been very long and very fruitful.

             He is going to talk a little bit to you today about using ultrasonic nebulization for
determining metals by ICAP.

                                        MR. MARTIN: Thank you, Bill.
                                          189

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190

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                    DETERMINATION OF METALS IN WATER
                        BY ULTRASONIC NEBULIZATION
                    ICP-ATOMIC EMISSION SPECTROMETRY

                        Theodore D. Martin, Carol A. Brockhoff
                                        and
                                   John T. Creed

                 U.S. ENVIRONMENTAL PROTECTION AGENCY
                  OFFICE OF RESEARCH AND DEVELOPMENT
           ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
                             CINCINNATI, OHIO 45268
             Disclaimer Notice:  The mention of trade names or commercial products in this
presentation does not constitute endorsement but is only given as information relevant to this
presentation.
             For more  than ten  years now,  inductively  coupled  plasma-atomic  emission
spectrometry  (ICP-AES)  has been recognized as a  mature analytical  technique  for  the
determination of trace elements in environmental samples.  It provides rapid, reliable data and
can be used for both analyte screening and quantitative analysis.  Many laboratories consider
ICP-AES an essential tool necessary for providing complete analytical service at reasonable cost.

             The inductively coupled plasma is a unique source of high energy.  The resulting
analyses are virtually free of chemical interference with analytical linearity that covers five orders
of magnitude.  However, one drawback facing complete acceptance of ICP-AES has been the
higher limits of detection when compared to graphite furnace atomic absorption.

             Current EPA ICP-AES methodology used for compliance monitoring does  not
specifically state that pneumatic nebulization must be used in all analyses, but from the direction
given in Method 200.7, its intended use is obvious. Pneumatic nebulizers of various designs have
proven to be very rugged and useful in the analysis of complex matrices.  Unfortunately, they
are also one of the limiting factors in achieving  lower detection limits. When using pneumatic
nebulization, a general approach to lowering detection limits in the analysis of aqueous samples
has been to preconcentrate the sample by evaporation prior to  analysis. This has been useful,
particularly in the analysis of drinking water, but the procedure is considered time consuming,
especially when the nature of the sample does not require digestion prior to analysis.

             A more direct approach to lowering ICP-AES detection limits is the use of a more
efficient nebulizer so more analyte will be transported to the plasma. The continued development
work on ultrasonic nebulization has been one response to this need.  Although both pneumatic
and ultrasonic nebulizers generate an aerosol, their functional aspects are somewhat different.


                                        191

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              In pneumatic nebulization, a pressurized flow of argon is used to aspirate and
break up the liquid into small droplets, while in ultrasonic nebulization,  as illustrated on Slide
1 (a schematic of the GET AC U-5000) liquid is peristaltically pumped through the sample inlet
and flows over a  chemical-resistant plate surface covering a  piezoelectric transducer  that is
generating an acoustical wave perpendicular  to  the flow of  liquid.   The energy  from this
acoustical wave fragments the liquid into a fine mist aerosol.  The transducer in the CETAC U-
5000 is powered by a small auto-tuned radio-frequency generator operating at 35 watts incident
power at a frequency of 1.4 MHz.  Heat from the  transducer is  dissipated through the heat sink
which is air cooled.  Argon entering the spray chamber at the gas inlet carries the fine mist
aerosol through the heating  tube where most of the water  is stripped  from the droplets by
evaporation.  As the dry aerosol and water vapor proceed into the condenser, the water vapor
condenses and is  removed at the drain allowing a relatively dry aerosol  of analyte  to be
transported to the  plasma.  Removal  of water from the aerosol is essential to reduce solvent
loading of the plasma and to stabilize its performance.

              The ultrasonic  nebulizer has four operational parameters: sample flow rate, argon
flow rate, desolvation temperature, and coolant temperature. Of the four, the argon flow rate and
desolvation temperature are considered the two most critical parameters affecting performance.

              Prior to the development of Method  200.15, it was decided to incorporate the same
uniform sample preparation procedure used in other EMSL-Cincinnati spectrochemical methods.
This decision dictated that  the calibration standards be prepared in acid solution containing 2%
(V/V) nitric and 1% (V/V) hydrochloric acids.

              This was  readily  accomplished with an appropriate  dilution of the calibration
standards normally used with  pneumatic nebulization.  These  standard  solutions  had been
previously verified for  accuracy and were  of an analyte combination  known to  be free of
interelement spectral interference.    Using pneumatic  nebulization  they showed  excellent
agreement to a quality control check solution purchased from SPEX Industries.  However, when
verification was attempted using ultrasonic nebulization, the analysis data  for arsenic, chromium,
and selenium in  the  SPEX  QC solution were elevated by 80 percent, 46,  and  35 percent
respectively (see Slide 2).

              From the  investigation of this elevated response, it was  concluded that the +5
valence state of arsenic  and the +3  valence state of chromium must form a more  stable dry
aerosol during desolvation. This allows more analyte to reach the plasma, thus giving greater
signal intensity.

              In  the  case  of selenium, the explanation of enhancement is probably similar.
However, the cause is a  concomitant effect from other analytes in the  QC solution.

              To determine that the ultrasonic transducer was  not a factor in the enhancement,
the transducer assembly  was removed from a BAIRD Corporation UDX unit and replaced with
the THERMO JARRELL ASH fixed  crossflow nebulizer spray  chamber  assembly.   This


                                           192

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convenient change allowed desolvation to be applied to the aerosol generated from the pneumatic
nebulizer.

              It should be noted that the heating tube on the UDX was intended to be operated
at a temperature of 250 degrees centigrade and was not altered for this investigation.

              Given on Slide 3 is a brief data summary of that work.   Please note the four
operational conditions under which intensity counts were collected:  heat on, chiller on; heat on,
chiller off; heat off, chiller on; and heat off, chiller off.  (The chiller supplies the coolant to the
condenser.)  Except for these operational changes, all other analytical  conditions were  held
constant.

              It is apparent from the data that the  intensity counts for  As+3  and hexavalent
chromium, for the conditions heat on, chiller on and heat on, chiller  off are much lower than the
corresponding counts for As+5 and trivalent chromium, collected under the same conditions and
listed in the same column.  Note the greatest difference occurs under the conditions heat on,
chiller on which is the normal operating condition of an ultrasonic nebulizer.   Also, the data
given in the right-hand column for the conditions where the heat is off show excellent agreement
between the two valence states of each element.

              The elevated response of the SPEX QC solution is attributed to this difference in
valence state response, since it is known that As+5 and trivalent chromium compounds were used
by  SPEX  in  the preparation of the  QC solution, while As+3  and hexavalent chromium
compounds were used in the preparation of the EMSL-Cincinnati calibration  standards.

              To eliminate the difference between valence states, 50 percent hydrogen peroxide
was added to 1 mg/L solutions of each analyte and analyzed using the GET AC  U-5000 ultrasonic
nebulizer.  The intensity counts collected are  given on Slide 4.

              The As+3  and the  Cr+6 intensity counts for  the  solution  without hydrogen
peroxide, are again much lower than the intensity counts for As+5 and Cr+3 in the corresponding
single-element solutions.   However, when hydrogen peroxide is added, the AS+3 is oxidized to
As+5, and the hexavalent chromium is  reduced to trivalent chromium.  The analysis of these
solutions now provide the same level of intensity counts as the As+5 and trivalent chromium
single-element solutions.   Also, it is worth noting that the addition of hydrogen peroxide to the
As+5 and Cr+3 had no effect on the signal response.

              The actual  phenomenon that occurs during desolvation causing the two valence
states of arsenic and chromium to give different signal intensities  cannot be explained at this
time.  Two possible answers for the lower intensity counts may be that a portion of the analyte
is either plating onto the  walls of the  heating tube  or recombining with the condensed water
vapor and lost to waste.
                                           193

-------
              In any event, it appears that the chemical nature of these analytes and the dry
aerosol  resulting  from  desolvation can  affect analyte  transport to the  plasma.   As stated
previously, this comparative work was done in a mixed acid solution of nitric and hydrochloric
acids. A similar phenomenon was also observed in single-acid and no-acid solutions.

              To determine if this same effect occurs in environmental waters, two aliquots from
four different  water  sources were fortified to a concentration of 1 mg/L  with either As+3 or
As+5.  These aliquots were then analyzed in the same manner using the CETAC U-5000.  The
intensity counts for those analyses are given on Slide 5.

              It is obvious from the data given in the right-hand column that As+5 responds the
same in environmental waters as in the standard solution.  The same is true for As+3 samples
in the 1 st column,  except for the Cincinnati, Ohio  tap water.  Because it was known that of the
four waters, only the tap water was chlorinated, a sample was collected at the filtration plant
prior to  chlorination.  When this sample (Tap-No  CL2)was fortified  with As+3, similar  data to
the  other non-chlorinated waters were obtained. From other studies, it is known that chlorine will
oxidize As+3 to As+5 in waters of neutral pH.  Therefore, it is not surprising to find the same
occurrence in an acidified chlorinated water.

              Since  acid preservation alone does not oxidize As+3 to As+5, aliquots from two
of the environmental  waters fortified to a concentration of 2 mg/L with either As+3 or As+5 were
subjected to the total recoverable digestion.  These digested aliquots were  then analyzed along
with non-digested aliquots taken from the same solutions.  Following analysis, hydrogen peroxide
was added to the analysis solutions and then  reanalyzed.  The instrument was calibrated using
an As+5 standard solution.

              Data from these analyses are presented on Slide 6.  It is apparent from the data
that either sample  digestion or the addition of hydrogen peroxide can be used to convert As+3
to As+5 prior  to analysis.

              On  Slide 7 analyses data  are  given for the  same environmental  waters where
aliquots had been fortified with 2 mg/L with either hexavalent or trivalent chromium.   The
instrument was calibrated using  a trivalent chromium standard solution. Note that the analysis
data for the single element hexavalent standard without peroxide gave low recovery, as would
be expected. However, when a cation is  added such as sodium (5 ppm) that will bind with the
negative chromate ion  and form a chromate compound, a larger percentage of hexavalent
chromium  reaches the plasma.  When an additional amount  of sodium  (80 ppm) is added,
complete recovery is obtained.

              Although  it is evident that there is equal recovery  of both  valence states of
chromium from environmental waters, the addition of peroxide would be helpful, because less
wash out time is required for higher levels of trivalent chromium, therefore reducing possible
memory effects.
                                           194

-------
              From the data presented, it must be obvious that the preparation of arsenic and
 chromium calibration standards is critical and that these analytes must be in the same valence
 state in standards and samples alike.  For this reason, the addition of hydrogen peroxide to both
 samples and the calibration standards containing arsenic and chromium will be a requirement of
 Method 200.15.

              The enhancement of selenium is a concomitant effect from other analytes present
 in solution. Normally, a concomitant effect is recognized as an interelement interference where
 the interferant is present at much  higher concentration than the analyte of concern.

              If a ratio is calculated between the  sum of the other analytes to  selenium in the
 multianalyte standard given on Slide 8, the ratio is only 6.4. Also, the ratio between the other
 analytes and selenium in ICP-19  is only 18. However, from the data given on  Slide 8, it is
 apparent that when the instrument is calibrated using the  multianalyte standard and the three
 standard  solutions  listed,  each  containing  1 mg/L of selenium are  analyzed as  samples,
 significantly different selenium concentrations are determined for ICP-19 and the single element
 selenious  acid solution.

              To determine which of the other analytes cause the enhancement, 1 ppm single
 element solutions of the other 18  analytes were prepared and fortified with  1 ppm of selenium.
 The instrument was calibrated using a single element solution of selenious acid.

              As indicated by the effect from  arsenic listed at the top  of Slide 9, responses
 ranged  from no effect from  elements  such as  arsenic, antimony, cadmium, and thallium  to
 significant enhancements like that from  aluminum and iron.  When  the concentration of the
 interferant was increased, very little or  no change  occurred as shown  for the  10 ppm solutions
 of aluminum and iron.  However, when the analytes were  combined as shown  by the 20 ppm
 solution of aluminum and iron, there is additional enhancement. But this increase occurring from
 combining analytes also has limitation as can be seen from the 60 ppm solution of aluminum,
 beryllium, chromium,  iron, titanium and vanadium.  These analytes were the elements that
 provided the greatest enhancement as single element solutions.

              At the bottom of Slide 9  are the determined concentrations for ICP-19 which
 contains 1 ppm selenium and ICP-19 fortified with an additional 1  and 2 ppm selenium.  These
 data confirm that the enhancement effect is nearly linear. Unfortunately, a concomitant matrix
 effect can only be circumvented either by matrix matching the calibration standard to the sample
 or analysis by method of standard additions.

              Slide 10 shows the enhancement  effect on selenium from  calcium, sodium, and
magnesium, the major cation constituents present in all ambient waters.  The enhancing effect
from calcium is most prominent up to 50 mg/L,  while the maximum effect from sodium would
appear to be a concentration above 300 mg/L.
                                          195

-------
              For magnesium, it could  be estimated  that the maximum effect occurs at  a
concentration between 10 and 50 mg/L.  Also, the selenium response in the 300 mg/L magnesium
solution would indicate that a possible reverse trend in enhancement  will occur when these
constituents are present in very high concentrations.

              To avoid methods  of standard addition  for the analysis of drinking water and
ambient waters, a more practical approach is to prepare  a calibration standard in a matrix of the
major  constituents.   The  concentration of the  major constituents in the  standard  should
approximate that of the sample matrix.

              After analyzing combination solutions of calcium, sodium, and magnesium where
the concentrations of all three  analytes were varied, a compromise combination of 40 mg/L
calcium,  10 mg/L magnesium, and  20 mg/L sodium was  selected as the  preferred matrix.
Analysis of this standard as a sample is displayed at the top and right-hand side of Slide 11.

              Also, on Slide 11 are the comparative data for the analysis of 1 mg/L selenium
in environmental waters using both a single  element and mixed standard  calibration.  The
enhanced selenium data obtained from the single element calibration are given in the 1 st column,
while the data from the mixed standard calibration are  in the 2nd column.  To the right of the
selenium data are the analyses data of the major constituents in these waters. The concentrations
listed for the rain water are attributed to  storage in a concrete cistern. Please note that when ICP-
19 was analyzed  using the mixed standard  calibration,  the determined value for selenium was
within 5 percent of the stated true value of 1 mg/L.

              Given on Slide  12 is a partial listing of ultrasonic ICP-AES MDLs and MDLs
determined by ICP-mass spectrometry  and  stabilized temperature or platform graphite furnace
atomic absorption.  All values are expressed in ug/L.

              For the first  two groups of seven analytes, all  respective  MDLs between the
techniques  appear to be within a factor  of 5  and are at a concentration that is sufficiently low to
ensure that the methods will provide accurate  and reliable determinations at the listed MCL
concentration.

              In  the bottom group of the ultrasonic ICP-AES MDLs, only selenium appears to
meet the old criteria that the method MDL should be at  least 1/5 the MCL for use in compliance
monitoring of drinking water.  Although MDLs can always be lowered  by preconcentrating the
sample prior to analysis, the purpose of using ultrasonic nebulization is to avoid the extra time
and cost of sample processing.

              Since the  Office of Ground Water and Drinking  Water now uses acceptance
criteria to determine adequate  laboratory performance,  the listing  of ultrasonic ICP-AES as an
approved  drinking water method may depend more  on meeting  the required performance
acceptance criteria than on reaching a particular MDL.
                                           196

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             The following is a brief summary of Method 200.15. The method is in draft form
in the EMMC format and is applicable to the analysis of 32 analytes. It is proposed for the
analyses of clean waters and currently  is not intended to be used in the analysis of NPDES
discharge samples.

             The Method 200.2 sample preparation procedure is included for total recoverable
analysis of samples containing particulate material and provides for direct analysis of drinking
waters where turbidity is less than 1 NTU.

             As stated earlier, the addition of hydrogen  peroxide  to all  samples and the
calibration standards  containing arsenic and  chromium will  be required.   Also,  a specific
preparation of the selenium calibration standard will be required to compensate for  matrix
enhancement.

             The method will include  the same required quality control common to all other
EMSL-Cincinnati spectrochemical  methods.   MDL, precision, and  recovery data  on  waters
collected from five different sources will be provided as statements of performance and for
comparative  use by other analysts in assessing their  own laboratory performance. The method
will be  included in a supplemental manual  to Methods for the Determination of Metals in
Environmental Samples.  This  supplemental manual is also in  draft form. However, it should
be available  for review sometime this summer.

             This concludes my presentation.
                                   REFERENCES

1. FASSEL, V.A. and BEAR, B.R., SPECTROCHIMICA ACTA 41B, No. 10,1089-1113,1986.

2. OLSON, K.W., HAAS, W.J. Jr., AND FASSEL, V.A., Analytical Chemistry, Vol. 40,
No. 4, 632-637, April 1977.

3. TARR,  M.A., ZHU, G., AND BROWNER, R.F., Applied Spectroscopy, 45/9, 1424-1432,
1991.

4. TARR, M.A., ZHU, G., AND BROWNER, R.F., Journal of Analytical Atomic Spectrometry,
Vol.  7, 813-817, September 1992.


                                       MR. TELLIARD:  Thank you, Ted.  Wait, wait,
don't escape.  They  are slow getting to the mic.   Any questions?  Are you out there?  (No
response.)

                                       MR. TELLIARD:  Thanks, Ted.


                                        197

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198

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?u°/ooo

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K)
O
O
     ULTRASONIC NEBULIZATION

        DESOLVATION EFFECT


SPEX       RECOVERY        PERCENT

ICP-19          mg/L           INCREASE


 As            1.80             80%


 Cr            1.46             46%


 Se            1.35             35%
       As & Cr  - Attributed to Different Stable Valence States


       Se      - Concomitant Effect from Other Analytes
                            SLIDE 2

-------
N)
O
                PNEUMATIC NEBULIZATION
                W/WO  250°C  DESOLVATION
               SINGLE  ELEMENT SOLUTIONS
ARSENIC - 2 ppm
 CHILLER ON
  As + 3
  As +5
 CHILLER OFF
  As 4-3
  As 4 5

CHROMIUM - 1 ppm
 CHILLER ON
  Cr -f-3
  Cr 4-6
 CHILLER OFF
  Cr 4-3
  Cr 4-6
                               INTENSITY COUNTS
                            HEAT ON        HEAT OFF
 970
1790

1030
1790
                              4090
                              1660

                              4440
                              1930
                            SLIDE 3
2900
2930

2350
2400
                4250
                4150

                3400
                3350

-------
                 DESOLVATION EFFECT
        SINGLE ELEMENT STANDARD SOLUTIONS
       VALENCE             1 mg/L             INTENSITY
       STATE               STD               COUNTS
                      H3AsO<                  12830
                      H3AsO4 + H2O2           12760
§        +3           As2O3                    7950
                      AsO3 + H2O,             12620
         + 3           Cr (NO3);)                43270
                      Cr (NO3)3 + H2Oa          43140

         4-6           CrO3                   30740
                      CrO3 -f HEO^             43300

                           SLIDE 4

-------
                    ARSENIC
               DESOLVATION EFFECT
             ENVIRONMENTAL WATERS
UJ
      SOLUTIONS
      1 mg/L
 INTENSITY COUNTS
As + 3         As + 5
I 	 	 	 	
STD
CINTl TAP
TAP - No CI2
RAIN WATER
WELL WATER
POND WATER
8080
11550
9190
8520
8960
8990
11000
11970
12280
11800
11500
11740
                       SLIDES

-------
                              ARSENIC
                     ENVIRONMENTAL WATERS
                          Fortified  - 2 mg/L
                         Calibration - As + 5
          SAMPLE
          SOLUTION
NOT DIGESTED
As f3    As 4-5
       TOTAL RECOVERABLE
         As f3     As +5
to
o
STD
RAIN WATER
WELL WATER
1.25
1.20
1.44

2.19
2.10
2.02
2.12
2.02

2.21
2.04
          H2O2 Added
           STD
           RAIN  WATER
           WELL WATER
 2.08
 2.04
 1.94
1.98
2.04
2.08
1.99
1.90
2.08
1.93
                                 SLIDE 6

-------
Chromium
Environmental Waters
Fortified - 2 mg/L
Calibration - Cr-f 3
2% HNO
Solution 1% HCI
L.
Cr-f 6 Std 1.53
Cr + 6 + 5 ppm Na 1.88
Cr-f 6 -f 80 ppm Na 2.06
Cr-f 6 - Cinti. Tap 2.01
Cr-f 3 - Cinti. Tap 1 .94
Cr-f 6 - Rain Water 2.01
Cr f3 - Rain Water 2.08
Cr-f 6 - Well Water 1.93
Cr-f 3 - Well Water 2.00
Cr-f 6 - Pond Water 1.90
Cr-f 3 - Pond Water 1.93




Acid
H20;>
2.04
_
-
1.99
1.95
1.99
1.96
1.93
1.94
1.99
1.95
SLIDE 7

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     SELENIUM
DESOLVATION EFFECT

     CALIBRATION
MULTIANALYTE STD., mq/L
Ag 0.2
As 2.0
B 0.2
Ba 0.2
Ca 2.0
Cd 0.4
Cu 0.4
Sb 1.0
Se 1.0
ANALYSIS           Se
SOLUTIONS         mg/L

CALB. STD.          1.01
EPAQCICP-19       1.35
1 ppm KSeCX        0.73
       <-    o

          SLIDES

-------
O
-J
                       SELENIUM
          CONCOMITANT - DESOLVATION EFFECT
                 Calibration - 1 mg/L H^SeO
1 ppm Se
Solutions
1 ppm As
1 ppm Al
1 ppm Fe
10 ppm Al
10 ppm Fe
20 ppm Al, Fe
60 ppm Al, Be, Cr, Fe, Ti, V
ICP-19
ICP-19 + 1 ppm Se
ICP-19 + 2 ppm Se
Se
mg/L
1.01
1 .46
1.55
1.57
1.47
2.04
1.98
1.96
3.80
5.62
Percent
Increase
1%
46%
55%
57%
47%
104%
98%
96%
90%
87%

-------
O
oo
         SELENIUM
 EFFECT OF Ca, Na, & Mg
 CALIBRATION - 1  mg/L H.SeQ,

1 ppm Se Solutions      Se, mg/L
  Ca     1 ppm          1.12
        10 ppm          1.46
        50 ppm          1.81
       100 ppm          1.88
       300 ppm          1.89

  Na     1 ppm          1.14
        10 ppm          1.25
        50 ppm          i 52
       100 ppm          1.64
       300 ppm          1.75

  Mg     1 ppm          i 29
        10 ppm          1.77
        50 ppm          1.97
       100 ppm          2.00
       300 ppm          1.88
              SLIDE 10

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NJ
O
                        SELENIUM

                ENVIRONMENTAL WATERS
                   Fortified - 1 mg/L Se

                     Concentration, mg/L

                            Se
Solutions
H^SeOa Std.
Mixed Std
ICP-19
Cmti. Tap
Rain Water
Well Water
Pond Water
H,SeO,
Calb.
1.02
-
1.92
1.65
1.57
1.87
1.92
Mixed Std.
Calb.
.
1.01
1.05
1.03
0.94
1.03
1.04
Ca
.
40.3
1.01
26.6
10.3
78.9
42.9
Mg

10.0
1.01
6.90
1.10
21.4
9.20
Na
_
20.0
-
10.7
4.70
30.6
15.5
                              SLIDE 11

-------
to
(—*
o
                  COMPARISON OF MDL'S

                  DRINKING  WATER CONTAMINANTS

                  CONCENTRATION,/xg/L

ANALYTE
As
Ba
Be
Cd
Cr
Cu
Ni
Pb
Sb
Se
Tl

MCL
50
2000
4
5
100
1300
100
15
6
50
2
ULTRASONIC
JCP-AES
3
0.2
0.05
0.4
2
2
0.7
4
3
10"
6
200.8
ICP-MS
1.4
0.8
0.3
0.5
0.9
0.5
0 5
0.6
0.4
7.9
0.3
200.9
STGFAA"
1.0
-
0.04
0.1
0.2
1.4
1.2
1.4
1.6
1.2
1.4
           'DETERMINED IN TAP WATER


           (1) BASED ON 1X DETERMINATION


                             SLIDE 12

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                                         MR. TELLIARD: Our next speaker is going to be
talking about ultra-clean sampling, storage, and analytical strategies for accurate determination
of trace metals in natural waters. Nick Bloom is going to be going over a lot of issues that right
now we are addressing in the Agency.

             Nick is here under the auspices of EPRI, I think, and I hope you enjoy his talk.
                                         MR. BLOOM:  I am going to be talking today about
a historical perspective of methods and things that we have  learned about ultra-clean sampling,
storage, and analysis of trace metals. It doesn't represent a specific research project but, rather,
represents an evolution over the last 15  years in our laboratory of pushing detection limits to the
point where we can measure trace metals in ambient waters at their actual concentrations.

              The concentrations that  we look at are typically  much, much lower than EPA-
mandated monitoring criteria, but I think there is a trend toward lowering those values.  For
example, in Minnesota, I believe, they have lowered the monitoring requirements for mercury
in ambient waters; they have to be monitored at the ambient level, and that may be a wave of
the future.

              I would like to credit EPRI who has funded most of the work over the  last 10
years that we have undertaken to develop these methods and  also give some credit to open ocean
oceanographers such as Bill Fitzgerald  and Claire  Patterson  and  Gary Gill who have developed
a lot of these methods for doing very low level work in the open ocean.

              It is only  somewhat of a  surprise to us that we found that when applied to
terrestrial systems, waters in the terrestrial environment are typically as low in trace  metals as
they are in the open ocean.

              The first slide (Figure  1) is probably my  most interesting.   This  is a plot
representing the mean concentration of mercury in pristine surface water samples taken by simply
going through my filing cabinet containing hundreds of reprints on the subject of mercury in the
environment and grouping them in two-year intervals or so, depending on how many reprints I
had per year, and taking the mean value for these unpolluted samples and the standard deviation
of that value.  Typically, for each data point, there are about 12 different research papers.

              It should be noted that  this represents the best science  at the  time.   This isn't
routine  compliance monitoring. This is university open ocean research and so  forth.

              As you can see, the axis  starts  from 1970  and  goes up to 1990.  There is a
dramatic decrease in both the mean concentration  and the standard deviation of those values for
water which we  now understand should have all  roughly the same  concentration which is
indicated by the leveling out of the curve after  1995 or so at about 1 ng/L.
                                          211

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              I should note that the error bars which are the two lighter lines on the top and the
bottom are the standard deviation of the mean, and we had to plot them in that manner in order
to fit them on the scale. If we plotted just the standard deviation, then we would have scales that
were ten times higher.

              This is actually quite an interesting graph.  One's first  hope would be that this
indicated how the world is becoming cleaner and cleaner as environmental laws come into place,
but it turns out that is not the case. It represents how the laboratory researchers have become
cleaner and cleaner in implementing their sampling, largely their sampling strategies.

              This isn't only the case  for mercury. Most of my discussion today will focus on
mercury, because we have the largest  amount of this type of QA information for mercury, and,
if anything, it is the most difficult of the elements to correctly obtain ambient values for, but the
same trend has been observed for virtually all of the trace metals.

              In this  case (Figure 2),  the graph on the left indicates a  sort of three-point curve
of the same type showing 1965, '75, and '85, and the mean open ocean concentration for copper,
zinc, iron, and mercury. As you can see, there is this same general trend, dramatically decreasing
from the '60s to the '80s, typically by  a factor of 100 or so.

              The graph on the right is a graph for one lake in northern Wisconsin.  We started
doing most of this work for EPRI on  this lake in a process-oriented study trying to look at the
fate of mercury in the environment. The first bar on that graph, I believe, is 198...I  can't see it
now...looks like  1983, and it represents the accepted value of mercury in that lake as conducted
by the Wisconsin Department  of Natural Resources.

              The second bar represented a sort of a hybrid. It was a grab sample collected by
the Department of Natural Resources but sent to the University of Connecticut to Bill Fitzgerald's
lab for analysis in 1985.

              The following bar which is too small to even fit on the graph represents the values
that we typically find in that lake now that we employ clean techniques from the beginning to
the end.

              I think this picture is quite typical.  While the oceanographers have traveled  the
path down this slope  to being able to measure ambient levels  quite reliably for most metals,  I
think that many compliance monitoring and State labs of hygiene and so  forth are still at  the
other end of that graph as was supported by the fights that we had when we presented this data
before we won the project.

              The State of Wisconsin simply wouldn't believe it and ultimately resorted to  the
claim that "well, they had 20,000 data points that showed they were right, and we only had 12
that showed we  were right."
                                           212

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              So, thinking about this type of trend and my experience in analytical chemistry for
trace metals, led me to develop this simple schematic diagram for  the  downward spiral in
concentrations of mercury in the environment (Figure 3).  Essentially, it is an interactive loop
where the top one is discoveries near the detection limit.  Because I think that the tip-off is if
you are measuring some constituent and  all of your determinations are near the detection limit
and you talk in a language that emphasizes whether or not  you have "hits," then I think you are
at a point where you are probably not getting very real data. Typically, you are overestimating
the mean value of that constituent.

              This puts a pressure, then,  to develop, at least in the case of trace metals, cleaner
sampling techniques. I should note that typically in trace metal work, instrumental detection limit
has not  been the problem. The detection limit has been a function of the variability of the blank.

              And measuring things  at the method detection limit required  improvements in
clean sampling techniques which then led to the disappearance of all of the hits which then, in
turn, mandates improvements in analytical detection limits.  And then you are  ready for another
crank of this turn  until you  get  to a point  where you have  consistent  results that are
geochemically meaningful.

              So, I am mostly going to talk today about clean sampling techniques, but I will
talk a little bit about detection limits just in the  case of mercury to give you an idea of how far
we have come.

              This table (Figure  4)  indicates seven different common analytical methods for
mercury and the absolute peak detection  limit in nanograms.  You can see they vary by seven
orders of magnitude.

              In the '60s in this country and still in most of the world today, the colormetric
technique was the standard technique for mercury, and you see it has a detection limit of about
1 microgram.  By the mid '60s and almost to the present day, cold vapor atomic absorption has
become the standard for mercury.  It has a detection limit much better, about 20 pg, although
most laboratories and, I believe, the EPA methodologies still typically see this method as one
where the sample is purged directly into  the analyzer.

              An enhancement of the method detection  limit by up to  a factor of 1000  is
routinely obtained in research labs by preconcentrating the  mercury first onto a gold trap before
admitting the mercury into the analyzer. This allows much  more mercury, a much larger sample,
to be effectively input into the detector.

              In the mid '80s, improvements were made in atomic fluorescence detection, the
second  one on the list, which improved  the detection limit over atomic absorption by about a
factor of 50 to 100.  At the latest mercury meeting I attended,  it seems like almost all research
laboratories in the world  have now gone  over to  atomic fluorescence  in  place of atomic
                                           213

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absorption, although atomic absorption is still certainly the technique of choice for a routine
monitoring lab.

              So, the evolution  of the detectors  has trailed  the evolution in clean handling
techniques to keep pace.  Very sensitive detectors are also necessary if you then begin to look
at mercury speciation, where each component is only a fraction of an already small total.  This
is a schematic of the technique we use for measuring total mercury in the sample (Figure 5).  It
is digested and placed  into a bubbler, reduced with stannous chloride,  and then the gaseous
mercury is purged onto a gold trap.

              The gold trap is then thermally heated into an atomic fluorescence detector, and
this can give us detection limits down in the parts per quadrillion range.

              This setup (Figure 6) shows a technique for determining mercury speciation. In
this case, an ambient sample is ethylated with sodium tetraethylborate in the aqueous phase which
forms volatile ethyl analogs  for  methylmercury and  divalent  mercury.  Dimethylmercury and
elemental mercury remain in their original volatile state.

              These can all be purged out and collected onto a Carbotrap™ column which is
then thermally desorbed into a GC unit, and the separated peaks are determined by atomic
fluorescence.

              For mercury, in particular, but also  for several of the metals such as arsenic and
selenium, speciation is very, very important to understanding toxicity and biogeochemical fate.
As we move into  a time period where speciation is recognized as necessary for monitoring metals
in the environment,  extremely sensitive detectors will be required, because often these species
may be present at only  a fraction of l/1000th of the total metal there, but they may actually be
more biogeochemically important than the dominant, relatively inert species.

              So, in our work with mercury, we typically analyze eight different fractions for
mercury,  and this table (Figure 7) indicates the detection limits in the  second column which
range,  in the case  of elemental  mercury, from close to the  parts per quintillion up  to total
mercury which is reagent limited at about 50 parts per quadrillion.

              All of these concentrations are typically well below...the detection limits are well
below the actual  environmental level which can then allow you to feel relatively certain that the
numbers you are getting are accurate.  If you are detecting a species  at the same level that it
exists in the environment, then, certainly geochemically, your results are meaningless.

              So, having said that about detectors, I will just go briefly through the  clean
techniques that we have employed in the field and laboratory and some of the things of concern
that you have to  have.
                                           214

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              When we are in the field, we start with, in this case, water sampling with an all
plastic boat.  The boat has been acid cleaned previously by washing down with acid, and then
it is stored in an area which is away from, say,  automobile exhaust and so  forth and so on.
Whenever it is taken out to the field, it is washed with lake water and sponged down and rinsed
prior to each use.  We never use a metal boat in our research in these lakes.

              The sample bottles are prepared in a clean lab, and they are all teflon bottles.
They are cleaned by boiling in concentrated nitric acid for 48 hours and then rinsed and filled
with ultra high purity water and low mercury hydrochloric acid.

              The lids are sealed with a wrench to minimize diffusion, through the threads, of
gaseous mercury, and then they are double bagged in the clean room into polyethylene bags to
keep dust and dirt out and to provide  somewhat of a mini-clean room environment in the field
for the field crew to be able to use the bottles.

              In the field, there are typically three people in a sampling crew, one person who
takes notes and then the other two  people are called "clean hands"  and "dirty hands."  "Dirty
hands" is the person who grabs the bag with the sample bottle out of the  box and opens the
ziplock bag.  That is all that person can do. Then, "clean hands," wearing clean gloves, reaches
into the bag,  pulls out the bottle, collects the sample, replaces the lid, puts it back into the bag,
and then "dirty hands" can then close  the bag back up.

              In this way, the sample bottle has never  contacted anything except clean room
environment  and ambient air.

              This is a photo showing collection of the water sample by "clean hands."  In this
case, the water is being pumped through a teflon tube from depth in the lake.

              After the sample is collected, the lid is put back on, and screwed back down with
a wrench. There has been documented evidence which indicates that if the lids are not screwed
on tight enough, that in storage, mercury vapor can diffuse up through the threads into the bottle
and give you inflated answers.

              Now, of course, once you get the samples back to the laboratory, you have the
question of storage to consider. I should note that all of our work on geochemical problems has
been done using teflon bottles or, in the worst case, glass bottles with teflon lids.

              However, it is standard  practice, I believe, to use polyethylene bottles, and for all
other metals  these are documented to  work quite well, but it is a well known and documented
fact that they can't be used for mercury, although they are still accepted for collecting mercury
samples, I believe, by EPA protocols.
                                          215

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             This is a test that was done in 1975 by  Dave Robertson (Figure 8) where an
acidified sea water sample is placed into  standard ultra-clean polyethylene bottles  used for
oceanographic work and then stored in the laboratory for a period of time.

             The line on the bottom, the results indicated by the red line that is relatively level,
was stored in a plywood box out of doors. The blue line was stored on a bench top, and the line
reaching up to 200 after only 20 days was stored on the  laboratory floor.

             These dramatic increases in mercury concentration in these polyethylene bottles
is due to diffusion of mercury through the  polyethylene. This has been documented at lower
levels in our own lab where we  have  collected water samples in an ultra-clean EPA type
sampling bottle and stored them in one laboratory where the room air concentration was very
low, 2 ng/m3, and witnessed an increase in concentration of 1 ng/L over three weeks which is
small, but that did double the ambient concentration in the bottle.

             Then we moved it to a laboratory which had 16 ng/m3 in the air which is still very,
very low for a laboratory, and the concentration jumped  to 20 ng/L in three days.

             The opposite can also happen in an unpreserved sample. If you have high levels
of mercury in the bottle, it can diffuse out,  and you can  get lower results.

              So, one of the things, obviously, that  you have to  do if you  are going to do
mercury is you have to pay attention to the mercury concentration  in the air.  Unlike all your
other metals where you can have a clean room that essentially uses HEPA filters to  remove the
paniculate metals, in the case of mercury, most of the  mercury is not on the particulates, but in
the gas  phase.

              So, a standard clean room can be the dirtiest place in the whole building as far as
mercury goes. So, you have to develop some way to remove the mercury from the room air, and
at the very least, know what the concentration is.

              This is just an example of what we have done in one laboratory of ours that had
high mercury levels when we started, 320 ng/m3 (Figure 10).  The first thing we did was bring
in large volumes of outside  air which is typically quite low in mercury.  That dropped the
concentration to 80 ng/m3.

              Our investigation indicated that the walls of the lab were painted with a latex paint
that contained mercury, and we covered those by painting them with a paint that had sulfur added
to it. That reduced Hg levels somewhat.

              Then we also  discovered that laboratory  sinks were contaminated from historic
spills of mercury or dumping of reagents or something in the past.  We removed the sinks, and
that dropped the concentration to a reasonably low level, 15 ng/m3, which would be acceptable
for doing mercury at ambient levels.


                                           216

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              Finally, then, we took the incoming air from outside which is in the city of Seattle
and typically averages about 10 ng/m3,  and we added gold filters to the incoming air to remove
the mercury that is coming into the laboratory air.

              These gold filters are made by impregnating cloth with metallic gold using wet
chemistry.  That reduced the air in the incoming clean hood to about 1 ng/m3, and it reduced the
room air ultimately to 2 to 10 ng/m3.  Typically, it was about 4 ng/m3.

              So, these are the types of considerations that you have to take.

              Some other just really quick kind of checks that we have done that some people
might be surprised about.  We looked at the magnitude of various potentially contaminating
activities in the laboratory (Figure  11).  The first four bars represent a bottle of water, ambient
water, that  was left open for one day in various places in the building, and you can see that the
concentration anywhere from doubled to went up by a factor of seven in one day.

              The next two bars represent the incremental contamination that could occur by
breathing once on the sample. Typically, people have mercury amalgams in their mouths, and
that could cause about a doubling of the concentration from one misplaced breath.

              That very tall bar there represents what happened when the sample was touched
by the sampler's finger, an uncleaned finger.  Just to give you an idea that it is not really coming
out of the person, that it is really because of, you know, spit and so forth on people's hands as
they work throughout the day, we used a gloved finger and got no contamination using a clean
room glove, and then we used an acid-cleaned finger, believe it or not. After washing my hands,
I then dipped them in 10 percent HC1 for a bit and rinsed it off and stuck that finger, the entire
finger, into the bottle, in fact, and it gave a very small increase in concentration.

              This type of contamination has been documented although not...I mean, has been
shown but  not published for other metals as well, when I was at Bartelle.

              Here are some even more  surprising findings (Figure 12).   This  is levels of
mercury in various water and acids that you find in the laboratory.

              The first set of bars are  water, and the very  first bar there is a milli-Q of water,
of course, which is too low to detect.  Tap water is very, very low  in mercury, and when there
is a doubt, it is always better to use tap water than some other so-called purified water in the
laboratory,  as the next three bars will show.

              Those are deionized laboratory water, including the tallest one there which is
14,000 ng/L compared to, say, the tap  water which was about 0.2  ng/L.  That is the same tap
water going into the deionizing system  that came out at  14,000, so you can see the efficiency of
that system for cleaning up for mercury.
                                          217

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              It turns out, after much investigation, the reason we learned for this very strange
behavior is that deionizing columns are recharged with sodium hydroxide, and apparently the
only really good kind of sodium hydroxide for this purpose is a  kind made in a mercury cell
electrolytic plant, and they said that, basically, that is tough luck.  You know, they are not going
to change their system for us. So, this is very common for deionized water.

              Then, the next set of numbers with the hatch marks are various laboratory acids
hi ng/ml.  The big point, I think, to make is that the two highest bars there are the ultrex acid,
and the cleanest acids that we find typically are the  regular old  reagent grade stuff that, you
know, costs $10 a case.

              I think it is quite common to buy the ultrex  stuff at $100 for  500 ml and just
accept it as clean and use it to preserve samples and so forth when, in fact, not only is it more
expensive, but it can be considerably dirtier.

              In the case of mercury, it is always dirtier.  The sub-boiling distillation technique
that they use to purify it for iron and sodium and so forth actually results in contamination for
mercury.

              This slide (Figure 13), then, is...well, it is hard to read, but it is trying to show for
four metals...this story is actually true for all of the EPA priority  pollutants, but for these four,
arsenic, lead, mercury, and cadmium, the first bar hi the graph shows the detection limit by the
EPA ICP methodology.

              The  second bar...this  is a logarithmic  scale, incidently.  The second bar is the
detection limit for the EPA  graphite furnace technology.

              The third bar represents a detection limit that we had obtained, back when I was
at Battelle, by using  sophisticated  preconcentration techniques  and then  suitable detection.
Typically, it was graphite furnace AA for most metals. For mercury, it was atomic absorption
at that time.

              Then the last bar is the actual typical value for these metals in the ambient water
sample.

              As you can see, the current accepted methodologies will never allow you to detect
these metals at ambient levels, often by several orders  of magnitude.   If the goal is ever to
ultimately use the data that is collected for anything more than compliance, for example, the data
that goes into data bases like the USGS data base, is going to be used for any geochemical or
long-term monitoring or something, then the current methods are unacceptable, because they will
give you essentially the same number no matter where you take the sample.

               In fact, the detection limits are such that you would  get the same number for many
polluted sites or contaminated sites as you would for pristine.

                                           218

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              To give you an example, research that we have done at Onadaga Lake in Syracuse
which may be about as mercury polluted of a site as you can imagine (had a chloralkalide plant
for a long tune discharging  100,000 pounds or so of mercury into it) even now, the mercury
levels in the water there are about 25 ng/L which is about 25 times higher than a clean lake hi
the region would contain.  Still, it would be a non-detect by the current methodology.

              Finally, just to sum up, I put together this slide to indicate how obtaining ambient
level information can actually change our perceptions  of the magnitude and importance of given
pollution-related problems.  Here we have 1970 and 1990. This is, again, for mercury.

              In  1970, the accepted belief for mercury in pristine water was about 100 to 1000
ng/L. There was speculation about the presence of methylmercury, because it was known  that
fish contain methylmercury, but, basically, nobody knew anything about what it might be hi
water.

              For polluted water such as Onadaga Lake, you got exactly the same answer.  So,
it was apparent that even lakes receiving high discharges of mercury showed no ill effects from
having that mercury, because they had the same concentrations as a pristine lake would.

              Total mercury in a fish was easy to measure at the time.  As I say, it was 1 ppm,
and it was known, like I say, that that was mostly methylmercury.

              This led to a belief that the bioconcentration factor for mercury was somewhere
around 103 or 104 which is rather low, and the  expected impact of a discharge, therefore, to a
lake would be none.  You know, it wouldn't be seen as a problem.

              Today, on the other hand, we see that  the water from that lake probably should
contain about 1 ng/L of total mercury and about a tenth of that as methylmercury. By contrast,
a polluted lake such as Onadaga Lake might contain somewhere in the range of 5 to 25 ng/L of
mercury with a similar proportion hi the methylated form.

              Now we see, however, since we understand more what the food chain transport
and so forth that is happening in a lake is, that the  active species in the lake is methylmercury.
This results hi a bioconcentration factor for that same  fish of 106 to 107 which is quite dramatic.

              We could see, then, that if we were going to allow a discharge of 1 ug/L into  this
hypothetical lake that we might then see that as a severe impact rather than a nonexistent impact.

              That is all. Any questions?

                                        MR. TELLIARD:  Any questions?
(No response.)

                                        MR. TELLIARD:  Thanks, Nick. Appreciate  it.


                                         219

-------
220

-------
 Ultra-Clean Sampling, Storage, and Analytical
Strategies necessary for Accurate Determination
        of Trace Metals in Natural Waters

                    May 5, 1993
                  Nicolas Bloom
                Frontier Geosciences
                 414 Pontius North
                 Seattle, WA 98109
                    221

-------
180
160
 -40 J~
                                   Julian year
  2. Decrease in the observed Hg concentration of pristine waters, 1970-1990.
                                    222

-------
  FIG  1:  A  HISTORICAL  PERSPECTIVE
  OF   TRACE  METAL  CONTAMINATION
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1. MEAN OCEANIC CONCS.
ESTIMATED IN REVIEWS  BY
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 MEASURED IN VANDERCOOK
 LAKE,  Wl SURFACE WATERS
 DURING 3 DIFFERENT STUDIES
        (AFTER FITZGERALD AND WATRAS 1989)
             3. Decrease over time in observed metals concentrations.

-------
4.  Mechanism for downward spiral in observed metals concentrations.
                                224

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                    species    peak D.L.
  method         detected   (pg
  CVAAS             Hgo      20
  CVAFS             Hg°        0.1
  AES                Hg(g)       0.5
  PAS                Hg°       10
  GC/ECD          RHg-X      50
  Colormetric       Hg(II)(aq)    lo6
  ICP/MS           Hg(aq)      10
  Resistance          Hg(g)     500
  NAA                Hg      500
  Piezoelectric        Hg(g)      106
5. Absolute detection limits for various types of Hg detectors.
                   225

-------
1. Purge

   Gas
               Soda Lime Pre-Trap   Gold Sample Trap
                                                   Gas
                        Aqueous Sample + SnCl2
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Hg Free
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      6. Schematic for dual amalgamation Hg analytical method.
                              226

-------
 Helium
   in
                                                         0-1000 volt DC
                                                          Power Supply
350°C
  Oven with
  GC Column
                                                        Current-to-voltage
                                                           Converter
                 110°C
         7. Schematic for Hg speciation technique using GC/AFS.
                                  227

-------
           TYPICAL DETECTION LIMITS FOR MERCURY  SPECIATION IN WATER
oo
       Mercury Species
Total
Acid labile
Hg°
Participate
Complexed Organic
Total methylmercury
Dimethylmercury
Labile Methylmercury
Paniculate methylmercury
                           Sample Size
Detection Limit
   ng«L~1
Typical Level in
Uncontaminated
Waters, ng«L
100 mL
100 mL
1,000 mL
On filter
100 mL
50 mL
1,000 mL
50 mL
On filter
0.05
0.002
0.0001
-0.02
0.08
0.004
0.0001
0.002
-0.005
1.0
0.05
0.02
0.2
0.8
0.05
< 0.0001
0.02
0.04
                         8. Detection limits for 8 typically studied Hg species in water.

-------
9 - 13.  Illustrations of various laboratory and field techniques.
                       229

-------
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          STORAGE   TIME   DAYS
245
        14. Increase in [Hg] when water is stored in polyethylene bottles
                      (Bothner and Robertson, 1975).

                                   230

-------
    CLEAN-UP OF LAB AIR FOR LOW LEVEL Hg ANALYSIS

        Initial Condition:                     [Hgt] ng-nr3

           Closed room, old paint,
             used lab benches                    320

           Ventilate with outside air               79

           Cover old paint containing Hg          60

           Remove contaminated sinks            15


        Final Condition

           Gold filters on clean air benches,
           venting outside air

           Room air (varies)                      2-10

           Clean hood air                        1-2

           Outside air, Seattle:                   3-15



15. Effectiveness of various steps in the clean-up of high Hg lab air.
                              231

-------
          Magnitude of Various Potentially

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                17. Hg levels in various supposedly "clean" laboratory waters and acids.

-------
    18. Comparison of true observed levels for As, Pb, Hg and Cd in
uncontaminated waters with detection limits by EPA sanctioned methods.
                               234

-------
         parameter
   total Hg (pristine water)
  methyl Hg (pristine water)

   total Hg (polluted water)
  methyl Hg (polluted water)

        total Hg (pike)
      methyl Hg (pike)

         BCF (pike)

expected impact of 1 M-g/L Hg
  discharge to pristine lake
     1970
 1990
100-1000 ng/L   0.5-3 ng/L
      ?          0.03-1 ng/L

100-1000 ng/L   5-25 ng/L
      ?          0.5-10 ng/L
    lMg/g
   0.8 |ig/g

   103-104

     none
1Q6-107
severe
  19. Change in scientific perception of anthropogenic Hg impact, with data
              resulting from using ultra-clean techniques.
                             235

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236

-------
                                        MR. TELLIARD:  Our next speaker is from EPA's
Office of Water. Bob April is going to be talking about, again, clean and ultra-clean techniques
as it relates to trace metals.
                                        MR. APRIL:  After that presentation by Nicolas
Bloom, I am very tempted to just get up here and say ditto. I am also very chastened to consider
my graduate work with mercury, some years back. I was very proud to do work in the subparts
per billion range, and now I think about what I just heard and realize that almost all my results
were no doubt contamination.

             My intent up here  is somewhat  different.   I am going to give a regulatory
perspective from an EPA regulator.  You folks are the real experts in this business, and my
agenda is to hear from you.  I am going to try and move right along with my presentation, pose
a few  questions, and hopefully get some feedback from the floor, which is basically why I
twisted Bill's wrist to let me come here.

             I would also like to give thanks to my two co-authors, Charles Delos of EPA and
Carlton Hunt of Battelle. Because of the format of this conference, somewhat informal, and the
timing of my presentation, they haven't had a chance to review in detail what I am going to say.
So, any mistakes are my own, and the good stuff I stole from them.

             Trace metals have been receiving increased regulatory attention, I would say,  in
the past two to three years.  The reason for this is that we got many  more State water quality
standards for toxic  metals, and these were promulgated, and then  we started writing NPDES
permits with these limits.  Particularly for dischargers such as POTWs, where we hadn't looked
very much at the toxic  metals in the discharges before, this caused controversy.

             Also  accelerating the trend were the 1987 Clean Water Act, in which Congress
expressed their impatience at the pace of water quality regulation, and the resulting 1992 National
Toxics rule.  Under  the rule's impetus, many States promulgated water quality standards, and the
toxics rule itself finished the job.

             As metals got this attention, controversy surfaced over the water quality criteria
and their validity, and that is my end of the business right now.  For a time, these discussions
were very contentious and not very fruitful.

             When we really started  to think about it, we thought were that we were running
into matrix effects, effects of the matrix on metals toxicity, and that still is an important factor.
A metal's toxicity is very subject to the matrix that it is in, something you need  to consider.

             But we made a mistake, I guess, in deciding that matrix effects were really the
central issue and focusing on that.
                                          237

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             When we looked at data, some of the data that you just saw, we saw very high
levels of metals everywhere.  One of the authors of this paper, Charles Delos, drafted a paper,
"Metals Criteria Excursions in Unspoiled Watersheds."

             Now, this paper may hold a record for a paper that has never been formally
published, actually never been formally submitted, and actually has never gone beyond a draft.
It may be the most cited paper in that catagory anywhere. What it said was that in a variety of
unspoiled watersheds of all sorts of chemistries such that you would expect that the matrix effects
would be small, the values that we saw for these toxic metals were well in excess of the criteria.

             We did not think that there were severe  impacts. At least, there were so many of
these watersheds that we did not think that there were severe impacts everywhere.

             The paper listed possible reasons for this, and one of the possible reasons that was
listed was maybe the data is wrong. But it really wasn't prominently listed as one of the reasons,
because we didn't really believe that the data could be that bad.

             Well, we are wrong; it was.  But when the paper came out, there were even more
controversy, even more doubt cast  on the criteria.  After all, EPA itself had written this paper
which said that the criteria were exceeded virtually everywhere.

             And this is where we were when two of,  I would say, very useful things happened.
Through the 1980s, thanks to work such  as done  by  Dr. Bloom, there was a recognition that
some of the data was bad.  And another event was some of our own work that we did  in New
York Harbor.

             One thing that is interesting is, as was  said, marine chemists basically went
through this in the  1970s, and they went through it in  a very major way, publishing papers,
giving presentations to conferences and the like.  I guess one of the surprising things to me is
it has actually taken so long for the fresh water people to make  use of that information to the
extent that they now have.  Another of the authors of the paper, Carlton Hunt, did some of that
work in the oceanography.

             One thing that came  up was the USGS data. Now, USGS tends to get mentioned
a lot when we talk about this topic, and I really think that one of the reasons is that they have
been very, very proactive  in bringing this issue to the forefront and making it clear what the
problems with the  data are;  and then proceeding very proactively to try and address these
problems in a thoughtful and  substantial way.

             Several papers came out talking about  the USGS data. Of course, we  became
aware  of it, and, of course, this was  the data on which Charlie Delos had based his paper,
"Metals Criteria Excursions in Unspoiled Watersheds."
                                          238

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             Now, looking at some of the papers that we have seen on the USGS data, it
appears that most, if not all, of the seeming excursions in unspoiled watersheds were based on
analytical errors.

             There is still some doubt about iron and aluminum.  I am not sure exactly why
iron, but as I am sure everybody knows, aluminum chemistry is very complex hi a number of
ways, including fate and transport and toxicology.  So, we are still not quite sure about what is
going on there.

             Another thing that happened, and it is illustrative both from  the standpoint of
figuring out the problems and understanding what the problems are in a regulatory context, was
work that we did in New York Harbor.  EPA, in developing its water quality approach, examined
various watersheds to decide which pollutants were causing the problem and then went after
those pollutants.

             The vehicle for this was the so-called 304(L) list. We would look at watersheds
and put them on the 304(L) list for various pollutants.  We  did that for New York Harbor.

             This is another  case of the 20,000 data points versus the  20  data points. We
looked at many, many data points, and most of them were very high for a  lot of metals.  A few
of them were pretty low, but we went with the majority of the data.

             So, we put New York Harbor on the 304 list for several toxic metals. And what
this triggered was a process called the  TMDL process, total maximum daily loads.

             What it means is you go into the watershed, and you model that pollutant very
carefully. You  look at what the sources are.  You look at the transport.  And  you try and come
up with a plan  to control the sources and to figure out what control measures will bring this
water into compliance with water quality standards.

             When we tried to do that for New York  Harbor, it didn't work, and the reason
didn't work was the data didn't make any sense. It didn't have the right kind of spatial variability
that we would expect, given the hydrology and the sources and the variations  in salinity. It just
didn't match up.

             What we then thought was well, maybe the data set that had low concentrations
of most of these metals was the right one. So, we went back out, and we did some more work.

             When we did that work...I will give you the bottom line first...basically, everything
dropped out except copper, and copper changed from being  a very serious exceedance problem
to a more marginal exceedance problem.
                                          239

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             What we did was redo some of the sampling work very carefully and also the
analytical work.  We split samples to two different labs.  One lab came out high; one lab came
out low.  It turns out we are now convinced the low lab is correct.

             This leads us to some conclusions. First of all, for EPA, toxic metal contamination
is far.less widespread than we thought. It is not as big a problem as we thought.

             When we look at good data and when we do things such as make  appropriate
corrections for site-specific factors we see that matrix effects are  still important.  Matrix effects
on metals toxicity are not inconsequential, but when you look at good data, a fair number of
these problems really go away.

             We now have a lot more faith in the underlying validity of the criteria.

             Another  lesson is that it is not just  sampling.   The work we have just seen
emphasized sampling problems  and  some lab contamination of a fairly esoteric nature, but the
work that we did in New York Harbor showed that more gross lab contamination can occur very
easily.

             Also in New York Harbor, it turned out that appropriate extraction techniques to
handle saline samples were crucial in getting good data.

             The bottom line here is that we have to be careful start to finish. It is fairly easy,
I think, to focus on sampling, and we need to be very careful to cover the whole of the process.

             This is very, very serious business for EPA. Two important results have happened,
that I have talked about here.

             First of all, we are uncertain about some  of the priorities that we have set for
looking at watersheds and whether we are, in fact, looking at the most  important problems.

             Secondly, we have gone through a period where enormous doubt was cast over
criteria which are actually among the most scientifically based and thoroughly developed criteria
that EPA puts out.

             So, as I say, this is very serious business for us. We have outstanding problems.
One of them is, how bad is the  historical data?

             This is a problem to determine, because in many, many instances, all that is stored
is the final result. We don't have the QA/QC data that goes with it, and that makes it essentially
impossible to evaluate.

             At a metals conference that we had earlier this year to discuss this whole issue,
a well-respected scientist got up and said all of the historical data is junk, and the people who


                                         240

-------
disputed that were only disputing it in a very modest sense, not the overall thrust of it.  It was
just the intensity of his statement.

              I have some questions, and I am really hoping that people will feel that they can
respond to them. My questions are...and people should feel free to address these or anything else
about this issue that they want that they think is important...first of all, how widespread is this
problem, particularly in the compliance monitoring business,  not the  scientific community?
Because that is my end of the world.

              My impression is, from everything that I  have heard, is that  it is very, very
widespread.  Is that true?

              Second, there has been a lot of talk about this in the past couple of years, as I say,
much of it spearheaded by USGS.  Is the problem going away? Are the natural effects of the
scientific community really solving this problem?

              The reason I am asking that question is that we are interested in what does EPA
need to do.

              So, the third question is, what does EPA need to do?  Do we need to do anything?
What would be useful?

              One  of the questions that brings to mind is, are clean and ultra-clean techniques
basically just good laboratory practices? Does everybody really understand pretty much what is
going on, and it is just a matter of being careful?

              Can we just collect people's experience and put it together, or are there still some
arcane things that we don't understand or maybe only a very few of us understand that are going
to be difficult to come up with?

              That being said, I would like to open the floor for comments.
                                           241

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                         QUESTION AND ANSWER SESSION

                                        MR RICE:  Bob, Jim Rice.

             First, I might like to say I didn't think I would live to see the day.  I mean that
from the heart, and I find this absolutely refreshing, and I do congratulate you for doing it.

             I hate to add a note of caution to what you have said in any questioning of some
of the underlying criteria that are involved for the level of risk or the chronic toxicity or what
have you, but I would suggest you put the same searchlight on the data that was used to create
the chronic and acute toxicity data. Those biological tests are subject to all the same variabilities
that we are talking about analytically otherwise.

             So,  this  is  going to go  around,  and  I  go back to  Nick Bloom whom  I also
congratulate.  I think that is just wonderful.  I love him.  But this circle goes  around, and here
you will see another part of it.

             You have set criteria that are health-based of an organism or of people, and the
means  used to get that  are in question also.

             It is like a lot of jobs.  Until you anchor down as best  you can the method of
analysis and take care of the error, you don't really understand the other problems that you have.
You don't understand the sampling problems until you know how to measure as error-free as you
can be and so on and so on.

             To get to some very specific things that you had, though, how wide is the problem
in compliance? Very wide, in my experience.  Very wide.

             Is the problem going away?  No, it will not go away. And the reason it won't go
away is that new methods keep coming, and as you move to an ever lower level, there is another
method, and it generates all the same problems all over again, and as you go  around, you find
out facts that you had thought were right are not any longer.

             Finally,  what does  EPA need to do?   I think it needs to do the same kind of
searching thing you are doing right here in talking about on all the bases for what is happening.

             I believe that if, somehow, all of us who have been involved and those who are
currently involved could work on a level playing field on a lot of this, we could really exchange
information much better than  we have in the past when it has been largely adversarial.

             Thank you.

                                        MR. APRIL:  Thank you.  I understand the point
that you were making about the derivation of the criteria.


                                          242

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              There is one thing that has come up as a result of this that I would like to make
 clear to everyone here.  When we do the criteria, we have all kinds of checks on the analytical
 data of the metals in terms of how we run the experiments, how we make up the solutions, where
 we are going.

              We know what we  are trying to do.  So, we are reasonably confident of the
 magnitude of the actual metals levels in the criteria experiments themselves.

              Others?

                                        MR. BLOOM:  I have a comment.

                                        MR. APRIL: Yes?

                                        MR. BLOOM:  I just might say that from my
 experience previously at Battelle Northwest and then with my  own company that I think  it is
 going to be a very, very difficult task ahead  of you to try to get as much data as  you need for
 compliance monitoring at the level that university researchers can produce it.  And  I think the
 reason for that  is the incentive for the people that are doing the work.

             I think scientists, research scientists who are doing this kind of thing because they
 are going to discover new facts and processes and publish the results have a very strong incentive
 to do it right.   My observation at Battelle Northwest as  they converted from  that type of
 operation to a very large and sophisticated routine testing laboratory over the last ten years is that
 they have totally lost that incentive, and the quality of the work has  gone down because of that.

             I just don't think, just by offering the carrot of money, that you can  get people to
 have  the interest level necessary  to do these sophisticated kinds of analyses.

                                        MR. APRIL: But wouldn't a counter to that be that
 the regulated community has a great interest in having data developed that are not showing high
 levels of contamination?  Because  commercial labs who hand back to  the  regulated clients
 excessively high  values  because of contamination  are going  to be  at a severe commercial
 disadvantage to people who are doing it right?

                                        MR. BLOOM:  Right, but that is still taking a stick
 rather than a carrot approach.  I mean, we turn down work, routine monitoring work, all the time
just because it is not fun. I  mean,  there is no interest for us to get 10,000 blind samples,  you
 know, and I think that is what you will find.  The really top notch research labs aren't going to
 be interested in doing this kind of work.

                                        MR. HUNT:  Carlton Hunt with Battelle.

                                        MR. BLOOM:  He is from the other  branch.

                                          243

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                                        MR. HUNT:  I am East Coast.

             The incentive issue is very clearly that. Some of the work we are doing as an
outfall of the meetings in January, clearly our incentive is a lot of capital investments that various
firms may have to put in place if it is based on bad data, if the numbers are high as a result of
bad data.

             That is an incentive that has to be really looked at, and that is an issue that has
to be addressed carefully.  That is just a general comment I would make.

             The other side of the coin is that I agree that, in general monitoring programs,
compliance monitoring is probably not the incentive for the commercial firms to necessarily or
the type of firm that you have or that I am in the East Coast with in Battelle is that we want to
do that kind of monitoring work that gives realistic values, that puts us into the place where we
are gaining knowledge as a result of the monitoring, and I think there are a lot of firms out there
that are interested in  doing that type of work.

             I know in one program I worked with, the 106-mill site, these issues came up in
terms of sewage  sludge disposal in the ocean, and we  ended up going through these clean
techniques in order to really address the issues of water quality criteria exceedance.

             Without the clean techniques, we wouldn't have demonstrated that the near field
disposal was  not  a problem  from that perspective.   So,  it is applied in a lot of monitoring
programs and needs to be  applied in monitoring programs that are looking at those end points
of water quality criteria.

             New York Harbor is the other classic point, and there are a lot of reports out on
that.  So, that is just  my general comment.
quiet out there. George?
                                        MR. APRIL:  Thank you.

                                        MR. TELLIARD:  Anyone else? You are awfully
                                        MR.  APRIL:   Yes, I  have one  question  very
specifically. People in the audience have worked with EPA and EPA methods. EPA is thinking
about developing guidance on how to do clean techniques.  What kinds of things would you like
to see us do?  What kinds of things do you think that we  would possibly do that might not be
productive?

                                        MR. TELLIARD: Let me make a suggestion. Bob
has posed like three questions to you.  I promised you a paper that was somewhat mislaid this
morning.  Why don't I send you those three questions, since I  have all your names  and I know
                                          244

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where you live, and think over what you have heard here this afternoon and give me  some
feedback.

             I know, you know, some of you are reluctant to talk openly, but drop me a note.
Let me know if you have any suggestions, ideas, or if you know somebody who has done some
of this stuff.

             The Agency does not wish to reinvent  the wheel if it is already  in someone's
garage.  A lot of you are involved in this. A lot of you know the stuff going on.  You tell me
this in the hallways and at the bar. So, why don't you drop me a line, because before we spend
a trillion dollars  of his money and my money, we would like to take what is already in the
community and use it.

             We are certainly talking to USGS, and that will continue. People like Nick Zeffert
and people in the research area, they are feeding us.

             There is also the practical level which we are getting at which is the NPDES and
the compliance monitoring effort that you are involved in. I don't want the letter that comes in
and says I don't want to have to put a clean room in, I think it is crazy, we have  never needed
it.

             If you have got anything to come on in with that is informative or suggestions,
please send them in.  We will send you the paper, you send us the questions or the answers back.
Okay?

             I would like to thank our morning speakers or afternoon speakers, whatever they
were. We are going to take a quick 10-minute break.  There is coffee outside and soda.  Do
what you need to do and come on back in.

(WHEREUPON, a brief recess was taken.)
                                         245

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246

-------
                                         MR. TELLIARD:  Could we get started, please?
If you would come in and take your seats, I would appreciate it.

              The final session for the day is going to deal with some radiochemistry activities
and also a discussion of the determination of diesel, mineral, and crude oil in drilling muds.

              The first speaker is Dave Demorest from Core Laboratories.  He is going to be
talking about the cost and minimization of cost for radiochemistry determinations.

              Dave?
                                         MR. DEMOREST:  In the commercial analytical
business, there are three areas that need to be addressed in order to maintain a viable business
in today's market.  The first issue is that the clients requirements must be met.  In the case of
analytical services for the environmental marketplace the requirements are driven by regulatory
and/or liability issues. The requirement is to provide legally defensible data. In order to provide
defensible data the laboratory must utilize approved methodology performed by a qualified staff.
The operating procedures and training programs must be documented and continually updated.

              The second issue is  one concerned with maintaining a viable business.  In order
to maintain a share of the market a commercial laboratory must provide the data at a competitive
price.  As the data packages become more complex and  the  analytical requirements  more
stringent,  it is difficult to keep costs down.  Hence, it becomes more difficult to maintain a
reasonable profit.

              Finally, as the data is produced for the data packages, it is essential that now new
waste streams be generated.  Any wastes generated may come back as a liability the laboratory
and client or the general public as a health risk. This necessitates that the last requirement of
an analytical laboratory is that it performs its business in a manner that does not create new
problems as it attempts to solve old ones.

              This paper will provide an approach that  may provide an avenue to minimize
and/or eliminate  waste  streams generated as  analytical data is  produced in  an analytical
laboratory.

              Most of the current methods utilized for isolation and purification of radiochemical
analytes produce complex waste steams,  and those include mineral acid wastes and  organic
solvents and mixed waste.

              These waste streams, as well as associated production costs, can be simplified and
reduced by utilization of advances  in technology such as new extraction chromatography.
                                          247

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             In this presentation, we will examine the results of preliminary investigations using
these technologies in a commercial laboratory setting.  We are going to examine the accuracy,
the waste generation profile,  and the manpower requirements of two conventional analytical
schemes.  We will  compare these to two alternative analytical schemes in which extraction
chromatography has been introduced as a means of separation and isolation of the target isotope.

             The first method that will be examined is a derivation of a method developed by
Percivel and Martin at INEL.  This procedure isolates radium-226, radium-228 and thorium-230
from water and soil. Core Laboratories has developed a permutation on the Percivel and Martin
that will  also isolate lead-210.  The isotopes of interest are isolated by co-precipitation on lead
sulfate. The sulfate precipitated is dissolved in DTPA and the radium isolated by co-precipitation
on barium sulfate.  The radium-226 and 228 are  then isolated and  determined  by classical
methods.

             The  thorium and lead-210 remaining in the  DTPA  fraction are  isolated  by re-
precipitation out of DTPA on lead sulfate. The sulfate is removed and the lead converted to a
carbonate. The carbonate precipitate is dissolved in 2 M nitric acid.  The thorium is isolated by
co-precipitation on bismuth phosphate, purified by  a TOPO extraction and counted via alpha-
spectroscopy. The lead is isolated as a carbonate, redissolved and counted by liquid  scintillation.

             This technology has been approved for use at Wright Patterson Air Force Base in
Ohio, at  Fernald in  Ohio and by the Hazwrap program.

             In this paper classical methodology  was compared to a new methodology that
utilizes TRU-Spec  resins as  an extraction technology developed by ElChroM Industries hi
Chicago.  The isotopes are isolated via lead sulfate precipitation as above.  The sulfate is
converted to a carbonate and dissolved in nitric acid. The radium-228 decay product is allowed
to ingrown.  The sample is then run through a TRU-Spec column. The radium and lead isotopes
are not bound on the resin and the radium-226 and lead-210 are isolated as described in the
classical  method described above. The radium-228 decay product actinium-228 and the thorium
isotopes  are bound on the column. The actinium-228 is stripped, isolated as an oxalate and beta
counted.   The thorium is then  stripped  from the column and isolated for alpha-spectroscopy
analysis.  The Tru-Spec isolation method was developed at ElChroM in Chicago. The actinium
method was developed and presented at a conference in 1992 in Santa Fe by Cable, Brinnell, and
Westmoreland.  The thorium  procedure  was  provided to Core Laboratories by ElChroM
Industries.

              In examining the effectiveness of this new separation technique thorium recovery
was examined. Know standards were separated on TRU-Spec and the each elution was saved
and the thorium isolated and analyzed to determine recovery. The first eluent (El), which is the
6 M Hydrochloric acid was containing the actinium-228, contained less that 5% of the thorium
recovery. The nitric acid wash (E2) contained only 2% of the thorium.  The thorium wash (E3)
continued the majority of the thorium (average of 90%). This demonstrates that the technology
is very effective.


                                          248

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             A know radium-226 standard was isolated on lead sulfate and then taken through
the TRU-Spec columns.  The radium was isolated and counted via alpha proportional counting.
The  radium data was compared with the  average recovery achieved by the traditional EPA
method over a 2 month period in our analytical laboratory. The radium-226 recovery by the EPA
method was 98% with an error of 8%.  The radium-226 recovery by the TRU-Spec method was
95% with an error of 9%.  There is no significant difference in the data from the two analytical
methods.

             The radium-228 data were compared.  The traditional method yielded a recovery
of 97% with an error of 10% while the TRU-Spec method yielded a 90% recovery with an error
of 7%.  Again there is no significant difference in the analytical results between methods.

             Finally, the lead-210 data were compared and again there was no difference in the
data.  The traditional  method yielded 93% chemical recovery with an  error of 15% while the
TRU-Spec method demonstrated an 88% recovery with an error of 10%.

             The second procedure examined compared the proposed EPA CLP procedure for
isolation of plutonium and americium to a procedure utilizing TRU-Spec for the separation. The
traditional  method isolates the isotopes by a ferric hydroxide precipitation  followed by  a
reprecipitation on bismuth phosphate. The precipitate is dissolved in 8 molar hydrochloric. The
plutonium  is isolated by extraction on TIOA and  counting  via  alpha-spectroscopy.   The
americium is purified by TOPO extraction and counted via alpha-spectroscopy. (See flow chart).
Both the TIOA and TOPO extractions generate fairly significant mixed waste streams.

             In comparison, plutonium and americium can be  isolated by one pass through a
TRU-Spec resin column.  (See flow chart).  The method involves isolation of the isotopes on
ferric hydroxide.  This precipitate is dissolved in 2 Molar Nitric acid and loaded on a TRU-Spec
resin column.   The  americium is eluted  with 4  N  hydrochloric  and counted  via-alpha-
spectroscopy.  The plutonium  is eluted with 2 N hydrochloric and 0.1 N hydroquinone.  The
results demonstrating  the  activity present in each fraction from the americium and plutonium
standards are presented in the bar table.  The results demonstrate that 86% of the americium was
recovered in the E4 elution.  The plutonium was recovered in the E5 eluent with a recovery of
87%. There was less that a 12% loss of either americium or plutonium into the other elution and
wash fractions.

             In comparison with the conventional method for the plutonium and americium the
average recovery runs from 75% to 90%.   It is  apparent that the TRU-Spec separation is as
effective or more effective than the conventional techniques.

             It is apparent that the extraction chromatograph provides  similar recovery  and
accuracy as the tradtitional technology available. However, the waste streams generated and the
manpower requirements for the conventional versus the extraction chromatography methods are
much different.  In examining these issues three areas were identified to  use as a comparison.
                                          249

-------
The acid waste stream, the organic (mixed waste) waste stream and the time requirements in
terms of man-hours.

             A model was devised which examined the flow through our own laboratory over
a 28-day period.  Each sample set included a full  set of 20 samples for all of the analytical
parameters.  The model was developed with 8 sets a day for 28 days, so that 244 sets were run
for all the parameters.

             The acid waste stream generated the traditional method produced 4.7 barrels (42-
gallons/barrel) or 197 gallons of acid waste.  In comparison the TRU-Spec method generated 2.7
barrels or 98 gallons of acid waste.  This  represents a 50% reduction in a significant waste
stream.

             Examining the organic waste stream  the traditional generated  around 1.2 barrels
a month (60 gallons).  The TRU-Spec method generated 1  Kg of a solid waste which contained
no detectable activity.  The resin utilized for the  thorium  extraction  was isolated and alpha
counted. There was no detectable activity above background. This idicates that the resin could
be disposed of in a local landfill.

              In comparing  the  time  involved man-hours  or man-days  per  month  were
determined for the traditional and the new methods. With the traditional method 117 man-days
were required or an equivalent of 4.2 staff members were required to perform  this work. The
TRU-Spec method utilized 75 man-days or an average of 2.7 people to perform the same amount
of work.  This cuts the time and personnel necessary in half.

              When the americium and plutonium  methods were examined  for the same three
criteria the following results were obtained.  The tradtional method genereated 7.1 barrels of acid
waste/month in comparison to 1.1 barrels for the TRU-Spec method.  When the organic waste
stream was examined the traditional method generated 1.3  barrels of organic waste compared to
1.17 Kg of solid resin.  Finally,  96 man-days (3.4 staff members) using traditional methods
compared to 66  man-days  (2.4 staff members) with the  TRU-Spec method.

              The results indicated that there is very little cross contamination between isotopes
utilizing TRU-Spec (less that 10 percent between americium, plutonium and thorium).

              The recoveries range from  85% to  95% on all isotopes of interest  using  the
extraction chromatography methods.

              The acid waste streams are reduced 40% in the radium 228 method and 80% in
the case of the plutonium  method.

              Organic waste generated decreased from  1.1 barrels of potential  mixed waste to
an average of 1.1 kilogram of waste that can be disposed  of in a local landfill.
                                          250

-------
              The  man-hours  are  decreased overall  by  30  percent  utilizing  the column
chromatography.
              Conclusion, isolation of radionuclides with liquid-liquid extraction versus TRU-
Spec  has fairly comparable recovery.  There is no sacrifice in recovery or accuracy when
comparing historical data from our facility.  And the decreased time at the bench level will
decrease turnaround and allow laboratories to be more competitive.

              Finally, the pronounced decrease in waste generation should result in substantial
savings in disposal costs and also have a significant reduction in liabilities by eliminating the
mixed waste stream generation. Utilizing this technology is beneficial to the analytical labs, the
client, and to the general public by not generating a mixed waste stream.

              We would like to thank ElChroM for their support and help and advice  on this
technology.  John Mitchell and Dee Fairservis did a lot  of work on the analytical side for this
paper.

              I will take questions if you want.

                                        MR.  TELLIARD:  Questions?
(No response.)

                                        MR.  TELLIARD:  Okay, thank you.
                                          251

-------
252

-------
to
Minimization of Production Costs
    and Waste Generation in
    Radiochemical Analysis
               by
   Dave Demorest and John M. DeHart
 EPA Annual Methods Conference, Norfolk
            VA. April 1993

-------
t-o
U)
         INTRODUCTION

• Current methods for the  isolation and
 purification  of  radiochemical  analytes
 produce complex waste streams of mineral
 acids and organic solvents.
• These   waste   streams,   as  well   as
 associated  production  costs,  can   be
 simplified  and reduced  by utilization  of
 recent  advances in extraction chromato-
 graphy.
• In this presentation we  will examine the
 results of a preliminary investigation using
 these  technologies  in  a  commercial
 laboratory setting.

-------
Extraction Procedure for Thorium,
    Ra-226, Ra228, and Pb-210
• 0.4 grams of TRU-Spec® (EIChroM) is placed
 in a 20 ml column.
• Conditioned with 2N HNOs
• Sample is loaded on  the column. Wash is
 saved for later isolation of  Ra-226  and
 Pb-210.
•  Column  is washed  with 6N  HCL. Ac-228
 elutes (E1).
• Column is washed with 2N HCL (E2).
• Column  is washed with .1N ammonium
 oxalate. Thorium elutes (E3)

-------
         Flow Chart of Ra-Th-Pb Procedure

                       PbSO4
           BaSO4

               	DTPA	PbSO4
to
L/i
ON
Ra-226  Ra-228 (Ac-228)        	BiPO4
                               I        ••*••









                               04 fl      f
                          Pb-210
a-spec      '                         TOPO
      Liquid-liquid          (LSC)

      Extraction
                                        TH


           i-count                     a"

-------
         TRU-Spec® Procedure for Ra-Th-Pb
to
                       PbSO4
                      2N HMOs
  Ra-226            _._.. 0
  Pb-210	TRU-Spec®
                           6NHCI    Ac-228

                                    B-count
                           2N HCI
                           	Th
                                    a-spec

-------
   Percent Recovery
00
                  Thorium
                                           E1
                                           E2
                                           E3

-------
        Percent Recovery of Standards, Ra-226
Ki
Traditional
Procedure
 TRU-Spec
                                             a=9

-------
      Percent Recovery of Standards, Ra-228
Traditional
Procedure
TRU-Spec
-10

-------
      Percent Recovery of Standards, Pb-210
Traditional
Procedure
TRU-Spec
                                             -15
                                             a-10
                20
                       40
60
80
100

-------
Procedure for Separating Pu, Am,
               andU

 • Column is prepared with TRU-Spec® resin
  and conditioned as in previous procedure.
 • Sample is prepared in 2N HNOs and loaded
  on the column. Wash collected is E1.
 • Column is rinsed twice with 1N HNOs (E2
  and E3).
 • Am is eluted with 4N HCL (E4)
 • Pu is eluted with .1M hydroquinone in 4N
  HCL. (E5).

-------
                    EPA Pu-AM
              Am
NJ
O\
            WASH
            TOPO
             Am
            a-Spec
                       FeOH
  w
BiSO4 (liquid-liquid)
  I
TIOA
  I
  Pu
  I
a-Spec

-------
                                                 3

                                                0.
                                       CO

                                      o
Q_
X
o
 (I)
                                              o
                                              CM
                       CM
                               264

-------
Separation of Americium and Plutonium
Percent Recovery
                                     Am
                                     Pu
                       E5

-------
 Ra-226, Ra-228, Pb-210 and Thorium Procedure
             Represents (1 Month)

          Acid Waste Generation
Barrels (42 Gal.
        Traditional
        Procedure
TRU-Spec®

-------
Ra-226, Ra-228, Pb-210 and Thorium Procedure
            Represents (1 Month)
         Organic Waste Generation
 Barrels (42 Gal.)
                          07 Kg resin
          Traditional
          Procedure
TRU-Spec®

-------
   Ra-226, Ra-228, Pb-210 and Thorium Procedure

               Represents (1 Month)


            Man-Days Per Month
to
Ox
oo
         Traditional

         Procedure
TRU-Spec®

-------
          Am and Pu Procedure
            Represents (1 Month)

            Acid Waste Generation
   Barrels (42 Gal.)
K)
Os
           EPA-CLP
TRU-Spec®

-------
        Am and Pu Procedure
          Represents (1 Month)
        Organic Waste Generation
Barrels (42 Gal.)
                    1.17 Kg resin.
         EPA-CLP
TRU-Spec®

-------
NJ
140

120

100

80

60

40

20

 0
            Am and Pu Procedure
              Represents (1 Month)

              Man-Days Per Month
            EPA-CLP
                   TRU-Spec®

-------
                  RESULTS

        Cross contamination  between  isotopes
        using TRU-Spec® is <10%, and  usually
to
-J
to
The recoveries ranged from 85% to 95% on
all methods.
Acid waste can be decreased from 40%
(Ra,  Th, Pb-210 procedure) to 80% (Am,
Pu, U procedure).
Organic waste generation decreased from
1.1 barrels of liquid waste to 1 .1 Kg of solid
waste.
Man hours decreased by 30% by utilizing
column extraction techniques.

-------
U)
        CONCLUSIONS

• Isolation of radionuclides using liquid-liquid
 extraction  or  liquid-solid  extraction using
 TRU-Spec® result in comparable  recov-
 eries.
• There  is  no  sacrifice  in  recovery or
 accuracy when comparing historical data of
 the more  established  methods to these
 results.
• Decreased time  at  the  bench level will
 decrease turnaround time and allow the
 laboratory be more competitive.

-------
      CONCLUSIONS (cont.)
The pronounced decrease in waste generation
should result in;
(1) Substantial savings in disposal costs

(2) Significant reduction in long term liability by
   eliminating the mixed waste streams gener-
   ated by the conventional methods.

-------
 o


 
-------
276

-------
                                        MR. TELLIARD:   Our next speaker is Richard
Rivera from Shell Development.   He is  going to talk about high purity germanium gamma
spectrometry, and late in the afternoon, you have got to stay awake, because there is a quiz on
this or you don't get dinner.
                                        MR. RIVERA:   My talk this afternoon is on the
development of a procedure using high purity germanium detector for the analysis of radium-226
and radium-228 in barium sulfate scale and produced solids, that are present in the oil production
facilities.

              The determination of radium-226 and radium-228  for solids containing naturally
occurring radioactive material was developed at Shell Development Company in conjunction with
projects and radium fate studies carried out by sister companies like Shell Offshore, Incorporated
and Shell Western Exploration and Production.

              The people involved in the development of the procedure were J.C. Postlewaite,
W.T.  Shebs who is now retired but works as a consultant for us, and myself.

              Naturally occurring radioactive materials are found in the barium sulfate scale and
produced solids in  the oil  and gas production facilities  and the separation equipment that is
involved.  The isotopes of major concern are radium-226, radon-222, and radium-228.

              The radon is not so much a problem in the barium sulfate scale but is a problem
in the gas plants.

              The radium-226 and radium-228 are presumed to be solubilized during the water
flood process during secondary phase of oil recovery.  Under the proper temperature and pressure
the barium and the radium solubilize into the formation water and when mixed with sulfate form
a scale with radium inside the barium sulfate matrix.

              The origin of these two isotopes, are uranium-238 which gives off the radium-226
and the thorium-232 which gives off the radium-228.

              Occasionally, we will  see  a sample that may have some U-235 in very minor
amounts.  We can tell that uranium-235 is there, because it affects part of our results.

              The radioactivity is concentrated by this process  and, in some cases, sufficient
material may accumulate  so that the external radiation dose  rates are  in the radiological
significant  range.  We  have to be  careful when we familiarize the employees in the field as to
what  they are handling and how much.

              Here we have the uranium decay chain that shows uranium-238 and its immediate
descendants. The uranium-238 is mostly immobile and remain in the formation.  The radium-226


                                          277

-------
is partially mobilized and accumulates in the barium sulfate scale and the sludges.  The other
isotope is the radon-222 that is soluble  in the petroleum liquids and  also emanates from the
radium/barium sulfate scale and the sludges.

             The reason that Shell Development had to come up with a procedure for the
analysis of radium-226 and radium-228  was for guidance in handling of a NORM scale and
NORM contaminated equipment, for use in radiation safety, for waste disposal purposes, risk
management calculations, and in environmental studies.

             The data was also  used by regulatory agencies such as the MMS and other
agencies that regulate the offshore activity and also non-regulatory agencies  such as API.

             In a study that we did where we sent NORM samples to  commercial labs, we got
results back that we did not like because the results were very inconsistent.  This is one reason
why the procedure was developed.

             This vu-graph shows the results obtained when we sent out some NORM scale
containing radium-226 and radium-228 in these concentrations in pCi/g  to the seven commercial
laboratories. As you can see from this information, laboratory number 1 over-reported on the
radium-226 and did quite well or what we consider quite well on radium-228.

             The second lab over-reported on radium-226 and then under-reported on radium-
228. Lab number 3 used a radiochemical procedure that did not digest the barium sulfate scale
enough and, consequently,  reported low numbers, but when they switched to a gamma ray
spectroscopy method, they reported numbers that were more in line with what was submitted.

             Labs 4, 5, and 6 over-reported in both cases, in radium-226 and radium-228.  Lab
number 7 here over-reported on the radium-226 amount and then did fairly well on the radium-
228.

             As it turned out, I sent out samples to labs number 6 and to lab number 7, but lab
number 7 forwarded the samples to lab number 6.  You can see that the results are not consistent
and this adds to the confusion.

             The procedure that we developed gave results that are listed here under lab number
8 which,  we feel, are a lot more consistent than the commercial labs.

             We also sent along some samples that had radium-226 on the sand, not inside the
sand matrix.  We picked two concentrations, 60 and 240 pCi/g.  As you can see, lab  numbers
1,2, 4, 6, and 7 under-reported the results.  Lab number 3,  using the radiochemical procedure,
was able to extract the radium-226 off the sand and reported results back that were right on the
money, but when they reported results by gamma spec, the  results were a little low.
                                          278

-------
              Lab number 5 over-reported on the radium-226.  Lab number 8 shows the results
that we obtained using our method.

              These two samples had no radium-228 in it, and some labs still reported radium-
228 in these cases.

              The procedure  that we have developed, as in any other procedure, requires
standards so that you can make the calculations against your standards.  You heard earlier today
from Bob April that matrix effect is a very important part of your analysis.

              What we have here in the oil patch are samples that are produced in the production
of oil and gas. There can be barium sulfate scale or produced solids from the reservoir or a
combination of both.   Since these two types of samples have different densities, the way we
decided to handle this situation was to make two sets of standards.

              The standards are  prepared in the same matrices as the unknown. A radium-226
standard is made in barite, and we also  have a thorium nitrate standard that is  made in barite.
We also have  the radium-226 standard made in  sand and also a thorium-232 made in  sand.

              The liquid standards are added to  the matrix, followed by mixing and drying, and
the standard matrices are transferred to a sample holder where they are counted after they are
sealed.  The sample is counted after the  sample  reaches secular equilibrium.

              For geometry consistency, the standards and samples are counted in the same type
holders.  This  is very important.

              The preparation of the samples in our procedure, as I said a while ago, are either
NORM scale,  produced solids which are mainly sand particles from the  reservoir along  with
some clay and maybe a mixture  of a little bit of NORM scale in  the produced solids.

              When we get clean wet samples,  all we are required to do is to dry the sample.
Samples that contain oil require removal of the hydrocarbon. This is done by extracting the oil
off the sample with toluene. You decant the toluene off, and you  dry the sample with a solvent
such as acetone. This gives you a quick cleaning  and drying procedure.

              Samples with heavy crude or very tarry material require  Soxhlet extraction and
then drying.

              Once the sample is dried, the material is ground, because sometimes we do get big
chunks of material.  The sample  is sieved through a 35-mesh sieve to match the particular size
of the standard also.

              A weighed amount  of material is placed in the petri dish.  The petri dish is
covered, sealed and then placed on the detector for analysis.


                                          279

-------
             The equipment that is used for this gamma ray spectroscopy method as a detector
is the high purity germanium detector that requires liquid nitrogen temperatures for it to function.
The  detector is coupled with a devvar that contains the liquid nitrogen.  As shown here, the
detector is inside our lead shield.

             On the electronic side, we use a spectroscopy amplifier, a multichannel analyzer,
high voltage supply, and the NIM power supply.  Here you see a lot of electronic Nim bins, but
that is because we have four of these detectors.

             We  also have a computer that is  coupled to the instrumentation, has the proper
software and does  the calculations.

             In the procedure steps, first, you must calibrate your MCA energy scale, and we
do this using a cobalt-57 and a cobalt-60 source.  We use the 122 KeV from the cobalt-57 source
to  calibrate on the low end of the energy scale, and we use the 1332 KeV from the cobalt-60
source to calibrate on the high end of the energy scale.

             Once the energy scale is calibrated, you count the radium-226 standards at seven
regions of interest. You count the thorium-232 standard at 4 regions of interest for the radium-
228.  You have a background count at  11 energies  and your unknown sample count at  11
energies.

             The difference between 7 ROIs for radium-226  plus 4 ROIs for radium-228 and
17 is that we have 6 ROIs thrown in there for the determination of thorium-228.

             The data is stored in a directory.  The data files are inputted into a Lotus spread
sheet, and after other data is inputted into the spread sheet, the software calculates the results.

             The picture that you get on the video terminal of your computer may look like this
where you have energy in KeV and counts on  your vertical scale. Here you see nothing but
straight lines that look like they don't mean anything, but this is a full gamma ray spectrum.

              You can zero in on these regions of interest and expand to show that there are
some real counts in the regions of interest that you set.  Here, for example, we set a region of
interest from channel 546 to channel 558.

              We have a background spectrum with counts in the peak, the background peak,
and  a gross  sample with counts in the sample  gross count peak.  The software  takes  care of
subtracting the background from the sample gross counts, giving you a sample net  count.

              This is done for each region of interest that you pick for all the isotopes that you
select.
                                           280

-------
             For the determination of radium-226, we do not rely  solely on the 186 peak,
because that is a weak energy and can be influenced by several factors. We allow our sample
to reach equilibrium. In order to do  that, we must trap the radon gas being given off in samples
that are not equilibrated.

             Once you trap  the radon-222, the other daughters of the radon-222 will grow in,
and after they reach secular equilibrium, you can use the results from  these peaks to determine
and check your answer for radium-226.

             The other reason we can do this is that all these daughters from radium-226 have
short half-life and equilibrate  in a rather short time, say, 30 days or so.

             For the radium-226, we use 295 and 352 from the lead-214. We use four energies
from the bismuth-214.  The other one not included in here is a 934 peak energy.

              From the thorium series, since the radium-228 has no  gamma rays we wait for
the ingrowth of the actinium, because it has a very short half-life.  We use four energy peaks
from the actinium-228.  The fourth one here is 463.

             Once the actinium equilibrates, you can use the answers you get here for reporting
the radium-228 concentration.

             For the thorium-228 that we do not report but we just like to  analyze for, we use
a 239 KeV from lead-212, the 727 from the bismuth-212, and four from the thalium-208.

             In  all of these  regions of interest, the calculation is done very  simply as shown
here.  We have the activity for whatever region of interest you want in pCi/g. The software takes
the counts per hour for the unknown in that region of interest divide by the  counts per hour per
nanocurie of your standard for that same region of interest.

             You multiply that times  1000 to convert nanocuries to  picocuries and divide by
the weight of your sample.

             A result sheet would look like this where you have the count time that the sample
was counted for, the weight of the sample, and the sample identification, when the standard was
last counted, what the standard's concentrations are, and  some identification code  for  the
standards that you are using.

             Here, shown in red, are the energies that we use for the analysis of radium-226.
You can see here that the sample is at equilibrium. The answer came out to 44.8 for radium-226,
and we say that these are all in equilibrium with the parent and, therefore, the software calculates
an average.
                                          281

-------
             The results are not an arithmetic average.  It is an average based on the percent
abundance from the prominence of the isotope.

             The same computation is done for the radium-228.  We use the actinium energies
shown in blue, and, again, the software calculates a weighted average.

             If you come across some results like this on the method that we have, I am not
sure how it shows back in the back, but here you have a number that is higher for the radium-
226 and results that are quite close to each other  for the rest of the isotopes from radium-226.
After looking at the spectrum, we decided to go looking for uranium-235 in this sample, because
uranium-235 has an energy at 185 KeV that will add counts in this region of interest. We looked
also for the 1000 KeV peak  from uranium-235.

             So,  given this answer 8.8 is not the correct one, in this case, we would  average
the numbers shown in black here.

             Earlier today, you heard about matrix effects or the differences in matrix.  You
will remember that we match our unknown sample to the standard matrix. If it is barium sulfate
sample, we match it to the barium  sulfate standards.

             Just to give you an example of what happens when you have a produced solids
sample, mainly sand from the production reservoir, and you calculate it against a sand standard,
you will come up, after your sample equilibrates, with numbers in this fashion, giving you an
average of about 605. But if you calculate the results against a wrong standard, against a barium
sulfate standard, you will probably get answers looking like this.

             In conclusion, there  are a lot of methods out there that the different commercial
labs use,  but we  feel that  matching  the unknown with the  standard matrix and  staying at
approximately the same density as your standard, we feel that our method has several advantages:

             One, we do not need a radiochemical separation to determine radium-226 and
radium-228 in these  types of samples;

             The sample preparation is quick and straightforward;

             The standard  and sample use the same matrix and geometry;

              We have a quick turnaround time, not as quick as some of the labs claim to have
              about 8 hours, but we can't beat that;

              The procedure is tailored for production and environmental  soil samples;

              We feel that our answers are more accurate when compared to commercial labs;
                                          282

-------
             And our results are not based on the 186 peak alone but are based on equilibrium
             of radium and its daughters;

             And we also have the ability to  look for potassium-40 and the other uranium
             isotopes that may creep up.

             And that is the end of my talk.

                                      MR. TELLIARD: Do we have any questions?
(No response.)

                                      MR. TELLIARD:  I thank  you,  sir.  Thanks so
much.  Appreciate it.
                                        283

-------
284

-------
  SHELL DEVELOPMENT COMPANY
         J. C. POSTLEWAITE
          R. V. RIVERA
           U. T.  SHEBS
     SHELL  OFFSHORE INC.
SHELL WESTERN EXP & PROD  INC
             285

-------
  ISOTOPES OF
MAJOR CONCERN
     226Ra from 238U

     222Rn from 226Ra

     228Ra from 232Th
        286

-------
    ORIGIN  OF  NORM

U-238    Half-life   4.5 billion years
Th-232  Half-life   14.1  billion years
K-40      Half-life   1.5 billion years
U-235   Half-life   700 million years

These isotopes have been present since the
formation of the earth.
               287

-------
 U-238
 4.5 Byr


.iJ
                                         U-234
                                 2281 i<247,000yr
                          Pa-234m
                            1.17m
           Th-234
            14.1 d


   Mostly Immobile. Remaining in
   Underground formation.
          '" ' ••'""•«»w*»*i»*r;sjy«**jt


 Partially Mobilized. Occassionally
 Accumulates in Scale and Sludges
P«MK* *M«*-~,.*....	«,m WMmpajij,^^ ^ -A. £ * -^ ^,- n   ,^
OO
oo
                                       4.780 I
                                           Th-230
                                           80,000 yr
                                         4.690 i
                              Ra-226
                               1602yr
                             (186.2)3.3%

                            4.7801


                              Rn-222
                               3.82 d

                            5.490 4

                            DPo-218
                               3.05m
                                      DPb-214T

                                       (295.2) 19.2%
                                       (351.9)37.2%
                                                                 LEGEND
                                                                v
                                                         alpha decay, energy in MeV
                                                         beta decay, energy in keV


                                                   gamma decay, (energy in keV) % abundance


                                                    D   short lived daughters     IQPVTOPF
                                                                 O  long lived daughters
                            half-life
                                                         Mobile Gas.  5*-22%  Emanated  from
                                                         Scales and Sludges.  Soluble  in
                                                         Petroleum Liquids
      DP6-214
1540 Jf^ 0.164ms


       7.687,
                                                                                          116110^ 13

                                                                                         210   5-305
                                                                                               Po-210
                                                                                               138.4d
                                                                                                 l
                                                                                                 f
                                                       14, ->c* c\ H c
                                                       (1764"5) 15'
                                                                                                 Pb-206
                                                                                                  stable
                                                                        (46.5) 41%

-------
          WHY NORM ANALYTICAL PROCEDURE NEEDED
to
00
                  TO PROVIDE THE SHELL COMPANIES
             WITH RELIABLE, DEPENDABLE ANALYTICAL DATA
    * FOR GUIDANCE IN HANDLING OF NORM SCALE AND NORM
     CONTAMINATED EQUIPMENT

    * TO USE IN RADIATION SAFETY, WASTE DISPOSAL PURPOSES, RISK
     MANAGEMENT CALCULATIONS, AND IN ENVIRONMENTAL STUDIES

    * FOR USE BY REGULATORY AGENCIES

    * THAN PROVIDED BY COMMERCIAL LABORATORIES

-------
                    NORN SCALE ROUND  ROBIN RESULTS
                     BY GAMMA  SPECTROSCOPY METHOD
to
V£>
O
    SAMPLE
   CONTENTS
 26
 52
104
208
  0
      18
      35
      70
     141
       0
                                 LABORATORY NUMBER
                                                             8
RADIUM- 226,
34
62
119
245
0.7
43
97
186
425
0
31
40
64
65
1.4
31
57
98
199
<1
32
63
130
260
<.2
RADIUM- 228.
23
38
73
138
0.5
5
21
34
109
0.1
16
16
27
10
0.5
20
33
61
121
<1
25
46
94
200
<.4
PCl/GM
35
71
137
251
0
PCl/GM
23
48
93
172
0

51
81
190
323
1.3

24
20
96
214
0.3

37
81
162
346
<.2

18
28
71
117
0.2

26
52
105
192
0.5

18
35
72
137
0
     RADIOCHEMICAL ANALYSIS

-------
K)
II RADIUM IN SAND ROUND ROBIN RESULTS
LABORATORY NUMBER
SAMPLE
CONTENTS 1 2
3* 3
4
RADiUM-226,
60 33 38
240 112 145
60 51
240 214
40
160
RADiUM-228,
0 0.9 0.8
0 1.0 0.8
2.8 <1
5.8 1.6
<.6
<3.0
5 6
PCl/GM
70 47
270 183
PCl/GM
0 6
0 16
7 8

37 59
184 236

1.8 0.5
9.0 0.6
    * RADIOCHEMICAL ANALYSIS

-------
                      STANDARDS  PREPARATION
   STANDARDS ARE PREPARED IN SAME MATRICES  AS THE UNKNOWN SAMPLES
        RADIUM-226 STANDARD IN BARITE  OR  SAND
        THORIUM NITRATE (TH-232 FOR RADIUM-228 IN BARITE OR SAND
S  STANDARDS ARE ADDED TO MATRIX,  FOLLOWED  BY MIXING AND DRYING
   STANDARDS MATRICES TRANSFERRED TO SAMPLE HOLDER AND SEALED
   STANDARDS COUNTED AFTER REACHING SECULAR EQUILIBRIUM
   FOR GEOMETRY CONSISTENCY - STANDARDS AND SAMPLE COUNTED IN SAME TYPE
   HOLDER

-------
                   SAMPLE PREPARATION
SAMPLES ARE NORM SCALE. PRODUCED SOLIDS OR COMBINATION




* CLEAN WET SAMPLES REQUIRE ONLY DRYING




* OILY/SLUDGY SAMPLES REQUIRE REMOVAL OF HYDROCARBONS AND DRYING



* SAMPLES WITH HEAVY CRUDE REQUIRE SOXHLET EXTRACTION AND DRYING




* ONCE DRIED, MATERIAL IS GROUND AND SIEVED (35 MESH)




* MATERIAL IS PLACED IN PETRI DISH AND WEIGHED




* PETRI DISH IS COVERED AND SEALED




* SAMPLE PLACED ON DETECTOR FOR ANALYSIS

-------
r

-------
             PROCEDURE STEPS
         MCA ENERGY SCALE CALIBRATED
RADIUM-226 STANDARD COUNTED AT SEVEN ENERGIES
THORIUM-232 STANDARD COUNTED AT FOUR ENERGIES
  BACKGROUND COUNTED AT SEVENTEEN ENERGIES
UNKNOWN SAMPLE COUNTED AT SEVENTEEN ENERGIES
        DATA ARE  STORED  IN A DIRECTORY
DATA FILES ARE  IMPORTED  INTO LOTUS SPEADSHEET
     OTHER DATA INPUTTED INTO SPREADSHEET
         SOFTWARE CALCULATES RESULTS
                  295

-------
    o
    O
K)
'O
      8000
      6000
      4000
      2000
         0
              ^
                   a
                      < 00
  -i	r

           0
   500   1000  1500  2000  2500  3000
            Energy, KeV


Figure 6.  Gamma Ray Spectrum

         from Scale

-------
to
o
O
600
500
400
300
200
100
  0
              	] | | 1 I I I I I I i i i	  — x»  f AN A
         528  534  540  546  552  558  564
                      Channel Number
              Figure 7. Example of Sample
                and Background Peaks
                                       570

-------
                    URANIUM  SERIES
NUCLIDE
HALF-LIFE
GAMMA ENERGIES (KEV)
       U-238  TH-234  PA-234M AND PA-234  U-234  TH-230
RA-226
1602 YRS
      186  (4%)
RN-222
Po-218
  3.8 DAYS
  3.1 MIN
      510 (0.07%)
       NO GAMMAS
Pe-214


Ar-218

Bi-214
26.8 MIN


   2 SEC

19.7 MIN
      295  (19%)
      352  (36%)

       NO GAMMAS

      609  (47%)
     1120  (17%)
     1764  (17%)
Po-214
TL-210
Pe-210
Bi-210
Po-210
TL-206

Pe-206
  164 USEC
  1.3 MIN
   21 YRS
    5 DAYS
  138 DAYS
  4.2 MIN

   STABLE
      799 (0.014%)
      296 (80%)
      795 (100%)
      1310 (21%)
       47 (4%)
       NO GAMMAS
      803 (0.0011%)
       NO GAMMAS
                         298

-------
                   THORIUM SERIES
NUCLIDE
HALF-LIFE
GAMMA  ENERGIES  (KEY)
TH-232
1.41 B YRS
      NO GAMMAS
RA-228

Ac-228
TH-228

RA-224
RN-220
Po-216

Pe-212


Bi-212



Po-212

Tt-208
  5.75 YRS

  6.13 HRS
  1.91 YRS

  3.64 DAYS
    55 SEC
   .15 SEC

  10.6 HRS


  60 MIN



  304 NSEC

  3.1 MIN
      NO GAMMAS

      340 (15%)
      908 (25%)
      960 (20%)

       84 (1.6%)
      214 (0.3%)
      241 (3.7%)
      550 (0.07%)
      NO GAMMAS

      239 (47%)
      300  (3.2%)

       40 (2%)
      727 (7%)
     1620 (1.8%)

      NO GAMMAS

      511 (23%)
      583 (86%)
      860 (12%)
     2614 (100%)
Pe-208
STABLE
                        299

-------
          CALCULATION FOR EACH ENERGY


                REGION OF INTEREST
o
o
                        (c/h)iu    1000
                            I,U

            A;, pCi/gm = 	 x	

                        c/h/nCi)is   Wu

-------
                   RADIUM GAMMA RAY ANALYSIS
      Project Name: MC-194A
     Project Number: CPI UNIT 3/7/93
Sample Identification: 229810824
Count time (s)
Weight (g)
83459.9
  32.02
                   CALIBRATION DATA
   Date   Stnd. Activity (nCi)    Ct time (hr)   Identif. Spectrum File
  03/09/93 Ra-226         36.0      2.00 2298-36-1 D4RA0393.CHN
  03/09/93 Th-232         46.0      2.00 2298-36-2 D4TH0393.CHN
  03/09/93                        27.30         D4BG0393.CHN
  Analyst: RVR
 Analysis Date:
03/16/93
Isotope, picocuries/gram
Peak#
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
i
Isotope
Ra-226
Pb-212
Pb-214
Ac-228
Pb-214
Ac-228
TI-208
TI-208
Bi-214
Bi-212
TI-208
Ac-228
Bi-214
Ac-228
Bi-214
Bi-214
TI-208
II
Energy Counts
186.1
240.0
295.2
338.4
351.9
463.1
510.6
583.0
609.3
727.3
860.3
911.6
934.0
965.0
1120.3
1764.5
2614.4
r *•" jT-"" Average
11226
33228
39167
24587
64780
6231
27 '17
3732
44140
872
501
23008
2058
16834
8456
6869
1313
(pCi/g)
Ra-226 Ra-228
44.8

43.9
54.2
43.8
50.1


43.5


50.9
42.9
49.3
42.0
42.7

43.7 51.5
Th-228

5.7




6.1
5.4

5.8
5.6





5.6
5-ZJ
                             301

-------
      Isotope, picocuries/gram
Peak # Isotope
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Ra-226
Pb-212
Pb-214
Ac-228
Pb-214
Ac-228
Tl-208
Tl-208
Bi-214
Bi-212
Tl-208
Ac-228
Bi-214
Ac-228
Bi-214
Bi-214
Tl-208
Energy
186.1
240
295.2
338.4
351.9
463.1
510.6
583.0
609.3
727.3
860.3
911.6
934.0
965
1120.3
1764.5
2614.4
Counts
5405
9376
3943
1078
6343
377
1117
1691
4093
356
111
1115
176
858
774
693
553
Average, pCi/gram
Ra-226 Ra-228
32.1

7.3
4.0
7.1
4.8


7.0


4.3
6.6
4.4
6.9
7.6

8.8 4.3
Th-228

4.2




4.3
4.5

4.1
2.2





4.9
4.3
302

-------
    EFFECTS OF MATRIX DIFFERENCE
PRODUCED SOLIDS SAMPLE CALCULATED
  AGAINST TWO DIFFERENT MATRICES

 ENERGY     AGAINST     AGAINST
  KeV         SAND       BARITE
               STD         STD
              (pCi/gm)       (pCi/gm)

  186          612         830
  295          600         684
  352          602         660
  609          614         646
  934          632         638
 1120          607         629
 1764          603         615
              303

-------
              ADVANTAGES OF METHOD
NO RADIOCHEMICAL SEPARATION METHOD NEEDED




QUICK, STRAIGHT FORWARD SAMPLE PREPARATION




STANDARDS AND SAMPLE USE SAME MATRIX AND GEOMETRY




QUICK TURN AROUND TIME




TAILORED FOR PRODUCTION OR SOIL SAMPLES




MORE ACCURATE WHEN COMPARED TO COMMERCIAL LABS




RESULTS BASED ON EQUILIBRIUM OF RADIUM AND DAUGHTERS




ABILITY TO SEARCH FOR OTHER NORM ISOTOPES ON SPECTRUM

-------
                                        MR.  TELLIARD:   Our final  speaker for this
afternoon is Joe Raia. Joe is going to be talking on a project that the Office of Water has been
involved with for the last decade.  It is on the analysis and determination of diesel, mineral, and
crude oil in drilling muds.

             For those of you who aren't familiar with what drilling muds are, they are muds
that you use for drilling, and it is basically a characteristic of the petroleum industry which, as
we all know, is dirty anyhow and that is why they have muds.

             So, this particular project is something that Joe and I and numerous other people
who have since retired, passed on, quit, been maimed, have been working on so long we have
forgotten why. Now we are to that point where we are almost done, and I am sure we have lost
the original data,  but Joe is going to report on, we hope, the final of that study.
                                          305

-------
306

-------
METHODS FOR THE DETERMINATION OF DIESEL, MINERAL, AND CRUDE OILS
        IN DRILLING MUDS FROM OFFSHORE DRILLING OPERATIONS
                                by
                   Joseph C. Raia (Consultant),
                    Dan Caudle (Conoco Inc.),
          Ronald E. Benjamin (Southern Petroleum Labs),
       Donald J. Weintritt (Weintritt Consulting Services)
            16th Annual EPA Conference on Analysis of
                   Pollutants in the Environment
                         Norfolk, Virginia
                           May 5-6, 1993
                            307

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                             ABSTRACT

The  effluent  limitation  guidelines  being promulgated  by  the
United  States Environmental  Protection  Agency  (EPA)  for  the
offshore oil  and gas  industry include  the  prohibition of  the
discharge of diesel oil in  drilling muds and drill  cuttings from
offshore oil and gas platforms.   Analytical test procedures have
been developed by the EPA  to allow monitoring for diesel  oil in
drilling  fluids whenever necessary  to ensure compliance  to the
regulation.  In  the development of these  analytical techniques,
the EPA and the Technology and Diesel Analysis  Work Group of the
American Petroleum Institute (API) conducted studies  to evaluate
various  extraction  and  analytical  measurement techniques  for
reliable  determination of  diesel, mineral,  and  crude oils  in
drilling muds.   This work  has resulted in Method  1662 (Soxhlet
Dean-Stark  Extraction  and  Gravimetry   for  Total  Extractable
Material  in Drilling Mud), Method 1654A (HPLC/UV for Polynuclear
Aromatic  Hydrocarbons Content of  Oil), and Method  1663 (GC/FID
for differentiation of Diesel and Crude Oil).

This  paper   will  discuss  the   methods,  the  inter laboratory
validation   results,  and  how  the  methods  are  employed  for
differentiating diesel, mineral,  and crude oils in  drilling mud
discharges.
                                308

-------
                           INTRODUCTION
Diesel oil in drilling fluids (muds) and drill cuttings cannot be
discharged from offshore  oil and gas platforms.   The diesel oil
prohibition is part of the effluent limitation guidelines for the
offshore oil  and gas industry being promulgated by the The U. S.
Environmental Protection  Agency (EPA)  [1].  In  support of  the
final rule, EPA has issued a compendium of analytical methods for
the determination of diesel, mineral,  and crude oils in offshore
oil  and  gas  industry  discharges  [2].   The  analytical  test
procedures were  developed to allow monitoring for  diesel oil in
drilling  fluids whenever necessary  to ensure compliance  to the
regulation.

Initially,  Method  1651  (Retort,  Gravimetry, and  GC-FID)  was
developed for  diesel monitoring and  proposed as part of  the 40
CFR Part  435 rule (56 FR 10664-10715). This method uses a retort
apparatus to thermally extract oil from drilling mud.  The oil in
the  extract  is  weighed  and  then  further   analyzed  by  gas
chromatography with flame ionization  detection (GC-FID),  Diesel
oil identification is  done by comparing the pattern  of GC peaks
in the oil with the pattern produced by a diesel oil reference.

The American Petroleum  Institute (API) and its  member companies
critized Method  1651 because  the method is  not definitive  for
diesel,  since it can  show potential interferences  from mineral
oil and crude oil.  Mineral oil is an allowed lubricity  additive
for drilling fluids, which may  be discharged in drilling muds as
long as the  discharge passes the sheen test  and toxicity limits
are met.   Crude oil arising  from the oil bearing  formation can
have hydrocarbons which interfere in  the same boiling range used
in Method 1651 to identify diesel hydrocarbons.  Other objections
to  Method 1651 were that the retort apparatus used in the method
is  not sufficiently  reproducible  to  serve  as  an  analytical
extraction technique,  and  the  device  can  produce  analytical
artifacts with some types of muds.

In order to develop a suitable analytical procedure for diesel in
drilling  muds, the  EPA and  the Technology and  Diesel Analysis
Work Group of  the API conducted studies  to evaluate alternative
extraction  and  analytical  measurement  techniques for  diesel,
mineral, and crude  oils in drilling muds  [3, 4, 5].   This work
has  resulted in Method  1662 (Soxhlet Dean-Stark  Extraction and
Gravimetry  for Total  Extractable  Material  in  Drilling  Mud),
Method  1654A  (HPLC/UV  for  Polynuclear  Aromatic  Hydrocarbons
Content of Oil),  and Method  1663 (GC/FID for differentiation  of
Diesel and Crude Oil).


                            309

-------
This paper  will discuss  these methods  and the  inter 1aboratory
validation results.
      DRILLING MUD DISCHARGE MONITORING FOR OIL AND TOXICITY
The discharge of  drilling muds from offshore  platforms requires
environmental  compliance   monitoring  for  oil   and  toxicity.
Regulatory  requirements are:   no  free oil  can be  present, as
measured  by the  static sheen  test  (the visual  sheen test  is
allowed in EPA Region VI); a toxicity limitation in the suspended
particulate phase of the mud to mysids as measured by the 96-h
LC50 >= 30,000 ppm; no diesel can be present as documented by the
well  inventory record, and  verified by  confirmatory analytical
testing when required.  For confirmatory analysis of diesel,  EPA
Methods  1662, 1654A,  and 1663  are  used in  a tiered  analysis
approach as discussed below.
         DEVELOPMENT OF EPA METHODS 1662, 1654A,,AND 1663


In  the  development  of  Methods  1662,  1654A,  and  1663, work
conducted by EPA  and the API Task Group was aimed at obtaining a
good  alternative extraction  procedure  to  the  retort,  and  a
measurement  finish that would  allow diesel to  be distinguished
from mineral oil and crude oil.

The extraction  techniques evaluated  in addition  to the  retort
were:     Soxhlet   Dean-Stark   (Soxhlet-DS),  sonication   with
acetone/methylene  chloride  (1:1  V/V),  and supercritical  fluid
extraction (SFE) with  carbon dioxide.  Laboratory  prepared hot-
rolled muds  were spiked at  two concentration  levels  of diesel.
One level was  at 0.2% and the  other at 2.095.   Similarly, other
mud samples were spiked with mineral oil and with crude. Based on
the recovery data  from these extraction studies,  Soxhlet-DS was
selected  as the best extraction procedure for  diesel in drilling
muds [3].   SFE  gave lower  recoveries for  diesel than  did the
other techniques tested in this study.  This may have been due in
part to problems caused from  the relatively high water  contents
of drilling muds.

In  the  analytical  measurement  of  diesel  in  drilling  muds,
definitive  techniques are   required  that  allow  diesel  to  be
distinguished  from potential interferences caused by mineral oil
and crude oil.   Diesel oil  is known to generally  contain higher
concentrations of polynuclear  aromatic hydrocarbons  (PAHs)  than
does mineral oil.  Further,  the alkane hydrocarbons in diesel are
typically in the  boiling  range of C10-C24, while  in crude oils,
the alkane hydrocarbons generally range  lower than CIO and extend
beyond C24.   These  distinguishing characteristics,  PAH content
                                310

-------
and  alkane  boiling range,  were  the  basis of  selecting  High
Performance  Liquid   Chromatography/Ultraviolet  (HPLC/UV)   for
measuring PAHs, and GC-FID for determining n-alkane boiling point
profiles.

A study was then  made to quantify the PAH  contents and n-alkane
distributions  in diesel, mineral,  and crude  oils [4].   Retort
results  for  drilling  muds from  offshore  drilling  sites were
surveyed to  determine levels  of total  extractable material  in
drilling muds  [5].  These  data provided PAH concentration levels
that could  be used to  distinguish diesel oil from  mineral oil,
and  n-alkane distributions that  could be used  to differentiate
diesel  oil  from  crude  oil.    The  survey  also  provided  an
indication  of  background  concentration  levels of  extractable
material in drilling  muds to which diesel had  never been added.
This information provided the basis  for how the tiered  analysis
approach   is   employed,   using  PAH   content   and   n-alkane
distributions,  to determine diesel oil in drilling muds.


       DIFFERENTIATION OF DIESEL, MINERAL, AND CRUDE OILS
               BY EPA METHODS 1662, 1654A, AND 1663


The tiered analysis approach is used to determine the presence of
diesel in drilling muds as shown in Figure 1.

Method 1662  uses a  Soxhlet/Dean-Stark extractor  to remove  oil
from  the drilling  mud. The  total  oil in  the  extract can  be
measured  by weighing  a measured  portion of  the extract.   The
other portion of the extract is used in Methods 1654A and 1663.

The PAH content of the  extracted oil is measured as phenanthrene
by HPLC/UV in Method 1654A.  If the PAH content is less than 0.35
weight percent, the  oil is mineral oil.   If the PAH  content is
equal to or  greater than 0.35 weight percent, the  oil is diesel
oil or crude oil.

Method 1663 uses GC-FID to measure the presence  and distribution
of hydrocarbons in the extracted  oil.  The presence of n-alkanes
in the  C9-C24 range  indicates the presence  of diesel  or crude
oil.  If less  than 10 n-alkanes are present in the  C9-C24 (at a
signal-to-noise ratio of 3 or greater for  each n-alkane), diesel
oil  is not present.  If 10 or  more n-alkanes are present in the
C9-C24 range,  the percentage of  n-alkanes in the  C25-C30 range
are used to determine if the oil is crude oil.   The oil is crude
oil if the  C25-C30 n-alkane content is greater  than 1.2 percent
of the total C9-C30 n-alkane content.
      INTERLABORATORY STUDY OF METHODS 1662, 1654A, AND 1663


An  interlaboratory round-robin test  of methods 1662,  1654A and

                            311

-------
1663  is underway  and the  results are  being completed  at this
time.   The  results presented in this paper  are only preliminary
and  are  not  yet  completed.   The  test  design   includes  six
analytical laboratory participants, and one additional laboratory
which  prepared  and  distributed the  drilling  mud  samples for
testing.  DyneCorp  Viar is serving as sample  control center for
the  study.    The laboratory  participants  have  received three
drilling mud  samples.   One sample was  spiked with  diesel oil,
another with mineral  oil, and  the other  with crude  oil.   The
laboratories  are reporting  initial  and  ongoing precision  and
recovery results for  each method as specified.   Each of the mud
samples is analyzed in duplicate.

Results obtained  thus far  show that  all four laboratories  who
have reported data  have been able to meet  the initial precision
and  recovery  acceptance  criteria for  the  methods  (Table 1).
Results for  the spiked drilling mud samples  however are showing
measureable interlaboratory variabilities (Table 2.).  As soon as
all the data has been completed and reported, the results will be
examined in detail  for verification.   The completed results  of
the  interlaboratory study  will  then be  used to  determine any
required method revisions.
                            REFERENCES
[1]  40 CFR Part 435 (58 FR 12454-12512, No. 41, March 4, 1993)

[2]  "Methods for the Determination of Diesel, Mineral, and Crude
Oils  in Offshore Oil and Gas Industry Discharges", EPA-821-R-92-
008, 1992

[3]    "Results of  the  API  Study  of Extraction  and  Analysis
Procedures  for the Determination of Diesel Oil in Drilling Muds"
Final Report, American  Petroleum Institute, Offshore  Guidelines
Steering  committee, Technology  Work Group,  Prepared  by J.  C.
Raia, Shell Development Company, Houston, Texas, April 8, 1992.

[4]  "Polycyclic   Aromatic   Hydrocarbon   and   Normal   Alkane
Distributions in Diesel,  Crude, and Mineral Oils:  A Comparative
Study", Volumes 1 and 2, American Petroleum Institute, Technology
Work Group,  Offshore  Effluent  Guidelines  Task  Force,  Report
Prepared by Ronald  Benjamin, Core  Laboratories, Lafayette,  LA,
January 10, 1992.

[5]  "The  Analysis  of  Drilling  Fluids  and Cuttings  from  14
Offshore  Drilling  Sites",   Final  Report,  Weintritt   Testing
Laboratories, March 31, 1989.

                                 312

-------
                                    Method 1GG2
                                    SDS extraction
                           Rotovap to approx imately  1 ml_
                      Adjust volume to 5.O ml_ with acetonitrile
               Evaporate <4.O ml_ to cJryness  with  nitrogen blowdowri
                 Determine total oil in 4.O-mL_ portion by gravimetry
UJ
                       Method 1654A
 Determine PAH content of  1 .O-mL portion by HPLC/UV
       If PAH content O.35 wt °/o.  oil may be diesel or crude oil
                                     Method 1663
              Determine n-alkane pattern of 1.O-ml_ portion by GC/RID
          If <1O n-alkanes present in Cg — C^/j range © S/N >3. no diesel
         If n-alkanes present in Cg— 030 range & ^25—^30 n-alkanes => 1
                     % of total Cg— C3Q n-alkanes. oil is crude oil
                                                                                   CS2 10-5
                                     FIGURE-1
           Differentiation of Diesel, Mineral, and Crude Oils by SDS Extraction.
           HPLC/UV. and GC/FID,  using Methods 1 662.  1 654A.  anH  1

-------
                  TABLE-1
RESULTS OF INTERLABORATORY STUDY OF METHODS
1662, 1654A, AND 1663 (ALL DATA NOT YET REPORTED)
INITIAL PRECISION & RECOVERY
LABORATORY A B C D E F
1662(%W Extract.)
SPIKE
MEAN
S.D.
0.25
0.22
0.02
0.25
0.18
0.04
0.20
0.15
0.02
0.25
0.20
0.02
1654A(mg/ml PAH)
SPIKE
MEAN
S.D.
1.25
1.39
0.04
3.21
3.56
0.41
1.25
1.05
0.03
1.25
1.36
0.13
1663(mg/ml C25-C30)
SPIKE
MEAN
S.D.
1.25
1.24
0.02
1.25
1.16
0.14
1.25
1.13
0.12
1.25
1.20
0.22

-------
U)
                          TABLE-2
       RESULTS OF INTERLABORATORY STUDY OF METHODS
       1662, 1654A, AND 1663 (ALL DATA NOT YET REPORTED)

LABORATORY
%W Extract.
M+Mineral
M+Diesel
M+Crude
%W PAH
M+Mineral
M+Diesel
M+Crude
%W C25-C30
M+Mineral
M+Diesel
M+Crude
A

0.18
0.14
0.14

0.18
2.70
1.16

<1.0
<1.0
1.53
B

0.028
0.050
0.041

0.50
2.74
1.78

<1.0
0.6
7.5
C

0.26
0.17
0.13

0.19
0.28
0.40

<1.0
<1.0
<1.0
D E F

0.05
0.34
0.14

<0.01
0.04
<0.01

<1.2
/ *4 ^\
> H ^)

-------
METHODS FOR THE DETERMINATION OF  DIESEL,
MINERAL,  AND  CRUDE OILS  IN DRILLING  MUDS
FROM  OFFSHORE  DRILLING OPERATIONS

                        by

 Joseph C. Raia,  Consultant;  Dan Caudle,  Conoco;
 Ronald E.  Benjamin, Southern Petroleum labs,  and
 Donald J.  Weintritt,  Weintritt Consulting Services

                Presented  at the

           16th Annual EPA Conference on
      Analysis of  Pollutants in the Environment
                Norfolk,  Virginia
                May  5-6.  1993

-------
ACKNOWLEDGMENTS
Robert  C.  Ayers, Consultant(Exxon)
Carrie Buswell, DynCorp.Viar
Thomas M.  Randolph, Consultant(Shell Offshore)
Dale  R. Rushneck,  Interface
George  H.  Stanko,  Shell Development
Alexis E.  Steen,  American  Petroleum Institute
Michael  T.  Stephenson,  Texaco
William  A.  Telliard,  Environmental  Protection Agency

-------
               DRILLING MUD DISCHARGE MONITORING
                        OIL AND TOXICITY
00
          •  NO FREE OIL
            STATIC/VISUAL SHEEN TEST
            NO TOXICITY
            MYSID LC50 >• 30,000 PPM
          •  NO DIESEL
            WELL INVENTORY RECORD/ANALYSIS
          • Ref.: Oil and Gas Extraction Point Source Category;
            Offshore Subcategory Effluent Guidelines and New
            Source Performance Standards; Final Rule
            [Fed. Reg. 56, No. 41, March 4, 19931

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   EPA & API METHOD DEVELOPMENT EFFORT
           DIESEL IN DRILLING MUDS
INITIAL WORK - EPA METHOD 1651A(RETORT-GC/FID)

ALTERNATIVE EXTRACTION/ANALYSIS STUDIES
 Ref.fAPI Diesel Analysis Work Group Report April 92]

TIERED ANALYSIS APPROACH

EPA METHODS 1662, 1654A, 1663
 Ref.lEPA 821-R-92-008, December 19921

INTERLABORATORY METHOD VALIDATION

-------
         200
          150
          100
          50
            OIL RECOVERY vs EXTRACTION METHOD
               BASE MUD SPIKED WITH DIESEL(D)
            % Wt. Recovery of Oil Added
              Soxhlet-DS
         Retort
                                    nnr
        Sonication
          SFE
   Mud «• 0.2% D
   Mud * 2% D
87
94
123
116
171
170
69
22
                      EXTRACTION METHOD
                      Mud * 0.2% D
                    Mud * 2% D
Ret: API Comments of 5/13/91(Vol.8 Tab2)
to 56 Fed Reg 10664-10715(3/13/91)

-------
to
           SOLVENT EXTRACTION VS RETORT GRAVIMETRIC
                 Extraction of Diesel Oil in Drilling Mud
           Measured Oil, g/KQ
            0
      10         15
DIESEL OIL ADDED, g/KG
             20
                 NOMINAL
 + RETORT
SOXHLET-DS
SONICATION
        Ret: API Comments of 5/13/91(Vol.8 Tab2)
        to 56 Fed Reg 10664-10715(3/13/911

-------
                  GRAVIMETRIC  OIL RESULTS
                   A)BASE MUD - NO OIL ADDED
K)
       1000
       800
        600
        400
        200
          MQ/KG OIL
                                    837
               579
                         278
 138
             Sonication    Soxhlet-DS      SFE
                       EXTRACTION METHOD
Retort

-------
         SURVEY OF EXTRACTABLES IN DRILLING MUDS, PAH IN
         MINERAL OILS, AND C25-C30/C9-C30 IN DIESEL OILS
                            a)
           EXTRACTABLES IN
            DRILLING MUDS
                 mg/kg
                                   b)
                           PAH IN
                         MINERAL OILS
                           % WT
                                         b)
                              C25-C30 IN
                              DIESEL OILS
                                  %  WT
LO
N
Mean
S.D.
Mean+2SD
  14
1267.
 748.
2764.
 9
0.1590
0.0935
0.3459
10
 0.45
 0.39
 1.22
        a) The Analysis of Drilling Fluids and  Cuttings from
          14  Offshore Drilling Sites",  Weintritt Testing
         Laboratories Report, March  31,  1989.

        b) "PAH and n-Alkane  Distributions in Diesel,  Crude, and
         Mineral Oils: A  Comparative  Study, Core Laboratories
         Report, January  10,  1992.

-------
                                      Method 1662
                                     SDS extraction
                           Rotovap to approx imately 1 mL
                      Adjust volume  to 5.O ml_ with acetonitrile
              Evaporate 4.O rr»L to  dryness  with nitrogen blowdown
                Determine total oil in 4.O-mL_ portion  by gravirnetry
                                      Method  165-4A
               Determine PAH content  of 1 .O-mL portion by HRLC/UV
                      If RAH content O.35  wt *?4», oil may be diesel or crude oil
U)
N)
                                       Method 1663
             Determine n-alkane pattern of I.O-mL portion by GC/RID
          If <1O n-alkanes present in Cg—C2^ range  <§>  S/N =»3. no diesel
        If n-alkanes present in Cg—030 range & 035—^SO ri-a'*
-------
METHOD 1662 [From EPA 821-R-92-008,12/92]
        Soxhiet/Dean-Stark Extractor

-------
               METHOD 1654A [From EPA  821-R-92-008,12/92]
                    HPLC/UV  of Standard & No 2 Diesel Oil
to
                                     00
                                     0>

                                     O)
                               .' <5
                                I
                                re


                                o.
                                

                                    O)
                No. 2 Diesel Oil
               0.00
 i

0.50
1.00        1.50

  x 101 minutes
                      CM
                                                       00 _'
                                                        CD
2.00
                                                                AM-010 1

-------
             METHOD 1663 [From EPA 821-R-92-008.12/92]
             GC/FID of Crude Oil & Diesel through C25-C30
U)
(O
              Crude Oil
                       C/5
                      O
in
»—
O
 1/1
        O
        C\J
        O
                 I • • ' ' I
              Diesel Oil
                        HI

-------
K)
GO
      INTERLABORATORY STUDY OF METHODS 1662, 1654A, 1663
             Six Lab Participants + One Sample Prep Lab
Sample
IPR

M1662
Extractable
%W
4X
Blank(1662) 1X
Blank(1654A) 1X
or(1663)
OPR

1X
Mud+Diesel 2X
Mud+Mineral 2X
Mud+Crude 2X
M1654A
PAH in Oil
%W
4X
1X
1X
1X
2X
2X
2X
M1663
C25-C30
%W
4X
1X
1X
1X
2X
2X
2X
M1663
Diesel Oil
mg/ml
4X
1X
1X
1X
2X
2X
2X
Mean
% Diff.

-------
UJ
K)
       RESULTS OF INTERLABORATORY STUDY OF METHODS
       1662, 1654A, AND 1663 (ALL DATA NOT YET REPORTED)
INITIAL PRECISION & RECOVERY
LABORATORY A B C D E F
1662(%W Extract.)
SPIKE
MEAN
S.D.
0.25
0.22
0.02
0.25
0.18
0.04
0.20
0.15
0.02
0.25
0.20
0.02
1654A(mg/ml PAH)
SPIKE
MEAN
S.D.
1.25
1.39
0.04
3.21
3.56
0.41
1.25
1.05
0.03
1.25
1.36
0.13
1663(mg/ml C25-C30)
SPIKE
MEAN
S.D.
1.25
1.24
0.02
1.25
1.16
0.14
1.25
1.13
0.12
1.25
1.20
0.22

-------
      RESULTS OF INTERLABORATORY STUDY OF METHODS
     1662, 1654A, AND 1663 (ALL DATA NOT YET REPORTED)
LABORATORY
%W Extract.
M+Mineral
M+Diesel
M+Crude
%W PAH
M+Mineral
M+Diesel
M+Crude
%W C25-C30
M+Mineral
M+Diesel
M+Crude
A

0.18
0.14
0.14

0.18
2.70
1.16

<1.0
<1.0
1.53
B

0.028
0.050
0.041

0.50
2.74
1.78

<1.0
0.6
7.5
C

0.26
0.17
0.13

0.19
0.28
0.40

<1.0
<1.0
<1.0
D E F

0.05
0.34
0.14

<0.01
0.04
<0.01

> -4 f\
£ ^ ^5
^ *4 f\
OJ
o

-------
U)
                  CONCLUDING COMMENTS
    • THE TIERED ANALYSIS APPROACH IS PRESENTLY THE
     MOST DEFINITIVE AND COST EFFECTIVE WAY TO
     MEASURE DIESEL, MINERAL, AND CRUDE OILS IN
     DRILLING MUDS FROM OFFSHORE DRILLING OPERATIONS
    • EPA METHODS 1662, 1654A, and 1663 WERE DEVELOPED
     FOR THE MEASUREMENT OF PAH CONTENT OF OIL TO
     DISTINGUISH MINERAL FROM DIESEL, AND THE ALKANE
     DISTRIBUTION TO DIFFERENTIATE DIESEL AND CRUDE OIL
     THE RESULTS OF THE INTERLABORATORY VALIDATION STUDY
     OF THESE METHODS, WHICH IS NEARLY COMPLETED, WILL
     BE USED TO DETERMINE ANY REQUIRED METHOD REVISIONS

-------
                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD:  Do we have any questions?

                                       MR. CROWLEY:  Ray Crowley from Millipore.
             I have a question on 1654. You do an HPLC separation, and then you add up all
the peaks.  Why was that chosen over just doing a UV analysis and doing a total absorption,
since you deal with the sum at the end anyhow and reference it to the phenanthrene?

                                       MR. RAIA:   Are you talking about not doing a
separation?

                                       MR. CROWLEY:   Yes.   You  have got an
acetonitrile.  Why don't you just put it in the UV spectrometer and measure total absorbance?
Because you add it up at the end anyhow.

                                       MR. RAIA: I think that you may end up with some
interferences.
                                       MR. CROWLEY? From?

                                       MR. RAIA:  From other additives  that could be
extracted in the drilling mud.
                                       MR. TELLIARD: There is more than one material
that would come over in the extraction that we...it isn't real oil but would appear as oil in the
analysis which is why we are doing the separation.

             Anyone else?  (No response.)
                                       MR. TELLIARD:  I would like to have a round of
applause for our speakers today for this afternoon's session.

             Thank you all for your attention.  Tomorrow morning at 8:30, quarter of 9:00, we
will  start.  For those of you  attending  the magic  show tonight, please  do not disappear,
particularly if you are a speaker.

             We'll see you.

(WHEREUPON, the proceedings were recessed at 4:30 p.m.)
                                        332

-------
                               PROCEEDINGS

                                     May 6. 1993

                                        MR. TELLIARD: I would like to get started, please.
Could you come on in and take a seat?

             To get  the day off on a really upbeat note, I have a schedule change.  Mike
Kravitz who is  supposed to be here at 9:45 will be showing up in Ms. Rhodes' place  at 3:15.
So, we are switching two papers. We are going to have the pesticide paper this morning and the
dredge materials this afternoon.  I hope that does not inconvenience anyone.

             This morning, we open with George Stanko. George has been, I think, at every
Norfolk meeting since inception. There is no prize for that. He just keeps coming back.

             George  is going to talk about the storm water sampling and analysis program for
Shell.
                                          333

-------
334

-------
          STORM WATER SAMPLING  AND  ANALYSIS
              Author:  G. H. Stanko
                       Shell Development Co,
Presented at: 16TH Annual EPA Conference on Analysis
          of Pollutants in the Environment
                  Norfolk,  Virginia
                    May  5,6,  1993
                          335

-------
                                ABSTRACT
The Fina] Rule for storm water discharges under  the  NPDES Permit system
was published in the Federal Register on November  16,  1990.   This Final
Rule  established  requirements  for  the  storm  water permit  application
process.   Initial  review  of  the  Final  Rule  identified  a number  of
technical issues associated with the  flow-weighted compositing requirement
for organics.

EPA published their "NPDES Storm Water Sampling  Guidance Document"  in July
1992 and the  EPA guidance document was very explicit about the regulatory
requirement to use flow-proportioned samples  for storm water monitoring.
A comprehensive  review  of the EPA guidance document indicated it provides
detailed  information   and  should  prove  helpful  in  meeting  regulatory
requirements, but  EPA may need  to  provide  additional  information  in some
areas.

A hypothetical example  for a storm water event  along with all the needed
calculations  to  prepare the flow-weighted  composite samples for organics
and volatile  organics  was  prepared  and  is  included in this  paper.   The
hypothetical   example  demonstrates   the  EPA  flow-weighted  compositing
requirement could  be met with some  difficulty  and  also identified a number
of areas where additional  EPA guidance may  be considered.
                              336

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                    STORM  WATER  SAMPLING  AND  ANALYSIS


                              INTRODUCTION
The Final Rule for storm water  discharges  under the NPDES Permit system
was published in the Federal Register  of November  16,  1990.   This Final
Rule  established  requirements  for  the  storm  water permit  application
process.   The  Chemical  Manufacturers  Association  (CMA)  Environmental
Monitoring Task Group (EMTG)  was asked  to review the  Final Rule and draft
a  guidance  document  for member companies.   The review  indicated  that
compliance monitoring for  storm water  regulations  was  not a  simple task
and identified a major technical issue concerning the requirement to use
flow-weighted composite samples  for organics analysis.  The Final Rule did
not provide sufficient  details for preparation of flow-weighted composite
samples  for  semi-volatile  organics  nor for volatile organics.   The EPA
methods  also  do  not  contain protocols for  preparation of flow-weighted
composite samples.  The CMA Task Group  prepared  a draft guidance document
which identified this major  technical  issue and recommended  using time-
weighted  composite  samples  based  on  protocols that  were  used  during
effluent   guideline   limitations   samplings    conducted   by   EPA   and
participating CMA member companies.

All of the technical  issues associated  with  the  flow-weighted compositing
requirement  were  subsequently  discussed with  EPA  and the CMA guidance
document was  offered for EPA review  and  concurrence.  In July 1992, EPA
published their guidance document,  "NPDES  Storm Water  Sampling Guidance
Document" (EPA 833-B-92-001,  July 1992).  The CMA EMTG was  asked to review
the EPA guidance document and to prepare comments.

Review of the EPA guidance document  identified  several technical issues
which  could  bias the  analytical results.    However,  the EPA guidance
document was very explicit about the regulatory requirement to use flow-
proportioned  samples  to   satisfy  storm  water   regulations.    Comments
resulting  from  the  review  were  prepared  to  share  with   EPA  and  a
hypothetical   example for a storm water event along  with  all  the needed
calculations to prepare the  flow-weighted composite  samples for organics
and volatile  organics were prepared  to demonstrate how one might comply
with storm water  regulations.  The example demonstrated  that the EPA flow-
weighted compositing  requirement could be met but with some difficulty.
                                    337

-------
    COMMENTS  FOR  EPA's NPDES STORM WATER SAMPLING GUIDANCE DOCUMENT
Review of the EPA guidance document revealed that  EPA  provided  detailed
information which should prove helpful  in  meeting  storm water  regulatory
requirements; however, there are still some areas  where more  details  or
further clarifications are needed.   The comments  that  follow address the
specific actions  required to meet  the  regulatory requirements for the
entire process and more importantly, point  out potential problem areas and
options  that one  may  want  to  consider for  meeting  the  regulatory
requirements.
Chapter 2

Chapter 2 (p. 15-18) clearly identified the specific  nature and criteria
for a storm  event.   The EPA guidance specifies that one needs to establish
and document details  for  the  storm event to verify the event  meets  EPA
specified criteria.  One first  has  to establish in which rain zone of the
United States the sampling  is to occur (Exhibit 2-8, p. 21), then identify
the annual  statistics and the  average  parameters  for each  independent
storm event  for the site to be  sampled.   For example,  if the site were in
East Texas (Houston),  one would find that the average storm duration is 8
hours with an intensity of 0.137 inches per hour,  and the  average volume
of rain is 0.76  inches.  The average interval  between storm midpoints is
213 hours.  With  such  information in hand, one can prepare a sampling plan
and then establish whether  a given storm event met the specified criteria.
The example  (Exhibit 2-9,  p. 22)  was quite easy to follow and understand.
For a  site  in  Houston,  Texas,  a storm event that lasts between  4  to 12
hours where  the rain volume is between 0.38  and 1.14 inches would meet the
criteria provided  it occurred 72 hours after the last storm event.

One detail missing from Chapter 2 is the  need to have and use a rain gage
at  the  sampling  site  during  the  storm  event.   Rain  volume  (depth)
information is needed to establish  that the  storm event met the specified
criteria.  While the  EPA  guidance  document  does  not  preclude the use of
local weather information  to establish meeting the storm event criteria,
local weather reports may not  be appropriate because of the distance from
an official  weather gathering  site from  the sampling  location or due to
the local nature of the storm event.  These and  other factors need to be
considered.   Use of a rain gage at the sampling  site  is perhaps the most
reliable way to  obtain  the needed  information.   It  is important to note
that the rain volume information is only  used to establish that the storm
event  met criteria, and this  information is not used  in  any subsequent
calculations for the  flow-weighted composite samples.
Chapter 3

Chapter  3  provides  useful  information  concerning  different  options
available  to  measure or estimate flow rates.   Perhaps  one  of the least
                               338

-------
expensive and practical ways is described as the "Float Method" (p. 49).
Initial review of the  guidance  revealed  no  major  problems.   Exhibit 3-8
(p. 51) provides an  example for a  storm event.  These data in Exhibit 3-8
were used for  the hypothetical  example.   Sample #1  in  this  example was
taken at "0  minutes"  when there should have been  no flow.  One explanation
would be that they set  the  clock  to  "zero"  at the  time the  first sample
was  actually  collected.   This  may be the  situation since  Exhibit 3-8
showed flow  and  flow  calculations at SO.   However, a corresponding example
in Exhibit 3-16 is inconsistent with 3-8  because Sample #1 was collected
when there was no flow.  We think  the best way to address this problem is
the way it was done in Table 1 of our hypothetical example.  "SO" was used
to denote no sample was  collected; to was  used to denote when the sampling
clock was started; and "clock time" was used to document the actual times
involved. No flow calculations were made  at this time  (tO) since the flow
just started.  Table  1  for  our  hypothetical example also included the use
of "S," "t," and  "Q"  to  make the Table easier to use when calculations are
made.  All of these  terms are used in subsequent EPA example equations.
The problem with S#l was  previously covered and  addressed  in  Table 1 of
the hypothetical example.  Exhibit 3-16  (p. 63)  shows  that the flow was
measured and  calculated  when S#9 was  collected.   Exhibit 3-16  (p.  64)
shows how the  data  from p. 63 would be  plotted.  In this example, it shows
S#l would  have  been collected 20 minutes  after  flow started.   S#9 was
collected at 180 minutes  and  the curve shows the flow  (Q9) was zero at 180
minutes.

Step  3  advises  to  "assume  that  flow drops  uniformly  from the  last
calculated flow  rate  (Q9)  to zero at  the time when  Q10  would have been
taken."    This  is  where  the real gray areas  exist.   First,   the  curve
actually shows zero flow  at  Q9.   It was confirmed that Q9 = zero was used
to calculate  the volume  of  runoff (V9) during the time  from  160  to 180
minutes  (p. 66).   Secondly,  Q10  is not used in  subsequent calculations.
We think Step  3  should  have  stated the  flow at Q9 should have arbitrarily
been set to zero.

This brings up a second point.   Do you have to measure the flow when S#9
is collected?  All   the EPA examples show such a  calculation and  we also
showed a flow calculation  in Table  1  of the hypothetical  example.   The
second point is  why should the  flow be  assumed to be zero rather than use
the measured flow when  S#9 is collected.  Arbitrarily setting the flow to
zero would introduce some bias (low)  to the actual  flow calculation from
the time flow was  observed  and when  S#9 was collected.   If there  was a
large incremental increase in flow from Q8 to Q9,  the  amount of bias would
increase  substantially.     The  EPA   guidance  document  needs  further
clarification.   In  the hypothetical  example,  Q9 was arbitrarily  set to
zero to  follow the  EPA example in Exhibit 3-16.   We are not certain this
is the correct way  to calculate the volume  or  the way EPA intended it to
be done.

Chapter  3  (p. 39)  specifies  the nature of  the samples  to  be  collected.
One must take  one grab  sample (for each parameter to be monitored) within
                                     339

-------
the first 30 minutes of discharge,  or as soon as possible.  One must also
collect  a  flow-weighted composite sample for  at  least the  first  three
hours of the discharge, or for  the  event's entire duration (if it is less
than  three  hours).    The  flow-weighted  composite  samples   must  be  a
combination of at least three  sample aliquots  taken  during each hour of
discharge, with a minimum  of 15 minutes between each  aliquot.  These  are
the identified sampling requirements to meet the  regulatory  criteria.

While there  are  a lot  of  details  and  useful  information presented  for
these samples, Exhibit 3.22 (Chapter 3, p. 74) gives an excellent example
of some sampling  times that might  be considered; however, there are a few
things to consider.  The example identified the  discharge time from 2:15pm
through 5:15pm.  In  the example, they collected the first grab sample for
the composite at  2:20pm which  is  only  5 minutes after  flow or discharge
was first  noted.  The area of  concern  is for  one's  ability  to estimate
flow with any degree of accuracy only 5  minutes  after it started.  Perhaps
an alternate  option  would be  to  collect  samples  at 2:35pm  (20 minutes
after flow), 2:50pm, 3:05pm, 3:25pm,  3:45pm, 4:05pm,  4:25pm,  4:45pm,  and
5:05pm.   The initial  grab  sample for all parameters would be collected at
the 2:35pm  sampling time  following directions  given  in  Exhibit 3-17  (p.
69).

The nine required grab samples  would be collected  at the times indicated
and would be used  to prepare the flow-weighted composite  samples.  The EPA
guidance document did  indicate  on p.  75 that the  flow-weighted composite
samples should be prepared at the laboratory.  The guidance  document did
not specify the container size  to be used  to collect the grab sample for
the composite sample.   Later in the document EPA  indicated that a total
volume of 5,000 mL is  needed to have sufficient sample to perform all  the
analyses.  This total  volume requirement would  be  independent of the VGA
samples for volatile organics.  A one-liter amber glass container for each
sampling time would  provide more than the  required volume.  Page 75 gives
two different ways one should consider to collect the nine individual grab
samples.

Page 75 also states that "generally,  1,000 ml for  each aliquot collected
should provide enough  sample volume,  when  composited."  Their example on
p. 80 resulted in  a final composite of 5,100  mi.  Our hypothetical example
in Table  3 resulted  in  a final  Volume of  5,950  mL.   If one  used  the
example in Exhibit 3-16 (p. 63)  and go through the calculations, the final
volume would have been 4,000 which is somewhat  short.  Review of the flow
data showed  a  surge during  three  samplings  with minimal  flow during the
rest.  It is important to  note  that the  1,000 mL at each  sample may not be
sufficient to achieve  the  5,000 mL target volume.   The nature of the storm
event and subsequent flow impacts  this  final  volume considerably.  In our
hypothetical example we recommended collecting two  1-L containers to cover
the possibility of breakage.  This second container could also  be used for
preparing  a composite when an  unusual  storm event  was experienced.

The  EPA   guidance  document   provided   information  for  proper  sample
containers and preservation requirements  (taken from 40  CFR Part 136) but
additional  information may be  required for  some  analytical  tests.   For
                               340

-------
example, the pH method specifies that the pH should be taken at the time
of collection which is a field  measurement.  EPA has not approved the use
of narrow-range pH paper in 40  CFR Part  136, so one would  have to use a
meter in the field to meet EPA's pH method requirements.   It should also
be noted that the approved EPA methods for pH also have a requirement to
record  the  sample  temperature  at  the time the pH  measurement  is taken.
This would have to be done for full compliance  with the method.

Assuming that one measures  the  pH of the storm water when each of the nine
individual  grab  samples are collected  for the flow-weighted  composite
sample, one would end up with nine pH readings.   No guidance is provided
with respect  to  reporting  the  pH  data.   The EPA  guidance  document did
specify in Chapter 3,  p.  38,  "Monitoring  by grab sample must be conducted
for pH, temperature,  cyanide,  total  phenols, residual  chlorine,  oil and
grease  (O&G), fecal  coliform, and  fecal streptococcus.   Composite samples
are  not appropriate  for  these  parameters	"    This guidance  is
consistent  with  Page 48803  of the  November  16,   1990 Federal  Register
Notice  which  states,  "you are  not  required to analyze  a  flow-weighted
composite" for oil  and grease. One could interpret  this  to mean that these
tests are to be performed only on the initial  grab  sample taken within the
first  30  minutes of  the  storm event and  there  is no further  need for
additional samples or testing for these parameters.

Use of narrow-range pH paper would be more realistic and reliable, but EPA
has not approved the  use of narrow-range pH paper in 40 CFR Part 136 and
they may not or cannot accept such measurements.

Presumably  the  flow-weighted   composite  for  all  other  environmental
parameters except volatile organics is prepared at the laboratory in one
large container.   Method specified volumes  would have to be portioned out
from the large container  to other smaller containers specified for each of
the analytical parameters.   The different chemical  preservatives could be
added at this point.

Another  associated  problem  is  with the  one-liter  sample  used  for
semivolatile  organics.   The sample container used for the semivolatile
organics analysis is also rinsed with the extraction solvent (as with oil
and grease) to prevent loss of organics to the sample container walls.  If
one  considers that  nine  different  bottles were used  to collect the
individual grab  samples  to make the  composite  sample;  that some kind of
measuring  device was used to  transfer  the proper volume to  a single
compositing container; and that another  device was used  to transfer the
sample  from the single compositing container to the one-liter bottle used
for the semivolatile  organics  methods, one  has to be  concerned with the
potential loss of semivolatile  organics during this entire operation.  One
should  be aware of the potential problems relating to  the measurement of
semivolatiles, etc.   Clarification  may be required from EPA.   The same
situation would exist for  other tests such as  pesticides.

The problems associated with the preparation of a flow-weighted composite
sample  for volatile organics was even more difficult than any previously
stated  problems.   The  EPA guidance document  first acknowledged the
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uniqueness of the vials used for volatile organics.  In Chapter 3, p. 39,
the document states automatic samplers  cannot be used to collect volatile
organic compound (VOC)  samples.  Additional  guidance for collection of VOC
samples can be found  on  p. 69.  Again, the guidance  clearly identifies the
VOC sample as being a grab sample.  Some additional guidance is given on
p. 70 as well.  On p.  75 a reference is given to Section 3.5.2 of Chapter
3  for  preparation of  the  flow-weighted composite sample  for  volatile
organics.   Pages 85 and 86  of Section 3.5.2  give the details  for two
different ways for obtaining a flow-weighted composite result for volatile
organics.

One  way is  "mathematical  compositing"  and the  second   is  "procedural
compositing."  There  are technical and procedural problems associated with
the EPA guidance on pages 85 and 86.

The  "mathematical  compositing"  approach  is the  most  technically,  and
procedurally  sound;  however,  it is quite costly since it  involves  nine
different  sample  analyses  (approximately  $2,000)   to have  the  necessary
data  to construct  the  "mathematical"  composite   result.    As   the  EPA
guidance pointed  out,  this  approach  also  provides specific information
concerning each of the nine sampling  events.

The reference on page 85 for 40 CFR Part 141 along with the four EPA 500
Series Methods is inappropriate.  The reference is  for requirements under
the Safe Drinking  Water Act and  not for  NPDES samples under  the  Clean
Water Act.  The  500 Series method cannot be  used for compliance monitoring
under the Clean Water Act.  The reference should have been for 40 Part 136
and the 600 Series methods  should  have  been referenced.   A reference is
also given for a 25 ml_  purge  vessel.  This refers to Method 524.2 and not
Method 624 where the purge  vessel is  5  mL.

Review of the  specific sections  cited in the EPA guidance document (40 CFR
Part 141.24(f)14(iv) and (v))  revealed  additional  problems.   While  this
section  provides  instructions  for  preparing   a   composite  sample  for
volatile organics, it must be noted that the instructions are for a time-
weighted  composite since  equal  volumes  are  required to  prepare  the
composite.   To  further complicate matters,  the  maximum number  of  grab
samples allowed for the composite  is five.   The minimum total  number of
grab samples  resulting  from a storm event sampling  is nine which would not
be allowed.   Based on the review  of 40  CFR  Part 141, EPA  really did not
provide specific details for  preparation of  a flow-proportioned composite
sample for volatile organics.

The "procedural  compositing"  approach is more cost-effective but has some
serious technical and procedural  problems.   Normally,  a 5 ml syringe is
used to introduce the proper volume of  sample  to  the purge vessel.   For
one sample, there is  no  problem.  The flow-weighted  portions from each of
the nine vials will be  approximately 0.5 ml and will be determined  from
the  flow  rate/volume measurements.   One  could  probably   calculate the
precise volume to three  significant figures.  An example would be that the
first aliquot required is 0.543 mL and  the  second  is 0.473 mL and so on.
It is not technically possible  to  measure either or any of the calculated
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volumes with a 5 mL syringe.

There is some  difficulty in  trying to place 0.473  ml  of sample into a 5 ml
syringe containing 0.543  ml and so on.   One  could  probably use a  1  ml
syringe to measure 0.54 mL and 0.47 mL and so  on  and then introduce each
of the portions directly  to  the  purge  vessel.  One  could also  introduce
each of the portions to  a  5 mL syringe which is then  used to introduce the
flow-weighted composite  sample  to  the  purge vessel.  One would  have  to
introduce the internal  standard(s)  and/or  surrogates into one of the nine
different syringes or to the  5 mL syringe.   This alternative is viable but
is both time and labor intensive and still has the potential  for loss  of
volatile organics.

The EPA guidance gives directions to "draw the sample into the  syringe."
This technique is not the normal practice followed for volatile organics
analysis.  You can lose volatile organics following  this practice.   This
is the  reason why one  cannot use an automatic pump to  collect volatile
organic samples.  Volatile  organic  samples  are normally poured into the
barrel of the syringe.   To go back to the previous example,  how does one
pour 0.437 mL  of water into the barrel of a syringe containing 0.543 mL of
water and so on?

One proposal  that  may be considered to prepare the flow-weighted composite
sample  for  volatiles  is  to use  a  1  mL  syringe (Hamilton  1000  series
syringe with fixed needle, Model* 1001-LTN Cat.# Hamilton 81317) to pierce
the VGA  septum.   The correct volume  to two significant  figures can  be
carefully drawn  into  the syringe without creating a headspace.  The flow-
weighted  aliquot  is  then transferred  to  a 5  mL  syringe  (Hamilton 1000
series  syringe  with  teflon  luer  lock  no  needle model# 10050-TLL  Cat.f
Hamilton 81520)  fitted with  a two-way valve with  CTFE fittings  (Hamilton
Cat.# 86580).  When this operation has been completed for all the VOA grab
samples, the internal  standard(s) or surrogate(s) are added  to the 5  mL
syringe prior to  transferring the  flow-weighted  composite sample to the
purging vessel.    This  procedure has been  attempted and appears  to work
quite well.  For the hypothetical  example  that follows,  this proposal was
used.

Another technical  consideration  is that none of the current EPA procedures
being  followed  by  commercial  environmental  laboratories  or  in  fact
industry  laboratories  have  a  need  for  the  necessary   instructions  to
prepare  a  "procedural  compositing" sample  for  volatile organics.   The
laboratories    also  lack  experience   in  preparing  these  "procedural
composite"  samples.    Laboratories  will  have  to  learn how  to do  the
compositing and  there will be some additional  costs  since this  procedure
is not  routine  and  has to  be done  manually.   Because  of the  number  of
samples  and  syringes   involved,  cross  contamination   problems  may  be
amplified.
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Comments Summary

In summary,  the  review of the EPA guidance  document  identified a number of
problem areas and attempts  were  made to provide suggestions or details in
order to gain an understanding for these problems.   Some technical options
were posed and should be considered.  Faced with the various problems and
options noted, just how would  one envision a storm water  sampling that
would meet  the  regulatory  requirements?   A  hypothetical example  for a
storm water  sampling event was prepared to  gain a better understanding for
the actual physical requirements to conduct a sampling meeting regulatory
requirements  and  the  subsequent analyses  for  flow-weighted  composite
samples.
Pi sclaimer

While  neither  the  author  nor   CMA   assume   responsibility  for  the
hypothetical   example,  we  feel  the  example  does  meet  the  regulatory
requirement of the Final  Rule for storm water regulations.
         STORM WATER SAMPLING AND ANALYSIS HYPOTHETICAL EXAMPLE

Site Location 	 Houston Texas

Facility 	 Chemical  Plant

Parameters Required on NPDES Permit:
      Oil and Grease
      pH
      BOD5
      COD
      TSS
      Total P
      TKN
      Nitrate + Nitrite
      Volatile Organics (Method 624)
      Semivolatile Organics (Method 625)
      Cyanide
      Fecal Coliform

Sampling Point 	 "V" Shaped Grass-Lined Ditch (completely dry)

Last Rainfall 	 Ten Days Ago

Forecast 	 Light to Moderate Rain Expected During the Morning  Hours
              with Clearing in the Afternoon.   Approximately 0.25  to 0.75
              Inches Total  Expected.

Decision 	 Conditions Appear Optimal  to Conduct  a  Storm Water Sampling
              and Sampling  was Approved and Authorized.

Logistics  	 Sampling Crew was  at the Site at Sam.


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Sequence of Events:

1.    It was recorded that the rain started at 5:30am.

2.    Flow at the selected sampling point began at 5:40am.  The rain gage
      indicated that 0.10 inches of rain had fallen  the first 10 minutes
      and  the  rain  continued  at  a  relatively  steady  pace.    Since  it
      appeared the  forecast  might be  accurate,  a  decision was  made  to
      collect the samples.

3.    At 6:00am  the  flow in  the ditch was such that  one could  make  a
      reasonable estimate of the  flow  rate  using the  "Float  Method" and
      the flow was determined to be 1.8 cfm.  (Table 1  contains the flow
      calculations).

4.    All  of  the  required   grab  samples  were  collected  in  labeled
      containers at 6:00am.   A 1-L glass container and  three  VGA vials
      were collected for  the  composite sample.   The pH  was  measured  on
      site with a calibrated meter  and was found  to be 6.9 units.  This pH
      value was verified with  narrow-range pH paper.   The temperature was
      recorded  and  found  to  be 53  degrees  centigrade.    All  of  the
      collected samples were placed in a chest containing wet ice.

5.    Since the commercial  laboratory  selected to perform the analyses of
      samples was located within  10  minutes  of the  sampling  site,   a
      decision was  made to  transport  the   initial   grab samples  to  the
      laboratory for preservation and  analysis.  No chain of custody form
      was required since a member  of  the sampling team took  the samples
      directly to the laboratory.  The laboratory was  advised to add the
      proper  preservation  to  the  containers  and  to   analyze  for  the
      selected parameters using EPA approved methods specified  in 40 CFR
      Part 136 under the Clean Water Act.   The analysis requirements for
      the initial grab  samples were quite  simple since they  are handled
      the same as any  other  samples normally  submitted for NPDES Permit
      compliance monitoring.

6.    The flow was measured at 6:20am  and was 3.5 cfm.   A 1-L  container
      and three VGA vials were collected and placed on  ice.  The pH was
      6.7  units  and   the temperature of  the  water  was  49  degrees
      centigrade.  The  rain gage  showed a  total  accumulated  rainfall  of
      0.13 inches of rain.

7.    The flow was measured at 6:40am and was  3.6 cfm.   A 1-L sample and
      three VGA vials were collected and placed on  ice.   The pH was 6.5
      units and the water temperature was 48 degrees  centigrade.  The rain
      gage  indicated  a  total  of  0.17 inches of  accumulated   rain  had
      fallen.
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8.    The flow was measured at 7:00am and was 3.9 cfm.   A 1-L sample and
      three VOA vials were collected and placed  on  ice.   The pH  was 6.3
      units and the water temperature was 48 degrees  centigrade.  The rain
      gage indicated a total  of 0.25 inches of rain  had fallen.

9.    The flow was measured at 7:20am and was 4.0 cfm.   A 1-L sample and
      three VOA vials were collected and placed  on  ice.   The pH  was 6.2
      units and the water temperature was 48 degrees  centigrade.  The rain
      gage indicated a total  of 0.30 inches of rain  had fallen.

10.   The flow was measured at 7:40am and was 3.7 cfm.   A 1-L sample and
      three VOA vials were collected and placed  on  ice.   The pH  was 6.2
      units and the water temperature was 48 degrees  centigrade.  The rain
      gage indicated a total  of 0.35 inches of rain  had fallen.


11.   The flow was measured at 8:00am and was 1.8 cfm.   A 1-L sample and
      three VOA vials were collected and placed  on  ice.   The pH  was 6.3
      units and the water temperature was 48 degrees  centigrade.  The rain
      gage indicated  a  total  of 0.37 inches of  rain had  fallen  and the
      rain was letting up.

12.   The flow was measured at 8:15am and was 1.9 cfm.   A 1-L sample and
      three VOA vials were collected and placed  on  ice.   The pH  was 6.3
      units and the water temperature was 47 degrees  centigrade.  The rain
      gage indicated a total  of 0.39 inches of rain  had fallen.

13.   The flow was measured at 8:30am and was 1.7 cfm.   A 1-L sample and
      three VOA vials were collected and placed  on  ice.   The pH  was 6.3
      units and the water temperature was 48 degrees  centigrade.  The rain
      gage indicated a total  of 0.40 inches of rain  had fallen.


While the rain continued lightly  for the next hour, the  sampling event was
terminated since the required  number of grab samples  had been  collected to
prepare the flow-weighted composite samples.


Verification  of Storm Event

There was no  rain reported at the site  for  the last  72  hours  prior  to the
current storm event.   Officially, the last rainfall was  recorded 240 hours
before this storm event.  The  rain started  at 5:30am and  ended at  9:45am
which  is  a total  of 4 hours and 15 minutes.   The rain gage used  in the
field during the storm event indicated that the accumulated volume of rain
was  0.42  inches  during  the time the samples were collected.  A check on
the  officially  recorded  rainfall   reported  by  the  local   TV  station
indicated  that 0.48  inches of  rain had  fallen that  day.   All  of the rain
was  in the morning hours.
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The storm event's duration of 4  hours and  15 minutes met the 4 to 12 hour
criteria  calculated  for the  Houston  area and  both the  field  recorded
volume of 0.42 inches and  the official report of 0.48 inches met the 0.38
to 1.14 inches criteria  for the Houston area.  The  storm event clearly met
the regulatory criteria and the necessary information was documented for
regulatory purposes.
Verification of Sampling Criteria

A review of the field log notebook indicated the initial grab sample was
collected 20 minutes after flow was observed at the sampling point.  The
reason for  not  collecting the grab  sample  sooner was  the  inability to
estimate the flow rate  any sooner.  The initial grab sample was collected
within the regulatory criteria.

Review of  the  field log  notebook  further  revealed the grab  samples to
prepare the composite  samples  were collected  at  6:00am, 6:20am,  6:40am,
7:00am, 7:20am,  7:40am,  8:00am,  8:15am,  and 8:30am.   There  were  9 grab
samples collected.  There were three  samples collected each hour and the
minimum duration of 15 minutes was used for the last two samples because
the rain was letting up.  The rain started at 5:30am; storm water flow was
noted at 5:40am; and the first sample was collected at 6:00am.  The last
sample was collected at 8:30am which represents a span  of time 2 hours and
50 minutes.  All samples  were  collected as soon as feasible and did occur
within the first 3  hours  of storm water  flow.   The  nine samples all met
the 15 minute/3 per hour criteria.


Sampling Conclusions

All of the storm event criteria  were met  and  the samples  collected also
met regulatory criteria.   The  sampling was a success.   What remains to be
done  is  to transport  the  remainder  of  the  samples to the  laboratory;
prepare the necessary calculation needed  by  the laboratory to prepare the
flow-weighted composite sample  for most parameters; make a decision on how
to analyze for volatile organics and  advise the laboratory how to do it;
and to provide  the  specific instructions on how  to  preserve  and analyze
the flow-weighted composite samples.

A decision was made to use the "procedural  compositing" proposal for our
hypothetical  example because  we actually  tested  the proposal  and it
appeared to work.
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Calculations for Preparation of Flow-Weighted  Composite Sample

1.     It should be noted  that  the flow rates expressed as cfm's that were
      listed in our example Table  1  for each sampling  event  were  taken
      directly from Exhibit 3-8 on  p.  51.

      Exhibit 3-8 was rather  straightforward  and was  easily understood;
      however,  for the hypothetical storm event we used, it was necessary
      to make  some modifications.    It  also  became  obvious  later  that
      Column "B" would be better labeled "t";  Column  "G" would be better
      as "Q";  and Column  "A" would  be better as "S."  The reason for this
      suggestion is that  later the  equations show time as "t" and flow in
      cfm as "Q."  "S" represents  the samples that we  identified as SI,
      S2, etc.  making  things clearer  when  performing  the calculations.

      It also  became obvious later that the  time column  in Exhibit 3-8 was
      offset by  one position.  Since we  collected  our first  sample  20
      minutes after flow started,  the first number  should be 20 which is
      for tl.   It is understood  that to  is  0  minutes.   Table 1   was
      prepared to measure  flow for our  hypothetical  example  and  is the
      equivalent for Exhibit 3.8 in the  EPA guidance  document.  The same
      numbers were used.   We liked  our version better than Exhibit 3.8.

Table 1.

2.     The next calculation is  to estimate  the outfall  volumes associated
      with each sampling  event. One portion of this calculation uses the
      cfm's calculated in Table 1 from Step 1.  Exhibit 3-16, starting on
      p. 63,  provides  the step-by-step process  for the volume calculation.
      Essentially  Exhibit  3-8 (and Table  1)  is  somewhat  equivalent  to
      Exhibit 3-16 on  p. 63 except that they calculated cfm's differently.
      It was found later that  one really does not have to perform Step 1
      of Exhibit  3-16 since  all  the  needed information  is  contained in
      Exhibit 3-8 or  for our  hypothetical  example  in  Table  1.  The only
      information used for subsequent calculations are  the values for "t"
      and "Q" which are time and flow rate.  It  is  recommended that only
      an Exhibit 3-8-type table such  as  Table 1  be  prepared.  Also, Step
      2  of  Exhibit  3-16  represents another way to calculate  flow which
      again was found  to  be redundant and not  needed since Table  1 already
      contains the same information.

      Steps 3,4, and 5 of Exhibit 3-16 provide  examples  for calculation of
      flow volume; however, later it  was found that it was not necessary
      to plot the data to complete the calculations.   Some problem areas
      were also  identified  as well as some possible  errors (these were
      covered in the comments  section of the paper).  There also were some
      necessary details missing.
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      Step 3 shows a  plot of "Q" and "t"  values.  The area under this plot
      represents the  total volume of flow at the  time the storm water grab
      samples were collected.   Instructions  say to assume that flow drops
      uniformly from the last  calculated  flow rate (Q9) to  zero  at the
      time  when  (Q10)  would  have  been taken.   This  statement  is  not
      consistent  with  the  drawn  curve  and  is  one  of the  identified
      problems.  While  not  entirely agreeing with  the  procedure in Steps
      4 and 5, we arbitrarily set  Q9 at  zero when  the  last  sample S9 was
      taken because that appears what EPA  did in their example.  The EPA
      calculations on p. 66 were validated  and found to be consistent with
      arbitrarily setting Q9 to zero.

      On p. 66 of  Exhibit 3-16  the  equations  used  to  calculate the flow
      are provided.  Everything  was  fine until the calculation for Volume
      #6 of the hypothetical  example.  In  our example,  it was noted that
      Q6 was less  than Q5.  In the  equation  the quantity  (Q6 - Q5) results
      in a  negative  value.   The same  is  true for  (Q9  -  Q8).    The EPA
      guidance document did  not point  out  how to handle these negative
      values.  It was established  that  the  equations  are correct and the
      proper flow volume results when using these  negative  values.

      The next problem was noted in  the calculation of V9.   Table 1 shows
      the calculated  flow rate as  1.7 cfm.   Using  this  value for Q9 will
      result in higher  value than  if one assumes Q9 to  be zero  (based on
      one interpretation of Step 3).  For  purposes of  this hypothetical
      example, Q9 was set to zero. The volume calculations were  completed
      and are shown in  Table 2.
Table 2
      The next set of calculations use the  volume information from Table
      2 to make the necessary calculations to prepare  the  flow-weighted
      composite sample for most  parameters  (also  for volatile organics).
      The values  listed  in  Table  2,  in  cubic  feet  units,  were  also
      converted to volume expressed in liters  (L)  using the equation:

         Volume (liters)  = Volume (cubic feet) x 28.32 liters/1 cubic feet

      This equation was listed on p. 78 of Exhibit 3-24.  Table 2 was also
      used to show the discharged volume expressed  in  liter  units.   The
      EPA  example used   another  step  and  table  to  accomplish  this
      conversion.   We felt this  was not necessary.

      Step 8 of Exhibit 3-24 provides  the  equations  needed to calculate
      the volume  one  must take  from  each of  the  1-L grab  samples  to
      prepare the  flow-weighted composite sample with an approximate final
      volume of 5,000 mL.  Table 3 was prepared to  summarize the results
      from these calculations  and  provides  the proper aliquots (Al - A9)
      needed for the flow-weighted composite sample for  all parameters for
      the hypothetical  example.

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Table 3
      The final  volume of  the flow-weighted composite was more than 5,000
      mL which should be more than  sufficient  for  all  the  analyses.   It
      follows that the same information calculated for the  flow-weighted
      composite sample can also  be used and was used to give instructions
      on how  to prepare  the  flow-weighted  composite  (VOA)  sample  for
      volatile organics.   To accomplish this, one just had  to divide the
      values for the 5 L composite aliquots (Al - A9)  by 1,000 and round
      the results to  two  significant  figures.   This  information  for the
      volatile organics flow-weighted composite sample was  also included
      in Table 4.   The EPA guidance  document provided no guidance for the
      volatile organics calculation.

      The calculation for  the flow-weighted composite sample for volatile
      organics indicated  a  total  volume  of 5.96 mL.   This  should be no
      problem since the 5  ml purge vessel  is capable of handling a volume
      of 6 ml.   It  should be  noted that  this  volume  difference  of 5.96
      instead of 5.0  also  needs  to  be corrected  for in the calculations
      for analyte concentration  since  the  normal  sample size for volatile
      organics is 5 mL.

      One option available to  prepare the flow-weighted composite sample
      for volatile organics that will  result in a final volume of 5.0 mL
      is to  multiply the Al -  A9  values  in  Table 4  by  an appropriate
      factor.  For example, multiplying the Al - A9 values by the factor
      0.000840 will result in  a final  total volume of 4.99 mL or 5.0 ml.
      If this practice was  followed,  there would be no need to make any
      volume difference in the method calculations.
IT  IS  ABSOLUTELY  ESSENTIAL  THAT  THE   LABORATORY    IS  PROVIDED  THE
INFORMATION CONTAINED IN TABLE 4 AND THAT THEY COMPLETELY UNDERSTAND THE
SIGNIFICANCE OF TABLE 4 AND THE NEEDED CORRECTION IN ANALYTE CONCENTRATION
CALCULATIONS BECAUSE OF THE VOLATILE ORGANICS SAMPLE VOLUME DIFFERENCE.
The  laboratory  should  be  able to  prepare the  flow-weighted composite
samples using the information from Table 4 and  provide  the data needed to
complete the storm water permit application.  However,  it would be a good
idea to have a capable analytical chemist within your own company validate
the data.
Other Considerations

For  the  hypothetical  example,  a  total  of 9 grab samples were collected.
The  volume collected followed EPA guidance and  no  additional samples were
collected to cover the possibility  of breakage.  We would make a strong
recommendation  to  collect  additional   samples  to  cover  any  possible


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breakage.  It is recommended that two 1-L containers should be collected
at each sampling event to address the possibility of breakage.

It was also determined from  one  of  the  EPA  examples that the 1-L volume
may be insufficient  to  prepare a composite volume  of  5,000  ml  if there
were unusual flow patterns.  The second 1-L container that was collected
to cover  the  possibility  of breakage could also be  used  if  such a flow
pattern was experienced  (see comment section for details).   Applying a
correction factor to the Al - A9  volumes in  Table 4  can be used to ensure
a final target volume of 5,000 mL.

Another recommendation would be to keep the collection intervals equal for
the entire sampling  program  if possible.   Later in  the calculations all
the quantities (Table 2)  of (tl - tO),  (t2 - tl), (t3 - t2), etc., become
a  constant  value for  the  interval.    Using  a  constant  interval  would
simplify  preparation of  an  electronic  spreadsheet  to perform  all  the
necessary calculations.   Either a 15 or  20 minute interval could be used.
Using different  intervals  for  the hypothetical  example resulted  in some
initial errors which had to be corrected.

Review of Table 4 shows  that the  calculated  aliquot  volumes (Al - A9) are
three  significant  figures.    The  EPA  guidance did  not  specify  any
regulatory criteria  for  significant  figures  for  these volumes.  Since the
volumes ranged from  181 mL  to  1,000 mL, it  was  obvious that  a graduated
cylinder  should  be  considered.   However,  it  was   learned  that  a  1-L
graduated cylinder  can  only measure to  the closest  10 mL;  a  500  mL
cylinder  to 5  mL;  and a 250 mL  cylinder  to 2 mL.    Several  options are
available to consider.   One option is to round to two significant figures
and use only the  1-L graduated cylinder.  A second  option is to  use the
appropriate combination of graduated cylinders  to measure the volume to
three significant figures.   A third  option,  and  perhaps the most precise,
is to use a balance capable of weighing 3,000 grams and  to  pour the proper
weight corresponding the Al - A9 aliquots into a 1-L graduated cylinder.
Several experiments  were conducted to see  if there was a preferred way to
do it.  All  three ways had  some small errors, but all three ways appeared
to work.   Since  the  EPA guidance did not provide specific  criteria,  it
would appear that the laboratories can make the  choice.
                                    351

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                              CONCLUSIONS
The  EPA's  "NPDES   Storm  Water  Sampling  Guidance  Document"  provides
detailed  information which  should  prove helpful  in meeting  storm water
regulatory requirements.  It is strongly recommended that anyone who has
to perform sampling  or analysis of storm water should obtain a copy of the
EPA  guidance  document.     It  would  also  be advisable  to  prepare  a
hypothetical  example   for   the   sampling  location  to  have   a  good
understanding for the sequence of events and what is required.

It is possible to meet  the  storm water  regulatory  requirement for flow-
weighted composite  samples.   The hypothetical  example demonstrated it can
be done but with some difficulty and with a lot of detailed instructions
and subsequent calculations.   There are also a  number  of problem areas
where EPA may want  to provide more details.   It also appears some options
are available that  one  may  want to  consider.   Concerns  still  remain for
the potential to lose analytes to container walls because of the process
needed to prepare these flow-weighted composite  samples.   There is also
some concern  with  commercial  laboratories who will have  to  be provided
explicit  instructions  in  order to  prepare  the  flow-weighted composite
samples.  The  volatile  organics flow-weighted sample  preparation is far
from a routine operation and also poses some potential problems.

We think the hypothetical  example meets  regulatory criteria and should be
acceptable to regulatory agencies.
                                352

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TABLE 1 - Example Calculation of Float Method for Unimpeded Open Channel Flow
Step 1: When each grab sample was collected, the data for the time involved;
length between points A and B (at least 5 feet apart); flow depth and
width; as well as the flow calculation.
Sample
Number
(S)
SO
SI
S2
S3
S4
S5
S6
S7
S8
S9
Clock
Time
5:40 a.m.
6:00 a.m.
6:20 a.m.
6:40 a.m.
7:00 a.m.
7:20 a.m.
7:40 a.m.
8:00 a.m.
8:15 a.m.
8:30 a.m.
For SI: V
Time in
Minutes
(t)
to = o
tl = 20
t2 = 40
t3 = 60
t4 = 80
t5 = 100
t6 = 120
t7 = 140
t8 = 155
t9 = 170
Distance
Between
Points
A & B
(ft)
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
= 5.0 ft = 29.4
0.17 min
A = 0.12 ft X 0.5 ft
Ql = 29.4 ft/min X O.C
Time of
Travel
(A to B)
(min)
0.00
0.17
0.18
0.20
0.21
0.18
0.17
0.17
0.16
0.18
Depth of
Water at
Point B
(ft)
0.00
0.12
0.25
0.29
0.33
0.29
0.25
0.12
0.12
0.12
Width of
Flow at
Point B
(ft)
0.0
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Calcul.
Flow Rate
(cfm)
(Q)
QO = 0
Ql = 1.8
Q2 = 3.5
Q3 = 3.6
Q4 = 3.9
Q5 = 4.0
Q6 = 3.7
Q7 = 1.8
Q8 = 1.9
Q9 = 1.7
ft/min
= 0.06 ft2
6 ft2 = 1.8 cfm
353

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TABLE 2
           Volume (V) = Flow Rate (cfm) X Duration (minutes)


           VI =  HQl-QO)(tl-tO)

              =  t(1.8-0)(2JJ-0)

              -  18 ^ *                =    "Ollters
           V2 =  |(Q2-Ql)(t2-tl) + Ql(tZ-tl)

              =  H3.5-1.8)(40-20) + 1.8(40-20)

              =  H1.7)(20) + 1.8(20)

              =  17+36

              =  53 ft3 X ^p-          =  1,501 liters



           V3 =  J(Q3-Q2)(t3-t2) + Q2(t3-t2)

              =  i(3.6-3.5)(60-40) + 3.5(60-40)

              =  H0.1)(20) + 3.5(20)

              =  1+70

              =  71 ft3 X ^p^          =  2,011 liters



           V4 =  KQ4-Q3)(t4-t3) + Q3(t4-t3)

              =  H3.9-3.6)(80-60) + 3.6(80-60)

              =  i(0.3)(20) + 3.6(20)

              =  3 + 72

              =  75 ft3 X ^f^          =  2,124 liters



           V5 =  J(Q5-Q4)(t5-t4) + Q4(t5-t4)

              =  i(4.0-3.9)(100-80) + 3.9(100-80)

              =  i(0.1)(20) + 3.9(20)

              =  1 + 78

              =  79 ft3 X ^^          =  2,237 liters
                                    354

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TABLE 2 (CONTINUED)    Volume (V) = Flow Rate (cfm) X Duration (minutes)





       V6 =  i(Q6-Q5)(t6-t5) + Q5(t6-t5)



          =  H3.7-4.0)(120-100) + 4.0(120-100)



          =  f(-0.3)(20) + 4.0(20)



          =  [-3] + 80



          =  77 ft3 X  ——                =    2,181  liters








       V7 =  HQ7-Q6)(t7-t6) + Q6(t7-t6)



          =  Hl-8-3.7)(140-120) + 3.7(140-120)



          =  H-1.9)(20) + 3.7(20)



          =  [-19] + 74



          =  55 ft3 X ^~^                 =    1,558  liters








       V8 =  |(Q8-Q7)(t8-t7) + Q7(t8-t7)



          =  HI-9-1.8)(155-140) + 1.8(155-140)



          =  i(0.1)(15) + 1.8(15)



          =  0.75 + 27



          =  27.75 ft3 Xp^                  =    786 liters








       V9 =  HQ9-Q8)(t9-t8) + Q8(t9-t8)



          =  i(0-1.9)(170-155) + 1.9(170-155)



          =  J(-1.9)(15) + 1.9(15)



          =  [-14.25] + 28.5



          =  14.25 ft3 X^                  =    404 liters
                                   355

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TABLE 3	___^_

Step 8:     Calculate the volume of each sample aliquot
            (A) which must be used to comprise a flow-
            weighted composite sample.  The following
            equation should be used:

Aliquot volume (A)(ml) = Minimum aliquot volume
(ml) X Aliquot discharge volume (VHliters)
       Largest discharge volume (V)(liters)
        Al-  1,000ml X-   228ml
         AO    i r\nn mi v 1501 liters     £71 mi
         A2 =  i'000 ml X 2237 liters =   671 m1
        A3 =  1,000 ml X 227     r  =   899 ml


        A4=  1,000 ml Xf$-U|£f-   949ml


        A5 =  1,000 ml X HI] }\Hrrl -   1,000 ml


        A6 =  1,000 ml X          r  =   975 ml
        A7  =1,000 ml  X  I**  liters =    6g6  ml
         A8  =  1,000  ml  X£            =    351  ml


         A9-  1.000  •1Xt-    181ml
                             TOTAL    =  5,950 ml
                      356

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TABLE 4 - Summary of Volumes Needed to Prepare a
Flow-Weight Composite for all
Parameters and Volatile Organics
Sample
SI
S2
S3
S4
S5
S6
S7
S8
S9
Parameter
Composite
Al = 228 ml
A2 = 671 ml
A3 = 899 ml
A4 = 949 ml
A5 = 1,000 ml
A6 = 975 ml
A7 = 696 ml
A8 = 351 ml
A9 = 181 ml
Volatile
Organic
Composite
VOA1 = 0.23 ml
VOA2 = 0.67 ml
VOA3 = 0.90 ml
VOA4 = 0.95 ml
VOA5 = 1.00 ml
VOA6 = 0.98 ml
VOA7 = 0.70 ml
VOA8 = 0.35 ml
VOA9 = 0.18 ml
Total (V) 5,950 ml 5.96 ml
357

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358

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VO
       STORM WATER SAMPLING AND ANALYSIS
                     G. H. STANKO
              SHELL DEVELOPMENT COMPANY
      16TH ANNUAL EPA CONFERENCE
        ANALYSIS OF POLLUTANTS
         IN THE ENVIRONMENT
          NORFOLK, VIRGINIA
            MAYb-6, 1993

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ON
O
      FINAL RULE STORM WATER	40 CFR PARTS 122, 123,124
      NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PERMIT
      APPLICATION REGULATIONS FOR STORM WATER DISCHARGES,
      FEDERAL REGISTER FRIDAY NOVEMBER 16, 1990.
"NPDES STORM WATER GUIDANCE DOCUMENT1 -- JULY 1992
(EPA 833-B-92-001, JULY 1992)

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o\
                   COMMENTS FOR EPAs
    "NPDES STORM WATER SAMPLING GUIDANCE DOCUMENT"

       CHAPTER 2
       IDENTIFIED SPECIFIC NATURE AND CRITERIA FOR STORM EVENT
            V HOUSTON, TEXAS SITE:
         • STORM EVENT -- 4 TO 12 HOURS.
         • RAIN VOLUME BETWEEEN 0.38 AND 1.14 INCHES.
         • LAST RAIN 72 HOURS.
         • NEED RAIN GAGE AT SAMPLING SITE.
         • RAIN DEPTH  DATA NEEDED TO ESTABLISH CRITERIA MET.
         • RAIN VOLUME INFORMATION ONLY USED TO ESTABLISH
          STORM EVENT CRITERIA WAS MET.

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K>
                                                              fa.
               COMMENTS FOR ERA'S

"NPDES STORM WATER SAMPLING GUIDANCE DOCUMENT



 CHAPTER 3


 PROVIDES THE NECESSARY INFORMATION FOR THE DIFFERENT OPTIONS
 AVAILABLE TO MEASURE OR ESTIMATE FLOW RATES, CALCULATING FLOW
 VOLUME, PREPARATION OF FLOW-WEIGHTED COMPOSITE SAMPLES, AND
 METHODOLOGY.

 PROBLEMS WERE EXPERIENCED AND A NUMBER OF PROBLEM AREAS WERE
 IDENTIFIED IN CHAPTER 3.

-------
ON
U)
J EXHIBIT 3-8 TABLE L
(Cont.)
Step 1 : When each sample or aliquot is taken, record the data for the time the sample was
taken and the length between points A and B (at least 5 feet apart). See columns
A,B and C.






Wl

mi
L
Example Data:
A
Sample
Number

1
2
3
4
5
6
7
8
9
B
Time in
Minutes

0
20
40
60
80
100
120
140
160
C
Distance
Between
Points
A&B, ft
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
D
Time of
Travel
(A&B)
(min)
0.17
0.18
0.20
0.21
0.18
0.17
0.17
0.16
0.18
E
Depth of
Water at
Point B,
ft
0.12
0.25
0.29
0.33
0.29
0.25
0.12
0.12
0.12
F
Width of
Flow at
Point B,
ft
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
G
Calculated
Flow Rate,
cfm
1.8
3.5
3.6
3.9
4.0
3.7
1.8
1.9
1.7
wrc93-









-074—01^^

-------
                       EXHIBIT 3-8 (Conf.)
Step 2: Place a float in the water flow at point A and time it as it moves from point A to
       point B. Record the time in minutes. See column D.

Step 3: Measure the depth of the water and the width of the flow at point B. See columns
       E and  F.

Step 4: Calculate the flow rate for each sample time using the common flow rate formula.
       See column G.


 Formulas:               i/P/nrih/ n/\ - Len9th from AtoB
                        veiuuiy (vj -   Tjme Qf Travei
                     Area (A) = Water Depth x Width of Flow

                           Flow Rate (Q) = (V) x (A)

 Example: For Sample 1
      K          K         V =  5.0ft   = 29.4 ft/min
                              0.17 min
                         A = O.T2ft x 0.5ft = 0.06 ft2

                        Q = 29.4 ft/min X 0.06 ft2 '= l.Scfm
                                                                      wrc93-074-02

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OS
J 	 "'" 	 • 	 	 • 	 """ 	 """ 	 L
EXHIBIT 3-16 EXAMPLE CACULATION OF TOTAL
RUNOFF VOLUME FROM FLOW RATE DATA (Cont)
Step 1: Measure and tabulate flow depths and velocities every 20 minutes (at the same time
that the sample is collected) during at least the first 3 hours of the runoff event.




TV
m

mm
1
Example Data:
A
Sample
Number
1
2
3
4
5
6
7
8
9
B
Time in
Minutes
0
20
40
60
80
100
120
140
160
C
Flow
Velocity,
ft/min
—
4
8
12
8
4
8
4
4
D
Flow
Depth, ft
—
0.2
0.4
0.4
0.4
0.2
0.2
0.2
0.2
E
Width, ft
—
5
5
5
5
5
5
5
5
F
Calculated
Flow Rate,
cfm
—
4
16
24
16
4
8
4
4









wrc93-074-09 f™

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                                    EXHIBIT 3-16 (Cont)
        Step 2: Calculate and tabulate the cross-sectional area of flow for each of the flow depths
              measured. Calculate the flow rate for each discrete set of measurements.
         Formula:
                       Flow Rate Q (cfm) = Velocity (ft/min) x Area (sq ft)
                                   Area = Depth x Width
CTs
ON
  Example: For Sample 1          Area = 0.2ftx5ft = 1sqft
                             Flow Rate = 4 ft/min x 1sq ft = 4cfm
Step 2: Plot the flow rate, Q, versus time. Also, assume that flow drops uniformly from the
       last calculated flow rate (Q9) to zero at the time when Q10 would have been taken.
       Example: The flow rates calculated in Step 3 are plotted against the time between
       samples.
                 28 |-
                 24
              *£  20
                 16
                 12
                  8
                  4
                  0
                     CD
                     -i-»
                     £
20    40    60   80   100   120
           Time (minutes)
                                                             140
                                                           160
180
                                                                                 wrc93-074-10
                                                                                                 LO
                                                                                                 ^J
                                                                                                 Ln

-------
                            EXHIBIT 3-16(00/7*.)


Step 4: The total flow volume (Vt) can be calculated by geometrically determining the area
       under the curve. The summation of the individual volumes per increment of time
          through V9) is the total flow volume of the event.
             2

             o
             u.
                 Example:
28


24


20


16


12


 8


 4


 0
                       20    40    60   80   100   120

                                  Time (minutes)
                                    140
160
180
                                                                         wrc93-074-11

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                                    EXHIBIT 3-16 (Conf.)


       Step 4: Compute the flow volume associated with each observation (V15 V2,..., V9) by
              multiplying the measured flow rate by the duration (in this case, 20 minutes). Be sure
              the units are consistent. For example, if durations are in minutes and flow velocities
              are in cubic feet per second (cfs), convert the durations to seconds or the velocities
              to feet per minute.
oo
                             Example
                                12
                             7  8
                             2

                             1  4
                             u.
                                 0
                                                 20               40
                                                     Time (minutes)
                                                                                  wrc93-074-12

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U)
         CHAPTER 3
         • EXHIBIT 3.22 (P. 74) PROVIDES EXAMPLE OF TIMES
          TO CONSIDER FOR SAMPLING.
          EXAMPLE SHOWS FIRST GRAB SAMPLE COLLECTED
          AFTER 5 MINUTES OF FLOW.
         • GRAB SAMPLES FOR ALL PARAMETERS COLLECTED
          FOLLOWING DIRECTIONS IN EXHIBIT 3-17 (P.69).
1

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UJ
-J
o
          CHAPTER 3
          • NINE GRAB SAMPLES NEEDED FOR COMPOSITE SAMPLE.
FLOW-WEIGHTED COMPOSITE SAMPLE SHOULD BE

PREPARED IN LABORATORY (P. 75).
           1,000 mL GRAB SHOULD PROVIDE ENOUGH

           VOLUME FOR THE COMPOSITE
           PROPER CONTAINERS/PRESERVATION TAKEN FROM

           40 CFR PART 136

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CHAPTER 3
FLOW-WEIGHTED COMPOSITE FOR SEMIVOLATILE ORGANICS
PROBLEM
• NINE BOTTLES TO COLLECT GRAB SAMPLES.
 MEASURING DEVICE TO TRANSFER PROPER VOLUME.
• ANOTHER DEVICE USED TO TRASFER TO FINAL SAMPLE
 BOTTLES.
• LOSS OF SEMIVOLATILE ORGANICS TO CONTAINER WALLS?

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OJ
CHAPTER 3


FLOW-WEIGHTED COMPOSITE FOR VOLATILE ORGANICS


• AUTOMATIC SAMPLERS CANNOT BE USED TO COLLECT
 VOLATILE ORGANIC SAMPLES.

• GUIDANCE FOR COLLECTION OF VOC SAMPLE IS ON P. 69.


• GUIDANCE IDENTIFIES VOC SAMPLES AS GRAB SAMPLES.
         • PAGES 85 AND 86 OF SECTION 3.5.2 PROVIDE DETAILS
          FOR COMPOSITE.

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CHAPTER 3
FLOW WEIGHTED COMPOSITE FOR VOLATILE ORGAN ICS
   MATHEMATICAL COMPOSITING
   PROCEDURAL COMPOSITING

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OJ
-J
        CHAPTER 3

        FLOW-WEIGHTED COMPOSITE FOR VOLATILE ORGANICS
          PROCEDURAL COMPOSITING
         EPA GUIDANCE DOCUMENT (40 CFR Part 141.24(f)14(iv)
         AND (v)) REVEALED THIS SECTION PROVIDES INSTRUCTIONS
         FOR PREPARING A TIME-WEIGHTED COMPOSITE SAMPLE
         FOR VOLATILE ORGANICS.
         THE MAXIMUM NUMBER OF GRAB SAMPLES ALLOWED FOR THE
         COMPOSITE IS FIVE.

         BASED ON THE REVIEW OF 40 CFR PART 141, EPA REALLY
         DID NOT PROVIDE SPECIFIC DETAILS FOR PREPARATION OF
         FLOW-PROPORTIONED COMPOSITE SAMPLE FOR VOLATILE
         ORGANICS.

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CHAPTER 3
METHODOLOGY PROBLEMS
• ON PAGE 85, EPA PROVIDED AN INAPPROPRIATE REFERENCE
 TO 40 CFR PART 141 AND THE EPA 500 SERIES METHODS.

• REFERENCE SHOULD HAVE BEEN FOR 40 CFR PART 136 AND
 600 SERIES METHODS.

• A REFERENCE IS ALSO GIVEN FOR A 25 mL PURGE VESSEL.
 THIS REFERS TO METHOD 524.2 AND NOT METHOD 624.

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os
STORM WATER SAMPLING AND ANALYSIS HYPOTHETICAL EXAMPLE

Site Location -— Houston Texas

Facility — Chemical Plant

Parameters Required on NPDES Permit
   Oil and Grease
   PH
   BODS
   COD
   TSS
   Total P
   TKN
   Nitrate + Nitrite
   Volatile Organics (Method 624)
   Semivolatile Organics (Method 625)
   Cyanide
   Fecal Coliform

Sampling Point — "V" Shaped Grass-Lined Ditch (completely dry)

Last Rainfall —- Ten Days Ago

Forecast -— Light to Moderate Rain Expected During the Morning Hours
            with Clearing in the Afternoon.  Approximately 0.25 to 0.75
            Inches Total  Expected.

Decision — Conditions Appear Optimal to Conduct a Storm Water Sampling
            and Sampling was Approved and Authorized.

Logistics — Sampling Crew was at the Site at Sam.

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       STORM WATER SAMPLING AND ANALYSIS
            HYPOTHETICAL EXAMPLE
VERIFICATION OF STORM EVENT
 NO RAIN IN LAST 240 HOURS (72 HOURS REQUIREMENT).
 RAIN LASTED 4 HOURS 15 MINUTES (4 TO 12 HOURS CRITERIA)
• RAIN GAGE VOLUME 0.42 INCHES (0.38 TO 1.14 CRITERIA)
CONCLUSION
 STORM EVENT MET REQUIREMENTS

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oo
                  STORM WATER SAMPLING AND ANALYSIS

                       HYPOTHETICAL EXAMPLE
           VERIFICATION OF SAMPLING CRITERIA
            INITIAL GRAB SAMPLE AT 20 MINUTES (WITHIN FIRST
            30 MINUTES)

            NINE GRAB SAMPLES COLLECTED (3 EACH HOUR, MORE
            THAN 15 MINUTES APART)
                                                            tu

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u>
            STORM WATER SAMPLING AND ANALYSIS
                 HYPOTHETICAL EXAMPLE
      SAMPLING CONCLUSIONS
      • EVENT MET REGULATORY CRITERIA FOR HOUSTON AREA.
      • ALL SAMPLES WERE COLLECTED WITHIN REGULATORY CRITERIA.

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oo
o
                  STORM WATER SAMPLING AND ANALYSIS


                       HYPOTHETICAL EXAMPLE
            CALCULATIONS FOR FLOW
           • TABLE 1 DATA TAKEN FROM EXHIBIT 3-8 P. 51
            COLUMN "B" LABELED "t".
            COLUMN "G" LABELED "Q".
           • COLUMN "A" LABELED "S".

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OJ
oo
IT
t
T?>
TABLE 1 - EXAMPLE CALCULATION OF FLOAT L
METHOD FOR UNIMPEDED OPEN CHANNEL FLOW
Step 1: When each grab sample was collected, the data for the time involved; length between points
A and B (a least 5 feet apart); flow depth and width; as well as the flow calculation.
Sample
Number, S
SO
S1
S2
S3
S4
S5
S6
S7
S8
S9
k
Clock
Time
5:40 a.m.
6:00 a.m.
6:20 a.m.
6:40 a.m.
7:00 a.m.
7:20 a.m.
7:40 a.m.
8:00 a.m.
8:15 a.m.
8:30 a.m.
Time in
Minutes,
T
to = o
t1 = 20
t2 = 40
t3 = 60
t4 = 80
t5 = 100
t6 = 120
t7 = 140
t8 = 155
t9 = 170
!fT ForS1:
Distance
Between
Points
A&B, ft
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
Time of
Travel
(A to
B), min
0.00
0.17
0.18
0.20
0.21
0.18
0.17
0.17
0.16
0.18
5.0ft
Depth of
Water at
Point B,
ft
0.00
0.12
0.25
0.29
0.33
0.29
0.25
0.12
0.12
0.12
Width Of
Flow at
Point B,
ft
0.0
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Calculated
Flow Rate,
cfm, Q
QO = 0
Q1 = 1.8
Q2 = 3.5
Q3 = 3.6
Q4 = 3.9
Q5 = 4.0
Q6 = 3.7
Q7 = 1.8
Q8 = 1.9
Q9 = 1.7

**^ v- 0.1 7 mm -«••*«/»""
A = 0.72 ft x 0.5ft = 0.06 ft2
Q = 29.4 ff/m/n x 0.06 ft2 = t.8 c/m
HI wrc93-074-05|"""

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oo
               STORM WATER SAMPLING AND ANALYSIS

                     HYPOTHETICAL EXAMPLE
         CALCULATIONS FOR TOTAL VOLUME
         • EXHIBIT 3-16 P.63 PROVIDES STEP BY STEP PROCESS.
                                                               h.
• NOT NECESSARY TO DO STEP 1 THE WAY TABLE 1 WAS PREPARED.

• ONLY "t" AND "Q" FROM TABLE 1 ARE USED FOR VOLUME.
 CALCULATIONS.

• STEP 2 FOUND TO BE REDUNDANT SINCE TABLE 1 CONTAINS
 INFORMATION.

• STEPS 3, 4, AND 5 OF EXHIBIT 3-16 USED TO CALCULATE
 VOLUME.

• ARBITRARILY SET Q9 TO ZERO (EPA EXAMPLE).

• VOLUME CONVERTED TO LITER UNITS USING EQUATION FROM
 EXHIBIT 3-24 P. 78.

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TABLE 2 - VOLUME (V) = FLOW RATE (cfm)  x DURATION (MINUTES)
                                   (Confj
               V1 = 1/2 (Q1 - QO) (t1 - W)
                  = 1/2 (1.8 - 0) (20 - 0)
                  = 18ft3x  •&£$£**               = 510 liters
               V2 = 1/2 (Q2 - Q1) (12 - t1) + Q1 (12 - t1)
                  = 1/2 (3.5 - 1.8) (40 - 20) + 1.8 (40 - 20)
                  = 1/2 (1.7) (20) + 1.8(20)
                  = 17 + 36
                  = 53ft3 x ^2-                    = 1,501 liters
               V3  = 1/2 (Q3 - Q2) (t3 - 12) + Q2 ((13 - t2)
                   = 1/2 (3.6 - 3.5) (60 - 40) + 3.5 (60 - 40)
                   = 1/2 (0.1) (20) + 3.5(20)
                   = 1 + 70
                  = 71 ft3 x ^1                    = 2,011 liters
                                                                      wrc93-074-06l

-------
                           V4
                           V5
UJ
CO
             TABLE 2 (Cont)

   1/2 (04 - Q3) (t4 - 13) + Q3 ((t4 - 13)
   112 (3.9 - 3.6) (80 - 60) + 3.6 (80  - 60)
   1/2 (0.3) (20) + 3.6 (20)
   3 + 72
                                                                        = 2,124 liters
   7/2 fQ5 - 04) (t5 - t4) + Q4 ((t5 - t4)
   1/2 (4.0 - 3.9) (100 - 80) + 3.9 (100 - 80)
   1/2 (0.1) (20) + 3.9(20)
   3 + 78
   79 ft3 x ^^
                                                                        = 2,237 liters
                           V6  =
  7/2 (06 - 05) (t6 - 15) + Q5 ((t6 - 15)
  1/2 (3.7 - 4.0) (120 - 100) + 4.0 (120 - 100)
  1/2 (0.3) (20) + 4.0 (20)
  [3] + 80
= 77 ft3 X

                                                                       = 2,181 liters
                                 1/2 (07 - 06) (t7 ~ t6) + 06 ((t7 - t6)
                                 1/2 (1.8 ~ 3.7) (140 -  720) + 3.7 (740 - 720)
                                 1/2 (-1.9) (20) + 3.7(20)
                                 [-19]  + 74
                                 55 ft3 x ^2-                          = 1,558 liters
                                                                                         wrc93-074-07|

-------
                                         TABLE 2 (Cont)
          (08 - Q7) (t8 - t7) + Q7 ((t8 - t7)
    = 1/2 (1.9 - 1.8) (155 - 140) + 1.8 (155 -
    = 1/2 (0.1) (15) + 1.8(15)
    = 27.75 + 27

    = 75 ft3 X ^^
                                                                   140)
                                                                    = 786 liters
oo
V9  = 1/2 (Q9 - Q8) (t9 - 18) + Q8 ((t9 - t8)
    = 1/2 (0 - 1.9) (170 - 155) + 1.9 (170 - 155)
    = 1/2 (-1.9) (15) + 1.9(15)
    = [-14.25] +28.5

    = 14.25 ft3 X 2&2
                                                                    = 404 liters
                                                                                      wrc93-074-08l

-------
oo
OS
                STORM WATER SAMPLING AND ANALYSIS

                     HYPOTHETICAL EXAMPLE
          CALCULATIONS FOR ALIQUOT VOLUME
         • EXHIBIT 3-24 STEP 8 PROVIDES EQUATION NEEDED TO
          CALCULATE ALIQUOT VOLUME NEEDED FROM EACH 1-L
          GRAB SAMPLE TO PREPARE THE FLOW-WEIGHTED COMPOSITE
          SAMPLE.

-------
U)
oo
J
Step
Aliqi
(ml)
L
i
TABLE 3 u
8: Calculate the volume of each sample aliquot (A) which must be used
to comprise a flow-weighted composite sample. The following
equation should be used:
lot volume (A) (ml) = Minimum aliquot volume
x Aliquot discharge volume (V) (liters)
Largest discharge volume (V) (liters)
510 liters
A1 = 1,000ml x 2237 liters ~ 228m/
&9 1 nnn mi v ?5Qt /flers R71 ml
f\Z — 1,000 ml x 2237 liters ~ "' ' m'
A-? 1 nnn ml ^ 2Qt 1 liters RQQ .
A3 - 1,000 ml x 2237 liters ~ 8" m/
A i • rt™ i 2^24 liters - m .
A4 - 1,000ml x 2237 liters ~ 949ml
A5 = 1,000 ml x 2237 //tefs = 1>°°° ml
9 *f & 1 lift* f*c
A6 - 1,000 ml x 2237 liters ~ 975 inl
A7 1 nnn mf ^/ 3-OPo «(*®' ^ coc ml
A 7 — 7,000 mi x 2237 liters ~ **"" ^'
A a t /inn i 786 liters ~-1 .
A8 - 1,000 ml x 2237 liters ~ 351 m/
&OA //fpr
-------
           TABLE 4 - SUMMARY OF VOLUMES NEEDED TO PREPARE A FLOW-

         WEIGHT COMPOSITE FOR ALL PARAMETERS AND VOLATILE ORGANICS
oo
00
Sample
S1
S2
S3
S4
S5
S6
S7
S8
S9
Parameter
Composite
A1 = 228 ml
A2 = 671 ml
A3 = 899 ml
A4 = 949 ml
A5 = 1,000ml
A6 = 975 ml
A7 = 696 ml
AS = 351 ml
A9 = 181 ml
Volatile Organic
Composite
VOA1 = 0.23 ml
VOA2 = 0.67 ml
VOA3 = 0.90 ml
VOA4 = 0.95 ml
VOA5 = 1 .00 ml
VOA6 = 0.98 ml
VOA7 = 0.35 ml
VOA8 = 0.35 ml
VOA9 = 0.18ml
TOTAL (V) 5,950 ml 5.96 ml
                                                              wrc93-074-04l

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    STORM WATER SAMPLING AND ANALYSIS

          HYPOTHETICAL EXAMPLE
IT IS ABSOLUTELY ESSENTIAL THAT THE LABORATORY IS
PROVIDED THE INFORMATION CONTAINED IN TABLE 4 AND
THAT THEY COMPLETELY UNDERSTAND THE SIGNIFICANCE
OF TABLE 4 AND THE NEEDED CORRECTION IN ANALYTE
CONCENTRATION CALCULATIONS BECAUSE OF THE VOLATILE
ORGANICS SAMPLE VOLUME DIFFERENCE.

-------
U)
VO
o
     l
                 STORM WATER SAMPLING AND ANALYSIS

                      HYPOTHETICAL EXAMPLE
OTHER CONSIDERATIONS

• TWO 1-L CONTAINERS SHOULD BE COLLECTED AT EACH
 SAMPLING.

• KEEP COLLECTION INTERVALS EQUAL FOR ENTIRE PROGRAM
           ROUND ALIQUOT VOLUMES TO TWO SIGNIFICANT FIGURES
           WHERE NEEDED.

-------
U)
                STORM WATER SAMPLING AND ANALYSIS

                      HYPOTHETICAL EXAMPLE
CONCLUSIONS


• ERA'S GUIDANCE DOCUMENT IS HELPFUL IN MEETING
 REGULATIONS.

• PREPARE A HYPOTHETICAL EXAMPLE FOR SAMPLING LOCATION.

• IT IS POSSIBLE TO MEET STORM WATER REGULATORY
 REQUIREMENTS.

• EPA MAY WANT TO PROVIDE MORE DETAILS.

• CONCERN REMAINS FOR POTENTIAL TO LOSE ANALYTES TO
 CONTAINER WALLS.

• CONCERN WITH COMMERCIAL LABORATORIES TO PREPARE
 FLOW-WEIGHTED COMPOSITE SAMPLES.

• COMPOSITE SAMPLES FOR VOLATILES IS FAR FROM ROUTINE.

• HYPOTHETICAL EXAMPLE MEETS REGULATORY CRITERIA (?).

• ELECTRONIC SPREADSHEET SHOULD BE PREPARED FOR CALCULATIONS.

-------
MD
                 STORM WATER SAMPLING AND ANALYSIS

                      HYPOTHETICAL EXAMPLE
                            DISCLAIMER
          THE AUTHOR AND CMA ASSUME NO RESPONSIBILITY FOR
          ANYONE WHO MAY WANT TO USE OR FOLLOW THE HYPOTHETICAL
          EXAMPLE; HOWEVER, WE FEEL THE EXAMPLE DOES MEET THE
          REGULATORY REQUIREMENT OF THE FINAL RULE FOR STORM
          WATER REGULATIONS.

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                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD: Do we have any questions? We
all have storm water answers?  Come to the microphone.  Please identify yourself and your
organization.
                                       MR. CROWLEY:  Ray Crowley from Millipore.
             You didn't talk about the specific results, but if you profiled the VOCs or the non-
volatiles, the semi-volatiles, do you see most of the runoff in the first 30-minute sample?

                                       MR.  STANKO:   This was  only  a hypothetical
example. We believe that most of the volatiles are going to be in that first grab sample, and you
have to analyze the first grab sample for the volatiles and semi-volatiles in addition to doing this
flow weighed composite.

             If there is anything there, we think that the first flush, as it is called, the first flush
is probably going to have it,  and  it kind of conies down to why  are we doing all this flow
weighted compositing for zeros.  The rule says we have to.

                                       MR. CROWLEY:  And a second point, since I am
not aware o;f all the regs.  How often do you have  to do this to meet site compliance?

                                       MR. NOEL: That is negotiable. I think everyone
is going to have to have it in place. October is the deadline for this year? I think it is.

                                       MR. CROWLEY:  And then ever  year?  Or what
is it, once every five years?

                                       MR. STANKO: I think that is negotiable. You could
do it on a quarterly basis, whatever your agency wants you to do.

                                       MR. CROWLEY:  And for a chem plant like in
Houston, how many sites do you have to take samples at?

                                       MR. STANKO: Wherever you have a storm water
runoff.

                                       MR. CROWLEY: I guess you have got to have one,
huh?

                                       MR. STANKO: Well, I guess we are going to start
changing our ditches.

                                       MR. CROWLEY:  Thanks.
                                         393

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                                   MR. TELLIARD:  Any other questions?
(No response.)

                                   MR. TELLIARD:   Thanks  so  much, George.
Appreciate it.

                                   MR. STANKO:  Thank you.
                                     394

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                                         MR. TELLIARD:   Our  next speaker will be
 speaking on one of our favorite-est subjects, national sewage sludge survey or sludge sampling.
 John McGuire is with our Athens laboratory under the Office of Research and Development.
 John has been here before, and we want to welcome him back.  And he is now armed.
                                         MR. MCGUIRE:  Armed and loaded, Bill.  Thank
 you, Bill.

              This talk is going to be quite a bit different from the talks that you are used to
 hearing at this meeting, so bear with me.

              The title of this talk is, "Commonality of Non-target Organics and Extracts of
 National Sewage Sludge Survey Samples."

              Identification of organic compounds present  in sludge has been important in
 sewage treatment plants for many years.  Twenty years ago, Miller and Thistlethwaite defined
 several types  of sewage, including  silage, all-inclusive sewage, industrial waste, storm water,
 groundwater, and municipal  sewage.  From the engineering viewpoint, each of these has its own
 composition.

              However, the importance and complexity of domestic sewage which is defined as
 silage  plus  fecal  matter  and urine,  have  made that the  area  that has been most widely
 investigated.

              Fulton and Klein reported that domestic sewage consists of carbohydrates, fats,
 proteins, their decomposition products and synthetic detergents.  Having said that, they did  not
 identify specific organics.

              Garrison and his coworkers...it just happens that is in my lab...seem to have been
 the first to report specific organic chemicals in sewage treated by several treatments, including
 activated  sludge.  These workers  found 19 straight chain  carboxylic acids, two unsaturated
 carboxylic acids, seven branched chain carboxylic acids,  seven oxyacids, four ring-containing
 carboxylic acids, seven alcohols,  three thiolates, eight chlorine-containing  compounds, two
 steroids, four drugs, six aromatic compounds, and 11 miscellaneous.

              In 1981, Giger first reported the presence of nonylphenols and nonylphenol
 ethoxylates in  sewage.  Since then, he has published extensively in the area of improved methods
 for these compounds in various samples.

              He pointed out that the nonylphenols, which are toxic to fish in environmental
waters, may be the result  of biological treatment of sewage sludge containing the ethoxylated
nonylphenols,  common non-ionic surfactants. He also noted that anaerobic sludge treatment  led
to higher levels of nonylphenols than did aerobic treatment. His postulate that the nonylphenols


                                          395

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come from the ethoxylates is a concern in view of last year's CMA/EPA report that nonylphenol
ethoxylates themselves do not persist in the environment.

             Rosen and his group also detected nonylphenols but attributed them to degradation
of an antioxidant, tris-nonylphenol phosphate.

             Six years ago, Demirijian studied the fate of sludge applied to soils.  The initial
sludge was analyzed and found to contain 12  priority pollutants as well  as 29 other organics,
including aliphatics and aromatic  amines, acids, and phenols.

             Getting up to date, the National Sewage Sludge Survey was conducted in '88 to
'89.  Among other objectives, it was designed to provide concentrations of 419, including 176
semi-volatile, target organic analytes for which the EGD...I am sorry, that is now the Engineering
and Analysis Division of the Office of Science and Technology of the Office of Water, the group
that is  so well represented here today...had standards.

             These target compounds were chosen based on Section 307(a) of the Clean Water
Act, Appendix VI11 of the RCRA, compounds that were detected in the Domestic Sewage Study,
and ones that were suspected to be of interest in municipal sludge.  "Suspected" pretty much
means Bill Telliard.

             Nationwide, 180 plants were  sampled for this study.   The results, which were
based on low resolution electron impact mass spec, were reported by the contract labs conducting
the analyses and summarized in the Office of Water report in 1989.

              Low resolution EI-GC/mass  spec  has  been applied  since the  early  '70s to
identification of  organics in water.   At this time,  it is the accepted method for positive
identification of target analytes and the most significant analytical technique for monitoring and
regulation of organic pollutants, at least semi-volatiles.

              GC/MS with  automated spectra and retention time matching against a reference
collection is known to be excellent for specific substantiation of target compounds, but its current
success rate for tentative identification of unknowns is poor.

              There are about three studies I know of associated with the tentative identification
of unknown organics in the Superfund program, and they range  from 1 study that had a 1 percent
confidence in the identification to the highest confidence rate that was 42 percent.  So, current
success rates are rather poor.

              In particular, it fails to detect and identify compounds whose mass spectra are not
in the  spectral  libraries.

              As was to be expected, most of the compounds that appeared in the course of the
laboratory sample workups were not target analytes, and they were not identified.  Accordingly,

                                           396

-------
the BAD asked that qualitative multispectral analysis methods be applied to a subset of 20 of the
NSSS sludges.

              This paper summarizes some of the highlights of that work. The full report will
be published in the fall.

              The multispectral analysis approach uses high resolution mass spec to determine
elemental composition of ions, Fourier transform infrared spectroscopy to recognize submolecular
structures, and chemical ionization mass spectrometry, CI, to establish molecular weights of the
unknowns.

              The spectral information is then melded together by a team of analysts to postulate
the structures of the unknown compounds.

              At another meeting last year, one of the audience asked well, how does that differ
from good analytical chemistry? Well, in one sense, it doesn't, but the  big difference in our
multispectral analysis program  is the  bit I just mentioned, a team of analysts who are used to
applying this sort of approach.

              A number of locations have the individual scientists and equipment necessary to
apply FTIR, high res, and CI, but most of them are not set up as a team.  We are.

              The objective of this work is not the usual EPA quantitative methods approach but
the qualitative identification of sample constituents. Nor is it a complete qualitative/quantitative
analysis.

              Results  and application  of  this  technique to  unidentified  compounds in
environmental samples have been excellent. Upon reexamination of samples from another survey
conducted by the Office of Water, we identified two series of aldehydes...! believe that work was
reported here at an earlier meeting as well as a variety of organophosphates whose spectra were
not included in the reference  collection of mass spectra.

              Following the identification,  spectra of the identified compounds have  been
included in both the Wiley and the NIST collections of spectra so that future identifications of
these compounds should  be simplified for others.

              The 20 samples  chosen by the HAD for the  in-depth examination were to be
broadly representative of samples taken in the NSSS.  They included samples from seven regions
with examples of sludges that had been produced during primary and/or secondary treatments,
ones produced during aerobic and/or anaerobic digestion, ones produced by one or more of six
methods of separating liquids and solids, and ones dried with or without drying beds. All but
one of the samples have been characterized by one of the contract laboratories of the  Office of
Water as part of the NSSS.  Two of the samples were duplicates.
                                          397

-------
              This history, gross appearance, and residue weight of the samples as received are
given in the next slide.

              Based on screening tests, three principal approaches were used for extraction of
the analytes from the sludge matrix.  The first of these was used for drier sludges and consisted
of extraction with a 50/50 mixture of acetone and methylene chloride followed by filtration of
the solvent through a bed of sodium sulfate.

              For those samples that.appeared moist, a significant amount of granular sodium
sulfate  was ground  up...by that,  I mean  about  25 to 30  percent...with the sludge prior to
extraction.

              When a sample appeared to  be essentially liquid at room temperature, water was
added prior to a methylene chloride shakeout.  In all cases,  the final step was concentration of
the solvent using a Kuderna-Danish.

              That slide showed basically that sample appearance was related to dry weight, and
because appearance also was related to the method of prep, the dry weight and the method of
prep are confounded statistically.  That certainly would introduce a bias into any quantitative
analysis, but we expected at the start, and have no reason to believe now, that it had any effect
on the qualitative results.

              Now for this slide.  Results of the contract laboratory analysis for 176 target semi-
volatile analytes  were  reviewed in conjunction with the analyses of the  sludge samples.  This
table shows  the  21  target compounds that were  reported  in  at  least one  sample  by the
laboratories.

              Whether or not these identifications were confirmed in our re-analysis is indicated
by an appropriate tag in the table, and I am  not sure whether you can read the tag.  Basically,
a single asterisk indicates that the presence was confirmed at least once in this study.  A double
plus sign indicates that we could  not confirm those compounds in any of the samples,  and we
seriously doubt the identification from the laboratories.

              You will notice that most of the compounds that do have the double plus sign on
them are  the real "nasties," the benz[a]pyrene, the benz[b]fluoranthene, the benz[k]fluoranthene,
benzo[ghi]perylene are all double plussed.

              Samples that have  a pound  sign next to them...I am sorry...compounds that have
 a pound sign next to them...and I believe the only one in this table is pyrene...were not confirmed
 due to  a high sample background.

              Most of the non-phthalate target compounds that were reported were not reported
 in more than one sample.  The phthalates, in general, and  bis-iso-octyl  phthalate in particular,
 were found in all samples.

                                            398

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              The reason for the small number of targets reported is the same as the reason for
the small number of confirmations.   The samples are so complex and dirty  it is extremely
difficult to obtain a good mass spectrum of any specific compound.

              As an example of this, the range for the level of detection for the semi-volatile
fraction was found by the contract laboratories to range from a relatively clean sample having
a minimum detection level of 250 ppb to a particularly bad one having a detection level of 500
ppm. Our work in no way contradicted this.

              Yesterday, Jim Rice proposed a CMQL which I believe would make a great deal
of sense in analytical work such as that of the NSSS if they get lists that are going to be the
basis for regulation (which happens to be an approach I don't agree with.)

              The chromatographic profiles of the various samples did not resemble one another,
as is shown in the next slide.   However, this  quantitative attribute was not reflected  in the
qualitative aspect of the analyses.  Many of the same compounds could be found in all samples,
although a few were much more prominent in some samples than in others.

              These compounds are  ones that,  although not target compounds, are definitely
anthropogenic in the most restricted meaning of the word and  are not surprising in sewage
sludge.  Specifically, we found numerous fatty acids as well as their degradation products  such
as aldehydes and polyunsaturated straight chain hydrocarbons.  Other types of compounds found
that are man-made appear to be sterols and degradation products,  (thianes, thiols, and sulfur) of
proteins.

              Other compound types found are ones that are anthropogenic in the usual broader
sense of the term. These include surfactant amines and phenols, perfumes used in detergents and
soaps, and chlorine- and nitrogen-containing aromatics.

              The next slide is a brief summary of the various classes found in the course of the
study. Chlorine- and nitrogen-containing aromatics consisted of mono and dichloroanilines and/or
mono and chloroisocyanatobenzenes.  Because reduction of the isocyanatobenzene could lead to
aniline and oxidation of the aniline could lead to isocyanatobenzene, it is not  possible to say
which came first, nor is it  possible to say whether both may  simply be disproportionation
products of Triclocarbon®, a bacteriostat used in soaps which has been identified by Rosen using
LC/MS.

              Nonylphenols have been reported before in sludges, as I have already said, and
it has been observed that aerobic sludge treatment tends to result in lower levels than anaerobic.
As expected, the level of nonylphenols in the two aerobically treated sludges was very low.  In
fact, nonylphenols could only be found in sludge 16525 by using specific ion monitoring for the
most significant peaks of the nonylphenol.
                                          399

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              The levels in the other sludges were variable, ranging from levels equivalent to
those of the aerobic treated samples and some samples which were totally untreated to that of
sludge 16825 where the nonylphenols were the most significant GC peaks.

              One of the most obvious compound types evidenced in these sludge samples is that
of fatty acids.  The next slide shows a mass 60 chromatogram which shows the presences of
these compounds.  The series of acids is clearly evident from butanoic acid at scan 290 through
arachidic acid at scan 1575. The significant peak at 303 is a degradation product of acetone and
is not part of the series.

              Although these acids, in general, represent the largest organic components of the
samples, it is possible that they  are themselves only degradation  products of fats that were
extracted but could not be  chromatographed under  the conditions used.

              As an example of the types of identifications made  in this study,  the next slide
gives a full list of the carboxylic acids found.  I  am sure you won't be able to read it, but it is
not significant other than the fact that that long list is entirely made up of acids.

              Other families of compounds also  can be enhanced away from the high chemical
noise of the  sample.  The next slide shows a mass 70  chromatogram  which emphasizes the
aldehyde series, starting with hexanal at scan 244 and continuing at 363, 484,  599, and ending
with decanal at 705.

              Mass 70 is less distinctive than the  mass 60 used in the other slide.  Therefore,
this representation has a very significant number of GC peaks that are  not part of the  series.
Nonetheless, the presence of the series is evident.

              The next slide shows the mass 47  chromatogram that is characteristic of thiols in
a sample, starting with pentylthiol at scan 215 and continuing with hexylthiol at 314,  heptylthiol
at 416, octylthiol, nonylthiol, and ending with decylthiol at scan 692. The interferences here are
generally dimethylpolythianes.

              In the course of this work, we stored one of the extracts that had been rich in both
aldehyde and thiane families in a refrigerator for several months between analyses.  Aldehydes,
thiols, and a related series  of thianes all had disappeared when the  sample was rerun.  Because
all  of these compounds   are both  relatively  volatile  and relatively  active  chemically,  the
significance cannot be pinned down as to which effect caused the  disappearance, but the need
for a short storage time is  obvious.

              Of the 157  compounds and classes found in this study, only 15 of them or 10
percent are regulated  compounds.   This is based on the EMI which is being advertised rather
heavily at this meeting...although an additional  55 of 35 percent are non-regulated target
compounds such as those from the "4C other" list that was put together by Bill following the tape
study.


                                          400

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              Hence, more than one-half of all compounds found in these very common types
of samples are non-target compounds.  It  raises the question whether we  may  be failing to
regulate things we should be regulating.

              It is worth reemphasizing that this is to be expected for all but the most highly
characterized types of samples.  There are  significantly less than 1000 target compounds, but
Chem Abstracts  lists over 10 million reported chemicals.

              It is also worth noting that there was little need for a full range of multispectral
analysis in this  work.  Most  of the  compounds were readily  identified through  the  use of
conventional  mass spec matching when a sufficiently large collection of reference spectra was
used. In this work, we used both the most recent NIH collection and the Wiley collection.  The
older NIH collection by itself would have been inadequate.

              Examples of compounds whose identifications did use other  techniques are the
aldehydes,  the  mercaptopropionic  acid and its  ester, the  chloroisocyanatobenzenes, the
alkyltetralins, the perfumes shown in the next slide.

              (I like that one at the top.  That is actually caryophyllene, but it certainly looks
like pac man, doesn't it?  These are  two of the perfumes that were  found in the sewage sludge.
They are conventional perfumes that are used frequently in the soap industry.) And, finally, the
almost ubiquitous musk compounds shown  in the next slide that we identify as galaxolide and
versalide.

              The structures of these  last two compounds seemed so unlikely that we  decided
to investigate some commercial detergents to see if we could determine a likely source of such
compounds.  We then took two commercial  detergents from our  home shelves.   The second
detergent that we analyzed showed the same  two compounds in approximately the same GC peak
ratio.  It is a very well-known detergent.   I might refer  to it as Detergent C, and it  is quite
probably one of the sources of these two compounds in the sewage sludge.

              Three  unsaturated  straight chain compounds appear to be significant in these
samples.  The last eluting of these compounds was  easily identified by  spectra matching as
squalene, which  is a  reasonable compound in  sewage, but the other two had less obvious ionic
characteristics.

              Based on the hypothesis that  this might arise from some of the major fatty acids
in the  sample, we deliberately  decarboxylated several acids and  analyzed their degradation
products by both MS and GC retention times.  We conclude, as a result, that the first of these
unsaturated compounds is 8-heptadecene, arising from the decarboxylation of oleic acid.  The
second is 6,9-heptadecadiene, arising from decarboxylation of linoleic  acid, both of which acids
were very common in these studies.
                                          401

-------
              This  is probably a general process, but we did not determine if the level  of
heptadecane, presumably from decarboxylation of stearic acid, is higher than would be expected
from some of the other normal alkanes that were present in the samples.

              The sterols/phytosterols represent a new class of compounds for us. They may not
be for some of the people in the audience.  Their presence  in the various samples is manifest,
but the precise identifications that we make are very tentative.

              Many of you may have noted an instability in the mass spectrum of cholesterol
in your own mass spectrometers.  This dehydration effect is but one of many in the determination
of some of the less  common sterols.  As a result, we are sure that sterols are present but much
less sure of which ones that we see may be merely due to the GC thermal rearrangement of
others.

              GC is probably not the best way to pin down specific identification of this type.
It requires too high temperatures.

              More than half of the 157 compounds found in this qualitative analysis were non-
target organics.  Of the 15  regulated target compounds  found, the only one that appeared to be
significant in all samples was the common plasticizer, bis-iso-octylphthalate.

              As you know, that is also a very  common interfering compound in a laboratory.
We were  one  of the first labs to spot the source of that as an interference, and I am quite sure
it was not an  interference in our lab. It  may or may not have been a contamination that was
introduced during the collection  of the sample.  I don't know.

              The most common non-regulated target compound was nonylphenol, a compound
that has been reported to be less common in aerobic treated sludges than in anaerobic treated
ones-which we certainly agree with.

              I feel regulation should be based on what is  present  rather than  what is on lists.
Further analytical work is indicated in the field of  sterol/phytosterol analysis in order to
characterize these late-eluting components of sludge.

              At least four compounds in the sample are associated with soaps. This suggests
that it  may  be  worthwhile to characterize the  products of some  of the large volume
manufacturers. In particular, it seems likely that some  of the polynuclears found by one of the
contract laboratories (and only one) may have, in fact, been sterols which were beginning to elute
near the end of the GC run.

              The source of both the chlorinated analines and the chlorinated isocyanatobenzenes
needs to be determined to  permit fuller characterization of  sludges  in the future.
                                           402

-------
             I thank Bill for the use of his EMI system in the course of determining whether
or not a compound is listed, and I thank him for once again for having me speak here.  And
thank you all. Are there any questions?
                                          403

-------
                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD: Any questions?

                                       MR. SULLIVAN:  Richard Sullivan, Environment-
Canada.  Have you ever looked for any of the compounds related  from birth control pills?  I
understand that some biologists have reported the effects of these on minnows and similar
species.

                                       MR. MCGUIRE:   Richard, as soon as we saw
sterols coming in, we thought, "aha!"  The answer is we looked, and we did not see any.

                                       MR. KING:  Jim King, DynCorp-Viar.
Dr. McGuire, did you make any attempt to review the raw data tapes from the contract labs to
check on that misidentification?

                                       MR. MCGUIRE:  I did not. I took the reports that
were included in, what was it, two years ago summary, and went through those line  by line.  I
did not go back to the raw data tapes.  I hope that Bill has given you the correction to EMI that
I gave him the other day.

                                       MR. CROWLEY:  John Ray Crowley,  Millipore.
When you use these high-powered analytical techniques like your soap analysis, I mean, now that
you have got the CMA and the EPA working together, are you going to move more toward the
direction of finding out who is putting what into the sludge area? Let's say you call up P&G and
ask them what their favorite fragrances are rather than put in a lot of work in terms of trying to
identify unknowns that you might know it ahead of time?

                                       MR. MCGUIRE:  That sort of work doesn't fit into
our charter.  Whether the regulatory offices in Washington will is something I can't  address.  I
don't know.

                                       MR. CROWLEY:  But doesn't that make  your
information base more powerful, because you have...you are problem solving and you have better
information up front?

                                       MR.  MCGUIRE:   Absolutely.   Incidently,  in
conjunction with that, that is one of the approaches that my TIC identification task  group that
I head up for Superfund does do but not under this program.

                                       MR. TELLIARD:  Thank you, John.

                                       MR. MCGUIRE:  Thank you, Bill.
                                         404

-------
                                               Table 1
                                           Sample Summary
EPA Sample Number and
Episode
16525/1362
16534/1367
16537/1430
16542/1493
16544/1380
16803/1544
16819/1381
16825/1443
16827/1411
16835/1389
16838/1454
16848/1399
17028/1475
17042/1509
17047/1439
17055/1476*
17056/1476*
17059/1477
17087/1538
17131/1486
Plant and Location
Rainbow MWD,Cal.
Fredericksburg STP, Va.
Burnham STP, Pa.
Oakland WWTP, Kans.
Sioux Falls WWTP, SD
Hilton NWQTP, N.Y.
Brookings STP, S.D.
St Joseph WWTP, Mo.
Port Clinton STP, Oh.
Lake Zurich NWSTP, 111.
Egan WRP, Chicago, 111.
Wyoming WWTP, Grandville, Mich.
Weirton WWTF, W.Va.
Garden City WPCP, Garden City, Ga.
Cinnaminson STP, NJ
Corbin STP, Ky.
Corbin STP, Ky.
No information
Phoenix WWTP, Ariz.
Mason Farm WTP, Carrboro, N.C.
Physical Appearance
at Room Temperature
Dry
Solid and extruded
Dirt
Granular
Damp
Some water
Some water
Wet
Granular
Some water
Granular
Some water
Some water
Granular
Wet
Damp
Damp
Damp
Granular
Mainly water
Residue Reported
by Contract
Laboratory
100.%
89.6%
66.0%
83.4%
33.3%
20.3%
3.4%
3.9%
52.0%
34.8%
38.3%
4.2%
30.7%
47.6%
10.1%
22.5%
24.5%
<>
70.5%
2.6%
* Duplicates

-------
     	Table 2	

      Compounds found by Contract Laboratories
  Benz[a]pyrene++
  Benz[b]fluoranthene++
  Benz[k]fluoranthene++
  Benzo[ghi]perylene++
  Benzyl alcohol++
  Bis-(iso-octyl)  phthalate*
  Bis-(n-Octyl)  phthalate*
  Butyl-benzyl phthalate*
  Chloroaniline*
  p-Cresol*
  p-Cymene*
  Diepoxybutane++
  Even-carbon-#-alkanes from decane to
  triacontane*
  Fluoranthene*
  Hexanoic acid*
  Naphthalene*
  Phenol*
  Pyrene#
  Squalene*
  Terpineol++
  Thiophenol++
*  Presence was confirmed at least once in this study
++ Not confirmed & probably wrong
#  Not confirmed due to high sample background
                      406

-------
o
•-4
                               	Table 3	
                               Compound Classes found in Sludge Study
                   ALDEHYDES
                   ALKANES (NONANE to TRIACONTANE)
                   ALKYL PHENOLS
                   AMINES
                   AROMATICS (Cl to C12 BENZENES)
CHLORINATED ANILINES and ISOCYANATOBENZENES
DECARBOXYLATION PRODUCTS of FATTY ACIDS
FATTY ACIDS	
PERFUME INGREDIENTS and MUSKS	
PHTHALATES	
STEROLS and PHYTOSTEROLS	
TETRALINS	
THIANES and SULFUR	
THIOLS

-------
                                       Table 4




                     CARBOXYIJC ACIDS FOUND IN SIAJIHJKS
Methylthiopropanoic acid
Benzeneacefic acid
Pentanoic acid
Ilexanoic acid
Ileplanok acid
Octanok acid
Nonanoic acid
Phenylpropanoic acid
Decanok acid
Undecanok acid
Isododecanoic acid
Anteisododecanoic acid
Dodecanok acid
Isolridccanoic acid
Anteisotridecanoic acid
Tridecanoic acid
12-Methyl(ridccanoic acid (iso)
ll-Meflij'Kridccanok acid (antoiso)
Tetradecanoic acid
x-Melhylletradecanoic acid
13-Mecanoic acid (iso)
12-Melhylteoic acid (S(earic acid)
Arachidk acid




                                     408

-------
       \
Figure 5   Caryophyllene and Aromadendrene
                    409

-------
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Figure 6   Versalide and Galaxolide Musks
              410

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-------
                                        MR.  TELLIARD:   Our next speaker  is Ileana
Rhodes from Shell.   She is going to  speak on the use of determination of organochlorine
pesticides in soils.
                                        MS. RHODES:  Good morning.  Can you hear me?

              One of the nice things about changing the schedule is that I actually have an
audience.  I didn't expect to have one, having one of the last papers of the day.  I figured it was
going to be an empty house.

              I am going to talk about determination of selected pesticides in soils. One of the
things you might wonder is what is an oil company doing with pesticides.  Well, we used to
manufacture aldrin, dieldrin, endrin and so forth at the Rocky Mountain Arsenal  from the '50s
to the '80s, and we continue working in remediation aspects  of that area.

              One thing that is going to become quite evident is that some people like  myself
have two  different kinds of functions.  One of my functions is to  work with our locations,
meaning refineries or chemical plants, in making sure that their are meeting their permits  or they
are cleaning the areas they need to clean appropriately.

              In that sense, I use a regulatory hat, and I insist that all the contract laboratories
who do the work for us follow the methods as they are specified.

              When  it comes to the  work I do in-house for our environmental engineers  and
biodegradation experts, I do whatever is necessary to meet data quality objectives. The kind of
paper I am going to present to you today involves  taking some EPA procedures and some
USATHAMA type procedures, because we have to work with the Army as well on this project,
and then making it meet the data quality objectives,  in other words, going from A to B the
shortest way possible and still getting data that makes sense.

              What I would like to show you today is the fact that you can put the two of them
together and get a lot better data with a lot less trouble.

              Essentially, we took the EPA procedures/USATHAMA procedures...they are kind
of similar...and we took the best out of both of them and went on from there.

              I am going to talk about the  project requirements and goals.  I  have some very
specific goals in the project, and I wanted to support research. These were the people who are
doing different technologies, things like bioremediation. We all know that doesn't work very well
for chlorinated compounds, but we had to give it a try.  Thermal desorption techniques, chemical
treatment such as solvent washes and things of that nature were also  investigated.
                                          415

-------
              So, my goal was to support those experiments in-house. We developed a single
extraction technique, and I am going to talk about that some more.

              We developed two different analytical methods. In other words, when we put the
sample  into the instrument, we followed two  procedures, a split procedure and a splitless
procedure to kind of accommodate the wide  range of samples without having to do a lot of
sample manipulation.

              Then we went on and evaluated  the need to clean up the  samples.  These are
primarily  soil samples, but the soil samples  that I was getting were not only just field soil
samples. They were also soil samples mixed with cow manure, bacteria, fungi, algae. You name
it, we got them.  And also brines and impinger fluids, all kinds of things.

              So, when I  say soil, it is not just  soil.  It is soil with a lot of extra stuff on  it.

              We  need to compare  the  techniques  for  cleanup  not only   in  terms of
chromatographic quality but also how well can we quantitate the sample without doing all the
cleanup steps.

              Finally, I like to compare the short technique that we developed with the standard
approach done by contract laboratories.

              Essentially, we had several goals for this project.  One of them is  that we were
going to get samples that vary from percent level of pesticides, primarily dieldrin, aldrin and so
forth.  From now on, I am going to call them drins for short.   And they came  from sludges,
sediments from evaporation ponds, windblown soils, etc.

              We have a variety of samples, and we have to do it as quickly as possible, because
there were critical path samples. In other words, the next experiment couldn't be  planned until
we had the results from the previous experiment.

              Our goals were to get from point A to point B, in other words, from extraction to
analysis without doing any dilutions if we didn't need to, without doing any cleanups if we didn't
need to, and so forth.  Our solution was to come up with a single method that goes from point
A to point B with minimal effort.

              One of the things that I want to bring up and will show up on every single slide
just  about is data quality objectives.  Whenever we support research, I always find out what is
it that we  are going to use this data for. And that is what we home in on.  This is the only thing
we need to do.

              Not what should be done based on some procedure that was written 20 years ago
but what makes sense for our project.
                                          416

-------
              And I am going to talk about the development of a single extraction procedure
which is based on EPA and PMRMA methods.

              PMRMA is Project Management Rocky Mountain Arsenal, and the methods are
similar to the EPA procedures, but they are more capillary oriented rather than the old packed
column, and the cleanup techniques are slightly different. Essentially, you take your soil sample,
you dry it out with sodium sulfate, you extract it three times, treat it always as if it were a low
level soil rather than a high level soil.

              Most laboratories treat samples with a high level method. Most laboratories treat
the sample as if it were  the last part per billion  on earth.  It is extracted three times and
concentrated and so forth.

              Then you go through a  series of extraction procedures.  We follow the protocol
from  the USATHAMA procedure which was alumina column cleanup followed by a  sulfur
cleanup,  water washing, et cetera, concentration, and then analysis.

              We started taking steps one at a time, and essentially what we did is we extracted
a sample following the high level method.  Just sonicate and then centrifuge, put it on a sample
vial, and went from there.

              I would like to show you for purposes of this talk that it doesn't make any
difference what levels you got from parts per billion to percent level.  The recoveries are the
same.

              We take the soil sample and weigh 5 to 20 grams.  Typically, we take about  10
grams of soil  and 10 ml of solvent.  We use acetone/hexane. That  was the protocol in the
USATHAMA procedure that we used at the time, and we vortex the sample for 1 minute.  Later
on, we found out that vortexing just about takes almost more than 90 percent of the stuff that is
there in the first place.

              Then we go ahead and sonicate using a horn sonicator for about 5 minutes. The
alternate procedure is that if we have a few samples and we want to do it in a hurry, we use the
sonicator. If we have a bunch of samples, more than ten or so, we just throw them in the shaker
overnight and pick them up the next day, and we are ready to go.

              Then we go ahead and centrifuge the sample. We take the extract and put it in
another sample vial, and then we analyze it by GC/ECD. Our detection limits in the soil are 1
to 10  ppb.  That is the PQL, not the MDL.  The MDL is more like 0.25 ppb.

              And a second column is used for confirmation if need be.

             Now, most of the time we are working with samples that we knew were spiked
or contaminated, so confirmation was not necessary.


                                          417

-------
             Now, we have got an extraction procedure that is very simple, and one thing that
I want to bring up is the fact that a lot of times you are doing all these cleanup steps to get rid
of interferences.  The more you manipulate the sample, the more you pass it through sep funnels,
the  more you pass it through columns, the more chances you have  got to get it exposed to
phthalates and things of that nature that you end up having to clean up for.

              You saw that in some of the people that talked yesterday about mercury analysis
and the like, the fact that they thought a lot of the numbers and a lot of results that were reported
were mostly contamination rather than actually being present in the sample in the first place.

              And I truly believe that a lot of the reason why you have to do cleanups in many
respects is because of the stuff you add to it while you are trying to clean up the sample and
handle it.

              But we  developed a  split and a splitless analysis, and this is the same extract.
Remember, our goal was to try to do the least treatment to the sample. If it doesn't need to be
diluted, then don't dilute it.

              So, we simply used Hewlett-Packard instruments, and we use a split/splitless liner,
and the sample went higher than 10 ppb, we just simply shot them as they were. If we expected
lower levels, then we went ahead and did the splitless method.

              This is kind of a summary of the two methods that we used.  Essentially, the only
difference between the two methods is whether we used a splitter system or we don't  use  a
splitter.

              What I call the high concentration method which actually is a misnomer there is
not 10 ppb to 10,000, but it is 10 ppb to 100,000 ppb.  In this particular method, we simply use
an isothermal run of 20 minutes to try to minimize the time.  All we did is we shook the sample,
extracted, injected.  We were able to get our results in a very quick manner.

              For the  splitless method, we use temperature programming to try to use focusing
for the solvent, but that was the only difference between the two methods, and the difference was
 10 minutes longer.  That is just to be able to  get down an order of magnitude lower.

              We had two different columns, DB-17  which has some phenyl substitution, and
the DB-1701 was our confirmatory column. Even though the numbers are similar, the DB-1701
has cyanopropyl groups,  so the polarity is quite different.

              This is a  typical series of chromatograms of different standards for the split
 procedure. For the split procedure, we used heptachlor as an internal standard, and you see aldrin
 through endrin there from 40 ppb to 4000 ppm in the same run.
                                           418

-------
              This one is the splitless method in which you can see a 1 ppb standard and a 10
ppb standard.  Since we do  1:1 extractions from the soil, we don't go through any concentration
step.  Pretty much what you get in the extract is what you  get in the soil for detection limits.

              There is really no discrimination there. The peaks are wider towards the end. The
area counts are pretty much the same for all the compounds.

              And what you see in the front is pretty much the solvent.  The acetone portion,
the 1:1 acetone:hexane, the acetone does have a response in the BCD, but it is well way away
from the area of interest.

              Now, we have methods that we could use, very quick methods that we can extract
and shoot into an instrument and  get our answers very quickly.  Now, what we wanted to know
is do we need to do all the  cleanup steps that we originally started doing, and what I am going
to  do  is I am going to show you data for spiked samples.

              Now, remember, our spiked samples are not just clean soils. These things have
cow manure and wood rot fungi and you name it.  So, they are not really that clean samples to
begin with.  The soil was clean originally, but we pretty much dirtied it in a hurry by putting all
that in it.

              I am going to show you data with some sludges or sediments and data from native
soils.   What I would  like to show  you is that no matter what you do,  quantitation doesn't get
compromised, and the chromatographic quality does not change, either.

              This is the spiked  samples.  The people in the biodegradation group spiked soil
at  about 30 ppm or  so, and we  went and sent  those samples off for  analysis using standard
Method 8080 with the cleanup steps associated with it, and then we did it our way by just a
simple shake and shoot procedure, and you can see that the numbers are just about the same
within soil variability and methodology.

              And for soil samples, this is no mean feat, especially when you take a soil sample
that is 10 grams and a piece of it could be a fertilizer in these samples.

              Then we wanted to try out some real samples, because we thought well, spiked
samples, even though we have junk added to it, they are not as realistic as real samples that have
been exposed to the pesticide for quite  some time.

              The only thing we had originally in-house was a sediment from an evaporation
pond. This particular material is very, very high with percent level of dieldrin and aldrin present.
There is diesel oil present in there, there was a lot of urea, salts, very briny, lots of copper in it.
So, it was a very, very nasty matrix.
                                          419

-------
              What we first did was just use a hexane extract, and as you can see...let's see if
this pointer will work...you can see that when you use hexane only, not much is extracted from
the sample.  Aldrin is in blue, isodrin is red, and isodrin is pretty low in the sample.  Dieldrin
is green and endrin is in red.

              As you can see, not  much is extracted with  just  hexane.   If you go  to
acetone:hexane, your extraction works out pretty well, and you pull out everything in there.

              Then we go through a water washing step. Then we get to an alumina column
cleanup followed by just plain hexane. We wanted to see if we didn't add acetone to it we could
leave behind some of the polar species.

              Well, you also leave behind your epoxide linkage kind of pesticides.  For example,
you don't really pull out dieldrin very much, and you don't pull out endrin very much with just
hexane.  So, we had to put, I believe it is, about 20 percent acetone back in to be able to pull
them out from the alumina column,  and then we get recoveries similar to the very first run.

              Finally, we  went through copper shavings to get rid of sulfur, but essentially, we
got pretty much the same  results, and these were a very, nasty sample.

              Next, this was a series of eight samples. There are four  on the first slide and four
on the next one.  What it is  is that we  took four random samples from the field.   These are
contaminated at different levels from non-detect to 20 or so ppm.

              The first column is aldrin, then isodrin, dieldrin, endrin.  The last column was
blacked out.  There is nothing sinister there.  We didn't hide any compound or anything.  That
was intended to be the sum of all of them, but when I made these overheads and I imported from
Lotus into Harvard, I  had  some columns misplaced, and I never got a chance to  correct them.
So, I don't have anything hidden there.  I don't have this 2,3,-dinitrobadstuff or anything hidden
in there,  Bill.

                                         MR. TELLIARD:  Likely story.

                                         MS. RHODES:  So, what happened was that what
we did in here is we analyzed the sample the way that I  have described here just by a simple
shake and shoot procedure. The next is a water wash.  The is alumina  which, allegedly, will get
rid of the phthalates and things of that nature, but we didn't have them  in the first place, because
we didn't expose the sample to anything but just a clean vial.

              One thing that I forgot to mention early on is one of the advantages of this method
is that we take a VOA vial or a mini VOA, what  I call those half-vials, and we put the soil in
there, extracted that, and that  is the only container we use. We sonicate in there, and then from
then on,  we centrifuge in  that container.  We put it into another sample vial, and everything is
disposable.


                                           420

-------
              So, we don't have anything, any glassware to fool with, and that helps quite a bit
both in manpower savings and contamination and cross-contamination problems.

              If one looks at one or two of these, they are essentially the same numbers, whether
you go through these cleanup steps or not.

              This is the second set in here. Again, I don't expect you to read it, but if you want
to just kind of pick one of them,  you can  see pretty well  that there is  really  no change in the
numbers as you go down the different cleanup steps.

              This is a graphic presentation of the same thing.  These are the eight samples.
Some of them are just simply too low to see, but what I want to point out is whether you are at
ppb levels or ppm levels, the simple extraction procedure, the so-called high level method, works
quite well for  low levels as well.

              So,  you are really wasting your time to go through three extractions and then
having to concentrate, and then you might end up having to dilute your sample.  The high level
method works quite well for low level as well, at least  for soil  samples for  organochlorine
pesticides.

              As you can see, it didn't make any difference what cleanup  steps were used. The
concentrations came  out pretty much about the same.

              Now, the next thing you ask yourself is, what is it doing to my instrument? What
is it doing to your column, what is it doing to your system?  What do your chromatograms look
like?

              This is one of the chromatograms, and this is ppb levels of material present. The
front end of the chromatograms are  the solvents.  The top, the red line, is  the as-is sample,
extract and shoot kind  of thing.  The next  one is a water wash, and the last one is an alumina
column cleanup.

              As you can see, all the other peaks don't really change. They are all still present.
You don't gain anything by going through  column cleanup.

              One of the things that you could get rid of are phthalates, but we didn't introduce
any, because we didn't manipulate the sample. So, we didn't have any kind of late eluting peaks
to worry about.

              More of the same.  This sample was also sulfur cleanup using copper shavings.
One thing that I want to point out that the top chromatogram is the as-is  sample, the method that
we really pretty much settled on.
                                          421

-------
              The next one is the water wash.   The next one down is the alumina column
cleanup, and the last one is the copper shavings cleanup for sulfur.

              As you can see, all of them look the same.  The only thing that I want to point
out is the last two are diluted by a factor of 2 by virtue of going through the cleanup steps. The
sample was diluted in those steps, and we didn't bother to reconcentrate it.

              So, the peaks look a factor of 2 smaller simply due to dilution, but what I would
like to point out is that none of the peaks that were present in the non-cleanup sample have gone
away.  They are all there. So, we really don't gain anything by doing any of the cleanup steps.

              More  of the same, a little bit  more  complex a  sample.  By the way,  the
chromatograms are offset a bit so you can see the  peaks, but, again, what I want to point out is
there is no change other than a factor of 2 dilution for the latter two.  So, in other words, there
is no compromise in the  chromatographic quality.

              More  of the same.  Again, the peaks of interest are aldrin, isodrin, dieldrin,  and
endrin.  As you can see, the hash is in all of them. Cleanups don't help you a bit in the area of
interest.

              Now,  the last thing I would like to  go over is a comparison.  What I showed to
you is that cleanups  don't make any difference in  the  chromatographic quality or the  ability to
quantitate organochlorine pesticides in soils, in dirty soils and sediments.

              What  I would like to do is compare it to what results we are  getting in-house to
the results you would get using the standard EPA procedures as provided by contract labs.

              We took 20 samples and split them and sent some to the  contract lab and some
stayed with us.

              The first set would be what we call the high level method, the split method.  The
next row would be the splitless method for those samples of below 10 ppb for a compound, and
the last row would be for each set is the contract  laboratory results.

              By and large, the numbers are quite comparable, as well as can be expected for
soils.  This is clearly shown quite clearly in a  plot, and what this shows is  the correlation
between or a comparison  between  a contract laboratory results and  our results using the
procedures  outlined.

              What we  did in this case is sum all the pesticides.  In other  words, we took the
four pesticides of interest and added them up rather than to do them individually for simplicity.
                                           422

-------
              The green line or the  45-degree  line indicates if it were complete  agreement
between the contract laboratory results following standard EPA  procedures and our approach.
All the points would be lined up along the green line.

              These are the Shell results, and these are the contract laboratory results.  There is
a slight bias, and there are two outliers.  The big two  samples, we disagree totally on those
levels, but on the low samples, and this is an expansion of anything below 7 ppm is on this side
over here.

              If you look  at it, more or less, most of the results obtained or reported by the
contract laboratory fall below the 45-degree  line. That indicates that the contract  laboratory is
usually  biased a little  bit on the low side,  and that has probably to do with all the sample
manipulations and dilutions and triple extractions and so forth.

              But, essentially, the two methods  are quite comparable.

              This is a boxed-and-whisker plot,  and for each set, there are two boxes.

              The first box is an average of 6 Shell results using the methods that I  have
described  here.   The  second box is the average of three results provided by  the contract
laboratory for each sample.

              By and large, what you can see is that most of the two boxes kind of agree with
each other.  That is all I wanted to point out in here.  When you use a simple shake and shoot
procedure, it works just as well as using the long procedure and going through all the cleanup
steps.

              Now, what are the advantages of the simple station procedure?  One  of them is
that we used everything disposable. We start out with VOA vials or the mini VOAs like I call
them, the  20 ml or so.  When you are through, you throw everything away.  The only thing I
have is a VOA vial and an autosampler vial, nothing else.

              We  eliminate all  cross-contamination problems.   We have  minimal  sample
handling.  We have labor savings. We have no washing of glassware to do, no glassware to deal
with, really.

              We have great space savings.  No  Kuderna-Danish to deal with. Nothing to deal
with.  Just sonicate appropriately or shake and you are done.

              Great space savings. We don't need a solvent exchange. We don't use methylene
chloride.

              By the way, the contract laboratory results that you saw were using  methylene
chloride as an extraction solvent. I use acetone/hexane,  and the  data shows that there is really


                                          423

-------
no difference. If there is any difference, it is a little bit of bias on the negative side  for the
contract labs.

             We reduce the turnaround time.  We can get a sample in and out in 25 minutes
or so, half an hour, if we need to.

             We have no deleterious effects on GC columns or BCD detectors.  One thing that
I didn't mention earlier is for the split procedure which we use an isothermal method, we run our
injector at 200 degrees to prevent degradation of endrin.  The column is run isothermally at 215,
and the detector is at 350.  Anything that gets into the column makes it through the detector, and
the detector is hotter,  so there is no contamination.  Everything is kept  very clean.

             We can say that this method is about a third cheaper than the standard methods,
and, of course, time savings go without saying.

             As an example, we ran, on the first year that we worked on this project in 1988
through June of 1989,  we ran about 1500 samples in  support of thermal degradation experiments,
biodegradation experiments, solvent washing, chemical treatments and so forth.  We ran spiked
soils, we ran  RMA soils,  and we ran RMA sediments.  That is Rocky Mountain Arsenal.

             We ran spiked water.  The method applies for water,  too.  What we use is the
hexane extraction of the water, and because we have such good detection limits, we only extract
100 ml of water with  about 10 ml - 25 ml of solvent.

              We even used water samples that were loaded with just  nothing but all kinds of
algae and fungi and you name it when we were screening cultures to use in soils.  We ran them
in impinger fluids from different desorption experiments, etc.

             We ran 1500 samples in the  first year.  It says  there we ran about  20 to  50
samples a month, depending on the load.  It has sped up quite a bit recently, but those original
1300 samples or so were run on a single instrument with a single  column.   We have never
changed the column.   The only thing we do is change the liner every so often, and that is about
all we do.

             We have used the same extraction  procedure for PNAs, we  have used it for
lindane, DDT, PCBs,  and the method  lends itself quite well to field applications, because it is
so simple.  This is one of the cases in which if you can go from A to B without jumping through
a lot of hoops, don't do it.

             That is all  I have to say.
                                          424

-------
                       QUESTION AND ANSWER SESSION

                                     MR. TELLIARD:   Do we have any questions,
comments, suggestions?

                                     MR. STANKO:  We had papers  back there, Bill,
but...

                                     MR. TELLIARD: Oh, there are papers in the back
of the room?

                                     MR. STANKO:  They  are gone.

                                     MS. RHODES:  They are gone. I  expected a much
smaller audience, since I was going to be so late, so I only brought 20.

                                     MR. TELLIARD: Oh, well, there are more than 20.

                                     MR. STANKO:  If you didn't get a copy of the
papers, mine or Ileana's, if you want, just leave a business card and we will make sure you get
one.

                                     MR. TELLIARD: Thanks so much. Coffee break.
Come on back in and we will get going again in a few minutes.

(WHEREUPON, a brief recess was taken.)
                                      425

-------
426

-------
                OF SELECTED ORGAJVOCHLORINE

            PESTICIDES 7/V SOIL

              I LEAN A RHODES
        SHELL DEVELOPMENT COMPANY
               HOUSTON, T\
NORFOLK, VA
 APRIL 1993

-------
to
00
          DETERMINATION OF SELECTED ORGANOCHLORINE PESTICIDES
                                    IN SOIL
            PROJECT REQUIREMENTS AND GOALS
            DEVELOPMENT OF SINGLE EXTRACTION PROCEDURE
            DEVELOPMENT OF SPLIT AND SPLITLESS ANALYSES
     - <10 jig/kg

• EVALUATION OF NEED FOR CLEANUP STEPS FOR SOIL EXTRACTS
 USING SPIKED SOILS AND NATIVE SOILS

     - QUANTITATION

     - CHROMATOGRAPHIC QUALITY

• COMPARISON AND STATISTICAL EVALUATION OF RESULTS
 OBTAINED USING THE SINGLE EXTRACTION / NO CLEANUPS /
 GC-ECD PROCEDURES WITH RESULTS OBTAINED FROM STANDARD
 EPA METHODS

-------
to
FLEXIBILITY IS NEEDED FOR THE DETERMINATION
OF DRINS BECAUSE...

• DAMIlLLi I HOM P~JB IO% LLVLL OF DHINS

• SAMPLES INCLUDE CLEAN SPIKED SOIL TO
 HETEROGENEOUS SOLIDS TO WATER WITH
 ORGANISMS TO SOUPY LIQUIDS

• ALL SAMPLES REQUIRE SOME SORT OF
 EXTRACTION PROCEDURE PRIOR TO ANALYSIS

GOALS:

• MINIMIZE SAMPLE HANDLING STEPS IN THE
 EXTRACTION PROCEDURE
                  • ELIMINATE CLEANUP STEPS

                  • MINIMIZE DILUTIONS OF EXTRACTS
                  • MAINTAIN FLEXIBILITY

                  SOLUTIONS:

                  • DEVELOPMENT AND VERIF CATION OF
                   EXTRACTION AND ANALYSIS PROCEDURES

-------
 DETERMINATION OF SELECTED ORGANOCHLORINE PESTICIDES
                            IN SOIL
 PROJECT REQUIREMENTS AND GOALS
/ DEVELOPMENT OF SINGLE EXTRACTION PROCEDURE


• DEVELOPMENT OF SPLIT AND SPLITLESS ANALYSES

     - >10jL/g/kg

     - <10jL/g/kg

• EVALUATION OF NEED FOR CLEANUP STEPS FOR SOIL EXTRACTS
 USING SPIKED SOILS AND NATIVE SOILS

     - QUANTITATION

     - CHROMATOGRAPHIC QUALITY

• COMPARISON AND STATISTICAL EVALUATION OF RESULTS
 OBTAINED USING THE SINGLE EXTRACTION / NO CLEANUPS /
 GC-ECD PROCEDURES WITH RESULTS OBTAINED FROM STANDARD
 EPA METHODS

-------
DETERMINATION OF ORGANOCHLORINE PESTICIDES
     EPA/PMRMA
        WEIGH SOIL
      ADD EXTRACTION
        SOLVENTS
    SHAKE OR SONICATE (X3)
        CENTRIFUGE
       WATER WASH
       EXTRACT/DRY
     CONCENTRATE EXTRACT
       ALUMINA COLUMN
         CLEANUP
       SULFUR CLEANUP
                    EXTRACT IN A/S VIALS
                      GC/ECD ANALYSIS

-------
DETERMINATION OF ORGANOCHLORINE PESTICIDES
     EPA/PMRMA               SHELL WRC
                                                            tL
        WEIGH SOIL
           I
      ADD EXTRACTION
        SOLVENTS
    SHAKE OR SONICATE (X3)
        CENTRIFUGE
       WATER WASH
       EXTRACT/DRY
     CONCENTRATE EXTRACT
           I
       ALUMINA COLUMN
         CLEANUP
       SULFUR CLEANUP
  WEIGH SOIL
 ADD EXTRACTION
   SOLVENTS
SHAKE OR SONICATE
                   EXTRACT IN A/S VIALS
                     GC/ECD ANALYS 8

-------
UJ
u>
       PROCEDURE FOR DETERMINATION OF ORGANOCHLORINE PESTICIDES IN SOIL
        WEIGH
         SOIL:
         5-20 g
ADD 1:1
ACETONE
 HEXANE
 5-25 ml_
VORTEX
 1 min
SONICATE
  5 min
CENTRIFUGE
   5 min
            ESTIMATED PQL: 1-10 PPB
                                         ANALYZE
                                         GC/ECD
                      A SECOND COLUMN IS USED FOR CONFIRMATION
                                              TRANSFER
                                               EXTRACT
                                                TO A/S
                                                 VIAL

-------
U)
           DETERMINATION OF SELECTED ORGANOCHLORINE PESTICIDES
                                     IN SOIL
            PROJECT REQUIREMENTS AND GOALS
            DEVELOPMENT OF SINGLE EXTRACTION PROCEDURE
V DEVELOPMENT OF SPLIT AND SPLITLESS ANALYSES

       - >10 fjg/kg

       - <10 fjg/kg

• EVALUATION OF NEED FOR CLEANUP STEPS FOR SOIL EXTRACTS
 USING SPIKED SOILS AND NATIVE SOILS

     - QUANTITATION

     - CHROMATOGRAPHIC QUALITY

• COMPARISON AND STATISTICAL EVALUATION OF RESULTS
 OBTAINED USING THE SINGLE EXTRACTION / NO CLEANUPS /
 GC-ECD PROCEDURES WITH RESULTS OBTAINED FROM STANDARD
 EPA METHODS

-------
*>.
u>
          GAS CHROMATOGRAPHIC PROCEDURES
                COLUMN:
             1. DB-17, 30 m X 0.32 mm, 0.25 urn. J&W
             2. DB-1701, 30 m X 0.32 mm, 0.25 jum. J&W
   CARRIER GAS:  He
   MAKE-UP GAS:  P-10
   SAMPLE SIZE:  1-3/A.
   DETECTOR:    ECD


SPLIT METHOD

 •  ISOTHERMAL
 •  10 - 10,000 jug/kg
                                    SPLITLESS METHOD
                                         PROGRAMMED
                                         1 - 1,000 A/g/kg

-------
ON
               SPLIT INJECTION METHOD WITH INTERNAL STANDARD

          CHROMATOGRAMS (GC-ECD) OF A SERIES OF STANDARDS FROM
          0.04 TO 4 PPM EACH
                                                     h.
                      HEPTACHLOR

                      (INT. STD.)
           2.0
4.0
6.0
9.0
10.0
12.0   14.0    16.0   19.0    RT

-------
U)
                          SPLITLESS INJECTION METHOD


                CHROMATOGRAMS (GC-ECD) OF SELECTED STANDARDS
                  <.0.0
               :>
               E
               ± 20.0
                 16.0
                 12.0 -
                                            ALDRIN   ISODRIN
                 28.0
                 2V 0
                        10/yg/L

                         1 A/g/L
15.0        20.0


    T i me (to i nut es)
                                                                  25.0

-------
oo
           DETERMINATION OF SELECTED ORGANOCHLORINE PESTICIDES
                                    IN SOIL
            PROJECT REQUIREMENTS AND GOALS
            DEVELOPMENT OF SINGLE EXTRACTION PROCEDURE
            DEVELOPMENT OF SPLIT AND SPLITLESS ANALYSES
V EVALUATION OF NEED FOR CLEANUP STEPS FOR SOIL
  EXTRACTS USING SPIKED SOILS AND NATIVE SOILS

       - QUANT/TAT/ON

       - CHROMATOGRAPHIC QUALITY

• COMPARISON AND STATISTICAL EVALUATION OF RESULTS
 OBTAINED USING THE SINGLE EXTRACTION / NO CLEANUPS /
 GC-ECD PROCEDURES WITH RESULTS OBTAINED FROM STANDARD
 EPA METHODS

-------
 COMPARISON OF RESULTS OF SPIKED SOILS
   SIMPLE PROCEDURE VS. EPA APPROACH
SAMPLE ID
    1
    2
    3
    4
    5
    6
    7
    8
    9
   10
EPA METHOD 8080
     PPM
      35
      37
      35
      41
      35
      38
      36
      30
      32
      21
SHELL APPROACH
     PPM
      33
      38
      35
      38
      34
      39
      36
      29
      30
      20

-------
<0
0.
Q. C
D  0)
CD  T3
 CD
•t->
<*—
 CO

 V)
 co
 c
                        10
                   
-------
•











3 	
RESULTS OF FIELD SOIL SAMPLES
SAMPLE ID EXTRACT
A NONE
WASHED
AL COLUMN
SULFUR
B NONE
WASHED
AL COLUMN
SULFUR
C NONE
WASHED
AL COLUMN
flf^V SULFUR
\\l/\
WA
\.sf D NONE
WASHED

•
AL COLUMN
I
M
ALDRIN
PPB
180
195
166
200
359
349
250
360
1600
1500
1800
1400
26
20
21


	 C
BEFORE AND AFTER CLEANUP STEPS
ISODRIN
PPB
11
12
15
14
15
15
16
14
50
60
19
25
1
1
1


DIELDRIN
PPB
1420
1430
1450
1400
2460
2450
2500
2625
10000
7800
9600
9700
160
140
150


ET;? m
147 ^H
142 ^^1
150 ^H
150 ^H
180 ^1
177 ^H
180 ^^1
194 ^M
600 ^1
700 ^H
640 ^H
680 ^H
8 ^1
8 ^H
8 B
r


-------
to
3 	


RESULTS OF FIELD SOIL SAMPLES BEFORE
SAMPLE ID EXTRACT
E NONE
WASHED
AL COLUMN
F NONE
WASHED
AL COLUMN
SULFUR
G NONE
WASHED
AL COLUMN
SULFUR
m\
\U/x3 H NONE
^M WASHED
AL COLUMN
SULFUR
1
ALDRIN
PPB
<1
<1
<1
13
12
13
11
26
22
19
21
1040
1060
1010
930
ISODRIN
PPB
<1
<1
<1
8
7
11
11
8
8
11
12
47
55
110
98

AND AFTER
DIELDRIN
PPB
2
2
5
300
280
280
280
280
260
260
260
23000
23100
22600
22200
	 c
CLEANUP STEPS
•

-------
                            Results after cleanup steps
                           for selected field samples
    Thousands, PPB TOTAL DRINS
30 -fl
          NONE
                                       \
                               8       9
                             SOIL SAMPLE ID
                         15
WATER WASHED
AL COLUMN
              17
      20
SULFUR

-------
fc
                            SPLITLESS INJECTION  METHOD


                    COMPARISON OF CHROMATOGRAMS OBTAINED
                    BEFORE AND AFTER  CLEANUP PROCEDURES

               Selected  Isometric Plots
              300-
              250-
              200 -
              100 -
341 0-6"
ACETONE/HEXANE EXTRACT
WATER WASHED '
AL COLUMN
                                          tt
                                          a
                        6.0
                              _i—i—L—
                                 10.0
                                          1B.O        20.0

                                               Time  (minutes)
                                                              28.0
                                              Aldrin:    22 ppb

                                              Isodrin:   1  ppb

                                              I JiolcJrin   1 r;0 ppb

                                              Endrin:   8  ppb
                   From Top to Bottom: acetone/hexane extract, water washed extract,
                   alumina cleanup extract

-------
                 SPLITLESS INJECTION METHOD


         COMPARISON OF CHROMATOGRAMS OBTAINED

         BEFORE AND AFTER CLEANUP PROCEDURES


      Selected Isometric Plots
             221 0-6"
             ACETONE/HEXANE EXTRACT
             WATER WASH
             AL COLUMN DF-2
             SULFUR CLEAN UP DF-2
               s.o
                        10.0
                                 1B.O       20.0


                                     Time  (minutes)
                                                    20.0
                                                         Aidrin:    200 ppb


                                                         Isodrin;   13 ppb


                                                         Dieldrin:  1400 ppb


                                                         Endrin:   150 ppb
From Top to Bottom: acetone/hexane extract, water washed extract, alumina cleanup
extract, sulfur cleanup extract, Note dilution factors

-------
Os
                           SPLITLESS INJECTION METHOD


                   COMPARISON OF CHROMATOGRAMS OBTAINED

                   BEFORE AND AFTER CLEANUP PROCEDURES
                Selected Isometric Plots
                           NE/HEXANE EXTRACT
                           WASH
                        AL COLUMN DF-2
                        SULFUR CLEAN UP
                            350 ppb


                            15 ppb


                            2500 ppb


                            180 ppb
                         8.0
                                 10.0
                                           16.0
     20.0

Time (minutes)
                                                             25.0
           From Top to Bottom: acetone/hexane extract, water washed extract, alumina cleanup
           extract, sulfur cleanup extract. Note dilution factors

-------
                SPLITLESS INJECTION METHOD

         COMPARISON OF CHROMATOGRAMS OBTAINED
         BEFORE AND AFTER CLEANUP PROCEDURES

     Selected Isometric Plots
    210-
    180-
    160-
    120-
              5.0
                      10.0
                               18.0
                                         80.0

                                    Time (minutes)
Aldrin:   22 ppb

Isodrin:  10 ppb

Dieldrin: 270 ppb

Endrin:   50 ppb
From Top to Bottom: acetone/hexane extract, water washed extract, alumina cleanup
extract, sulfur cleanup extract, Note dilution factors

-------
oo
           DETERMINATION OF SELECTED ORGANOCHLORINE PESTICIDES
                                     IN SOIL
            PROJECT REQUIREMENTS AND GOALS

            DEVELOPMENT OF SINGLE EXTRACTION PROCEDURE

            DEVELOPMENT OF SPLIT AND SPLITLESS ANALYSES
               - >10/jg/kg
           • EVALUATION OF NEED FOR CLEANUP STEPS FOR SOIL
            EXTRACTS USING SPIKED SOILS AND NATIVE SOILS
               - QUANTITATION
               - CHROMATOGRAPHIC QUALITY
           V COMPARISON AND STATISTICAL EVALUATION OF RESULTS
             OBTAINED USING THE SINGLE EXTRACTION / NO CLEANUPS /
             GC-ECD PROCEDURES  WITH RESULTS OBTAINED FROM
             STANDARD EPA METHODS

-------
           Summary of analyses of soil samples using Shell WRC methods
           and analysis at a contract laboratory. Drins in ug/kg (ppb)
SAMPLE
ID
METHOD
ALDRIN
ISODRIN   DIELDRIN
ENDRIN
1 121 (0-6")


2 121 (6-12")


3 221 (0-6")


4 222 (0-6")


5 242D (0-6")


6 242D (6-12")


7 321 (0-6")


8 341 (0-6")


9 341 (6-12")


10 421 (0-6")


HiSM
LOSM
CLM
HiSM
LoSM
CLM
HiSM
LoSM
CLM
HiSM
LoSM
CLM
HiSM
LOSM
CLM
HiSM
LOSM
CLM
HiSM
LoSM
CLM
HiSM
LOSM
CLM
HiSM
LoSM
CLM
HiSM
LoSM
CLM
20
18
9
ND, <20
<1
3
130
140
140
64
77
70
200
250
200
ND, <20
1
ND, <3
3800
1600
5000
38
27
21
ND, <20
<1, <1
ND, <3
160
180
180
ND, <20
1, <1
ND, <2
ND, <20
ND, <1
ND, <2
ND, <20
9
ND, <10
ND, <20
5
ND, <4
ND, <20
13
ND, <20
ND, <20
1
ND, <2
50
50
ND, <400
ND, <20
1
ND, <2
ND, <20
ND, <1
ND, <2
ND, <20
9
42
170
140
60
ND, <20
2
3
1020
1400
850
430
420
400
1810
2500
1800
65
45
29
>5000
10000
24000
220
160
160
ND, <20
2
ND, <2
2200
3300
2400
ND, <20
11
7
ND, <20
ND, <1
3
140
140
110
53
44
60
150
160
95
ND, <20
1
ND, <2
440
600
ND, <500
ND, <20
9
18
ND, <20
ND, <1
ND, <2
360
430
300
HiSM: RELATIVELY HIGH CONCENTRATION SHELL METHOD, SRC 9W37/89R
LOSM: TRACE SHELL METHOD, SRC 9W38/89R
 CLM: CONTRACT LABORATORY

NOTE: EACH SET OF RESULTS OBTAINED FROM ANALYSIS OF INDEPENDENT
      SOIL EXTRACTIONS
                                    449

-------
           Summary of analyses of soil samples using Shell WRC methods
(CONT'D)   and analysis at a contract laboratory. Drins in ug/kg (ppb)
SAMPLE
ID
METHOD    ALDRIN
ISODRIN   DIELDRIN    ENDRIN
11


12


13


14


15


16


17


18


19


20


421 (6-12") HiSM
LoSM
CLM
422 (0-6") HiSM
LoSM
CLM
422 (6-12") HiSM
LoSM
CLM
423 (0-6") HiSM
LoSM
CLM
423 (6-12") HiSM
LOSM
CLM
423D (0-6") HiSM
LoSM
CLM
423D (6-12") HiSM
LoSM
CLM
442 (0-6") HiSM
LOSM
CLM
531 (0-6") HiSM
LOSM
CLM
531 (6-12") HiSM
LoSM
CLM
32
60
36
460
600
400
65
72
120
ND, <20
10
8
26
13
ND, <3
ND, <20
4
7
ND, <20
26
ND, <3
100
80
63
250
400
280
940
1000
970
ND, <20
6
ND, <8
25
10
40
ND, <20
7
ND
ND, <20
5
ND, <2
ND, <20
7
ND, <2
ND, <20
3
ND, <4
ND, <20
7
ND, <2
40
7
ND, <8
ND, <20
19
ND
90
50
ND
560
840
520
2500
3600
2200
440
560
480
320
290
200
230
290
78
110
62
200
305
270
55
1660
15OO
780
4100
5800
3800
>11000
23000
9900
90
93
56
130
170
74
<20
28
12
240
200
130
60
170
46
46
30
110
220
60
26
200
110
74
850
800
600
2310
2900
1700
HiSM: RELATIVELY HIGH  CONCENTRATION  SHELL METHOD,  SRC  9W37/89R
LoSM: TRACE  SHELL METHOD,  SRC  9W38/89R
 CLM: CONTRACT LABORATORY

NOTE: EACH SET OF RESULTS  OBTAINED FROM ANALYSIS OF  INDEPENDENT
      SOIL EXTRACTIONS
                                  450

-------
    Correlation plots of results  of analysis  of soils
     using Shell  WRC method and  EPA method.
DRINS IN SOIL: CONTRACT LAB/SHELL
      PPM TOTAL DRINS
 EPA METHOD RESULTS (CONTRACT LAB)
 0  2 4 6 8 10 12 14 16 IS 20 22 24 26 28 30
     SHELL METHODS AVERAGE RESULTS

 • SOIL SAMPLES —THEORETICAL LINE
DRINS IN SOIL: CONTRACT LAB/SHELL
  PPM TOTAL DRINS, <7 PPM ONLY
                                         EPA METHOD RESULTS (CONTRACT LAB)
0 0.5 1  1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7
    SHELL METHODS AVERAGE RESULTS

  • SOIL SAMPLES — THEORETICAL LINE

-------
(0
                            BOX AND WHISKER PLOT


          COMPARISON OF LOG OF SUM OF DRINS OBTAINED USING NO

          SAMPLE CLEANUP (SHELL) AND WITH SAMPLE CLEANUP

          (CONTRACT LAB, EPA METHOD)
                13 —
             jf^^  5
             0)
             (0


             I  .
             CO
             CeL
                -3 -
               -11  —
                    S I
                                   :* o.
                         iB-:0B^Q.,B:A :
                         i    ;  B|f  i B!
!  ON  !
                            ,



                            % \\
                                        Sample

         The first box plot of each pair summarizes 6 analysis done by Shell for each sample.

         The second box summarizes the 3 analysis done by the Contract Lab for each sample

-------
ADVANTAGES OF SIMPLE EXTRACTION PROCEDURE
•  DISPOSABLE SAMPLE EXTRACTION VIALS (VOA's)
•  ELIMINATION OF CROSSCONTAMINATION PROBLEMS
•  MINIMUM SAMPLE HANDLING
•  LABOR SAVINGS: NO WASHING OF GLASSWARE
•  LABORATORY SPACE SAVINGS
•  NO SOLVENT EXCHANGE
•  REDUCTION OF TURNAROUND TIME
•  NO DELETERIOUS EFFECT TO GC COLUMNS OR ECD DETECTORS
•  COST SAVINGS (~1/3 CHEAPER)
•  TIME SAVINGS

-------
         DETERMINATION OF "DRINS"
           MARCH 88 TO JUNE 89
  BIODEGRADATION, 739 (55%)
THERMAL & CHEMICAL
TREATMENTS, 539 (40%)
                                 OTHER, 20 (1°:.)

                                 THERMAL DESORPTION, 53 (4%)
                 - SPIKED SOILS
                 - RMA SOILS
                 - SEDIMENTS
                 - SPIKED WATER
                 - BRINY LIQUIDS
                 - IMPINGER FLUIDS
          TOTAL NUMBER OF SAMPLES: 1351

-------
SHELL RESEARCH COMPLEX METHOD SERIES


                         SHELL DEVELOPMENT COMPANY
                      ENVIRONMENTAL ANALYSIS DEPARTMENT

                             Determination of

         ALDRIN,  ISQDRIN, DIELDRIN AND ENDRIN IN SOIL BY SPLIT INJECTION
          CAPILLARY GAS CHROMATOGRAPHY WITH ELECTRON CAPTURE DETECTION
                    Hazardous  materials   used   in   this
                    method  are  designated  (*CAUTION*)  in
                    the  REAGENTS  and  PROCEDURE  sections.
                    A  current  Material Safety Data  Sheet
                    (MSDS)    for     each    material    so
                    designated, as  well  as for  all  other
                    chemicals  and   reagents,  should   be
                    reviewed  before proceeding  with  this
                    method.  Operations which  may present
                    a  hazard  are  given   in  the  UNUSUAL
                    OPERATIONAL HAZARDS section.
SCOPE
     1.   This gas  chromatographic  method describes the  determination of the
chlorocyclodiene pesticides Aldrin, Isodrin, Dieldrin and Endrin (collectively
referred  to  as   "Drins"   in  this  method)  in  soils.    The  method   involves
extraction followed by analysis of the extract by capillary gas chromatography
with electron  capture detection. The method  has been applied  to  spiked soil
samples as well as contaminated soil samples in a range of concentrations from
0.01 Mg/g  (ppm)   to  100 /zg/g  (ppm).  Samples  with  percent  concentrations  of
"Drins" can be analyzed by this method after appropriate dilutions.

METHOD SUMMARY

     2.   A  weighed  portion  of  soil   is  extracted  with  a  mixture of  1:1
acetone/hexane. The samples are placed in either a) a horizontal shaker for at
least 4 hours, or  b)  sonicated  using a  probe  for 5-10 minutes for extraction.
The  extracts  are  analyzed by  capillary  gas  chromatography  with  the  use  of
electron  capture  detection   (GC-ECD).   Separation   is   done  using  a  high
resolution fused silica capillary column with bonded methylphenyl-polysiloxane
phase  (DB-17).   The  internal   standard  method of  calibration is  used.  This
method was  developed for  the determination  of  "Drins"   in  laboratory spiked
soil samples  to  evaluate  remediation technologies.  The method  has  also been
applied to the analysis of moderately to highly contaminated  soil samples.

UNUSUAL OPERATIONAL HAZARDS

     3.   Caution  should  be  exercised  in handling  all  samples containing the
type of toxic components  being  determined by  this method. Handle all  samples,
extracts  and  calibration  solutions  in   a  well  ventilated  hood   and  use
appropriate gloves for hand protection.


                                  455

-------
     4.   Current health  hazard  data indicates  that  Aldrin and  Dieldrin are
known  carcinogens.  Heptachlor is  a  suspected carcinogen.  Presently,  Isodriint!
and Endrin  are  classified as highly  hazardous  based on  compounds  of simitar
structure. It is recommended that all of these compounds be handled with equal
precautions.

     5.   The solvents used for extraction, acetone and hexane, are flammable..

INTERFERENCES

     6.   Any compound  with the  same chromatographic  retention time  as the
compounds   of   interest   will   interfere   with  the   analysis.  A   seconudl
chromatographic  column  with  different  polarity from  the one  used  in  thiis
method may  be  used  for  confirmation. Alternatively,  gas chromatography/nass
spectrometry analysis of  the samples may  be carried out  to  confirm compotamdi
identification.

     7.   Sample  extracts  may  be  screened  prior  to  addition  of  internal
standard to ensure  that  there are no coeluting  peaks in  the  sample  with the
internal standard.

APPARATUS

     8.   (a)    Gas  chromatograph  -  Hewlett-Packard  5880a  or  equivalent,
equipped  with  an  electron capture  detector, capillary  injector  with  glass
liner packed with Pyrex wool.

          (b)    Chromatographic Column - Fused silica capillary column, 30 m I
0.32  mm  methylphenyl-polysiloxane  (DB-17)   bonded   phase of 0.25  /an  film
thickness (J&W Corporation).

          (c)   Chromatographic data  system  - Capable  of  on-line  electronic
integration of  chromatographic data. VG  Multichrom  data system is  used for
this method.

          (d)   Vials - VGA vials (40 ml) with caps with Teflon lined septa.

          (e)   Transfer pipettes, glass

          (f)   Autosampler  - Hewlett-Packard  7673a  Robotic Arm Autosampler or
equivalent.

          (g)   Autosampler vials

          (h)   Horizontal  shaker - Eberbach Corporation or equivalent.

          (i)   Ultrasonic  Processor  - Heat  Systems-Ultrasonics,  Incorporated!
Model W-385 or equivalent.

          (j)  Centrifuge  - IEC Centra-7,  International Equipment Company.

          (k)  Balance - Capable of weighing  to  the nearest 0.1 mg.
                                    456

-------
          (1)  Vortex Mixer - Maxi Mix 1,  Thermolyne or equivalent.

REAGENTS

     9.   (a)  Acetone  (*CAUTION*).  Baxter,  Burdick  & Jackson, B&J  Brand™,
High Purity Solvent.

          (b)  Hexane (*CAUTION*) . Baxter, Burdick  &  Jackson,  Hexane  UV,  High
Purity Solvent.

          (c)  Chromatographic grade air,  hydrogen,  and helium.

          (d)  Aldrin. (*CAUTION*). 99.0% purity,  Chem Service.

          (e)  Isodrin.  (*CAUTION*). 99.0% purity, Chem Service.

          (f)  Dieldrin. (*CAUTION*). 99.0% purity,  Chem Service.

          (g)  Endrin. (*CAUTION*). 98.0% purity,  Chem Service.

          (h)  Heptachlor.  (*CAUTION*). 98.0% purity,  Chem Service.

PROCEDURE

     10.  (a)  Instrumental parameters

               The gas  chromatograph  is  operated  according to the  parameters
listed  in Table  1.  The VG Multichrom  data system  acquisition  method  file is
included in Appendix A.

          (b)  Standard preparations

               (1)  "Drins" standards - Standards  are prepared by weighing out
appropriate  amounts  of  each  "Drin"  and  then diluting  by  volume  with  the
extraction solvent mixture (1:1  acetone/hexane) .  Typical  concentration of the
stock  solution  is  100-1000 /ig/mL  (ppm).  The  stock  solution is  then  used for
preparation  of the calibration  standards in  the  range of 0.01 ng/ml to 10
               (2)  Internal  standard  -  The  internal  standard  used  in  this
method  is  Heptachlor.  A  stock  solution is  prepared  by weighing  out  the
appropriate amount  of Heptachlor and diluting  by volume  with  the  extraction
solvent  mixture  (1:1  acetone/hexane)   to  obtain  a   100-1000  pg/mL  (ppm)
solution.  This  stock  solution  is  diluted  accordingly  to  obtain  a  working
internal standard solution of Heptachlor with a concentration level  of 1/ig/mL.

     Note 1:    The  concentration  level  of 1-ng/mL for the  internal  standard
solution was  chosen  because  most  of  the samples for which  the method  was
developed were at  this  concentration level in  solution. The  concentration of
the internal   standard  solution should be  in  the same  concentration  range of
the  samples   for  best  results,  thus  it  should  be adjusted  accordingly  as
needed.


                                  457

-------
     Note 2:   Sample  extracts  may  be  screened  prior  to  addition   of  the
 internal  standard  to ensure that there  are  no other compounds  in  the sample
 that elute with the  same retention time as Heptachlor.
               (3)  _
 (1:1)  with  the  l^g/mL
 "Drins" standard  level
 Figure  1  shows  a
 internal standard.
 Calibration  standards
     internal
     is  mixed
chromatogram
	      Each  standard  level  is  mixed
 standard  solution.  Typically,  3  ml of  each
 with  3 mi  of the  internal  standard  solution.
 of  a   nominal  1  fig/mi  "Drins"  standard  with
     Note 3:   It  should  be  noted  that  the  actual  concentrations  of  a
calibration standard are half of  the  indicated  values  since it is prepared by
mixing  equal   volumes  of  a  "Drins"   standard with  the  internal  standard
solution.  This dilution is  not  indicated  because  soil extracts are similarly
mixed with  equal  volumes  of the internal  standard  solution  and  are diluted
also by half.  Therefore, this dilution cancels out and is not  indicated to the
data system.

          (c)   Sample preparation

               (1)  Weigh a portion of soil sample (1-20 grams) in a VOA vial.

               (2)  Add 10-20 ml of 1:1 acetone/hexane.

     Note 4:   For customer spiked samples where approximate concentrations of
the "Drins" are known, the soil  weights and extraction volumes can be adjusted
accordingly to  place most  of  the  samples  in  the middle  of  the  calibration
curve to minimize uncertainty in  quantitation.  For example,  soil  samples with
"Drins" concentration range  of  0.01 to 1  /ig/g  are  extracted  1:1  (10-20  g of
soil with 10-20 ml of extractant). For soils ranging  in "Drins" concentrations
from 0.1-20 /ig/g,  1-5  g of  soil  are  extracted  with  10 ml  of  extractant.  For
soils ranging  in  "Drins"  concentrations  from  20-100 /ig/g,   1 g  of  soil  is
extracted with 25 ml of extractant.  The extracts can  also be diluted as needed
for higher "Drins" concentrations. Homogeneity of the soil  sample must also be
considered in selection of  sample size.  For visibly  heterogeneous samples, at
least 5-10 g of  soil  may  be needed with subsequent dilutions  of  the extracts
as needed.

     Note 5:   It is recommended  that  for samples containing  "Drins"  below 1
/ig/g, the analysis  be  done  using a  splitless  injection  method  documented
separately.

               (3)  Extract samples by either a) shaking for  at least 4 hours
using a horizontal shaker,  or b) sonication for 5-10  minutes.

               (4)  Centrifuge for 5 minutes at 2000  RPM if necessary.

               (5)  Take a portion of the extract and mix (1:1) with a portion
of the internal  standard solution (Heptachlor, 1 ng/mi).  Vortex mix briefly.

               (6)  Tranfer  to  an  autosampler  vial   and   analyze  by  gas
chromatography using parameters  listed  in  Table 1.  Typical chromatograms  are
shown in Figures 1-3.
                                      458

-------
          (d)  Data  collection  -  Data  is  collected  by  means  of a  level  4
Hewlett-Packard 5880A integrator and/or by VG Multichrom Data System. The data
system  is  used   for calibration,  quantitation  and  reporting  of  results.
Appendices  A-C  include  data  acquisition  method,  calibration  and  a  sample
sequence files.

CALCULATIONS

     11.  Calculations are  done using  an  internal  standard method based  on
peak areas. The VG  Multichrom  data system allows the  operator  to  select from
several curve fit options. The operator can  test different curve fits until  an
appropriate fit of  the data  is obtained.  Typically,  linear fits as  well  as
polynomial fits (up to third order) with a correlation coefficient of 0.999 or
better are required. Visual  display of the calibration curves is quite helpful
for inspection of curve fit. Figure 1  shows  a  typical  analysis  report  for one
of the calibration  standards. The  calculated concentrations  for the  standards
are compared to the prepared concentrations  to  diagnose curve fit.  Information
on sample weights,  extraction volumes  and dilutions  (if any) are entered into
the VG data system before the samples  are analyzed. The data system identifies
the presence of "Drins"  by retention time,  calculates the  concentration of the
"Drins" in the extracts  from the corresponding  calibration curve, then applies
the necessary weight/volume corrections. Figure  2  shows a quantitation report
for a  soil  sample containing Aldrin  and Dieldrin. Figure 3  shows  a  series  of
isometric plots for analysis of "Drins"  standards from  "0.05-4/ig/mL  typical
calibration  curves   for  each   "Drin".   Figures  4-7  show  the   individual
calibration curves  obtained from the analysis  of these calibration standards.
Analysis  reported   in Figures   1-2 were  quantitated  using  these  calibration
curves. Figure 8 shows isometric plots of a  series of Dieldrin standards.

     12.  The VG  Multichrom  data  system  method for data acquisition  and
calibration files  are included in Appendices A-B.


     13.  Calculations can also  be done  by  plotting  the  ratio  of  area counts
obtained from the analysis  of  a series of standards for  each compound  to the
area counts of the  Heptachlor  internal standard versus concentration  of each
level   of  each "Drin". The  concentration of Heptachlor  is  constant  in  both
calibration standards and samples and  does not need  to be taken into account.
The ratios  of the  area  counts  obtained  for each compounds detected  in  the
sample to  the  area counts  of  the  Heptachlor  internal  standard added  to  the
sample  are  then  used to read  off the  calibration  curve  the  corresponding
concentration  of  a  given  "Drin"   in  the   sample.  A calibration  curve  is
constructed for  each "Drin".  Once the  concentration  of the  "Drin"   in  the
extract is  determined,  the  concentration  in  the  soil can  be  calculated  as
follows:


                           Cone. "Drin"      Extraction        Dilution
     Concentration         in extract     X   Volume        X   Factor
     of a "Drin"            (/xg/mL)            (ml)              (If any)
     in a soil  sample  =
     (M9/9)                           Weight of soil  sample (g)


                                  459

-------
EVALUATION OF METHOD

     14.   The method was tested  by  spiking known amounts of  "Drins"  in clean
reference  soil.  Recoveries  are 95%  or  better.  The  limit  of detection  is
estimated to be 0.01 /ng/g.  The limit of detection can be lowered by decreasing
the split ratio and increasing the sample injection size.

     15.   Standard  EPA  methods  involve  water washing  of  the  acetone/hexane
extracts  to  remove polar compounds  and  acetone, drying  of the  extract  with
sodium sulfate  followed  by  clean-up  through  an  activated  alumina  column.
Twenty contaminated  soil  samples were analyzed  using  the simple  extraction
described in this  method and the chromatograms were compared to those obtained
after each additional  clean-up step. The results indicated that for these soil
samples,  it is not  necessary to perform these time  consuming  clean-up steps.
In addition, the method uses all disposable glassware and eliminates potential
cross-contamination.

REFERENCES

     16.   a)   M.  E. Wilcox and C.  C.  Chou, "Determination of Chlorocyclodiene
Insecticides in Soil by a Simplified Method",  MRS January, 1988.

          b)   EPA  Method  3550,  "Sonication  Extraction",  Test  Methods  for
Evaluating Solid Wastes, SW 846, Vol.  IB, 3rd. Edition,  1986.

          c)   EPA  Method  8080,  "Organochlorine Pesticides  and  PCBs",  Test
Methods for Evaluating Solid Wastes. SW 846, Vol. IB, 3rd. Edition, 1986.

          d)   EPA  Method   8270,  "Gas  Chromatography/Mass  Spectrometry  for
Semivolatile  Organics:   Capillary   Column   Technique",   Test   Methods   for
Evaluating Solid Wastes, SW 846, Vol.  IB, 3rd. Edition,  1986.
Westhollow Research Center
I. A. L. Rhodes
R. Z. Olvera
March 21, 1989
                                   460

-------
Gas Chromatograph:

Column:



Carrier gas:

Make-up gas:

Split Ratio:

Sample size:

Injector:

Detector:

Column program:


Chart speed:

Attenuation:

Threshold:

Peak width:
          Table 1


Instrumental Parameters


Hewlett-Packard 5880a

J&W, fused silica capillary column 30 m X 0.32 mm
ID, 0.25 pm film thickness (methylphenylsiloxane)
DB-17.

Helium, 10.5 Psig.

P-10 (10% Methane/Argon) 30 ml/min.

100:1

1 ML

200°C

Electron Capture, 350°C

215°C, isothermal. Hold for 20 minutes.
Post analysis bakeout to 265'C for 10 min.

Icm/min

24

3

0.04
                                  461

-------
 [GW-HWJ  12 WRCZJ^dUy, / , 1
 Reported on 17-MAR-1989  at 10:20

                                 Injection Report

 Acquired on  5-MAR-1989  at 12:35
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 Sample Name
 Sample Id
 Sample Type
 Bottle No
                Tin* (ninuteil


:  1.00 PPM  + I.S.
•
•
:  Standard   Amount-1.00000
:  7
             PEAK  INFORMATION
Peak RT mins
1 5.993
2 7.078
3 8.864
4 13.571
5 16.762
Residual
Total
Area uVs
110147
88310
118897
82175
103788
0
503317
Calculated
PPM Peak name
HEPTACHLOR
1.16 ALDRIN
1.60 ISODRIN
1.06 DIELDRIN
1.55 ENDRIN
N/A
5.37
Prepared Concentration
ppm
1.05
1.18
1.64
1.08
1.57


Figure 1:    Chromatogram and Quantitation Report for a "DRINS" Calibration Standard.
                                   462

-------
[GW-HW] 12 WRC232809,18,1
Reported on  6-MAR-1989 at 10:21

                               Injection Report

Acquired on  5-MAR-1989 at 16:44
                      z
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25.0
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Sample Id
Sample Type
Bottle No
             Tin* (ninutit)

LR 019432 -  8-3
19396-37-4
Sample    Amount-1.00000
18
             PEAK  INFORMATION
Peak RT mins
1 5.989
3 7.076
5 13.569
Residual
Total
Area uVs
110931
85498
47626
52974
244056
PPM

27.9
15.4
N/A
43.442
Peak name
HEPTACHLOR
ALDRIN
DIELDRIN


          ReP°rt f°r a Sofl  S«"1e-
                                                          01e,drin Here
                                463

-------
Analysis  View  -  Screen copy.     Reported on 15-MAR-1989
Chromatogram  :  12 WRC232809,7,1
     BO. 00
     60.00
     40.00
     20,00
     HEPTACHLOR

     (INT. STD.)
          2.0
4.0
6.0
9.0
10.0    12.0    14.0    16.0    10.0   RT
            Figure 3: Isometric Plots of a Series of "DRINS" Standards from 0.04 to 4 /zg/mL
                   Heptachlor Internal Standard 1s 1.05 /zg/mL.

-------
                          SHELL WRC  ENVIRONMENTAL  ANALYSIS VG SYSTEM
Os
          Calibration Name :  12  232809.
          CALIBRATION  FOR  DIELDRIN  ANALYSIS BY SPLIT  ISOTHERMAL  GC
          Peak  :  ALDRIN
  3.5


  3.0


  2.5


£2.0
3

jg 1.5
k

  1.0


  0.5


  0.0
                                                        Page  1  (of  1)

                                                 Calibration leyel_plpt_
                                                             3
                                    _ J_J	1 — I—I —L—1
                                 1.0       1.5
                                            Amount  (PPM)
          Constant
          1st  degree
          2nd  degree
          3rd  degree
      Figure 4
-0.02696
0.66145
0.08446
-0.00643
                                             Curve fit
                                             Coeff of determination
                                             Standard error
Cubic
1.01032
0.12168
                                                           on 15-MAR-!9e9 at 12:

-------
                    SHELL  WRC ENVIRONMENTAL ANALYSIS VG SYSTEM
   Calibration  Name :  12 232809.
   CALIBRATION FOR DIELDRIM ANALYSIS  BY SPLIT ISOTHERMAL GC
   Peak :  ISODRIN
o.o1-
                                                        Page  1  (of  1)
                                                 Calibration level plot
                                                             3
                                                                        _ I	•_  -t	• !
                                      .u. . i	1	»
                                            4.0
        0.0
1.0
2.0           3.0
    Amount (PPM)
   Constant
   1st degree
   2nd degree
   3rd degree
-0.02830
0.61729
0.07787
-0.00685
Figure 5
                      Curve  fit
                      Coeff  of determination
                      Standard error
                                    Cubic
                                    1.00801
                                    0.14373
                                           Reported on  15-MAR-1989 at  12: 48

-------
                     SHELL  WRC ENVIRONMENTAL ANALYSIS VG SYSTEM

    Calibration  Name :   12 232809.
    CALIBRATION FOR DIELDRIN ANALYSIS  BY SPLIT ISOTHERMAL GC
    Peak :  DIELDRIN
  2.5
  2.0
in
> 1.5
ID
0)

< 1.0
  0.5
  0.0
         0.0
                                                            3.5
                                       Amount  (PPM)
    Constant
    1st degree
    2nd degree
    3rd degree
-0.01784
0.75716
-0.00174
0.00107
Curve fit
Coeff of determination
Standard error
Cubic
1.00919
0.09109
                                            Reported on 17--MAR-1989 at 13: 51

-------
                          SHELL WRC  ENVIRONMENTAL ANALYSIS  VG SYSTEM
Os
oo
          Calibration Name :  12  232809.
          CALIBRATION FOR DIELDRIN  ANALYSIS BY SPLIT ISOTHERMAL GC
          Peak  :  EHDRIN
       3.5-
                                                       Page 1  (of 1)
                                                 Calibration level plot
                                                            3
                                            Amount (PPM)
          Constant
          1st  degree
          2nd  degree
          3rd  degree
-0.03079
0.65087
0.00431
-0.00012
Curve fit
Coeff of determination
Standard error
Cubic
1.01248
0.12915
                                                  Reported on  I5-MAR-1989  at  12: 49
       Figure 7

-------
                        SHELL  WRC ENVIRONMENTAL  ANALYSIS  VG SYSTEM
      Selected  Isometric  Plots
  to
  c
  0)
  +J
  c
       1

       3

       5
                          Page  1  (of  1)
                            3   RuHIchrort)
BOO
700
600
BOO
400
300
200
100
0


—

—
-
—
-
(








V








I

















V





Extraction
Solvents









V.



, , I
.0 a.o a.





0




1



—







—







Heptachlor
, (Int. Std.) |
1.05 ppm I

1

Dieldrin

.__ 6.3 ppm
II
I 11 4.2 ppm
A 2.1 ppm
A
A 1.05 ppm
A^ 0.53 ppm
yv 0.21 ppm
1 1 > 1 1 4 1 1 1 1 1 1 I
g.o 12.0 is.o la.o 21.0
                                          Time  (minutes)
[GW-HW]   12 WRC227005. 14. 1

[GW-HW]   12 WRC227005. 16. 1

[GW-HW]   12 WRC227005.  5, 1
2

4

6
[GW-HW]

[GW-HW]

[GW-HW]
12 WRC227005. 15. 1

12 WRC227005. 4. 1

12 WRC227005, 6. 1
                                                Reported on 23-NOV-1988 at 12: 48
Figure 3:  Isometric  Plots of a Series of Die'c^in Stancla^'.?.

-------
SHELL RESEARCH COMPLEX METHOD SERIES


                         SHELL DEVELOPMENT COMPANY
                     ENVIRONMENTAL ANALYSIS DEPARTMENT

                             Determination of

 TRACE AMOUNTS OF ALDRIN, ISODRIN. DIELDRIN AND ENDRIN IN SOIL BY SPLITLESS
  INJECTION CAPILLARY GAS CHROMATQGRAPHY WITH ELECTRON CAPTURE DETECTION

                    Hazardous  materials   used   in   this
                    method are designated "(*CAUTION*)" in
                    the Reagents  and Procedure sections.  A
                    current  Material   Safety  Data  Sheet
                    (MSDS)    for    each    material    so
                    designated, as  well  as for  all  other
                    chemicals  and  reagents,   should  be
                    reviewed  before  proceeding  with  this
                    method.  Operations which  may present
                    a  hazard  are  given   in  the  UNUSUAL
                    OPERATIONAL HAZARDS section.

SCOPE

     1.   This gas  chromatographic  method describes  the  determination of the
chlorocylodiene pesticides Aldrin,  Isodrin, Dieldrin  and Endrin (collectively
referred  to  as   "Drins"   in  this  method)  in  soils.    The  method   involves
extraction followed by analysis of the extract by capillary gas chromatography
with electron  capture detection.  The method  has been applied  to  spiked soil
samples as well as contaminated soil samples in a range of concentrations from
0.001 fig/9 to  1 /xg/g. Soil  samples  with  concentrations higher than 1 /zg/g may
be analyzed by this method after dilution.

METHOD SUMMARY

     2.   A  weighed  portion  of  soil  is extracted  with  a  mixture  of  1:1
acetone/hexane. The samples are placed in either a) a horizontal shaker  for at
least 4 hours, or  b)  sonicated using  a  probe  for 5-10 minutes for extraction.
The  extracts  are  analyzed by capillary  gas  chromatography  with  the  use of
electron  capture   detection   (GC-ECD).   Separation   is   done  using  a  high
resolution fused silica capillary column with bonded methylphenyl-polysiloxane
phase  (DB-17).   The  external  standard  method of  calibration is  used. This
method  was  developed  for the  determination  of "Drins"  in  soil   samples to
evaluate remediation  technologies.

UNUSUAL OPERATIONAL HAZARDS

     3.   Caution  should  be exercised in  handling  all  samples containing the
type of toxic  components  being determined by  this method. Handle all  samples,
extracts  and  calibration  solutions  in  a  well  ventilated  hood   and  use
appropriate gloves  for hand protection.

     4.   Current  health hazard   data  indicates that Aldrin  and  Dieldrin are
known  carcinogens.  Heptachlor is a suspected  carcinogen.  Presently,  Isodrin

                                       470

-------
-and Endri/i  are  classified as highly  hazardous  based on compounds  of similar
 structure. It is recommended that all  of these compounds be handled with equal
 precautions.

      5.   The solvents used for extraction, acetone and hexane,  are flammable.

 INTERFERENCES

      6.   Any compound  with the  same chromatographic  retention  time  as  the
 compounds   of   interest   will   interfere   with   the   analysis.   A   second
 chromatographic column  with  different polarity  from  the  one  used   in  this
 method may  be  used  for  confirmation. Alternatively,  gas  chromatography/mass
 spectrometry analysis of  the samples  may  be carried out to  confirm  compound
 identification.

 APPARATUS

      7.   (a)   Gas  chromatograph  -   Hewlett-Packard  5880a  or  equivalent,
 equipped with  an   electron capture detector,  capillary  injector  with  glass
 liner packed with  Pyrex  wool.

           (b)   Chromatographic Column - Fused silica capillary  column, 30 m X
 0.32  mm methylphenyl-polysiloxane(DB-17)  bonded  phase  of  0.25  urn  film
 thickness (J&W  Corporation).

           (c)  Chromatoqraphic data  system  -  Capable  of  on-line  electronic
 integration  of  chromatographic  data.   VG  Multichrom data  system  is  used  for
 this method.

           (d)  Vials - VOA vials  (40 ml) with caps with Teflon lined septa.

           (e)  Transfer  pipettes,  glass

           (f)  Autosampler - Hewlett-Packard 7673a Robotic Arm Autosampler  or
 equivalent.

           (g)  Autosampler vials

           (h)  Horizontal  shaker  -  Eberbach Corporation or  equivalent.

           (i) Ultrasonic  Processor -  Heat  Systems-Ultrasonics, Incorporated
 Model  W-385  or equivalent.

           (j) Centrifuge  - IEC Centra-7,  International  Equipment Company.

           (k) Balance - Capable  of  weighing to the  nearest 0.1 mg.

           (1) Vortex Mixer - Maxi Mix 1,  Thermolyne  or equivalent.

 REAGENTS

     8.    (a) Acetone (*CAUTION*).  Baxter,  Burdick &  Jackson,  B&J  Brand™,
 High Purity  Solvent.


                                  471

-------
          (b)  Hexane (*CAUTION*). Baxter, Burdick  &  Jackson,  Hexane UV, High
Purity Solvent.
          (c)  Chromatographic grade air, hydrogen, and helium.

          (d)  Aldrin. (*CAUTION*). 99.0% purity, Chem Service.

          (e)  Isodrin. (*CAUTION*). 99.0% purity, Chem Service.

          (f)  Dieldrin. (*CAUTION*). 99.0% purity, Chem Service.

          (g)  Endrin. (*CAUTION*). 98.0% purity, Chem Service.

PROCEDURE

     9.   (a)  Instrumental parameters

               The gas  chromatograph  is  operated according  to the parameters
listed in Table  1.  The VG  Multichrom  data system acquisition  method file is
included in Appendix A.

          (b)  Standard preparations

               Standards are  prepared  by weighing out  appropriate amounts of
each "Drin"  and  then diluting by  volume with the  extraction  solvent mixture
(1:1 acetone/hexane). Typical concentration of the  stock solution is 100-1000
/jg/ml_  (ppm).  The  stock  solution  is  then  used  for  preparation  of  the
calibration  standards  in   the  range  of  1   /ig/L  to   1000  ng/l.  Multilevel
calibration is essential since the electron capture detector response is often
nonlinear.

          (c)  Sample preparation

               (1)  Weigh  a portion of  soil sample  (10-20 grams)   in  a  VGA
vial.

               (2)  Add 10-20 ml of 1:1 acetone/hexane.

               (3)  Extract samples by either a)  shaking for at least 4 hours
using a horizontal shaker, or b) sonication for 5-10 minutes.

               (4)  Centrifuge for 5 minutes at 2000 RPM if necessary.

               (5)  Tranfer  to  an  autosampler   vial   and  analyze  by  gas
chromatography using  parameters  listed in Table  1.  Typical  chromatograms are
shown in Figures  1-3.

          (d)  Data  collection  -   Data  is collected  by means  of  a level  4
Hewlett-Packard 5880A integrator and/or by VG Multichrom Data  System. The data
system  is  used  for  calibration,  quantitation  and   reporting  of results.
Appendices A-C include the data acquisition method, a calibration  and a  sample
sequence files.
                                    472

-------
CALCULATIONS

     10.  Calculations are done  using  external  standard calibration  based  on
peak areas. The VG  Multichrom  data system allows the operator  to select from
several curve fit options. The  operator can test different curve fits until  an
appropriate fit of  the data is  obtained. Typically, linear fits as well  as
polynomial  fits  with  a   correlation  coefficient  of  0.999  or  better  are
required.  Visual  display  of  the  calibration  curves  is  quite helpful  for
inspection of curve fit.  Figure  1  shows  a typical analysis  report  for  one  of
the calibration standards. The  calculated concentrations for the standards are
compared to the prepared  concentrations  to diagnose  curve  fit.  Information  on
sample weights, extraction volumes  and dilutions (if any) are entered into the
VG data system before the samples are analyzed.  The data system identifies the
presence  of  "Drins" by retention  time,   calculates  the concentration  of the
"Drins" in the extracts from the corresponding calibration curve, then applies
the necessary weight/volume corrections.  Figure 2  shows a  quantisation  report
for a  soil  sample.  Figure 3  shows  isometric plots obtained  from the analysis
of  "Drins"  standards.  Figures  4-7  show  the  individual  calibration  curves
obtained  from  the  analysis  of calibration  standards   in  the  range  of 1-500
mg/L.   Analysis   reported   in   Figures  1-2  were  quantitated   using   these
calibration curves.

     Note 1;   It is recommended that  calibration  be  performed  with standards
bracketing the  samples  in concentration. For example:  if  the  sample extracts
range  in  concentration  from not detected  to 0.020 /wj/L,  then  it  is best  to
include in the calibration curve standards with similar range (ie. 0.001-0.020
/jg/L). Including in the calibration all of the standards (0.001-1 pg/L)  is not
recommended since it  is not  needed and this would only add  to  uncertainty  of
the measurement because the electron capture  detector  response  is linear over
a limited concentration range.

     11.  The  VG  Multichrom  data  system  method  for  data acquisition  and
calibration files are included  in Appendices A-B.


     12.  Calculations can also  be done  by plotting the  area  counts obtained
from  the  analysis  of a  series of  standards  for each  compound  versus  the
respective  "Drin"  concentration   in  each  standard  level.  The area  counts
obtained for each compounds  detected  in  the sample are then used to read off
the calibration curve the corresponding concentration of a given  "Drin"  in the
sample.  A  calibration  curve   is   constructed  for  each   "Drin".  Once  the
concentration of the "Drin" in  the  extract is determined, the concentration in
the soil can be calculated as follows:


                           Cone. "Drin"      Extraction        Dilution
     Concentration         in extract    X   4/olume        X   Factor
     of a "Drin"           (jig/L)            (L)               (If any)
     in a soil sample  =
     (pg/g)                          Weight of soil sample (g)
                                   473

-------
EVALUATION OF METHOD

     13.  The method was tested  by  spiking  known amounts of  "Drins"  in clean
reference  soil  and  with contaminated  soil   samples.  Recoveries  are  95%  or
better. The limit of detection is estimated  to be 0.001 /jg/g.

     14.  Standard  EPA  methods  involve  water washing  of the  acetone/hexane
extracts to  remove  polar compounds  and  acetone, drying  of the  extract  with
sodium  sulfate  followed  by  clean-up  through  an  activated  alumina  column.
Twenty  contaminated  soil samples were  analyzed  using  the simple  extraction
described in this method and the chromatograms were compared to those obtained
after each additional clean-up step. The results indicated that for these soil
samples, it  is not  necessary to perform these time  consuming  clean-up steps.
In addition, the method uses all disposable  glassware and eliminates potential
cross-contamination   Figure  8  shows  the chromatograms of  the  acetone/hexane
extract of a contaminated soil  sample. Also  included are  the  chromatograms of
the  same extract  after water  washing  and   after  passing the  water  washed
extract through activated Alumina. There are  no  differences  in  the quality of
the chromatograms.

REFERENCES

     15.  (a)  M. E. Wilcox and C. C. Chou,  "Determination of Chlorocyclodiene
Insecticides in Soil by a Simplified Method", MRS January, 1988.

          (b)  EPA  Method   3550,  "Sonication  Extraction",  Test  Methods  for
Evaluating Solid Wastes, SW 846, Vol. IB, 3rd. Edition, 1986.

          (c)  EPA  Method  8080,  "Organochlorine Pesticides  and  PCBs",  Test
Methods for  Evaluating Solid Wastes, SW 846,  Vol. IB, 3rd. Edition, 1986.

          (d)  EPA  Method   8270,  "Gas  Chromatography/Mass  Spectrometry  for
Semivolatile  Organics:   Capillary   Column   Technique",   Test   Methods   for
Evaluating Solid Wastes, SW 846, Vol. IB, 3rd. Edition, 1986.
Westhollow Research Center
I. A. L. Rhodes
R. Z. Olvera
T. E. Vipond
M. E. Wilcox
March 21, 1989
                                    474

-------
                                   Table 1
Gas Chromatograph:

Column:



Carrier gas:

Make-up gas:

Split Ratio:

Sample size:

Injector:

Detector:

Column program:



Chart speed:

Attenuation:

Threshold:

Peak width:
Instrumental Parameters


Hewlett-Packard 5880a

J&W, fused silica capillary column 30 m X 0.32 mm
ID, 0.25 Mm film thickness (methylphenylsiloxane)
DB-17.

Helium, 10.5 Psig.

P-10 (10% Methane in Argon) @ 30 ml/min.

Splitless. Then after 0.5 min, 80 mL/min.

1 ML

200'C

Electron Capture, 350'C

60*C hold for 0.5 min, program at 20'C/min to 215°C,
Hold for 30 min at 215*C. Post analysis bakeout to
265*C for 10 min.

Icm/min

24

3

0.04
                              475

-------
[GW-HW] 12  LR19396-29B,20,1
Reported on 21-MAR-1989 at 10:32

                                Injection Report

Acquired on  2-MAR-1989 at 04:32
     -'>- '
  "H   .  i

  I"  :•>•
                            &
                            o
      t   llll
      I—i
                   2
                   a
                   j
                   ui
                                        2
                                        Q
        -0>-
                                                5'J.U
Sample  Name
Sample  Id
Sample  Type
Bottle  No
             line inmutiil

10PPB 4DRINS

Standard  Amount-1.00000
20
PEAK INFORMATION Prepared
Peek RTrrarE 1
2 13.831
5 15.756
8 20.738
ID 24.053
IfeidLal
Tttal
itftvl/
31284
7fg?J
12034
11445
12960
82992
Ateaifyfe
147305
138039
89605
1CQJB30
84841
476779
~ , uoncentra i iun
Calc
Effl Efeakrene ppb
n.l fflXON "•»
14.7 jaiKlN 16-4
10.4 1 HH 1 KIN 10.8
15.1 EMHIN 15.7
NA
51.4
vfidth
4.3
4.8
7.2
8.5


PF slfTR W
132L3.4659
9377.3055
8534.7715
6724.7993


j^U^
0.0000
0.0000
0.0000
0.0000


      i:   ehre-tor- and qwtltttton Report for a •OMB- Calibration Standard.
                                   476

-------
IGW-HWJ  12 LR19396-29B,3,1
Reported on 21-MAR-1989 at 13:41

                                 Injection Report

Acquired on  l-MAR-1989 at 11:42

130
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-------
                            SHELL  URC  ENVIRONMENTflL flNflLYSIS  Vij SYSTEM

       Hnatysis Name •   [GU-HW]  12 LR19396-24.19.1.
       MuIt i chrom
       DETERMINflTION  OF DRINS  IN SOIL  EXIRPCTS BY SPLITLESS GC-ECl'
   40.0
   36.0
   32.0
   28.0
   24.0
£  20.0 -
   16.0 -
   12.0 _
                                      ALDRIN    ISODRIN
                                                         DIELDRIN
      —A-	1 JV	lJU
      A-JLJl
                                                                   ENDRIN
                                                                 	A	
                                   1  1   1  1
                                                         A.
                                                            Page 1  (of I)
                                                                 Mult Ichrom
                                                                                        -10 ng/L_
0.0
                  5.0
10. 0
15.0          20.0
      T ime (m inut est
                                                                    25.0
                                                   30.0
                                                                                         35.0
       Instrument     t
       Channel  Title i  Channel  a 12
       Lims  ID        t
       Required on  18-FEB-I989  at  05,00
       Reported on  16-MRR-19S9  ?t  }f».\7
                         Method        :  OR IN
                         Calibration   ,  DRIN
                         Run Sequence  i  DRIN
Fiourp V   !<;omr>t-Hr

-------
                         SHELL  WRC ENVlRONMENTflL  flNflLYSIS VG  SYSTEM

     Calibration  Name  i  12 DRIN.
     DETERMINflTION  OF  DRINS  IN SOIL EXTRPOS  BY  SPLITLESS  GC-ECO
     Peak ,  flLDRIN
                                                              . t_
                                                 Page 1  (of I)

                                         Callbracioii  level plot
  600
  500
  400
o
"300

_p
«o200
•

  100
                        100
200
     300
Amount IPPB)
AOO
500
600
     Constant    •  7.79825E+2
     1st  degree  •  1.38161E+4
     2nd  degree  i  -6.76714
                Curve  fit                i  Quadratic
                Coeff  of  determination   i  0.99992
                Standard  error           ,  3.09208E+A
                Reported  on  21-MRR-1989  at  08i52

-------
00
o
                                   SHELL  URC ENVIRONMENTflL flNflLYSIS  Vij bYSTEM

               Calibration  Name  i  12 DRIN.
               DETERMI NOTION  OF DRINS  IN SOIL EXTRACTS BY SPLITLESS GC-ECD
               Peak ,  ISODRIN
                                               U
                                 Page  I  (o f  1)
                          Calibration level plot
                                                                                                           900
                                                       flmount 
              Constant   ,  -4.222208E+4
              1st degree i  1.23152E+4
              2nd degree i  -4.71631
Curve fit                i  Quadratic
Coeff of determination  i  0.99989
Standard error          i  4.18238E+4
Reported on 21-MRR-1989 at  08i52
         Figure 5

-------
oo
                                   SHELL WRC ENVIRONMENTRL flNRLYSIS  VG SYSTEM

               Calibration  Name  i  12 DRIN.
               DETERMINOT ION  OF  ORINS  IN SOIL EXTRftCTS BY SPLITLESS GC-ECD
               Peak ,  DIELDRIN
            65A -
                                              Page 1  (of 1)
                                       Calibration level plot
                                   100
200             300
      Amount  (PPB)
400
500
               Constant   • -1.780815E+4
               1st degree • 1.02786E+4
               2nd degree • 2.681A 1
             Curve fit                i  Quadratic
             Coeff of  determination  i  0.99995
             Standard  error           i  2.56285E+4
             Reported  on  21-MRR-I989  at  08t53

-------
00
to
                                  SHELL URC  ENVIRONMENTAL  flNflLYSIS  VG SYSTEM

              Calibration Name  •  12  DRIN.
              DETERMINOTION OF DRINS IN SOIL EXTRACTS BY SPLITLESS GC-ECD
              Peak ,  ENDRIN
           708
           590
           472
         o
           354
           236
         CE
           118
                                                        Page 1  (of 1)

                                                Calibration  level plot
                              100
200
300
     400
Amount (PP6)
500
600
700
800
              Constant    i  -1.886063E+4
              1st  degree  •  7.96342E+3
              2nd  degree  i  0.95070
                      Curve fit               i  Quadratic
                      Coeff of determination  i  0.99996
                      Standard error          i  2.50020E+4
                      Reported on 21-MRR-1989 at 08,54
          Figure 7

-------
CO
U)
                                SHELL  WRC ENVIRONMENTAL ANAI YS1S  VG SYSTEM

               Analysis Name :   [GW-HW]  12 LR19396-24, 3. 2.
               Multichrom
               DETERMINATION OF DRINS IN SOIL EXTRACTS  BY SPLITLESS GC-ECD
                                                                       Page  1  (of  1)
                                                                           Multichrom
             0.0
160

140
~ 120
6
> 100
•M
rt
in
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-M
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M
60

40

on
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-
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ALDRIN
0.04 wg/g



j

A. 1
VM
UvJl



.1
i . NUL 	
	 iilC 	
^f*-WJu». » ».. JL. i*^- ..._u_^i_^





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ISODRIN
0.02 /ig/g
I _ »_ «.
JL^ ^ x

DIELDRIN
0.20 jig/9
^


3. WATER WASHED EXTRACT PASSED THROUGH
ALUMINUM COLUMN

2. WATER WASHED EXTRACT
1. ACETONE/HEXANE EXTRACT
ENDRIN
/0.005 M9/9
..At -
A _yv ^ ^^
.AAI..-.I...— II./W.,
          5.0
10.0
15.0        20.0
     Time  (minutes)
25.0
30.0
35.0
                              Channel  #12
Instrument
Channel Title
Lims ID
Acquired on  16-FEB-1989  at
Reported on  17-FEB-1989  at
                                          22: 59
                                          12: 31
                      Method
                      Calibration
                      Run Sequence
                           DRIN
                           DRIN
                           DRIN
   Figure 8:  Comparison of Chromatograms Obtained After Sample Cleanup Procedures,

-------
484

-------
                                        MR. MCCARTY:  The one thing this meeting lacks
is  an official T-shirt, so we have  chosen a design which, for those of you who were here
Tuesday, there is a lovely picture of Bill out here sampling with a caption that reads, "Hi, I am
from EPA, and I am here to help."

             Any of those who are  interested, please leave your card or give your name to
Tony.  We have another 200 on order. This is the prototype, but we thought that...yeah, it will
fit, just barely.

                                        MR. TELLIARD:   Thanks, Harry.

                                        MR. MCCARTY:   The original slide is in a safe
deposit box with instructions to be delivered to The Washington Post if I don't make it home this
year.

                                        MR. TELLIARD:  You know, the last T-shirt went
to  Bob Metz for...what was that one?  That was for 304(h), yeah. I guess that puts me in the
same old category? Yeah, I know.

             The next  set of speakers  are  going  to be  talking basically about matrix
interferences, problems, and issues.

             The Office of Water has put out a guidance package that is presently in circulation
dealing with matrix problems and some suggestions on both corrective actions that could be taken
as  well as an outline for the user community as to what type of information and data to collect
for supporting their issues or claims  that there is a matrix problem. Many of the matrix problems
that the Agency is facing is the fact that many  of the  dischargers send their samples out, they
come back, the detection limit can't be met, and with  no supporting data, they then solicit the
Agency for some sort of waiver, and,  of course, we have a number 5  which,  of course, we can't
make any real judgment to.

             So,  the  document does  lay  out a check sheet of things that either you,  as
laboratories, should make available to your clients or you, as clients, should get from your
laboratories. These are floating around the back. If we run out, we can send more out, and they
are available.

             Following along that line, Zhouyao Zhang from the Chemistry Department at the
University of Waterloo is going to discuss that now.  Thank you.
                                         485

-------
486

-------
                                         MR.  ZHANG:    Good  morning.   Before  my
presentation, I would like to thank my collaborator, Miss Karen Buchholz, and my supervisor,
Dr. Pawliszyn, for their contribution to this work.

              I  would  also  like  to  thank Supelco, Varian, and the Natural Science  and
Engineering Research Council of Canada for the financial support.

              In this presentation, I will introduce to you a new extraction technique called solid
phase microextraction or SPME. I will also discuss what is SPME and how it works.

              The main topic will  be  focused on how can we deal with the matrix interference
in SPME.  There are mainly two types of matrix interferences.  One is when you extract the
targeted organic compounds, you also extract hundreds  or sometimes even thousands of non-
targeted organic compounds which will cause interference in your analysis.

              Another major interference  at work is a matrix which absorbs the analytes very
strongly so you cannot get a very good recovery,  and it will affect the accurate quantitation.

              I will also discuss briefly how can we use some matrix effects to our advantage.

              Solid phase microextraction  or SPME uses a fiber coated with a polymeric coating.
This coating here has a strong affinity toward organic compounds. So, the analytes will partition
between the sample matrix and the coating.

              Due  to the strong affinity of the coating toward organic compounds, the organic
compound will be absorbed by the  coating, and then, as the fiber is directly transferred into the
GC injector for thermal desorption and analysis.

              The extraction process of SPME is very simple and time efficient and also can be
easily automated. Another very important  element in our SPME is that it completely  eliminates
the solvent both for the  extraction and the injection.

              In the SPME device, the fiber is connected with a stainless steel tubing to increase
the fibre's mechanical strength.  This assembly is  contained in this syringe for easy operation.

              When you do the SPME sampling, you first withdraw the fiber  into the syringe
needle, and the syringe needle is used to punch through the sample vial septum. Then, the fiber
is lowered into the  vial  by pressing down the plunger so the  analytes will be absorbed by the
fiber coating through the partitioning process.

              So,  as you  can see, in the  SPME  process,  we combine the extraction,  the
concentration (because of the strong affinity of the fiber coating), and the injection into a single
process.
                                          487

-------
             There are two ways to do the SPME extraction. One way is direct sampling. That
is, you put the fiber into a liquid sample such as an aqueous sample.  The analytes in the aqueous
matrix will be partitioned between the fiber coating and the aqueous matrix.  The amount of the
analytes absorbed by the coating will be directly related to the volume of the coating  and the
partition coefficients of the analytes between the coating and the aqueous phase.

             Also, these parameters can be easily modified through the design of the  fiber.

             This direct  sampling has been  working very successfully in analyzing  volatile
organic compounds from aqueous samples.  We have published more than a dozen papers on this
subject.

             But direct sampling has its limitations. The main limitation will be you cannot
use the direct sampling to extract analytes from a solid or very complex matrix, because the fiber
is very fragile and could easily be broken.

             Another way to do the SPME sampling would be to sample the analytes from the
headspace above the sample matrix. In this way, we can sample the analytes virtually from any
matrix, because the fiber is not in contact with the sample matrix.

             Sampling analytes from the headspace, as we all know, is not a new idea. It has
been used very extensively to extract volatile components from food or beverage or  volatile
pollutants from the environmental samples.

             But the  conventional headspace method has its problems. One problem is the
sample has a portion  of gas injected into  the GC column.  So, some of the oxygen  and the
moisture will get into a column.  It will degrade your stationary phase and shorten the column's
lifetime, or you will need some kind of device to remove the oxygen or moisture and make  your
whole system very complicated.

             Another thing is that conventional headspaces don't have the concentration effect.
So, only volatile compounds can be sampled and the sensitivity is usually low.

             But the headspace SPME has a premium asset,  so we  sought to eliminate these
problems. We use the fiber coating which is hydrophobic, and it has a very high affinity toward
the organic compounds.

             Due to  these two properties,  the headspace SPME  can extract  trace target
compounds but not moisture and oxygen.

             This is  an example of the headspace SPME sampling.  This is an extraction time
profile.  We can see that the system equilibrates in about 2 minutes.  So, practically, the temp
sampling time will be  2 minutes, because sampling 2 minutes  and  10 minutes will not make a
difference. The sampling is very efficient.


                                          488

-------
              Another thing is that it has also a very good sensitivity.  For example, for the o-
xylene, 1 ppm o-xylene, more than 50 ng of analyte has been absorbed by the fiber coating and
then transferred into the GC column.  So, if we use MS as a detector, it is capable to detect pg
of analytes, so we can detect parts per trillion analytes in the matrix.

              This is 0.1 ppm PAH in an aqueous sample, sampled from the headspace at room
temperature.   We can see the  naphthalene and anthracene each equilibrate in  less than 10
minutes, but for phenanthrene and chrysene, it will take quite a long time to reach  equilibration,
but between 20 and 30 minutes, a substantial amount of analyte has already been absorbed by
the fiber coating.

              So, if we use some kind of timing device or use isotopic labeled compounds as
internal standards, we can still very efficiently quantitate these analytes.

              This is 1 ppm BTEX in a soil matrix.  This is in sand. It was also sampled from
the headspace at  a moderate temperature, about 50  degrees. And  again the sampling is very
efficient.  The sampling time is less than 1 minute, and the sensitivity is also very good. This
is o-xylene, so more than 50 ng having been absorbed by the fiber coating.

              This is  a  40 ppb PAH in sand  being sampled by  headspace SPME at room
temperature.

              This is several chlorinated organic  compounds in three matrices at 5 ppb level
sampled from the headspace. We can see good detection limit and precision.  Most precisions
are below 10 percent.

              This is an example of using the headspace SPME  to analyze  a real PAH
contaminated soil sample. We used isotopic labeled PAH as an internal standard.  We were able
to quantitate 0.23 ppm benz[a]anthracene and the chrysene.

              So, these  results clearly show the headspace SPME can isolate volatile and
semivolatile compounds from various matrices, but if the matrix absorbs analytes very strongly,
the amount of analytes that exist in the headspace  will be low, that will affect the sensitivity of
this headspace SPME method.

              But there are ways to solve these matrix problems.  One simple way is to sample
the analytes at a higher temperature.

              By heating the sample,  we speed up the mass transfer of the analytes and release
more analytes into the headspace.  At the higher temperature, we also  increase the volatility of
the analytes.   Both of these effects will increase the existing of analytes in the headspace and
increase their concentrations in the headspace.   Thus, we can improve the  sensitivity of the
headspace  SPME method.
                                          489

-------
             This is an example of the temperature dependence of 1 ppm BTEX in soil. At
room temperature, the sensitivity is quite low. As we increase the temperature, we can see the
sensitivity improve quite significantly.

             When we further increase the temperature, the sensitivity starts to decrease. The
reason for that is while you increase the  temperature, you increase the concentration in the
headspace, but at the higher temperature, the fiber coating is also starting to desorb some  of the
analytes. So, you have a competing process.

             So, you need to be careful to choose an optimum temperature.

             This  is the  same for the clay matrix.   At about 50 degrees,  you achieve the
optimum sensitivity.

             But  even at the optimum sensitivity,  we can see  the  amount  of the analyte
absorbed by the coating is still low if we compare it to the aqueous example.

             The problem,  as I mentioned, is because the coating starts to desorb some  of the
analytes at high temperature. So, if we can heat the sample matrix to a higher temperature while
keeping the fiber coating at a reasonable temperature, it is going to improve the sensitivity.

             We designed an experiment called the heat-cooling experiment.  What we did is
we heated the sample to 140 degrees centigrade, then put it into a zero degree ice water bath, and
immediately put the  fiber into the sample,  and do  an extraction time profile.

             You can see at about 5 seconds, we achieved a maximum sensitivity.  The point
here is the sensitivity at the optimum temperature.  So, you see  a dramatic improvement in
sensitivity.

             This is the temperature dependence of the PAHs in sand.   You can see for the
relatively volatile PAHs, there was an optimum  temperature at about 50 degrees  before the
increased temperature decreases the sensitivity, but for the less volatile PAHs like phenanthrene,
chrysene, and perylene, increased temperature will increase the sensitivity.

              This effect is  very important, because we can use this effect to do some kind of
temperature differentiation.  We can sample a volatile compound at a lower temperature while
sampling less volatile ones at a higher temperature. So, we can reduce the interference between
compounds.

              Temperature is not the only  means we can use to solve this matrix problem. One
very important advantage for the SPME technique is we cannot only improve our extraction
efficiency by changing extraction media, we can also actually modify the matrix.
                                          490

-------
              As we all know, in the Soxhlet or in the supercritical fluid extraction, what we can
do is to change the solvent or add a modifier. In other words, changing the extraction media.
We can do the same  for the headspace SPME by changing the coating. We can use a more
selective coating to extract  a certain category of analytes and use another coating to extract
another category of analytes.

              For example,  the polydimethylsiloxane coating can be used very successfully to
extract BTEX and PAHs, but polydimethylsiloxane cannot extract phenols very well. If we use
a polyacrylate coating to extract phenols, it works very well.

              So, coating selectivity is also a way to reduce the interference from non-targeted
compounds.

              Besides this coating  selection, we  can actually modify the matrix.  This is an
example of 1 ppm BTEX in clay.  It is also a comparison.  It is a very interesting experiment.

              At room temperature, you can see the sensitivity is very low. At the optimum
temperature of 50 degrees Centigrade, the sensitivity increases. Then we add 10 percent of water
into the clay matrix, and you can see the further improvement of the sensitivity. With 30 percent
of water, the sensitivity is the same as that with 10 percent of water.

              When you  further increase the water to  50 percent, (50 percent means you
basically cover all the matrix with water), the sensitivity starts to decrease.

              This is another example, the PAH in the sand.  At 50 degrees, we cannot detect
chrysene.  With 15 percent of water, now we can detect chrysene.  At 100 degrees, we cannot
detect perylene. By adding  15 percent of water, we now  can  detect perylene at 100 degrees.

              For the soil # 7, (this soil # 7 has 30 percent of sand, 30 percent of clay, and 4
percent of organic carbon content), you can see the improvement of the limit of detection by
adding some water here.  Also, you can see the improvement of the limit of detection in clay
sample as well.

              BTEX in all four matrices have a limit of detection at the  ppt level.

              Increasing temperature and adding water works well for the solid matrix. So, what
about the aqueous matrix?  Well, we can modify the aqueous matrix as well.

              One simple modification is the use of a very old technique, salt-out, using the salt-
out effect.

              This is 1 ppm BTEX in aqueous matrix.   The extraction was  done from the
headspace. The white bar is BTEX extracted from the water without salt.  The black bar is
                                          491

-------
BTEX extracted from water with saturated salt. You can see the significant improvement when
salt was added.

              We  can also  modify the matrix pH values  in the aqueous  sample.  This is
extraction of phenols. This is direct sampling, that is, you put the fiber into an aqueous sample,
not sampling from'the headspace. The white bar is for our control sample, pH of 7, no salt. The
black bar is for pH=2 and saturated with salt. You can see a dramatic increase of sensitivity for
all the phenols.

              The coating used here, as I mentioned, is polyacrylate.

              With the help of pH  and  salt,  we can actually sample the  phenols from the
headspace. More interestingly, some of the phenols sampled from the headspace here have got
better sensitivity.

              This is another interesting experiment. We spiked some phenols into a sewage
sample, then do the sampling, direct sampling. Some of the phenols have very bad recovery.

              So, we saturate this sewage sample with salt and adjust the pH to 2.  Then we can
achieve a very good  recovery.

              So, what does this experiment tell us? If we are analyzing phenols  from various
aqueous samples like river water or waste water or drinking water, what we can do is we  adjust
the pH, salting it out to basically overwhelm the matrix, or, in other words,  you normalize the
matrix so you can achieve a very consistent recovery for all the aqueous samples.

              In summary, by  sampling  analytes from the headspace, we extend this SPME
technique to sample very  complex matrices and soil matrices.  Through  the temperature and
matrix modification,  we can help to release analytes from the matrix that absorbs analytes very
strongly.

              We can also use some kind of matrix normalization to achieve a more consistent
recovery and better precision, or we can, through a temperature differentiation and the use of
coating selectivity, reduce the interference from the non-targeted compounds.

              Thank you all for your attention.
                                          492

-------
                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD:  Do we have any questions?

                                       MR. COCHRAN: Jack Cochran, Hazardous Waste
Center.  Considering that you probably don't have an inert atmosphere in your sample vial and
you elevate the temperature sometimes as much as 150 degrees C,  are you worried that the
stationary phase on the fiber will break down under those conditions?

                                       MR. ZHANG:  Oh, no, the fiber is actually used for
GC coating, so it is stable at about 300 degrees.

                                       MR. COCHRAN:  But you do have oxygen in the
sample vial, and you have it hot.  I was just concerned that maybe the phase would break down.

                                       MR. ZHANG:  We did extensive experiments, and
the fiber can be used sometimes for a hundred times and it won't break down.

                                       MR. CROWLEY:  Ray Crowley, Millipore.  You
have shown a lot of work on sensitivity and limit of detection.  Do you have any plans to do an
actual accuracy study, let's say to compare your methodology with something like EPA 525? My
concern is that you have tremendous matrix interferences here that will impact the quality of
results.

                                       MR. ZHANG:  Oh, yes, we are actually...one person
is right now doing head-to-head comparison of SPME with purge and trap. We also plan to do
a lot of comparison experiments in the future.

             We have done a lot of experiments in the aqueous samples like Method 624 and
525, a lot in the aqueous samples.

             This headspace method to extract analytes from the solid matrix is just beginning.
I just show you some of the ways we can do. Certainly, we are going to do a lot of experiments
to compare with the others to show whether this method has advantages or not.

                                       MR. CROWLEY: Do you want to predict how long
it would take to calibrate your system for a 50-analyte component mixture?

                                       MR. ZHANG:   That  is  a difficult  question.
Basically, this type of technique can be used two ways. One way to use it is to rapid screening.
If you have hundreds of compounds and you want to see whether they exist or not, you just use
this technique to do it very easily.
                                        493

-------
             The other one is to do accurate quantitation.  It depends how accurate you want
it.

             Suppose you have 50 compounds.  You need to divide them into several groups
using compounds with relatively comparable partition coefficients as internal standards.

             If you want to do it very accurately, then you will have to use isotopically labeled
internal standards to match each compound of interest.

                                       MR. CROWLEY:  Thanks.

                                       MR.RISSER: Nelson Risser, Lancaster Labs. What
is the mechanical life of the fiber? How rugged is this system?

                                       MR. ZHANG:  The  fiber usually can last quite a
long time.

                                       MR. TELLIARD:  How many analyses?  Do we
know?

                                       MR. ZHANG:  What do you mean?

                                       MR. TELLIARD:  How many analyses?

                                       MR. ZHANG:  Oh, usually if you analyze volatile
compounds, you desorb at 200 degrees like I did, it can last more than a year. You can do it
hundreds of times, but I guess sometimes if the sample is very complicated, then you are likely
to have some kind of interference compounds.  Then you want to desorb at higher temperatures.
You probably will shorten the fibre's lifetime.

             But it just won't be a problem.  Once you try it,  you will know it won't be a
problem.

                                       MR. RISSER:  Well, with that fiber sliding inside
the  needle, isn't there a mechanical wear on the fiber as you continue to use it over time?

                                       MR.  ZHANG:   You  can continuously  use  it.
Supelco is making this syringe right now. I did not bring it. It is just like an ordinary syringe,
but you have a fiber inside, so you can push it down with your  plunger and expose  the fiber.
Then you pull up the plunger  and withdraw the fibre inside the needle.

                                       MR. RISSER:  But don't you rub the liquid coating
off of the fiber as you use the fiber?
                                         494

-------
                                      MR. ZHANG:  Liquid coating has a very high
viscosity so it won't come off.  It is just the kind of coating.

                                      MR. RISSER: Okay.  What do your blanks look
like for volatiles?

                                      MR. ZHANG: Blanks?

                                      MR. RISSER: Blanks, system blanks.

                                      MR. ZHANG:   It depends on  the desorption
temperature.  For the volatiles, it is very clean.

                                      MR. RISSER: Okay, thank you.

                                      MR. TELLIARD:  Thank you very much.
                                       495

-------
496

-------
ELIMINATION OF MATRIX INTERFERENCES IN
      SOLID PHASE MICROEXTRACTION
Zhouyao Zhang, Karen Buchholz, and Janusz Pawliszyn

             Department of Chemistry
     Waterloo Centre for Groundwater Research
             University of Waterloo
            Waterloo, Ontario, Canada
             FINANCIAL SUPPORT

                    Supelco
                    Varian
                    NSERC

-------
oo
                          OUTLINE






What is SPME?




What is headspace SPME?




How do SPME and headspace SPME deal with matrix interferences?



    Can SPME reduce the interferences from non-target compounds?



    Can SPME overcome matrix adsorption to achieve good recovery?




Can we use the matrix effects to our advantage?

-------
  SOLID PHASE MICROEXTRACTION (SPME)
   needle
            plunge   epoxy
      enlarged
             I
   silica rod
coating
stainless steel
tubing


-------
               DIRECT SPME SAMPLING
o
o
     fused silica rod
                     coating
                  aqueous phase
    V1: volume of coating
    V2: volume of water
The amount of the
analyte  absorbed
by fibre coating in
direct  SPME
sampling:
                                           n =
                                              KC.V.V,

-------
           HEADSPACE SPME SAMPLING
fused silica rod
    Kl
[
f
—• —.
*>
^
V3
             Uieadspace
      K2
   Co
V2
           aqueous phase
 V1: volume of coating
                       The amount of the analyte
                       absorbed  by   the  fibre
                       coating:
                                    n =

-------
          Headspace SPME
   BTEX IN WATER, SAMPLE AGITATED
              (room temperature)

0
CO
CQ
100

80

60

40

20
 0
     0
                          m,p-Xylene
                            o-Xylene
               Ethylbenzene
                   Toluene
                            Benzene
 246      8     10
Extraction Time (minutes)
                 502

-------
           Headspace SPME
   PAHS IN WATER, SAMPLE AGITATED
           (room temperature)
  20
 CD

1 10
CO
  0
                         Acenaphthene
Phenanthrene
                          Naphthalene
              m	».
                            Chrysene
           Extraction Time (minutes)
                    503

-------
               Headspace SPME
      1 ppm BTEX in sand  (time profile)
  150
be
  100
CD
cc
cd
   0
          •*•
          -•
                                47 °C
                                          E
D
                                       •i  C
B
A
     02     4     6     8     10     12    14
             Extraction Time (minutes)
                    504

-------
            Headspace SPME

 40 ppb of PAHs in sand (time profile)

           (room temperature)
 GO
1
*
20
 0
  0
          naphthalene
                acenaphthene
                  phenanthrene
               20         40
            Extraction Time (min)
60
                   505

-------
THE PRECISION AND LIMIT OF DETECTION (LOD) OF SEVERAL VOLATILE
ORGANIC COMPOUNDS  IN THREE  MATRICES AT 5 ppb CONCENTRATION
LEVEL.

(LOD is calculated from the MS spectra assuming S/N=3)
Matrix
1,1-dichloro-
ethane
chloroform
carbon
tetrachloride
trichloro-
ethane
dibromochloro-
methane
chlorobenzene
waste-water (5ppb)
precision
14%
5%
6%
7%
3%
14%
LOD
(ppt)
400
6
20
110
210
2
aqueous sludge (5ppb)
precision
14%
9%
3%
7%
7%
6%
LOD (ppt)
450
150
70
550
110
30
sand (5ppb)
precision
4%
2%
4%
6%
3%
4%
LOD
(ppt)
80
40
20
70
3
1
Sampling in headspace at room temperature for 2 minutes.

-------
            ANALYSIS OF SOIL SAMPLES BY

              HEADSPACE SPME/GC/MS
o
-J
      GO
      CO

      CO
      ro
BENZ[a]ANTHRACENE
                               r
                      CHRYSENE
        15:00   15:20   15:40   16:00   16:20


               RETENTION TIME (minutes)

-------
               Headspace SPME
 Temperature dependence (1 ppb BTEX in soil#7)
                (2 min sampling)
   6
'v ^>
I
nd 4
 o
-I
 QQ
                             E
GQ
   0
    20
 40        60         80        100
Extraction Temperature (°C)
                   508

-------
               Headspace SPME
 Temperature dependence (1 ppm BTEX in clay)
                (2 min sampling)
  3
CO
CD
  0
    20
                         E
 40       60      80       100
Extraction Temperature ( °C)
                    509

-------
  12
a
GO
  8
SS 4
   0
                Headspace SPME
         Heating-Cooling Experiments
              (1 ppm BTEX in clay)
    0
                            140°CtoO°C
        o-xylene
5       10      15       20
 Extraction Time (seconds)
   *: o-xylene at 50 °C
25
                  510

-------
               Headspace SPME
  Temperature dependence (40 ppb PAHs in sand)
              (5 minutes sampling)
   40
f—»
•3
 CO
   20
I
   0
     0
                            naphthalene
                            acenaphthene
                           phenanthrem
     chryse
perylen
   50        100      150
Sampling Temperature (°C)
             200
                      511

-------
I
 co
                 Headspace SPME
        The effect of water content in clay
       ( 1 ppm BTEX, 5 minutes sampling)
        A, room temperature
        B, 50 °C
        C, 50 °C, 10% water
        D, 50 OC, 30% water
        E, 50 °C, 50% water
       Benzene   Toluene  Ethylbenz m,p-Xylene o-Xylene
                     512

-------
               Headspace SPME
 40 ppb PAHs in sand (5 minutes sampling)
100000
 80000
A, 50 °C
B, 50°C/15% water
C, 100°C
D, 100° C/15% water
        Naphth  Acenaph  Phenanth  Chrysene  Perylene
                        513

-------
THE LIMIT OF DETECTION (LOD) OF BTEX IN SEVERAL MATRICES.
(LOD is calculated from the MS spectra of BTEX at 5 ppb level assuming S/N=3)

Benzene
Toluene
Ethylbenz
ra,p-Xylene
o-Xylene
Water
(ppt)
84
6
5
3
5
Sand
(ppt)
39
5
3
3
6
Soil#7
(ppt)
1000
125
28
16
32
Soil#7/15%
water (ppt)
8
2
1
1
7
Clay
(ppt)
1700
190
96
38
94
Clay/15%
water (ppt)
357
24
28
18
41
Water and sand samples were extracted at room temperature;
Soil#7 samples at 65°C (optimum temperature)
Clay samples at 50°C (optimum temperature)
Sampling in headspace for 2 minutes.

-------
               Headspace SPME
Salt-out effect (1 ppm BTEX, 2 min sampling)
 400
 350
water
salt saturated water
  benzene  toluene  ethylbenz m,p-xylene o-xylene
                      515

-------
              EFFECT  OF  ACID  &   SALT
GC Area Counts
1.88+07
1.58+07
1.2e+07
S.Oe+06
6.06+06
3.08+06
          Phe     2C     2N     24OM   24DC   24ON
      Legend
|   [control
    Add
                                                           Add&Salt
GC Area Counts
S.Oe+07 T
2.5e+07-
          4C3M     246TC     4N     2M46DN    PCP
                           516

-------
                PHENOLS  FROM HEADSPACE
GC Area Counts
2.8e+07
                                                        Legend
                                                       Control
                                                       Headspace
        Phe   2C   2N  24DM  24DC 4C3M 246TC PCP

-------
   ANALYTE RECOVERY FROM SEWAGE MATRIX
Compound
Phenol
2 -Chlorophenol
o-Cresol
m-Cresol
p-Cresol
2,4 -Dimethylphenol
2,4 -Dichlorophenol
2, 6-Dichlorophenol
4 -Chloro- 3 -methylphenol
2,3, 5-Trichlorophenol
2,4, 6 -Tr ichlorophenol
2,4, 5-Trichlorophenol
2,3,4 -Trichlorophenol
2 , 4 -Dini trophenol
4 - Ni t r opheno 1
Tetrachlorophenol Isomers
2-Methyl-4, 6-dinitrophenol
Pentachlorophenol
%
Recovery
74.2
128
118
95.8
95.8
104
105
21.3
91.5
56.1
21.5
64.5
66.8
2.7
38.4
16.7
0
8.0
%
Recovery
Acid+Salt
92*
92*
95.9
l_ 97.8
97.8
96.5
78.8
83.4
85.0
71.3
66.1
66.1
71.9
111
118
61.4
83.1
32.2
*coeluted on GC column
                   518

-------
       SUMMARY
    Headspace sampling
    Matrix modification
   Matrix normalization
Temperature differentiation
     Coating selectivity
              519

-------
520

-------
                                        MR. TELLIARD: Our next speaker is Bruce Colby
from Pacific  Analytical.  Bruce is going to talk about general approaches to solving matrix
problems.

             Bruce?
                                        MR. COLBY:  Good morning. I am going to talk
about a general approach to dealing with matrix problems. I don't have any magic in my pocket,
unfortunately,  but we have developed a way to contend with matrix problems when they arise,
and they do arise with a fair degree of frequency, as people out there who have to analyze
samples I am sure are aware.

              Before I really get into the discussion I would like to define to some degree what
matrix problems are.  There are two things that we use as categories for matrix problems. These
are situations where an analyte that we are after is either not recovered from a sample matrix or
it cannot be isolated from the matrix.  In other words, we  suspect that it is there, or, in some
cases, we know that it is there, but we can't seem to find it when we try to determine it.

              That is  one situation.  It is really quite different from the other matrix problem,
which is when something in the sample matrix interferes with the detection of a particular
analyte.

              Sometimes can be a bit confusing  which problem is which, but if you can't get a
compound  or  an  element into  your instrument, can't get  it out of the sample  and into  an
instrument, that is kind of the first one.  If you  have gotten it out of the sample  and into the
instrument  but there is something else from the  sample that you have put into the instrument
which keeps you from making the measurement, that is the second kind of problem.

              The thing I would like to do right now, is to quickly run through the approach we
use when we face these problems.

              Incidently,  my whole  discussion is going to be based around discrete analytes. I
am not trying to address any  kind of matrix problem associated with method-defined parameters
like "oil and grease" where the method defines what "oil and grease" is.

              The first thing we do  when we are going to try to solve a matrix  problem is kind
of classic.  We define what the problem is. Is there an interference or is it a recovery problem?
We have to settle on what kind  of problem we are trying to solve first.

              Then we identify the  boundary conditions  we are going to deal with. If we are
going to  continue trying to make a measurement, what kind of detection limits do we have to
achieve and what kind of time restrictions are there on getting the measurements and  so forth?
                                          521

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             Once we have decided we are going to move ahead with it, we have to generate
a hypothesis of how we are going to deal with the problem, what really explains the situation that
we have encountered.  If we can come up with an explanation of the situation, then we can move
along and start to make some sort of tests with respect to dealing with the problem.

             We then try to identify chemical differences between the analyte  or analytes that
we are trying to measure  and the matrix, whether it is a matrix recovery problem or a spectral
interference problem or a detector problem or what not.

             We then try to come up with some sort of physical separation technology that will
let us isolate the matrix from the analyte that we are after.  Sometimes we come up with more
than one possibility. We then have to pick the best one, and go  ahead and test it.

             Well, let's take these steps one at a time here.

             In  defining the problem, the first step really is to decide whether we have an
interference, or whether we don't have recovery.  This is a very fundamental difference, and it
has a lot to do with how we attack the problem.

             If it is an interference problem, then we have to identify what the interference is,
so it is apt to require someone with knowledge of the sample, what is present, what is likely to
be present in the  sample.  From a commercial  lab's viewpoint, normally we would have to go
back to someone  who understands the source  of the sample, what created the sample, what is
likely to be there; "We think there might be thus and so present, does that make sense to you?"

             If we are trying to get rid of something or separate something, it is critical to know
what those things are.

             Identifying the boundary  conditions that we have to deal with,  some of the
traditional QA/QC-related things,  is next.  We  need to know what detection limits are needed.
If we are going to  put something together, what kind of precision are we  going to have  to
generate, and what  sort of accuracy?  How many different analytes are we going to have  to
contend with?  Can we deal with just one, or are we dealing with 30 problem analytes?  What
kind of turnaround time do we have to come up with?

             We have got to do  some thinking, and possibly do some experiments.  We may
also have a development time issue, and, of course, time converts itself into costs at some rate.

             Sometimes it is important to put a lot of development time into something, because
we need a low-cost, quick-turnaround measurement in the end.  Other times, we just need  an
answer once, so there is no point  in putting a lot of development time into it.
                                          522

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              Once we have established in our own minds what the problem is and what the
boundary conditions are, we establish an hypothesis of how we might contend with things, and
then we move on and try to evaluate that hypothesis.

              We look at existing data and talk to people who know something about the sample.
Does our hypothesis make sense to someone who is aware of what might be in the sample?  If
it is an interference situation, we might have to collect some additional data to help identify the
interference.

              There are lots of things, but basically what we are doing is trying to look at the
information we have,  whether it is experimental data or information from external sources, to
justify the hypothesis  we have generated to explain the problem.

              Now we try to identify chemical or physical differences between the analyte and
the matrix problem. Is there something that we can use as a handle to  help separate these from
one another?  The types of parameter we go for are differences in vapor pressures, solubilities,
polarities, reactivities  and sometimes, pKa's.

              Once we have decided what the differences are between the analyte and the matrix,
we can pick some sort of separation technology to deal with the situation. Things that we have
to  work with  here  are different solvent  systems  and possibly  distillation,  this could  be
evaporation, but it is some mechanism using vapor pressure to isolate an analyte from the matrix.
We can sometimes remove the matrix and leave the analyte behind and vice versa.  Sometimes
chemical reactions are useful. Derivatizations, for  instance, could be a useful thing.  We also
have  got a lot of different  liquid  chromatography tools at  our  disposal, alumina column
fractionations, potentially HPLC separations, although those are usually fairly expensive if you
are putting  them in front  of something else.   We also  have  different gas  chromatography
techniques and columns plus  different types of detector systems.

              Well, having put all these pieces together, we try to select a candidate approach,
one that our gut feeling says is going to work. It has also got to be one that we can accomplish
with the tools that we have at our disposal.

              At some point, then, we have got to move along and undertake some experimental
effort to test our theory with real samples. We usually start out looking at blanks, spiked blanks,
then clean samples. We need to make sure that the technique that we are working with is going
to work in the easy situations.

              We then go on to looking at field samples and spiked field samples.  We look at
things like the recoveries and the precision of the recoveries, i.e., what kind of accuracy are we
getting.
                                          523

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              If we fail in working with a field sample, we are definitely going to run into
problems.  So, doing spiked field samples is very, very important.  It is the only way we can
really assure ourselves that we have solved the problem.

              Well, that is the  basic approach.  It  is not a cookbook thing, it is a thought
process.

              The next thing I would like to do is run through a few examples  that I brought
which illustrate some of these steps as we go through.   They are real problems that we have
encountered and solved. I should mention that we have encountered problems that we have been
unable to solve.  Fortunately, we have solved more than we have failed to solve.  So, overall,
things look pretty good.

              The first example is a situation where we were trying to measure, among other
things, nitrobenzene in a wastewater sample.  There was a huge spectral interference which made
it absolutely impossible for us to achieve the detection limit required by the regulatory people.
The detection limit required was around 2000 ug/L.  So, this is serious interference territory.

              Well, that is a boundary condition, 2000 ug/L. We needed a method that will get
down to that level on these particular samples.

              We looked at the GC/MS data we had and we felt that the interference was some
kind of phenolpropanol or something like that, and when we discussed this with the client, they
agreed that that was reasonable and it was quite probably that it was 2-phenyl-2-propanol.

              Well, we have nitrobenzene, water, and 2-phenyl-2-propanol, and we have to get
them separated. Things we can use for handles are different polarities, different solubilities are
different reactivities to work with. There are also potential differences in volatility that we can
work with.

              Tools that we might apply in this situation would include different GC columns,
ion exchange technology,  back  extraction techniques, and derivatization  (relying on that  OH
group as a key).  Finally, purge and trap might be a way to go after things. Nitrobenzene is,
after all, reasonably volatile.

              Well, we tried all of these, and finally kind of threw  in the towel  and said okay,
we will  have  to try purge and trap, because we have tried everything else, and  nothing really
worked.

              You can see in this chromatogram of the sample where nitrobenzene elutes.  It is
somewhere under the largest peak.  There is quite a bit of the interference in there, and there is
not much nitrobenzene that we can see. You can see  this is a pretty ugly looking chromatogram.
                                           524

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             The nitrobenzene-d5 that we put in to track exactly where nitrobenzene eluted
came out  as shown in the top trace. The center trace is the quantitation mass for nitrobenzene.
It happens to be a minor peak in the 2-phenyl-2 propanol spectrum, so it is totally wiped out.
The bottom trace is a total ion chromatogram.

             Nothing seemed to work so we finally took a crack at it with purge and trap using
a capillary column.

             Now, this is a fair deviation from the normal EPA wastewater GC/MS technology.

             Purge and trap  is not normal technology for nitrobenzene, but  in this  case, it
works. We were able to demonstrate an MDL in the vicinity of 10 ug/L, considerably lower than
the 2000 that was necessary. There was also plenty of precision. We were able to demonstrate
that, in fact, there was no nitrobenzene present even down at the 10 ug/L level.

             Another example  we ran into  had a volatile organics  analysis  that was quite
important.  The difficulty with this particular sample was percent levels of acetone and  phenol.
If you have ever tried to run a purge and trap on a sample that has several percent of acetone or
phenol hi it, you know that your instrument becomes so contaminated that after running the first
sample, it takes a day or more to get the thing back on line again.

             So,  there was no  way this sample could be run without totally destroying  the
instrument.  If we followed traditional thinking, i.e., dilution of the sample, the detection limits
for volatile aromatics and chlorinated solvents could not be achievable.

             The problem here is a matrix  isolation problem.   We don't have a spectral
interference problem.  We have got to get rid of this acetone and phenol somehow before we do
our measurement.

             Well, what have we got to work with?  Acetone and phenol are fairly polar, as is
the matrix. We are after volatile aromatics and chlorinated solvents which are not very polar.

             We finally settled on trying to do something with a solvent system. This, again,
is a fair deviation from normal EPA methodology.

             What we looked at was the possibility of doing a hexadecane:water partition and
then taking the hexadecane, putting that in an autoinjector vial and shooting it on a cap  column
GC/MS.

             The detection limit requirements were 5 ug/L, and we felt the only way we could
get the necessary precision and accuracy for the measurements here was to use isotope dilution.
That is more work, but we get a better result when we do it.
                                          525

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             After we settled on those  two things,  we decided  we had to calibrate our
instrument down to the equivalent of 0.1 ng/uL.  So, we are pushing instrument technology and
using extraction instead of purge and trap,  to solve a problem.

             We ended up with a chromatogram that looks like this.  This is a matrix spike of
a field sample.  All of the peaks in there are analytes that we put in.  The hump in the middle
is probably the  result of phenol.  We didn't see much of the acetone.

             We were able to get MDLs  at the 5 ug/L level.  We eliminated the acetone and
the phenol; established that we had accurate, precise measurements; and everybody went away
happy.  It took  some time to develop it, but it worked.

             Another example.  This one is not a wastewater example. All of my examples are
not wastewater.

             We had a need to measure volatile organics in waste oil. The data I am going to
show will be from used motor oil.

             The purge and  trap type technology is  essentially useless if you have  an oil
sample.  Very oily waters present a similar kind of a problem.  The  analytes we are  interested
in are very soluble in the matrix, and they just don't recover.

             Things that had been tried on the oil were headspace, and it didn't produce the
required precision, so the MDLs were not acceptable. We had to get detection limits  for...well,
the lowest one was for vinyl chloride down at 1 ug/kg  of oil. Again, the  problem in this case
was a matrix isolation problem. How do we get our analytes away from the matrix? There was
no interference  problem in particular.

             The only thing we had to go on that looks promising here was vapor pressure, so
we settled on doing a headspace type measurement.

             We  did some initial work that indicated that we had to equilibrate the samples at
a fairly high temperature for 8 hours prior to analyzing them. I think we used 80 degrees C for
the equilibration period.

             We used isotope dilution for the quantitation to try to improve the precision.  This
helps get MDL values down to the boundry condition level.  Some of the detection limits were
fairly high levels.  We wanted to be able to analyze a sample in one run yet get all the detection
limits covered.  We didn't want to have to analyze a sample twice, essentially dilute it so that
we could get everything on scale.

              Consequently, we ended  up  with calibration range on order a factor of 1000  to
cover everything.
                                          526

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              The next slide shows a chromatogram. This is a motor oil sample. It is spiked
with regulatory levels of volatile TCLP analytes.  They are all in there at regulatory levels, and
this is what a chromatogram looks like from a headspace isotope dilution run at the regulatory
levels.

              The next slide gives you some idea of the kind of sensitivity.  This is the same
sample showing a 500 ppb benzene peak near the center on the top trace and a 200 ppb vinyl
chloride peak.  As you can see, it is possible to get those  analytes out of the motor oil sample
matrix.

              The next  example  I  have got is a problem  we  ran into  with some PAH
measurements in soil samples. The situation had arisen where someone was trying to measure
"carcenogenic" PAHs using  Method 8310. The result was that there was a big huge peak that
started near the beginning of the chromatogram and went to the end of the chromatogram. There
were essentially no discrete peaks, just one big wide one.

              They spent a  lot of money and finally decided that it wasn't particularly useful.
They needed to get a detection limit for any given PAH down in the 1 ug/kg area.  Now, the
8310 method doesn't even produce that, according to  the method specifications, but for some of
the analytes, it will get close.

              We talked to the people about the samples a bit and discovered that the site had
most likely been contaminated with a coal tar derived waste.  Consequently there were more
alkyl PAHs there than unalkylated PAHs.  In effect there are thousands of PAHs present, not just
six or seven.

              We  decided that  the  thing we had  to work with in this case  was  detector
specificity. Fluorescence wasn't going to do the job, because all of the alkyl PAHs fluoresce.

              We also needed more  chromatographic resolution than HPLC was not going to
provide. Finally we settled on mass spec to increased detector specificity.  We also used some
additional with the chromatography separations to remove other components from the matrix and
we used a capillary column to increase chromatographic resolution.

              Some of the other things we did included a 100 gram sample instead of sort of a
standard 30 gram sample in order to improve sensitivity. The column chromatography selected
was an alumina column fractionation, which yielded three fractions, a polar one which we didn't
analyze; an aromatic which we did analyze; and an aliphatic which we didn't analyze.

              There was a lot of sulfur present. If anyone has ever analyzed the NIST sediment
sample, that one also has a lot of sulfur in it.  So, a sulfur removal procedure was added.

              We used a small final  volume, 300 uL, but we could still use  an autoinjector at
that volume.  We calibrated the GC/MS down to 0.1 ng/uL  for the injections.


                                          527

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              Quantitation was done by isotope dilution. We tend to use this technology a lot,
because it reduced development time substantially, and because it improves precision and the
accuracy.

              The next slide shows a total ion chromatogram. This is a field sample.  The hump
at the end of this is...actually, it is all kinds of different things, all aromatic things.  We have no
idea what most of them are.

              If we just take a quick look at this, what I put up here was a...well, the bottom
trace was a total ion chromatogram.  The next trace up shows phenanthrene and then anthracene
as the two little peaks on the left. The bigger one is phenanthrene.

              The next trace up with the two sets of two peaks is for the methylanthracenes and
methylphenanthrenes. The next trace up is the dimethyls and ethels, and the next trace up is for
the ones that are C3 anthracenes and phenanthrenes.  So, you can see that, indeed, there were
large quantities of these alkyl PAHs present.

              In this case, we can put traces up for all the other alkyl-PAHs, and, basically, we
just keep finding more and more of them the more we look.

              But if we now look at the quantitation mass peaks for the carcinogenic PAHs in
here that were identified as important in this case, we have clean traces for them,  and they are
all present.  Note that these are field samples, not spiked samples.

              One thing that is worth pointing out, is that in the middle trace there, is benzo(-b)
and benzo(-k-)furanthene,  and there is a peak at scan 2111. The peak at 2111 is benzo-e-pyrene.
It is normally present in field samples at a higher level than benzo-a-pyrene. If there were no
real benzo(-a-)pyrene present most GC/MS methods, if followed strictly,  identify  benzo(-e-
)pyrene as benzo(-a-)pyrene. This is because it is within the retention time window  for benzo(-a-
)pyrene, and it has got exactly the same spectrum. That can be a real problem with some of the
methods, if, say a health effects guy tries to use the data.

              Anyway, we achieved detection limits on all the carcinogenic PAHs, actually on
all the PAHs that we measured, down below 1 ug/kg.

              In the final  example, we had a sample where the total organic carbon numbers for
some well water samples were very  high. There was particular concern about contamination of
the groundwater at this point because of its proximity  to some  drinking water wells.  None of
EPA's HPLC  or GC/MS had detected  any  identifiable analytes using the traditional methods.
Effectively, none of the compounds on the lists were showing up.

              It bothered  some people that the TOC values could be high, and yet there weren't
any detectable analytes present.  That, clearly, could be a problem.
                                          528

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              The hypothesis that we came up with was that there were polar compounds in the
water that weren't on anybody's list.

              Well, if they are polar compounds in well water, we have got something we can
do with solubilities and possibly something with vapor pressures.

              We, in dealing with solubility, decided to alter the ionic strength of the sample.
We also tried working with vapor pressure through vacuum distillation.

              We maximize the ionic strength of the water sample by saturating it with sodium
chloride.  We would have preferred to use  calcium chloride, but we couldn't find any that
satisfied us in terms of the blank.

              We  then extracted the water in a continuous liquid-liquid extractor for 72 hours
and concentrated the extract by K-D. We concentrated the extract to 100 uL.

              In the second experiment we took a liter of water and essentially evaporated the
water in a vacuum centrifuge.  It took quite a while to do this, about a week to get 1 liter down
to dryness.  We then took up the residue  in 100 uL methylene chloride.

              We  analyzed the extracts by GC/MS and used some  special  software techniques
to deconvolute the spectra. I am not going to go into this in detail, because I talked about it here
last year.

              At any rate, the total ion trace for either one of the extracts look very much alike.
The five big peaks in the example are the internal standards. The rest of the peaks, only a few
of which are fairly good sized, are peaks  down in the baseline.

              You can see on the left-hand  side there  is a peak at scan  303.  If I take that
portion of the chromatogram and expand it, I get something that looks like this.  You can see 303
is now the biggest peak.

              In this region of the chromatogram, the  part that is  displayed, we were able to
identify 15 discrete compounds and get  good mass spectra from all of them.  Some of them were
even  in the NIST library.   Many of them  were not,  but since  there are  several  series  of
homologous type compounds present, we were able to pick up most of what was there.

              Some of the compounds  were things like this butoxy-ethanol. There are basically
glycol ethers with different end groups on them.  There are all kinds  of different end groups, and
each end group creates a different series.

              There were a few  other  things as well.  There were some relatively  nasty
chemicals in there which I can't go into much detail, but, we were  able to  come up with about
                                          529

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150 identifications out of this.  At this point, we don't know what any of the recoveries are,
because some attorney is still trying to figure out what to do about it.

             That is the last example I am going to go through. In conclusion, I would like to
say that there are usually ways to get around matrix problems. In order to get around them, we
have to be willing to deviate from the cookbook methods that are the heart and sole of most
environmental labs and generate modified methods. When we do this, we come up with results
that are acceptable from a data quality standpoint.

             We have found regulators generally reasonable to talk to and willing to listen to
this method kind of data. They haven't been hard to deal with, but they do want to be talked to,
and they want to understand what is going on.

             It takes some extra time  and money, and some decisions  have to be made
regarding when to  throw one's hands up in the air or whether to persist.

             If anybody has any questions, I will try to take a crack at them.
                                          530

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                        QUESTION AND ANSWER SESSION

                                       MS.  RHODES:    Ileana  Rhodes  with  Shell
Development.  I would like to suggest...well, actually, I would like to add a comment. Actually,
I would like to congratulate you on doing unusual things.  Some of the things that we have been
doing in the oil industry to correct for some time like fractionation in aromatics, polars, and
nonpolars.  We have done that quite a long time, and that is what we know how to do best, but
most of the time, we are forced to use EPA procedures that don't work for pure  oils.

             An example  I would  like to share with you,  we were forced to look at
benzo[a]pyrene in a diesel sample, and that was because of emissions.  The benzo[a]pyrene
number that we obtained using simple waste dilution was just too high of a detection limit, and
when you plugged into the modeling equations, then it came out as an exceedance.

             So, the engineers came  by crying to us, and we just went the old-fashioned way.
Look at the fractionation using a column such as the one you used and then took the aromatic
fraction and were able to drop the detection limit below.

             We still got a non-detect, but that non-detect plugged into the equations and gave
them a non-exceedance, and that was a lot better.

             So, this is the way.  It  is kind of refreshing to see using good old oil company
methods to apply to environmental problems instead of trying to analyze an oil sample as if it
were a water sample.

             That is my comment.

                                       MR. COLBY:  The alumina column fractionation
technique, incidently, is an SW846 recognized method.

                                       MS. RHODES:  But nobody uses it, though.

                                       MR. COLBY:  Yes, they do. We do.

                                       MS. RHODES:  Very few people do.

                                       MR. COLBY: It is on the books, and it works very
nicely. There is a good silica gel one, too.

                                       MR. SCHREINER:  My name is Dave Schreiner,
City of Phoenix.  Have you had any success in inorganic matrices for solving problems?
                                         531

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                                       MR. COLBY:  There are things that can be done
with different kelating agents to solve some of the problems that we have seen in the inorganic
area.  Typically, the increase in cost to work out those things has scared people away.

             Brine samples, in particular, are  one  area where people sometimes want what I
guess would strike most of us as ludicrous detection limit numbers.  The only way to  go after
them is to go to kelating and by doing a fair amount of chemical separation.

             So, yes, there are ways to go after some of it, but we haven't had  people that are
too willing to pursue it at this point. I would be very interested in doing some of it, but we can't
do it for free.

                                       MR. TELLIARD:  No, really?

                                       MR. COLBY:  Really.

                                       MR. SCHREINER:  But your approach would be
more towards prior to digestion to, you know, change the methods or whatever?

                                       MR. COLBY:   Kelating is not something that is
really anywhere that I have seen in any EPA technology at this point. So, that would be a pretty
big deviation from anything I have seen.

             It is in the literature, Analytical Chemistry and places like that, but it is not in the
environmental methods at this stage.

                                       MR. SCHREINER:  Thanks.

                                       MR. TELLIARD: Thanks, Bruce.   Appreciate it.
                                         532

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U)
A GENERALIZED APPROACH TO

 SOLVING MATRIX PROBLEMS

     Bruce Colby, Lee Helms and Steve Parsons
            Pacific Analytical
             Carlsbad, CA

                and
             James Smith
               Trillium
             Coatesville, PA

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              MATRIX PROBLEMS
       Analyte not recovered/isolated from the matrix



       Analyte interfered with by non-target chemical
U)

-------
              APPROACH
Define the analysis problem
Identify boundary conditions
Form a hypothesis which explains the problem
Test the hypothesis experimentally
Identify chemical differences between analyte and
matrix/interference
Identify separation mechanisms which play on the
above differences
Select the best candidate separation
Test the best candidate
U)

-------
            DEFINE THE PROBLEM
            Interference vs. isolation/recovery
            Identify the interference/matrix
U)

-------
U)
-4
IDENTIFY BOUNDARY CONDITIONS

         • Detection limit(s)
         • Precision
         • Accuracy
         • Range of problem analy tes
         • Turnaround time
            - Development
            - Routine application
         •Cost
            - Development
            - Routine application

-------
        FORM A HYPOTHESIS
U)
00

-------
EVALUATE THE HYPOTHESIS
      • Use existing data
      • Collect additional data

-------
IDENTIFY CHEMICAL DIFFERENCES

           • Vapor pressures
           • Solubilities
           • Polarities
           • Reactivities
           • pKa's

-------
IDENTIFY SEPARATION MECHANISMS

           • Solvent systems
           • Distillation
           • Chemical reactions
           • Liquid chromatography
           • Gas chromatography
           • Spectrometry

-------
     SELECT A CANDIDATE APPROACH
             Solve the analytical problem



             Satisfy the boundary conditions
to

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        TEST THE BEST APPROACH
                Blanks
u>
Spiked blanks




Field samples



Spiked field samples

-------
 NITROBENZENE INTERFERENCE

1. Spectral interference causes DL requirement not
  to be met

2. DL < 2000 (ig/L, routine monitoring

3. Interference is 2-phenyl-2-propanol

4. Polarities, solubilities, reactivities, volatilities

5. GC  Column,  ion  exchange, back extraction,
  derivatization, P&T

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       ROUTINE 1625 DATA
            Pacific Analytical
Sample: 45281 ES NOGPC
Instrument: UG06

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             METHOD 1625 10:1 DILUTION
&
                         Pacific Analytical
           Sample: 452B1 DIL ES NO GPC
Instrument: UG86
                               N itrobenzene-d5
                                   686
                                 2-Pheny1-2-propano1
                                                       11378787
     Scn660   665

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             PURGE & TRAP DATA
       Sample: FIELD SAMPLE
                    Pacific Analytical
Instrument: UG87
                        N i trobenzene—d5
                           1635
           774'
            hi
                            Nitrobenzene
                            MDL = 18 ug/L
Sen 1580  1590  1600 1619  1620  1630  1640  165Q 1660  1679  1689  1690

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oo
   EXCESS ACETONE & PHENOL
1. Inadequate DLs for all volatiles using Method
  624
2. Instrument contamination precludes analysis
3. Problem is acetone & phenol
4. Polarities, solubilities
5. Solvent system

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      SOLVENT EXTRACTION
1. Hexadecane:water partition/syringe injection
2. Isotope dilution for precision and accuracy
3. Calibration down to 0.1 |ig/L

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     MICROEXTRACTION SAMPLE TIC
8808
B7-ftpr-90
        Pacific Analytical
Sanple: Matrix Spike
UGft4 TRI01
          M9  300  4

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   VOLATILE ORGANICS IN OIL
1. Purge  &  Trap ineffective,  Headspace  not
  accurate at low cone.
2. Need DL for vinyl chloride at 100 |ig/kg
3. Matrix isolation problem
4. Vapor pressure
5. Headspace

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to
      HEADSPACE ISOTOPE DILUTION
     1. Heated headspace with 8 hr equilibrium time
     2. Isotope dilution quantitation
     3. Wide range (103) calibration

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                        HEADSPACE TIC
               Pacific Analytical
Sample: NEU OIL»3 SPIKED AT REG LIHITS,5PPH IS a
                                    1858
                                                   Instrument: UG 6
                                                            39449856
                                                                TIC
                                                                 ftl
OJ
               see
          1000
is00
2000
2 see
seee
3 see

-------
                 VOLATILE ANALYTES
                        Pacific Analytical

           Sample: NEU OIL83 SPIKED AT BEG LIMITS,5PPH IS & Instrument: UG 6
21484
100-

XFS-
0
100-

X.FS-
e-
Sen
2230 194568
benzene 1
See ppb 1
1511
f\ II .y ^JKTJQ
9?S9 18P7 U 2769 \
-« *A )l ft . /IVl A A A
13

vinyl chloride
Zee ppb
552
*n 1 v
22 132896
2230
1508
1 . ll , ZT
See ' 1000 ' 1500 ' 2000 ' 2500 ' 3000 ' 3588
Ul
<-f>
-li.

-------
              PAHs IN SOIL
1. HPLC-fluorescence  chromatograms  have  few
  distinct peaks

2. Need 1 |ig/kg DLs for carcinogenic PAHs

3. Alkyl-PAHs from coal tar obscuring target peaks

4. Detector specificity, chromatographic resolution

5. MS , liquid chromatography, capillary column

-------
              GC/MS PAHs
1. Extract 100 g sample
2. Alumina column  fractionation  to generate  an
  aromatic fraction
3. Sulfur removal
4. Final volume of 300 (iL
5. Calibrate GC/MS to 0.10 ng/|LiL
6. Quantify using isotope dilution

-------
                            PAH TIC
Sample: 595
                          Pacific Analytical
                                                    Instrument: UG86
6B82B87

1001
•XFS-
  0
Sen
            515
                                            1733
                            1139
                         1093
                            \
                   7"
                      890



                       JU.
                                        16
                                          10
                                  1362
                                     1580
                          2435794
                             TIC
                              #1
                                              18 4
                                                  1907
                                                      2140
            500
                        1000
1500
2000
2500

-------
           CARCINOGENIC PAHs
OC








Samp
6B82
100
X.FS •
100
XFS-
100-
XFS -
100
XFS-
100-
XFS-
0-
Scn
Pacific Analytical
le: 595 Instrument: UG86
!B87
24?9 21§I
n « • «*
2432 /I 415
II II
2478 7048
7l A 276
2005 2842 20?9 1 fl *4
^K/vAv/ 2^3/l /\
2844 42752
fl 21/f1 2*^
11. AA/146
18,38 78848
1831x| 228
17.95 fll
1834 1727444
A TIC
ij^JL^^ez^__2043 2i/° ttl
^ *^-*»*--v__rrv>_/ \ — ^ — -b^ j»**vj'c; . . _^
1800 ' 1900 ' 2000 ' 2100 ' 2200 ' 2300 2400 ' 2500 ' 2600









-------
                    ALKYL-PAHs
Sample: 595
                     Pacific Analytical
Instrument: MG86

-------
            WATER SOLUBLE BNAs
     1. Something is present (TOC data) but HPLC &
       GC/MS show nothing
     2. Need to know if ground water is contaminated
s      with dangerous chemicals
     3. Polar compounds not being extracted
     4. Solubilities, vapor pressure
     5. Increase ionic strength, distillation

-------
             APPROACHES
1 a. Maximize ionic strength
2a. Extract in CLLE for 72 hrs
Ib. Vacuum evaporate 1 L of sample
3. Concentrate final extract to 100 uL
4. Use deconvolution background subtraction on the
  GC/MS data

-------
                WATER SOLUBLES TIC
    Sanple:   5B62592C
                        Pacific Analytical
                             Instrument: UG81
ON
    8814R1B
    100-
    XFS-
      0
    Sen
          1058   1326
                   721
               486
                                      1803
                                    16.77
                           1296
                          11.46
                             992626
                               TIC
                               Vri
                                            2115
500
1O0O
1500
20O0
                                                   2500

-------
                WATER SOLUBLES TIC
    Sample:   5062592C
                       Pacific Analytical
Instrument: UGBi
0\
    0814R10
    100
    XFS-
      o
         92
                                           378
                                                    8
    Sen	280	3 O0     320     34O     360     38O
          400

-------
             WATER SOLUBLES SPECTRA
Sample:   5862592C
                        Pacific Analytical
                                             Instrument : UG81
ON
 RESOLVE'59 (18.388)  COMBINE:(52 to 73)

100-             57
                                       NBS 128 Hits
      0
        39
     *1

                                             128 Searched

                                                   576
                58
                  63
                           71
                              _.-
                              75
 #1 FI873 3137:ETHANOL, 2-BUTOXV-


100-            57
                               A
      0
    M/Z   40
                                                       255
                    58
                        72 75
           50
                60
70
                          (~
                                     „,

                                     87
80
90
100
110   120
                  CH3
                                 2CH2OH

-------
          CONCLUSIONS
Additional  matrix  isolation  techniques   are
available

Analyte specific  interferences can  usually be
resolved

Extra effort and flexible analysis approaches are
required to deal with matrix problems

-------
566

-------
                                        MR. TELLIARD: Our next speaker is from Battelle.
Hazel Burkholder is going to be talking on anion exchange resins for the collection of phenols
from air and water.
                                        MS. BURKHOLDER:   This morning, I will be
discussing the use of anion exchange resins for collection of phenols from air and water.  The
first section of this talk will be rather general, the second section will cover phenols in water, and
the final section will cover phenols in air.

              Methods have been established for sampling air and water with polyurethane foam
(PUF).  These methods are applied to pesticides and PAHs and do not include phenols.

              Current methods for phenols include Method 604, a liquid-liquid extraction of
wastewater, and  Method  TO8, an  aqueous sodium hydroxide impinger collection method.
Method TO8 is only a suggested method and has not been validated.  Our work demonstrates a
new technology, the use of anion exchange resins, for collection of phenols from either air or
water.

              This  is  a schematic representation of an anion exchange resin, AG MP-1.  The
resin has a styrene-divinylbenzene polymeric backbone with chemically bound quaternary amine
sites.  Sodium hydroxide is used to convert the counter ion of the resin to the hydroxide form
and thus obtain the  strongest possible aqueous base.

              When analytes are introduced to the  resin,  the hydroxide on the resin  readily
abstracts a proton from phenols and acids and causes attachment of their anion to a quaternary
amine site.

              Analyte anions are displaced from the resin by application of an acid of greater
strength, in this case methanolic HCR, regenerating analytes in neutral form in the eluent.

              Anion exchange resins were obtained from BioRad.  The granular resins were
evaluated in four mesh sizes, with the smallest size proving to be the most efficient for air
sampling.  We also  used an anion exchange membrane consisting of BioRad AG-1 resin, 5 um
particles, embedded in a 3M teflon matrix.  This membrane is very similar to the CIS Empore
membrane.

              The desired environmental detection limits are 1 ppb to 0.01 ppb for waters and
1 to 0.1 ppb for air.

              We try to match detection limits to methods of derivatization and instrumentation
systems. For high levels (1-10 mg/mL in the analysis volume), it is not necessary to derivatize,
and analysis  can  be done by  GC/FID or GC/MS.   With mid-range (0.1-1 mg/mL analysis
concentration), it  is  necessary to derivatize with BSTFA and use GC/FID or positive chemical


                                         567

-------
ionization GC/MS. Low levels require derivatization with pentaflurobenzylbromide and analysis
with GC/ECD or negative chemical ionization GC/MS.

              These are scenarios for achieving these desired detection limits.  With current
methods, it is essential to extract a liter of water or to sample 7200 liters of air.  This volume
of air. can be achieved by sampling at 10 liters per minute for 12 hours.  In  all cases the final
analysis volume is 1 mL.

              Advantages of the anion  exchange resin for water are the lack of use of large
separatory funnels; there are no continuous extractors, no refluxing  solvents, and no emulsions.
These features add up to reduced volumes of toxic solvents.  High extraction efficiency and high
retention efficiency  result because  of the formation  of a chemical  bond.   There  is  no
breakthrough.

              Advantages of anion exchange resins for air sampling include no glass impingers.
The resin is lightweight, it has high collection efficiency, high sampling rates can be used, and
high retention efficiency results. Because of the chemical bond, humid air has no effect.

              Disadvantages of anion exchange include the efficient passive sampling of the
resin. The resin must be protected from the atmosphere before it is used. There are also phenols
in styrene divinylbenzene polymers, and these resins must be cleaned thoroughly  before use.

              I will now briefly review the extraction of phenols and acids in  water. These data
were presented here last year by Marielle Brinkman. Liquid-solid extraction of phenols and acids
from water was accomplished  by  placing a silanized glasswool  plug  in  a silanized glass
chromatography column and adding 0.5 g AG MP-1 resin and  water.  The top of the water
column was spiked with phenols and the water was drained through the anion exchange resin.

              The resin was then eluted with 2 percent hydrochloric acid in methanol/methylene
chloride. Water was added to the extract and it was then acidified.  The extract was partitioned,
the aqueous layer discarded, and the organic layer dried through sodium sulfate.  After K-D
concentration, the appropriate internal standards were added.

              The sample was then split.  900 uL for acids was solvent exchanged into MTBE.
This portion was methylated with diazomethane and analyzed using GC/ECD.

              The remaining 100 uL was solvent exchanged into acetone, diluted to  1 mL, and
derivatized with PFBBr prior to GC/ECD analysis.

              This graph shows the collection efficiency of the AG MP-1 anion exchange resin
for phenols in water.  Even with a liter of water, there is no breakthrough due to  the formation
of the chemical bond. Please note, however, that the 1 ug in 1L used silanized glassware, while
the 1 ug in 100 mL did not.  The differences  in recovery clearly  show the need to tie up active
sites on glass surfaces.  Except for 1-naphthol, recoveries are generally greater than 80 percent.


                                           568

-------
             The shaded areas of this GC/ECD chromatogram mark spiked analyte peaks.
Despite some background peaks, the analytes are well resolved.  These data indicate that using
an anion exchange resin and PFBBr derivatization for trace levels of phenols in water is quite
feasible with GC/ECD analysis.  This approach eliminates the need  for more costly GC/MS
analyses.

             This GC/ECD chromatogram shows that 4-nitrophenol and pentachlorophenol can
be determined along with organic acids by this method without interferences.

             Method recoveries for acids, 4-nitrophenol and pentachlorophenol are generally
good, greater than 70%.

             In developing a method for sampling air, vapor spikes were done using a GC oven
held at 55 degrees C and an injector held at 250 degrees. Analytes spiked into the injector were
vaporized, mixed with helium carrier gas, and swept onto the anion exchange resin.

             The resin was then eluted with 2 percent hydrochloric acid in methyl-t-butyl ether
and methanol. Aqueous sodium chloride was added, along with additional methyl-t-butyl ether.
After partitioned, the aqueous layer was discarded.  The organic layer was dried through sodium
sulfate, concentrated to 1 mL, appropriate internal standards were added, and, again, the sample
was split, with 800 uL being analyzed by GC/FID and 200 uL diluted  to 1 mL, methylated and
analyzed by GC/ECD.

             High and low concentration standards show good resolution  of all analytes as
shown in the GC/FID chromatogram.  The analytes are easily quantifiable at the lower level of
0.6 ng/mL.

             Collection and retention efficiencies of vapor spiked phenols are related to face
velocity  of the  sampler.  When velocity is too high, there is not enough residence time for
analytes  to react with the resin, and channeling is much more apt  to occur.  The 4.3 cm/sec
velocity was obtained using a 7 mm i.d. tube with helium flow at 100 mL/min (0.1  L/min).  The
1.75 cm/sec velocity was obtained using an 11  mm i.d. tube with helium flow at 100 mL/min.

             Neutral compounds that are collected and retained by the polymer backbone can
be sequentially extracted from the resin with neutral solvents without extracting phenols.  When
using the sequential extraction with neutral solvents, alkanes, aromatics, and ketones are removed
without affecting the phenols.  The phenols can be recovered in a subsequent acidic eluent.

             These GC/MS chromatograms resulted from ambient air sampled using the tube
sampler as shown in an earlier slide.  Several of the alkyl  phenols were identified using EI-
GC/MS, and electronegative components, including nitre-phenols, were identified using negative
CI-GC/MS.
                                          569

-------
             However, sampling of 0.1 L/min with granular resin would not allow detection of
phenols at ambient levels.  An anion exchange membrane was used to achieve higher sampling
rates.

             This is a schematic representation of the inlet for a PS-1 high volume air sampler.
This air sampler normally contains a single filter and a sorbent trap. However, we used the inlet
for a series of stacked filters consisting of a teflon coated glass fiber filter, the AG-1 membrane,
a second teflon coated glass fiber filter, and a sodium hydroxide coated glass fiber filter.

             We would have preferred a  second  AG-1  membrane instead of the  sodium
hydroxide coated filter as a backup filter. However, in attempting this, we were  not able to
achieve the required flow rates. So, we used the sodium hydroxide coated filter in its place. The
analytes are spiked onto the first teflon coated glass fiber filter before it is assembled.  The
analytes are then swept onto the AG-1 membrane by the air flow. The phenols have sufficiently
high volatility that they are not retained by this glass fiber filter.

             Because of the  somewhat  fragile nature  of the membrane, initial extraction of
neutral  compounds is not possible.  It is necessary to extract all compounds, then partition
neutrals from the phenols.  Our analytical scheme includes extraction of the membrane with 2
percent hydrochloric acid in methanol/methylene chloride, addition  of hexane and aqueous
sodium hydroxide and  partitioning.  The organic layer, which now contains the neutrals is
discarded.  The aqueous layer is acidified with HC1, MTBE and sodium chloride (for salting out)
are added.  After partitioning we discard  the aqueous layer, dry the organic layer over sodium
sulfate, K-D concentrate, add the  appropriate internal standard, and derivatize with BSTFA. The
extract is analyzed using GC/FID.

             Although there are detectable amounts of the alkyl phenols hi the neutral fraction,
there is a very good material balance, and  recovery of phenols in the acidic fraction is high. The
low recovery for 1-naphthol is thought to be due to  its somewhat unstable nature under acidic
conditions.

             Continuous 8 hr sampling at 10 L/min demonstrated good collection and retention
of phenols following a vapor phase spike,  generally >60%.   The less volatile phenols (e.g.
pentachlorophenol) are left on the teflon coated glass fiber filter. For these phenols, we still
achieve a very good material balance.   Analytes were not detected on the back-up sodium
hydroxide glass fiber filter.

             The associated GC/FID chromatograms show well resolved analyte peaks and a
clean blank.

             Conclusions, then, a strong anion exchange resin can be used to efficiently sample
phenols from air and water. It provides high  collection efficiency, high retention efficiency, and
field portability.
                                          570

-------
             Are there questions?

                                     MR. TELLIARD: Any questions?

(No response.)

                                     MR. TELLIARD: Thank you, Hazel.

Thank you very much for your attention. I would like a round of applause for our morning
speakers.

             It is lunchtime.  For those of you who come back, we have a real treat. You can
buy a performance-based method, you can purchase accreditation, whatever you want this
afternoon.  So, come on back, and we will see you right after lunch.

(WHEREUPON, a luncheon recess was taken.)
                                       571

-------
572

-------
    Anion Exchange Resins
        for Collection of
   Phenols in Air and Water
 Hazel Burkholder, Marielle Brinkman, and
           Marcia Nishioka
       Battelle - Columbus, OH

          Jimmie Hodgeson
      EMSL-EPA - Cincinnati, OH

            Joachim Pleil
AREAL-EPA -  Research Triangle Park, NC
                                     NKA/NM**a/1&-1

-------
      Air and Water Sampling with PUF

PUF: Polyurethane foam
     Air:  pesticides    240 L/min  (TO4)
     Air:  PAH          20 L/min  (IP-7, TO-13)
     Air:  pesticides      4 L/min  (IP-8)
     Water: PAH [Saxena et al; ES&T  H, 682, 1977]

-------
     Current Methods for Phenols
Waste Water: Liquid-liquid extraction   (604)

Air:         Aqueous NaOH impinger (TO8)
            Not validated
            1-5 ppb

-------
  Retention  and  Elution of Phenols  and  Organic  Acids
          from Anion  Exchange Resin  (AG  MP-1)
Initial  State
 Suspend AG MP-1
 In solvent in open
 chromatography column
-CH2N(CH3)3OH
.CH2N(CH3)3OH
 Retention
Attach phenol or acid
to AG MP-1
Added Material:

   HO
CH2N(CH3)3O-
CH2N(CH3)30-
                               Eluted Material:
                              H20
                              Neutral molecules
                              Basic  molecules
    Elution
  fcemove phenol or acid
  from AG MP-1
  Added Material:
HCI  : MeOH : MeCI2
  -CH2N(CH3)3CI
  •CH2N(CH3)3CI
                               Eluted Material:
                                 HO-
                               - Excess HCI
                               • MeOH, MeCI2

-------
Strong Anion Exchange Resins
Granular:        BioRad    AG MP-1
           38-75 itm
          75-150 /u,m
         150-300
        300-1100
Membrane: BioRad/3M     AG-1
          5 ftm particles in Teflon
            ("Empore")

-------
   Environmental Detection of Phenols
00
   Waste Water:      1 ppb  (1 /u-g/L)
 Drinking Water:   0.01 ppb  (0.01 \JL g/L)
Near-Source Air:      1 ppb  (~7ftg/m3)
    Ambient Air:    0.1 ppb  (~0.7 /itg/m3)
                                          NKA/NM**a/15-Ont

-------
            Analyses of Phenols
             Detection Limit      Instrument
Underivatized   1-10  /^g/mL    GC/FID; GC/MS
BSTFA            1  A^g/mL    GC/FID
               0.1  A^g/mL    PCI  GC/MS
PFBBr         0.01  /ig/mL    GC/ECD; NCI GC/MS
                                             NKA/NtNoKi/16-fl*

-------
                    Sampling and  Detection
                         Water                     Air
00
o
                   Waste       Drinking      Source       Ambient

  Lower Detection   1 ug/L    0.01 Atg/L   7  i^ig/m3     0.7
  Volume             1 L          1 L        7200 L       7200 L

                                             (12 hr x 10 L/min)
  Final cone       1 /tg/mL    0.01  ^tg/mL   50 iig/mL      5 /Ltg/mL
                                                               NKA/Nllhlok»/16-06ti

-------
00
Advantages  of Anion Exchange
            for Water

•  No separatory funnels
•  No continuous extractors
•  No refluxing solvents
•  No emulsions
•  Reduced volumes of toxic solvents
•  High extraction efficiency
•  High retention efficiency
    —  Chemical bond — no breakthrough
                                            NKA/NW**«/15-06

-------
00
S)
Advantages of Anion Exchange for Air

      •  No glass impingers
      •  Lightweight
      •  High collection efficiency
      •  High sampling rates (>5 L/min)
      •  High retention efficiency
         —  Humid air has no effect
                                            NKA/Ntol**a/1S-Oe

-------
      Disadvantages of Anion  Exchange
oo
u>
•  Efficient passive sampling -
   must protect before use

•  Phenols in styrene divinylbenzene
   polymers - must clean  thoroughly
                                               NKA/NMfeta/16-10

-------
   LSE  of Phenols  and Acids
   from  Water
 Silanized glass
chromatography
      column
 0.5 g AG MP-1
     Silanized
    glass wool
  1 mL of 0.1 ug/mL
  analyte mix in MeOH
BioRad AG MP-1
100-200 mesh resin
70-150 urn, chloride form
                    584

-------
   Analytical
   Procedure
Elute AG MP-1:
6 mL 2% HCI in
MeOH:MeCI2 (20:80)
5 mL MeCI2 (x2)
Na2SO4 (ca 2 g)
  drying column
                                      10 mL H2O
                                      130 uL cone HCI
                                             Discard
              K-D concentration
              Add IS: 3,4-diCH3-phenol for phenols
                    4-CI-benzoic acid for acids
  Acids
 Solvent exchange to MTBE
 Methylate
 GC-ECD
              Phenols
 - Solvent exchange to acetone,
  dilute to 1 mL
 - PFBBr derivatization
 - GC-ECD
                       585

-------
Ul
oo
        1 ug in 100 mL vs1 ug  in 1L

             LSE of Phenols from Water with AG MP-1
                    Methylation and GC-FID
         V
                                                 1 ug in 100 mL



                                                 1 ug in 1 L

                                                 silanized glassware

-------
00
      O
      CO

      o
      Q.
      W
      0)
      CC

      Q
      O
      LJLJ

      6
      o
              of  Phenols from  Water  with  AG  MP-1

                         PFBBr and GC-ECD
         200 H
         150 -
100-
         50 -
                                        Spike: 0.1 ug

                                      Analysis: 1:10 dilution
                                                 i  i   i   i   i
              13
           15
17
                                Retention Time (min)

-------
Ul
00
oo
          LSE of Acids  from Water with  AG MP-1
        400
">  300


Q>
in

|  200
(/>
DC


o  100-

6
o
                           Methylation  and  GC-ECD
                                                      Spike: 0.1  ug
                                                      PCP

                                                        \
             DiCI-acetic
                4-Cl-benzoic (IS)
2,4-diCI-benzoic
             4-NO2-phenol

                /    2,4-D

               *.-
2,4,5-T

 \
                                                      Blank
         100 H
                                            JL
              I   I   I   I  I   I   I  I   I   I   I  I   I   I   I  I   I   I   I

              5      7     9     11     13     15     17     19     21    23
                                   Retention Time (mln)

-------
Method Recovery  and LSE  Efficiency

         of AG  MP-1 for  Acids
  Simulated 0.1 ug/L Drinking Water, Methylation and GC-ECD
100
  0)

u, O
00 Q

  Q)
  DC

  •4-"
  c
  0)
  O
 75
 50
 25
                                               Method Recovery

                                               Mean = 79 ± 9
                                           LSE Efficiency

                                           Mean = 79 ± 12

-------
  Vapor Spike
   Experiment
 GC
Oven,
55°C
                            He
                           Carrier
                            Gas
                             KA\Nfehioka5-13
             590

-------
Analytical  Procedure

     •  Elute 1 g AG MP-1 with
   *  10 ml 2% concentrated HCI in
jf    15:85 methanol : methyl-t-butyl ether

     •  Add to separatory funnel
       15 ml 15%aq. NaCI
        7 ml methyl-t-butyl ether
       Organic Layer

    K-D concentration to 1 ml
    IS for GC/FID
       3,4-diCH3 -phenol
    IS for GC/ECD
       Br2F8-biphenyl
               Aqueous Layer

                • Discard
   800
   GC/FID
200
Dilute to 1 ml
Methylate
GC/ECD
                                             KA\Nijl**o5-1 *

-------
70






60






sol






40






30






20
             Phenol  Standard GC/FID
c
o
a

-------
          Recovery of Phenols vs Face Velocity
              at 100 ml/min Sampling Rate
                 Spike   200-400 Mesh AG-MP-1
         0
OJ
    Alkyl
  Chloro
    Nitro
   Other
10  20  30 40  50  60  70  80  90
                Velocity
100
~J Corrected
  Recovery, %
      98
     102

      76
      97

      73
     101
                                      90
                                     105

-------
Recovery  of  Neutral Compounds in Neutral Solvents
         0   10  20  30  40  50  60  70  80  90  100
  Biphenyl
                                            Recovery, %
89
Naphthalene
84
 Fluorenone
91
   Legend:
                                                    XA\Nbh>oko5-'. I

-------
    Demonstration of Separate Extractions of

         Neutral Compounds and Phenols


Experiment: Spike 500 A* I solution of analytes to dry AG MP-1
          Extract AG MP-1  with Mtbe (x3) and Methanol (x2)
          Extract AG MP-1  with acidic Methanol: Mtbe

                      Average Total          Average Corrected
Results:             Recovery in Neutral       Recovery in Acidic
                   Solvent extracts, %    Methanol: Mtbe extract, %

          Alkanes          95                     0
          Aromatics        98                     0
          Ketone           96                     0

          Alkyl Phenols      0                    86
          Chloro Phenols     0                    104
          Nitro Phenols      0                    89
          Other             0                    100
                                                         ko/nohioko/5-20

-------
                                   o
                     C 2-alkyl phenol
                   C 3 -alkyl phenol
                              C 3 -alkyl phenol



                                ACA
                              ACA
                       ACA
                                                    ACA
QL
                                                (palmitic add)
                                        ACA
                          PHTH
                      PHTH
                                             m


                                             o
                                             o

                                             i
7
o
o>

-------
 Air Spiking with AG-1 Membrane
TCGFF
AG-1
TCGFF
NaOH-GFF
d = 9 cm
                       Air 10 L/min
phenol spike
                           1/8" gasket
Hi-Vol Air Sampler Inlet

-------
    Analytical Method for Membrane AG-1
      Extract
Ul
VO
oo
Add
Partition
Add
Partition
Derivatize
-   2% HCI in 65:35
          MeOH:DCM
—   Hexane, aqueous NaOH
—   Discard organic (neutrals)
-   Aqueous HCI, MTBE
—   Discard aqueous
-   BSTFA
                                              NKA/NW**»/15-11

-------
            Analytical Method Recovery
Alky!
phenol
2-CH3
4-CH3
2,4-diCH3
Nitro
2-NO2
4-N02
96
84
87
55
99
88
(2*; 98+)
(11; 95)
(8; 95)
(34; 89)

Chloro
2-CI
4-CI
2,4-diCI
pentaCI
Other
1-naphthol
2-naphthol
89
94
93
100
63
83
* Recovery in neutral fraction
* Total recovery; material balance

-------
                   Recovery of Vapor Spike
              AG-1 Membrane   10 L/min   8 hr
0\
o
o
Aikyl
  phenol
  2-CH3
  4-CH3
  2,4-diCHg

Nitro
  2-NO2
  4-NO2
                                    Chloro
72 ± 1
60 + 4
74+2
35+5
2-Cl
4-CI
2,4-diCI
pentaCI
NT
81 + 4
75 + 0
12 + 4(79*; 91+)
                                    Other
                  60+6
                  52 + 17 (49*; 101+)
                     1-naphthol  46+2
                     2-naphthol  57 + 8
     * Recovery from TCGFF
     + Total recovery
                                                            NKA/NtoNoka/1S-14

-------
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3
                                                        Phenol standard
                         Elution Time, Minutes
                                601

-------
s
              Conclusions

Strong anion exchange resins can be used to
efficiently sample phenols from air and water

     •  High collection efficiency
     •  High retention efficiency
     •  Field portable
                                                    NKWNI«hlok«/16-ie

-------
Os
s
           Acknowledgment

Battelle acknowledges support for this research
from U.S. EPA on Contracts:

       68-DO-0007    AREAL/RTP
       68-O2-4127    AREAL/RTP
       68-CO-0003    EMSL/Cin
                                              NKWNHhk*»/16-15

-------
604

-------
                                        MR. TELLIARD:  Could we get started, please, for
our afternoon session?

             This afternoon, we are going to address basically two small issues in the  first
session.  One is a derivation of an approach to methods development consolidation and use
called, basically, performance-based methods.  In addition, a later speaker will talk on lab
certification.

             The application of performance-based methods are going to be expressed by Mike
Conlon from the US EPA and Richard Turle for Environment Canada.

             Our first speaker is Mike Conlon from the Office of Ground and Drinking Water,
Drinking Water Standards Division, and he is going to give you basically the Agency's approach
as to the implementation  or use of performance-based methods.
                                        MR. CONLON: Thank you, Bill.

             As some of you know, I have been associated with Bill for almost 18 years now
in one way or another. I have spent a lot of Bill's money; Bill has spent a lot of my money.  But
in spite of all that money we spent, this is the first time he has ever let me come to Norfolk and
I thank you for the opportunity today.

             One of the things that one of the audience said to me on my way up here was "...I
remember when you were Bill's boss..." and it was funny, because I tried to think of when I was
Bill's boss. The best I can ever remember is being a tolerated associate, never a boss.

             Well, maybe now as we get into performance-based methods, Bill  and I  will
probably have not 100 percent meeting of the minds, but at least we will come a little bit closer.
I think both of us realize that there are major changes that need to be made, some major steps
that need to be  taken in the way the Agency approaches the specification and the acceptance of
alternative chemistry methods.

             Jerry, could you put that first slide up there?

             I want to  tell you I use slides that I steal from other people. I don't believe in
coming up  with brand new stuff all the time.

             This particular slide...and for those of you in the back of the room who cannot see
the  text, don't  worry.   The  thing I want you to  really focus  on  is  the expression on the
decisionmaker's face.
                                          605

-------
                                    EPA IM/DA

 Benefits:

 •  Improved decision making


 •  More flexible/adaptable organization and systems
                                                      ~^r
     More effective identification, definition, collection, /r
     storage, and dissemination of data
     More efficient development and use/reuse of systems
  From the brain of Rick Jackson
                                                              \
             You have all seen that glazed over look, the vacant stare. You have all contributed
to that.  You have helped him have that glazed look, that "...gee, what the hell do I do now..."
kind of look. All too often that look is caused by information that doesn't fit the decision being
made.  And what I would like you to keep in mind is there is no use for chemistry data unless
it results in improved decisionmaking and putting some light behind those eyes. It is not good
enough to simply know that you have measured something.

             My purpose is to help improve that decisionmaking process, and very often, quite
frankly, the  character on this slide has become a self-portrait because we didn't know just how
information was developed. But in spite of the need for certainty we want to see  more flexible
adaptation in how we generate information.

             We also need more explicit organization and systems, and I want to see more
effective identification, definition, collection, storage, and dissemination of the information.

             Now, as you have suspected that all applies to chemistry and the work that we do.
This particular slide, however, happened to be put together by people in an Information and Data
Processing group.  Yet, we all have the same objective and in many respects a common problem.
                                          606

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             If I am successful this afternoon, you are going to go away from here saying "...I
didn't learn anything new".

             "...All he is talking about is going back to some old basic science principles...."
That will mean that I have been successful if you come up with that understanding.

             Telliard has accused me of being a marketeer of performance-based methods, and
that is an understatement. If you have any sense when I  am done here today that I am neutral
on the subject;...if you  leave your name and address, I will come by your house and preach hi
your front yard.

             I am not neutral.  I believe  very strongly that the Agency has to take some steps
very quickly and needs to change the way it has done business.

             I get ahead of myself. Over the years...can I have that next slide?  We got started
                                    Background

                  Asychronous adoption of environmental
                  legislation

                  Validation and approval processes varied by
                  program

                  Formal evaluation/validation processes
                  cumbersome

                  Formal equivalency processes basically nonexistent
               From the brain of Llew Williams
in this business with basically the adoption of different kinds of legislation. We had a bunch of
uncoordinated and redundant methods developments. We had 15 or 18 different laboratories hi
the  Agency, each one being perfection itself knowing what the answer was,  not willing to
recognize that  anyplace else in the country  had any  skill, talent,  or knowledge that  they
themselves didn't possess at a higher level of understanding.
                                          607

-------
              We had four different validation and approval processes that varied by program.
Now,  the purpose of that was not to keep the folks outside the Agency off balance; it was to
keep the bureaucrats in charge of the methods.  "...Make sure that my method of approval was
just a little bit tougher than yours..."

              We "had formal evaluation and validation processes that took forever. Now, you
are going to say hey, this isn't all in the past, and yeah, that is the point of all this.  Some of it
needs to be in the past.

              And we had some formal equivalency processes that were basically  nonexistent.

              I have got to tell you a  little story.  About a year ago,  I sent  a microbiological
procedure to Cincinnati to have it validated.  The term of art is, "...is the method equivalent?.."
And I  got a memo back that said no, it is not equivalent.

              So, I called them up, and I said I had looked  at the data, and the test looks to be
more sensitive, more accurate, if there  is such a thing,  less  biased maybe,  and it seemed to be
faster, and it  cost 10 percent of what the conventional method cost.  I  asked, "what is the
problem?"

              He said well, you asked if it was equivalent. This one is more sensitive, costs
less, and is faster. I said oh, okay, now I understand the problem.
                              Background (continued)

                   Long leadtime requirement
                   -  One-at-a-time method development
                   -  Within - and among - lab evaluation
                   -  Prolonged public comment period

                   Public and Congressional pressure

                   Results of the tension?
                   -  Methods by committee
                   -  Prescriptive methods for contracts
                   -  Sub-optimal science
                From the brain of Llew Williams
                                           608

-------
             We had long lead times.  We felt we had to prove...still do..we have to prove
every scientific fact.  We went through a one at a time method development within and amongst
labs, we had public and Congressional pressure, and the results of the tension, was that we had
methods by committee.

             We had prescriptive methods for  contracts, and it has  resulted in suboptimal
science in both some of our contract efforts and in our regulatory requirements.

             Now, before I move to the next slide, I want everybody here who has used an EPA
method without change to stand up in place. I want everybody here who has ever run a drinking
water sample method without change to stand up.  (No one stands - but there are chuckles).

             Yet our rules say you follow our methods without change, except what is allowed
in the procedure.
                                     In the Past
                  Take what was available
                  - Live with it if you could
                  - Improve it if you could not

                  Balance quality with practicality/throughput/cost

                  Emphasize multianalyte methods to address long
                  list of regulated chemicals

                  Regulate what could be measured
               From the brain of Llew Williams
              Quite  frankly,  in many ways, we get a bum rap.   Our methods allow more
flexibility than people are willing to give us credit for, and on the other hand we are not willing
very often in our audit processes to allow the flexibility that exists, because the people who are
doing the audits may not have the full understanding of what the method was supposed to do.

              So, the way we deal with that is:  it is a hell of a lot safer to say "...do you follow
the methods?..." And the lab says "yes, we follow the methods, especially when the auditor is
                                          609

-------
there.  See? And I have them written down right here.  This is the EPA book, and I can show
you.  I have got finger marks and pencil smudges in absolutely the right places." " Oh, okay.
Well, then, everything is all right."

              So, what happens is we end up scamming each other. I am not talking now about
crooks.  Okay? I am talking  now about good-hearted, well intentioned smart analysts who are
working to give a better, more accurate, more reliable and cheaper result that actually serves the
purpose better.

              We all know there are crooks out there. We all know there are cheats and liars,
and you all know who they are. Every one of you has at least got your own  list of suspects.
Some of them are in your competitors'  labs, and some are in your own, but we will leave that
alone for now, I am not talking about those kinds of problems. I am talking about what should
be legitimate changes in methodologies  created in an environment in which they are suppressed.

              We have finally come to  realize that at a variety of levels in the Agency.  It only
took us 3 years, and we even got Telliard to admit it...well, at a sort of superficial level.  He is
still  not  prepared to give up his particular  set of methods, but  he is willing to  consider
alternatives that might also work.  We are actually going to use the transcript of this meeting as
evidence in our behalf.

                                        MR. TELLIARD:  That is why  I am not saying
anything.

                                        MR CONLON: What has happened in the Agency
is that there is a group of people who has gotten together under the auspices of the EMMC. That
is the Environmental Methods Monitoring Council.  It is a physical science policy group that is
one of the  really good interoffice organizations and has the potential for being  one of the good
longlived interoffice organizations.

              Its purpose is  to try and bring some sense and  some order out of this mess
associated  with chemistry  methods.  All of us in the different offices, we all have our methods.
The solid waste people have their method, the air people have a method, the water people have
their method.  The water people actually have two methods.

              Some of them  are validated and some of them aren't.  Pick the one you want and
take your chances.

              One of the aspects coming out of the EMMC group, though, is they have fostered
a committee called the Performance-Based Methods Committee. It is a group of people who are
kind of remarkable in the Agency.

              The committee has been  in existence a little over a year. But the remarkable part
is the same people come to the meetings all the time. That is the fascinating part.


                                          610

-------
             I have been in the business more years than I care to remember, and the one thing
that never happened on interoffice committees was you always got the same people, because
people would lose interest.  In this particular group, the same people are coming, the same offices
are being represented, and they are making material progress.
                          Performance Based Methods
                  Write Method in EMMC Format

                  Calibrate with reagent blank and minimum of 4
                  standards bracketing expected range

                  Use DQO's of the Program Office(s) to establish
                  performance range

                  Establish precision and bias with a minimum of 4-7
                  replicate spiked  matrices using certified QC materials
                  at levels  required to  satisfy DQO's

                  Verify acceptable performance in a blind PE study
                  (alternatively, with a certified QC sample from an
                  external  source)
               From the brain of Llew Williams
             What they have done is they have focused on what it would take to actually come
up with a performance-based method process that would work. The first thing that they agreed
on was that we had to have some target.

             The second thing they agreed on was we will  always have a reference method.
Now, let me say that again.  We will always have a reference  method especially in the drinking
water program.

             I am speaking now primarily about the Drinking Water Office, but what I say, I
believe, will be applicable to the other offices as well. There will never be a regulation that
deals with chemistry that is politically acceptable unless you  can demonstrate  that you can
                                         611

-------
measure at the compliance level.  So, you will always have to have an analytical method that
demonstrates you can measure at that compliance level.

             In the Office of Ground and Drinking Water, that target...or back in the olden
days, some of Bill's QA/QC friends used to call it the DQO, the data quality objective...will be
a derivative of the adverse health effect.  It may or may not be a derivative of how well a
method can measure, in fact or how low a method can quantitate.  What a method can achieve
and what a laboratory has to demonstrate to be certified are two different questions and should
not be  confused especially by us folks at EPA.

             We put out a rule last spring...I am sorry, a year ago, and we had an MCL at 600
ppb. We  had a required performance level for the laboratory at  0.7 ppb.  Now, can anybody
explain to me the logic of that?

             I signed  it.  It went over my desk. I agreed with it.  I missed it.

             We had  a copper number that was fairly high, a copper action level in our lead
and copper rule.  We had a required performance level for a laboratory to be certified two orders
of magnitude below the action level.  And in those two orders  of magnitude  was a shift in
measurement technique in which you drove  the price up by a  factor of four, at least, that
particular  problem we have fixed  in a subsequent modification to the rule.

             So, what we are trying to do in the Drinking Water program is separate the idea
that the target has to be what the reference method is capable of measuring.  We will have a
reference method. It will calculate an MDL (or, if Larry Keith has his way, an RQL instead of
our present PQL) and we will also set a separate performance level for lab certification, please
keep that in mind.

             Now, I want to talk about how we might go about demonstrating that your own
laboratory could achieve whatever is required.

             Remember, there is a reference method.  There will also be a  separate target, a
nominal concentration  X plus or minus  some confidence interval, an MDC and confidence
interval and an RQL, with its own confidence interval.  Hopefully, the confidence interval will
not overlap the adverse effect level.  I mean, that is part of our theoretical objective, to set RQL
requirements such that  the upper error band does not exceed the MCL.

             In  the past, the condition was  you had to live with what was available.  You
balanced the equity and the through-put, and you emphasized the multi-analyte methods if you
could.  And we regulated what could be measured.

             I am not advocating that you deviate from any rules. Our rules say follow the
method, you follow the method.   Please do so until we get this other new rules in place.
                                          612

-------
             The Performance-Based Methods Committee has actually looked at the situation
that they believe would provide adequate documentation for somebody using alternative method
or a derivative of one of the Agency methods.  These could include a fairly major significant
change, maybe even a shift in solvent, maybe even a shift in extractions, who knows, maybe even
a shift in detectors.

             Basically, it comes down to the idea that there  would have  to be an  initial
validation.  There would have to be, more or less, a routine validation in the particular matrix,
and then some performance check stuff.

             First  of all,  they  established data quality objectives (DQOs). Those, as I said,
would come from the programs and for drinking water derive from toxicological  data.  The
DQOs would be derivatives of the adverse effects information, maybe or a combination of what
we wanted to achieve using a specific technology - or what we thought was allowable for other
reasons under a particular drinking water rule.

             To benefit from, you would have to have a written method, and I will say a little
bit more about that  later.  You would have to have a required performance range. If I have an
MCL, for example, that is at 10 ppb, we are not going to let you use a method that operates from
0.5 to 1 ppb and then goes to hell and gone when you get above 2 or 5 or vice versa.

             I know that seems pretty silly to have to say  that out loud, but it is amazing some
of the stuff that the  Agency gets sent.
                            Initial Validation Criteria

                  Established data quality objectives
                  Written method
                  Required performance range
                  Calibration
                  Precision
                  Bias
                  Acceptable performance in PE study
                  Detection limit
                  Holding time
                  Preservatives
                  Surrogates, where applicable
                                         613

-------
             You would have to have, obviously, some calibration data, some precision data,
some bias data.  For those of us who are a little older, bias is now what we call accuracy.
Acceptable performance in a PE study.

             Let me answer the question now.  If we don't have PE samples available, then
there would be a provisional acceptance.  Of course, on the other hand, if you have done your
calibrations right, then participation in a PE study is a useful but not necessarily essential part
of the process except from a regulatory point of view.

             I don't believe that the Agency is ever going to accept alternative methods
without participation in fairly serious PE studies, and I don't think it should.

             You would have to specify detection limits, holding times, preservatives, and
surrogates where applicable.

             Jerry?
                          Routine Performance Criteria

                  Calibration, precision, bias
                  Internal and external check standards
                  PE studies, surrogates, where available
                  Independent performance samples
                  Matrix-spiked duplicates
                  "System blank" (through whole method)
                  Routine calibration checks involving external or
                  internal reference materials over required range of
                  the method
                  Acceptable results on blind PE study or analysis
                  of external, certified QC sample
                  "Batch" = <20 samples of similar matrix prepared/
                  analyzed together or in series
              We would require documentation on routine performance criteria, calibration,
precision and bias information again, internal/external check standards, PE studies, surrogates
where available, independent performance samples.
                                          614

-------
              This is a little bit different than what we would mean by PEs, performance
evaluation sample on sort of a round robin run by the Agency. This probably will create a
whole second market for people who are supplying performance standards.

              Here comes the one that all of you folks know most about, the matrix spiked
duplicates.  We have played these games in the Agency...and games is a bad word.  It is not
at all disingenuous.  We have pretended that somehow the standard methods work hi all the
matrices, and then we turn around and we say in order to be able to run a method, you must
test it in your matrix.

              By the time people get done running a method in their matrix,  very often, they
have made changes in the method. You have to do it hi order to make the method work.

              What  we are doing is we are sort of fessing up  to that condition, and in a
regulatory context being a lot more open with it.

              We would require you to run system blanks, routine calibration checks
involving external or internal reference materials over the required range of the method,
acceptable results on a blind PE, and...here comes one  of the stickers for  the high output
laboratories...we would begin to define batches as  20 samples  in a similar matrix and begin to
require specific calibrations in those intervals.

              There  is no free lunch.  This  is not  necessarily going to  result in less
documentation in your laboratories.  It would, however, provide you with a ratification of
some of the work changes you have already made, and it would provide you with a lot more
flexibility in  coming up with the innovative, cheaper techniques.

              I believe very strongly that unless we make some serious changes in
measurement cost, first, it is going to kill us politically, then it is going to kill us
economically, and then it is going to kill us physically.

              I think we are in a situation in this country right now where we have need of
analytical data, and the data costs too much. Unless we do  something  to help the venture
capital people or the innovative technique folks to move toward faster and better analytical
measurement techniques across the board, not just in drinking  water but in everything else, all
of it will go for naught, because the country will finally decide that they  can't afford it, and
compound by compound regulation, over the next  ten-year period will be hi jeopardy.

              I don't think that is going to happen.  I think  what will happen is we will come
up with better and faster analytical techniques.  Each of you who has spent considerable time
hi the laboratory probably has in your heart of hearts one or two ideas  that will work better,
places where we could save a hell of a lot of money and improve our accuracy at the same
time.
                                          615

-------
             What we are trying to do...there is a growing handful of us in the
Agency...what we are trying to do is create an environment in which you can make positive
changes in relative regulatory safety.

             Let's go to the next slide.
                         Performance Check Frequency


                  System Blank - Each batch or new reagent

                  Calibration check  -  Undecided

                  Matrix supplied duplicates - Each batch

                  PE study participation -  1 or more/year

                  Surrogates - As in reference method
             Finally, we have a performance check frequency requirement, run system
blank, calibration check, matrix spike dups, et cetera, et cetera.

             Now, all of this is great, but if you are actually in a laboratory, the real hard
part is what do I have to do to prove it. One of the members of our Performance-Based
Methods Committee, a fellow by the name of Joe Slayton, who, I have got to tell you, if Joe
tells me to go to jump out a window, I will do it, because I know good things will happen.

             Joe is a pretty bright fellow.

                                       MR. TELLIARD:  I will have to talk to Joe.

                                       MR. CONLON:  Bill is going to talk to Joe and
see if he can arrange that.

             But Joe has put together a draft, and some of us have critiqued a little bit on it,
a draft of what a basic documentation package might look like.  What would a reporting form
look like?
                                         616

-------
             As I said, there is no free lunch.  Let's go to the next slide.

             To be able to use one of these methods, you are going to have to keep it in our
format.  It is the only thing us bureaucrats got left.  We are going to require format if nothing
else.

             You have got to calibrate with the reagent blanks, et cetera, et cetera, et cetera.

             The key to this, though, is going to be in the documentation.  One group within
the Agency opposes the use of performance-based methods, because they say it will make
audits and lab inspections harder. They will actually have to look more and more at data.  I
agree that for some auditors, this program means more work.  I believe we ought to be
looking more and more at data anyhow.  Reviews of procedures alone don't get you answers
to the tougher questions.

             So, what we are going to do, is to trade off a much more explicit, consistent
documentation process for more flexibility in the actual use of whatever measurement
techniques that you choose.

             Jerry Thoma with Environmental Health Laboratories characterizes our
approach as loosening the grip and tightening the control, and I suspect that he is probably
right. We are not giving up all that much.  In fact,  what I believe will happen as a result of
this new documentation process is that the science will  actually improve.

             People will feel comfortable exercising more science judgement.  There will be
more responsibility on the analyst, and there will be more responsibility on the laboratory
management to see that what comes out of the lab is actually a correct answer, not one that
simply was generated by an EPA-approved method.

             What I would like to do, is to distribute 100 copies of this documentation to
those folks who happen to get here right at 1:30.  So, I would appreciate it if, as the copy
passed in front of you, if you weren't  sitting here at  1:30, we will have to get you your copy
later.
                                          617

-------
o\
00
                            Performance Based Method System
               Checklist (Initial Demonstration of Method Performance  )
Program:
Analyst:
            Analyte:
                                     Matrix Type2:
    1 Performed Each Time There Is A Change In Equipment, Personnel Or Procedure
    2 Major Matrix Types (Wastewater; Drinking Water; Hz. Liq.; Hz. Solid; Air)
    From the brain of Joe Slayton, et al.

-------
         Criteria:
Results:3:
DQOs (Program Specified4)
ON
Written Method (EMMC Format)
Copy of "Reference Method" On-Site
Listing of Difference Between PBM
& "Reference Method"
Y/N
Y/N
Y/N
Performance Range5 ( - )
Linear Working Range/s
Calibration Stds. (units6) Mblk:
Calibration Curve Available:
Slope & Line (Sensitivity):
• • *
Y/N
—
—
—
(-)
Mblk: : : :
     3 All Associated Supporting Data Necessary To Fully Reproduce These Analytical
      Results Must Be Retained On File
     4 Reflect Program Needs And  "Reference Method" Performance
     5 The Cone. Range Specified By The Program DQOs Is Of Primary Importance.
      However, Additional Ranges May Be Delineated.
     6 Cone. Of Calibration Standards Bracket The Measured Cone. For The Samples
      And Lowest Standard Is At 4 Times The MDL
     From the brain of Joe Slayton, et al.

-------
o\
6J
O
Preservatives & Holding Times7:
Interferences8:
Qualitative Identifications:
Perfromance Evaluation Study:
"Performance Evaluation"^:
Study Title/tf:
Surrogate Recoveries:






   7
   9
If Different From  "Reference Method"

Detected During Matrix Spikes, Experience Or As Indicated In  The Literature

List Analytes For  Which "Not Acceptable" Results Were Obtained. Corrective

Actions Taken Must Be Recorded.
   From the brain of Joe Slay ton, et al.

-------
OS
Spike Levels (Use External QC Material):
Number of Matrices:

Matrix
Description:
Precision (Std. Dev. (n-1))
Bias (% Recovery)
Method Detection Limits
Lab Pure Sub
Water Matrix A




Sub
Matrix B




Sub
Matrix C






Sub
Matrix D




Sub
Matrix E




DQOs




        From the brain of Joe Slayton, et al.

-------
ON
M
to
         Analyst's Name:


            Signature:


            Date:
Manager's Name


     Signature:
                10.
                                     Date:
                      QCO's Name:


                         Signature:


                         Date:
    10 As Personnel Are Replaced, The Information On This Form Must Be Signed By The Current

     Responsible Official.



    From the brain of Joe Slayton, et al.

-------
                   Performance Based Method System

     Checklist (Continuing Demonstration of Method Performance)
      Program:
Analyst:
      Analyte:
Matrix Type11:
                                        Matrix Supplement:
ON
to
     Major Matrix Types (Air; Wastewater; Drinking Water; Hz. Liq.; Hz. Solid)
   From the brain of Joe Slayton, et al.

-------
to

Criteria:
Frequency

Required12
Frequency
RESULTS
Acceptable13

Required12
Results

System Blank14:
Calibration151
Linear Working Range Verified
Calibration Check Std.
Fresh Ext. QC Material


2/Batch16
I/Batch16
J/Batch16
Y/N
Y/N
Y/N
Y/N


     12 Reflect Program DQOs And "Reference Method" Performance
     13 The Continuing Performance Checks Must Be Acceptable Or The Problems Must Be
       Corrected And The Affected Samples Reanalyzed
     14 Carried Through All Steps Of The Method
     15 Cone, of Calibration Standards Bracket The Measured Cone, for the Samples And
       Lowest Standard Is At 4 Times the MDL
     16 A "Batch" Is Defined As "A  Group Of Samples Not Greater Than 20 Of A Similar
       Matrix That Are Analyzed Together  Or In Series
     From the brain of Joe Slayton, et al.

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Performance Evaluation Study:
"Performance Evaluation:17
Study Title/*
Surrogate Recoveries:
Matrix Spike Duplicate Analyses




1/Yr


1/BatcV
Matrix
Y/N

Y/N
Y/N




to
     17 List Analytes For Which "Not Acceptable" Results Were Obtained.  Corrective Actions
        Must Be Recorded
     From the brain of Joe Slayton, et al.

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     Analyst's Name:

          Signature:

          Date:
                Quality Control Officer's Name:

                                     Signature:

                                     Date:
to
Manager's Name18:

         Title:

        Signature:

         Date:
     18 As Personnel Are Replaced, The Information On This Form Must Be Signed By The Current
       Responsible Official.
     From the brain of Joe Slayton, et al.

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              There actually will be complete copies in the proceedings of an updated
version of this form.  It is  basically a 5-page form, the results of which, when, and if you fill
them all out, you have presumably entered all the data pieces; I would expect people to
understand and be able to judge whether or not your method actually was equivalent to, or
maybe even better than or less than the reference method.  In any event this documentation
certainly should satisfy most auditors and inspectors, and demonstrate that the method you
were using would measure what it was supposed to measure.

              When we put out the proceedings, there will be a name and address where you
can send your comments.  If you want to send them before then, send them to me.  My
address is in the program. And we  will see if we can consolidate them and begin to use a
more formal docket process to review the comments we receive.

              We are very serious.  We are going forward with this in the drinking water
program.  We will probably make it a part of the so-called 6b proposal that is due out next
year.

              In that proposal, we will specify analytical requirements for somewhere
between 15  and 20 compounds. This notice will articulate what we think the reference
methods are capable of achieving and what level of performance is necessary for a lab to be
certified.  In order to maintain some consistency between the old way in which we calculated
MDLs and PQLs and the old ways we required people to document what they were doing, we
will  set some equivalency between the reference method and what would have to be
demonstrated using this new performance-based  system.

              But in the main, the record keeping  requirements would be pretty much what is
being passed out here.

              There will be a separate piece of paper that will be available  later on, maybe at
the door, and it is a form that talks about certification of laboratory results.  One of the
essential parts of this program is a requirement that the analyst and the management of the
laboratory certify the results and that what is in this 5-page documentation set that you see
was  actually what was done.
                                         627

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oo
WE CERTIFY that the methods
     in use by this facility
  for the analyses of samples
   for the programs of the
 U.S. Environmental Protection
        Agency have:

-------
OS
to
1.  Met the Initial and Continuing
   Demonstration of Method
   Performance Criteria as specified
   under the PBMS.

-------
2.  Written SOPs available on site
   in EMMC format (a copy of the
   associated "Reference Methods "
   are also available).

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    In addition, WE CERTIFY that the data
   associated with the Initial and Continuing
     Demonstration of Method Performance
      Criteria are complete (including the
      mandatory PBMS Checklist), that all
    necessary "raw" data to reconstruct the
       analyses are retained,  and that the
    associated information is well organized
and available for review by authorized inspectors.

-------
Analyst's Name:



Signature:	
Date:

-------
             QCO's Name:


             Signature:	
OS
U)
U)
             Date:

-------
Manager's Name:
Title:
Signature:
Date:

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              That is not an accident.  There is only one criminal violation.  It is not criminal
under the Safe Drinking Water Act to deliver bad water.  It is only criminal to lie about it or
to submit or to generate bad data.

              So, what we are going to do is require generators of information under the Safe
Drinking Water Act to certify  its accuracy.

              In exchange for that, what you get is a much greater level of flexibility in your
analytical techniques than the Agency has ever allowed before.

              Thank you.
                                          635

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                         QUESTION AND ANSWER SESSION

                                        MR. TELLIARD:  Any questions, comments,
suggestions?  Let me, before Jim gets going, point out a couple of things that Mike touched
on.

             Presently, in the 600 series, the dirty water techniques as opposed to the 500,
Mike's methods, there is a provision that you can alter the methods.  This is one of the things
that Mike points out.  We don't advertise this for some reason.  I don't know why.  But you
can make changes to a method, and it specifies what you  must do to show equivalency.

             In the case of the 1600 and 600 series methods, it basically means if you want
to change an extraction technique, a column, a temperature ramp, you could probably do that
and still meet the method specs.  You run the first four start-up samples like you did to show
proficiency, document that, keep it in the back of your folder so that when your  gestapo kick
in your door  and come to audit you, you  say see, I did that and that is why  I went to...I
wanted to run my samples through peanut butter before I  analyzed them.

             So, that is already in existence. That capability for change and flexibility is
already there.

             The other thing is there are certain methodologies for which performance-based
methods, of course, do not apply, and those are  definitive methods such as BOD, absorbable
organic halides, things along that line where the actual technique defines the measurement.
Oil and grease, one of our favorites, the cutting  edge of science.

             All of these things that those methods, of course, by their procedural format
define the analyte would not be amenable to that.

             The other thing that is inherent in this is that it does take away some of the
vulnerability  that we all know you do it out there but then you don't tell us  and  if you get
caught, then we have this thing called persecution, prosecution, or plagiarism,  whatever it is.
By having this  flexibility and documentation, it  allows you to make these changes as
necessary in your matrix and not have the liability for it.

              So, now that I have made my 2-cent advertisement, go ahead.

                                         MR. RICE:  Jim Rice.  It is all very interesting.
I haven't had a chance to look at it any more carefully than your presentations, so with that in
mind, I did notice one thing in passing that it said the data quality objectives will determine
the detection limit.  Now, that is intriguing.
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              How do you...is someone by fiat simply going to determine that is the detection
limit of the method?  We have been talking at great length about how one really establishes a
valid detection limit.

                                        MR. CONLON:  Well, let me answer that,
because if I said that, I was wrong.  I do not believe that an MDL or a method detection limit
should be the DQO. In fact, in my example where I said we had an MCL, a maximum
contaminant level of 600 and then for some reason, we had an MDL of 0.6, what I should
have said was that what we should do is recognize and calculate what the MDL is but then,
separately, establish what we think we need to achieve with the method.

              In the case of glycosate,  I don't believe we need to be able to measure at 0.6.
I think it is more likely to be somewhere closer to 100.

                                        MR. RICE:  Well, I will be happy, and I will
send you a copy of the paper that I gave yesterday which addresses this area, and it is not
quite that simple.

              One of the problems that one really faces in the whole area with all of our
methods where we try to analyze at the trace concentration in the environment, the whole
history is that these methods are constantly pushed to the low end of anything that is
available. When you do that, one of the real problems is in calibration.

              There are no, in almost all of the areas in the water arena anyway, there are no
traceable external standards at the trace or  detection  level.  Until you can do that, then you
have a real problem in adequately defining that short of running interlaboratory studies at that
level and very carefully designed.

              That is what the paper yesterday was  addressed at, and that is a subject that
cannot be done in any one single lab. You can't bootstrap  yourself.

                                        MR. CONLON:  Well, I agree that there is some
wisdom in what you say, but I also believe personally that our industry has misused interlab
studies.  We have substituted interlab studies for method validations.

              Very often, what we have done is we take the data from 5 or 6 or 10 or 20 or
100 laboratories, we pool the data, we do a statistical analysis, and we say that is what the
method is capable of. That is not what the method is capable of; it is what those laboratories
were capable of on the day they ran the method.

              And  what I propose is that we change the basic validation requirements on our
reference methods so that we spend a lot more time in the  Agency when we validate a
reference method, we spend a lot more time and take a somewhat different approach.
                                          637

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             I am not saying don't do interlab studies, but I am saying recognize that they
are what they are.  They are comparisons of competencies amongst laboratories.  They are not
necessarily driven by inherent characteristics in the method.

                                        MR. RICE:  Not so.  If you simply look at...you
are literally saying that all of the error, all of the differences that you observe are truly the
result of inadequacy or incompetence by the people that are running it.

                                        MR. CONLON:  Not at all.

                                        MR. RICE:  It is not so.  There is a very basic
variability to any measurement process.  You cannot get around that law.  And you can only
measure that in the environmental area at the trace levels interlaboratory, because there are
errors that only that picks up.  You can't find them by yourself.

                                        MR. CONLON:  No, I didn't mean to  imply that
I thought there weren't inherent method errors.  There are, but the statistical approach to
defining method error is different than the statistical  approach for defining interlab  or operator
error.

             When you get into operator error and  interlab comparisons, the actual numbers
of samples required and the numbers of runs required in each laboratory are generally well
above what we do now.

                                        MR. SHIREY:  I am Bob Shirey, Supelco,
Incorporated. As we introduce new products, I will  give an example, like a purge  trap, the
methodology seems to be very rigid in the selection  of traps, very flexible in selection of
columns.  We get calls from customers saying your trap is outperforming the existing trap,
but it is not listed in methodology.

             And we also see variation, depending  on the region that is doing...the region
that they are in. And this has created a great deal of problems for us in responding to their
needs.

                                        MR. CONLON:  I think what you describe is
probably more common than any of us want to admit, but it is what I was talking  about.
There is an unlevel playing field in many respects.

             What we hope to do is we hope to  substitute for line by line approvals, we
substitute this in-house documentation process.  It would be up to you to demonstrate that
your traps  did the job, but once they did, then you would be able to use them yourself and to
prove and  demonstrate and provide the data to your  customers to demonstrate that  they
actually work as well as they should.
                                          638

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             Theresa Prado with Suburban Water Company in Philadelphia makes a very
nice presentation where she has demonstrated that she has a microextraction process that
works great, works better than our extraction process ever did, yet it is not necessarily
approvable under the drinking water rules as  they stand today.

                                       MS. MOORE:  Marlene Moore with Advanced
Systems. I just want to commend you to finally see performance-based gets such excitement
from the Agency. The one question, of course, that constantly  comes up when you see these
kinds of definitions is what is  a matrix.

                                       MR. CONLON: For us, it is just drinking water.
For Bill Telliard, it can be just about anything.

                                       MR. TELLIARD:  We look upon our matrices as
much more challenging.

                                       MS. MOORE:  Is there going to be some kind of
consensus as you establish these DQOs that this might be more uniformly defined in all the
programs?

                                       MR. TELLIARD:  Well, in the case of, for
example, the Agency has put together a combined or consolidated VOA method which I was
hoping we would talk about this year, but we didn't, in which all three program offices have
now set their levels.  So, while it will be the  same method, same equipment, same QA, the
performance levels are going to be different,  of course, for my samples as opposed to
drinking water or for the contract laboratory program for Superfund,  and those are driven by
our DQOs which are a programmatic thing.

             But what we have done is we have at least standardized on what a shift is, how
many spikes you run, and what your  start-up  time is, what instrumentation to use, and also
the instrument  standardization.

                                       MS. MOORE:  I think you have kind of
answered it by saying that you think there might be a move towards  the Agency by just
classifying it by program, just  wastewater, drinking water, RCRA,  and that it might be
program-specific instead of looking at a matrix as being actually chemically what is the
combination in each sample?

                                       MR. CONLON: Well, if you really take the
theory behind performance-based methods, it  means that the matrix is really the sample that
you are  running right now.

                                       MS. MOORE:  Exactly.
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                                       MR. CONLON:  And it may be that this artificial
distinction we have between a wastewater and a sludge and a solid and a semi-solid and all
that goes away, because, quite frankly, what you ought to be doing is calibrating that
technique in those samples with those interferences that you have on the table right in front of
you, not something that one statute or another happened to define somewhat arbitrarily 20
years ago.

                                       MS. MOORE:  Well, I think that is something
that really has got to get into the comments, because I prefer to see us try to generalize things
a little bit more, to stick to program-specific DQOs generalities with more specific
developments having to be done for a particular matrix or a particular waste stream or
whatever you are dealing with.

                                       MR. TELLIARD:  I think we should underline
two things here, and I  will speak for someone who isn't here and myself. If it is in a
contract,  you don't mess with it. There is no such thing as performance-based contracts.

                                       MR. CONLON:  And for those of you who are
Superfund or RCRA contractors, I would suggest you write what Bill just said down on the
back of your hand and never ever forget it, or they won't pay you.

                                       MR. TELLIARD:  Hi, Yves.

                                       MR. TONDEUR: Hi, Bill. Yves Tondeur,
Triangle Labs.  I notice that in your routine performance requirements, you  indicated matrix
spike duplicates, and I didn't notice duplicates by itself. Was it an oversight or intentional?

                                       MR. CONLON:  That is not meant  to be an all-
inclusive list, and please don't take it as that.  What we are trying to do is sell the principle.
Okay?  If you have additional things that you think we ought to have on that  list...

                                       MR. TELLIARD:  Let us know.

                                       MR. CONLON:  Let us know.

                                       MR. TELLIARD:  Thank you. Thank you,
Mike.  This is round one.  We will talk about this next year,  and we will probably have some
more neat and spiffy stuff.
                                         640

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                                        MR. TELLIARD: Now we are going to talk about
the Canadian base for performance-based method. Richard, you want to come up here?
                                        MR. TURLE:  Can everybody hear me?  Before I
start my talk, I would just like to give some introductory comments.

              One thing I am very conscious of and I don't think I have  ever been  so much
conscious of is there is as great difference between Canada and the United States when it comes
down to environmental regulations. I have learned maybe 50 new acronyms this last day or two!

              One of the things is that many of the activities that we would call monitoring are
regulated in the United States; they are not in Canada, and I would like to just touch upon the
way we do monitoring methods.

              There is no particular requirement that a method be published or that a particular
method be used in much of the work that Environment Canada does under what we would call
monitoring.  Federal or provincial labs are free to choose the most appropriate method.

              However, I would state there has been a consensus of the most suitable method
for a particular analyte for a particular type of matrix.

              Often, the federal or the larger provincial labs have established a method which
is, as it spreads through the community, used by other labs.  Agencies contracting out  work for
monitoring may decide that they want a particular method used.  They will actually, in fact, say
it  will be done  this way or no way.   Alternatively, they may leave that  choice up to the
contractor as part of the contract proposal.

              Let me just leave that there and then move into the talk.  Let's have the first slide,
please.

              I would like to acknowledge my co-workers in this.  We are from a center just
outside Ottawa within what we call Environmental Protection. This work is financed underneath
Canada's Green Plan  which you may have heard about which is essentially spending several
billion dollars over the next few years to improve environmental quality in the longer term  in
Canada.

              Slide 2.   I think one of the things that we recognized  is  that we have  to
occasionally regulate.  I think the reasons for this  have to be made clear.  We are doing this
primarily to protect the environment. It is not just a nice scientific activity.

              I think  one of the major objectives is definitely to bring about new technologies.
This has certainly occurred with the pulp and paper dioxin regulation which I will be talking
about.


                                          641

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             It is obviously the basis for enforcement. You can't say to somebody don't do that
unless you have a legal framework.

             The other thing it does is it puts a level playing field across all the players in the
industry. For example, we have something like 47 pulp mills  in Canada that use chlorine-based
bleaching or did.  They are all on the same level playing field.  They all have to spend money
to come up to meet the same standard.

             The regulatory authority is the Canadian Environmental Protection Act which is
a federal piece of legislation.

             Slide 3. The consequences of this are obviously we must have analytical methods
which have appropriate detection levels, and I think I  would  underscore the word appropriate.
We should establish suitable accuracy and precision for those methods. I believe that we should
have a broad acceptability of the method. It should not be based on one that has been...a method
that is based on one experiment done in one university laboratory which gets down to a super-
low detection level and somebody says that is what we need.

             We should use widely available equipment, and that has obviously, in some cases,
made our decision as to which type of method we go. That has certainly influenced our decision
as we were revising our PCS  methods. And the method should reflect generally established
procedures.

             Slide 4.  There are two possible approaches. I guess there is the rigidly strictly
defined method, highly detailed, and assumes, I think...! think this is the basis...that if you follow
that method, then you must get good results.  Perhaps I will have to stand correct after realizing
there  is  more flexibility, but I always thought that was the way the EPA did business.  I stand
corrected.

             I think the performance-based method is you must be very clear about what your
performance means.  You must define those criteria.  I think  it can be flexible  methodology as
long as the criteria are met, and this is certainly the approach that we would go.

             This didn't take any great decision.  It took ten  lab managers who were sitting
around a table saying yes, this is the way we  go.  It is not in regulatory format, but that is the
way we have decided to go.

             I must admit we have had a lot of support from this approach from the private
sector laboratories who feel that this  is a good thing.

             Slide 5.  Performance  Based Methods can be built around two ways, as  far as I
can see.  You can use defined recoveries of surrogates which is what we have done with the
dioxin and will  be doing with the PCB method. I believe if you have suitable standard reference
                                          642

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materials, you could use this approach for perhaps methods which are well now established and
you are rewriting them. Of course, in some cases, there are not suitable reference materials.

              If we were, for example, to revisit the lead in gasoline method which we have, I
think we would probably go to one based on standard reference materials, because there is a good
NIST material available.  Similarly, in some regulations as I  think they will come up to be
revisited, there are enough standards out there in matrix spikes which we could actually use for
that particular purpose.

              Slide 6. There are limitations. Bill mentioned that where the method defines the
analyte, for example, AOX. You either follow that procedure and you get an AOX method, or
you don't.  Incidently, Canada is not going  to regulate at the federal level AOX.

              Alternatively, there is another situation where it is  impossible.  We have just
revisited the method for doing vinylchloride in air and in PVC  resin, and for the life of us, we
cannot find a way you can really assess performance.  It is difficult. There just does not seem
to be an obvious way. Maybe we have missed it, but we cannot do it.

              Slide 7. The two examples I would like to talk about are the dioxins and furans
in the pulp and paper industry regs and the new regulations that are  in the process of being
proclaimed in Canada for waste disposal and for new electrical products.

              Slide 8. Why do we actually, in fact,  bother to  regulate dioxins and furans?  I
think it is  pretty obvious.  I think the effects on fish and birds, particularly in two areas in
Canada,  British Columbia which  is a marine  environment and the  Great  Lakes, there  are
definitely serious effects which are well documented on fish and birds. I don't think there is any
doubt in the scientific community that they  had to be eliminated.

              It would appear that this could be achieved by either  eliminating or reducing the
amount of chlorine  in the bleaching process and by perhaps improving of secondary treatment
in those mills and also by removing the native dibenzodioxin and dibenzofuran from defoamers
which are,  in fact, also regulated in Canada.

              This  has been an amazing regulation in one sense in  that there has been already
more than  a 90  percent reduction from 1987 levels and we are down probably to achieve 99
percent reductions in the amount of dioxins and furans that are going out of the end of the pipes
by the end of this year.

              Slide 9.  How do we deal with this? Well, this was quite a problem. We actually
have had to come up with a regulation that  stated that effluents must not contain a measurable
quantity of 2,3,7,8-TCDD or a measurable concentration of 2,3,7,8-TCDF times 0.1  which was
the TEF factor, toxic equivalence factor, which exceeds 5 ppq.
                                          643

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             Well,  how  do  you define  measurable  concentration  or  no  measurable
concentration?  Well, we had to make a decision, and what we decided to do is one that was
most commonly available, one that we felt we could handle in the laboratory and that could be
applicable, and we decided to take the ACS definition of the limit of quantitation, which, as you
probably well know, is ten times the standard deviation of a sample near the blank.

             Slide 10.  There it is described schematically. If you have a signal increasing, you
pass through a region of high uncertainty, you reach a limit of detection which is three times the
standard deviation of the blank to  the limit of quantitation which is ten times the standard
deviation of the blank,  and then you enter your  solid area of quantitation.

             Slide 11. Well, we decided we needed a process to define this.  We decided that
we could not just do it in our own laboratory, and the comments regarding data of one laboratory
have been well  noted.  We did draft a reference  method. That was the first thing. We said that
is how we are going to do this, so that other people have a pretty good  idea of our thinking.

             The labs had to  follow this initially in some of this work.  They were free to
modify it to some extent, but they had to tell us what those modifications were, but we  asked
them to stick as closely as possible  to the draft  method.

             We made one decision which we said was not changeable and that it was  going
to be high resolution,  a resolution  of 10,000 GC/MS.  The method was going to cover tetra
through octa, even though the regulation only essentially regulates the  tetra, because we were
certain that  we would want and we did require  that all data be reported for tetra through octa,
and we  decided to  base the performance on  C13 surrogate  standards which were generally
available.

              So, those  were the decisions that we made up front. We obtained composite
effluents for an LOQ study.  We asked some labs to participate.  There weren't enough Canadian
labs, so we  went to North American labs.  We submitted samples to them, and we analyzed the
data.  That  was the overall process.

              Let's look at some individual steps.

              Slide 12.  This is a key slide. I  am not going to read it in detail, but there is an
important point is that we based it on a 1 liter sample. We have people who are reporting data
on 10 liter  samples. They cannot read. It says you must use a 1 liter sample.

              No, that causes us problems, because they are effectively reporting results which
are now measurable, thereby doing  so making mills which are in compliance out of compliance.
You know, it says 1 liter.
                                           644

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              Once you reach the end of that sentence where the curly brackets are all the way
down to that slide where it says adjust to volume, essentially, I  don't care  what goes on in
between.  That is the decision of the lab.

              We have used a method which I don't think is very different from that of Method
1613, and I know some labs in Canada are using Method 1613 essentially adapted to  this
procedure, and it works well.   But if somebody comes up with a particular technique, gel
permeation chromatography,  supercritical  extraction, I  don't care.  As  long as  it meets the
performance characteristics, they are free to do whatever they like between those two points in
the method.

              And we distinguish this in the written method by means  of bold type of steps
which are mandatory and regular type  for those parts of the method where there is choice.

              Slide 13.  How do we go around preparing a sample?  Well, what we went to is
we asked an organization...gee,  I am so acronymed out...the Pulp and Paper Research Institute
of Canada, PAPRICAN, to look at the  47 bleach mills.  Some mills were  already in the process
of cleaning up their act, so that was a bit of a problem.  We didn't want to know which ones,
obviously, because there were legal  implications.

              So, they identified nine mills as possible sources of effluent samples  which would
have the right range of analytes. Two mills were selected.  We got from those  210 liters of
composite samples.   We bottled them up into  about 180 bottles, and we confirmed the
homogeneity  of each bottle by just measuring the suspended particulate.  We found that the
relative standard deviation for that was less than 5 percent which wasn't  bad,  I understand, for
this type of sample.

              Slide 14.  We found there were ten  labs willing to participate in the study. One
of the differences between our study and the one that was talked about yesterday is we paid the
labs.

              Amazing, we got results really quickly. It cost money. It  cost  us $80,000 to do
that, and that is Canadian dollars, but we went and fought for the money and we got it, because
we said we were on a regulatory time  table, and it just could not be changed.

              So, each laboratory received eight 1 liter samples of the two effluents as blind
samples.  They  were just labeled 1 through 8.   They also received a  set of standards, C13
standards. These are not the same as the EPA standards.  They were ones that  we had prepared.
They received four GC/MS calibration  standards which I believe go lower  than the Method 1613
standards and two sets of fortifying  solutions.

              We were a little sneaky here, because one of these was a blank, and not everybody
realized that.
                                          645

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              Slide 15. Out of the set of the 10 labs, we got 8 sets of useful data.  Basically,
we had to reject 2 labs immediately,  because they failed to meet the initial calibration criteria.
In other words, they could not get the criteria that we required on the calibration step on the
GC/MS.

              Only three labs met all of the criteria that we required. It was interesting that no
more than two labs failed to meet  any one of the performance criteria, and there were five of
these criteria that we required.  One lab could not get the instrument detection level of 4 ppq,
and two labs failed to meet 40 percent recovery criteria.

              Now, I find this truly  amazing that some labs cannot get  at least 40 percent
recovery of surrogates in a method like this. There are other labs, I know, who are regularly on
an every day basis, including octas, are getting 80 percent recovery.

              The proof rinses and the method blanks indicated that contamination was not a
specific problem in this particular method.

              Slide 16. Well, what data  do you accept and what don't you accept? Well, we
used both Grubbs1 and Dixoris tests, and we said that a 5 percent level, but one lab had an outlier
for TCDD, and another one had one for TCDF, and we did a whole pile of interlab comparisons
between the sets of labs that really indicated that one lab had mean values that were really high,
significantly higher or lower than the other labs, and we found out that their precision of the
duplicates was poor for both dioxin and furan, so we threw out some of that data.

              Slide 17.  The maximum differences between the lab mean and the interlab median
was 35 percent for effluent 1 which was around 21 ppq TCDD, and one lab had a mean value
for TCDD 92 percent higher than the interlab median which really indicated a problem.

              Effluent 2 was a lot lower.  That was around 4 ppq for TCDD. So, it was a more
difficult sample.   So, it is not surprising we had that problem

              Slide 18.  The key  points of this slide are indicated by the red arrows.  The
standard deviations we got for the first effluent was 1.8 for TCDD; for TCDF, 2.7. You can see
the levels there were, roughly,  for TCDD 21  ppq and for TCDF 33.

              Slide 19.  Similarly for the second effluent, we had a standard deviation of 1.1 and
for dioxin and for furan, 2.4. The levels were a lot lower, as I said earlier.  4.3  for TCDD and
28 for TCDF.

              Slide 20.  We managed to pool these. This is where a statistician is a great friend.
This basically said there was no statistical  difference between any of the sets of data that we had,
and we came up with this magic number  of 1.543.
                                          646

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              We decided that that, based on a 1 liter sample, was our LOQ.  I wouldn't put
great confidence in those significant figures, but that was the number that spewed out of the
computer.  So, we in actual fact decided that the limit of quantitation will be written into the
regulation and into the method as 15 ppq for both TCDD and TCDF.

              The method has been published and, as required in Canada, it was Gazetted as part
of the regulation.

              So,  we  actually hi  fact now have a performance-based method on  hand and
available. If people would like copies of this, I suggest they write to me, because I  only have
the one with me.

              Slide 21.  We are now in the process of revising all the PCB regulations. This
is required, because regulations obviously change in time.  They were looked at about ten years
ago, and they decided to update them.

              They basically cover waste disposal and new electrical products, transformers, oils,
capacitors for fluorescent lights, things like this, and we decided to classify to accept all limits
for various categories of waste and for treatment.

              One thing you should be well aware of is that in Canada, we also have a whole
series of provincial regulations which may differ in value to the federal regulations, but  our
regulations will certainly cover inter-provincial trade, cover import and export, as well  as any
waste generated on federal lands.

              Slide 22. In Canada, we define PCB as a chlorobiphenyl which has 3 to 10 atoms
of chlorine.  That means mono and dichlorobiphenyl are not regulated substances.

              This is often a surprise to people, and we find people in actual fact spending a
great deal of money  or did at one time trying to get rid of aroclor  1228  which  is largely
unaffected by the regulation.

              Slide 23. The destruction regulations are quite stringent.  Basically, it requires a
high performance, a five nines efficiency, 1:1 million, and it should release at the end of the pipe
or the stack 1  mg/kg  of PCB put into the system.   There  are  also requirements for  dioxin
measured as TEF equivalents which I think is a very good approach and also as PCBs, whether
solid or liquid.  They are both covered in that regulation.

              Slide 24. Treatment systems basically require that at the end of the day, we have
less than 2 mg/kg of PCB.  We do allow conversion of the higher chlorinated species to lower
chlorinated species.  This seems a good approach,  given the fact we are only regulating tri to
deca chlorinated species.
                                          647

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             The other requirement is that PCBs must not be released into the environment if
greater than 50 mg/kg, and waste oil is sometimes used for road oiling to keep down dust, but
it can't be used if it has  more than 5 mg/kg of PCBs. People thought this was a great way of
getting rid of PCBs, but that was stopped pretty quickly.

             Slide 25.  New product regulations,  I think they are basically the same as in the
States.  Less  than 2 ppm  of PCBs in new products.  The previous limit set in  1985  was 50
mg/kg.

             Our concern now is not material manufactured in North America but goods coming
in from outside North America.  Some of the Third World countries are trying to tap into North
American markets, and some of the stuff coming out of Eastern Europe has been, we understand,
for sale which may cause problems, but most of the major North American companies  say this
is not a problem for them. They are well below those limits.

             Slide 26.   So, we  decided we should review how we  should go about PCB
measurement. Traditionally, it has been extraction and cleanup and quantitation by GC/ECD and
by GC/MS. We actually took a decision that since MSDs were quite universal these  days in
most private and government labs that that was a fairly good approach that we should try and
use.  We would not try a high resolution approach.

             Slide 27.  Traditionally, the quantitation has been as various levels, as aroclors,
as homologs,  or as individual congeners, and these were decisions that we had to look  at.

             Slide 28.  Measurement based on Aroclors is  quite  acceptable for a transformer
oil which does contain Aroclors and is not too degraded.  Traditionally, there have been various
approaches. The Webber-McCall which has been modified these days for capillary,  gives quite
good numbers.

             Single peaks which are unique to each aroclor  which I think gives poor numbers.
I have found in previous work that I have dealt with that we  had numbers a factor of twice too
high.

             We found that sometimes when they were complicated mixtures, people completely
blew it, because they use the wrong standard, but they are useful for rapid screening. After all,
if it is 1000 ppm, it is out of compliance.  It has to be destroyed.  It just can't be treated as a
PCB-free sample.  So, there is some merit to those approaches.

             Slide 29.  Specific congener analysis, on the other hand, requires the use of many
congener standards. They are available,  but they cost an arm  and a leg. Also, we found that the
calculation aspect of the methodology is tedious, to say the least, and there are many errors.
                                          648

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             One of the problems, of course, is there is no one column that can resolve all the
PCBs that you find in common aroclor mixtures.  So, I think we decided that an approach that
would be quite useful would be to look at the homologs.

             Slide 30.  This obviously lends itself to  the  GC/MS  approach.   It  is easy
quantitation based on  characteristic ion.  We have decided  and made the  decision that a
representative PCB from each of the homolog  groups can be used as a standard, and we can
obtain the total PCB  numbers simply by summing those homologs.

             We  did  note there is a poor sensitivity of MSD  in comparison with electron
capture detector as we set out to do our methodology development.  We decided, in actual fact,
to use all our work on  a very ancient MSD, because we  felt  if we could  do it with  that
instrument, then anybody else could with a newer one.

             Slide 31. We looked at a whole variety of cleanup methods. We hadn't visited
this for about ten years, and we found  out most people were using  a sort of "dilute  and shoot"
technique, sometimes doing a little bit of cleanup with alumina or silica column, but we found
out with the MSD  that it pays to get rid of most of the transformer oil.  Indeed, we  would like
to have got to 100 percent removal of transformer or mineral oil away from the PCB.

             We  use liquid-liquid extraction of DMSO, DMF, or  acetonitrile. DMSO in our
hands seems to be the best. We looked at gel permeation chromatography, and it has not worked
out as well as we anticipated.  We used other column cleanup techniques which have  been fairly
traditional.

             There are some people who seem to do very well on silica gel or silica gel with
silver nitrate. We are aware of other people who use Florosil and it works very well in their
hands, and other people say they can't use Florosil, they prefer alumina.

             But, basically, what we are saying is when we had this method published that the
choice of extraction and cleanup method will be totally dependent on the analyst, as long as it
meets the performance criteria. We don't care which one of these techniques people use as long
as it works and meets the criteria.

             Just to sort of bring some chemistry into it, this is one of our results using HPLC.
We used an amino silene column, and this was our best to date performance.  Obviously, the
chromophors affect the size of the two peaks. The PCBs are the second peaks, and the mineral
oil is the first peak.  There is actually about 99.2  percent separation between those two peaks.

             Unfortunately, this is still not good enough, because when we put that same sample
onto a MSD, we had some problems. The three chromatograms there represent essentially the
top one is the hepta, the middle one is  the hexa, and the bottom one is the penta.  If you focus
your attention on the bottom one, you will see what I call a humpogram. There is lots of mineral
                                         649

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oil causing interference, and it is obvious that we have to deal with that, but to date, that is our
best performance hi terms of separation.

              We think this  may be something we can live with, but that will be one of the
criteria that you will have to get baseline...a certain base performance for your baseline before
you will be allowed to quantitate.

              Slide 32.  So, basically what we  are doing in approaching this new reference
method.   It is a definitive  method for legal purposes in the sense that it  is quoted in the
regulation, and if Environment Canada takes somebody to court because they  have violated the
PCB regulations, then this is the method we use.

              We feel strongly that there must be a method that we know works. You just can't
put out performance criteria and not publish a method.  I think this was the point the previous
speaker alluded to, and I must admit I agree with it.

              We allow a variety of cleanup methods.  We feel the technique should be based
on GC/MSD  as an appropriate.  Maybe the ion trap that Barry markets (Varian) or Finnegan
markets would be acceptable.

              We in actual fact did look at and toyed about using other detectors. One of the
things on a quick search indicated that no one had an atomic emission detector, including us, but
apparently it works really well for PCB analysis.  You can do some really good work with that
if the levels are high enough.

              The quantitation using  homologs seems a lot simpler,  and it has been well
established, I think, in some EPA methods, certainly for monitoring.

              This slide is now wrong. The detection level that we are going to require is based
on the fact the regulation requires it, 0.4 ppm total PCB as determined by a particular column.
We are  going to specify the  column for quantitation.   It will probably be a  DB-1 or  a DB-5
column. We personally prefer the DB-1, but we know some other people prefer a DB-5 for this
type of analysis.

              And any single peak or congener has got to be no more than 0.4 mg/kg as long
as the total is less than 2 mg as far as the regulation is concerned.  So, that requires a detection
level of at least 0.2 mg per resolvable peak which is the way we are going to define it in the
method.

              We are going to use surrogates to determine performance. C13 PCB standards will
be required to be added to the sample  right at the beginning, and we are going to build in QA
specs based on the NIST PCBs in oil which are readily available.
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              We also found there was a distinct problem in the analytical world, because if you
give them a sample of 2 ppm, some people can do quite well.  50 ppm is certainly no problem,
but if you give mem a sample of 50 percent PCBs, we get numbers back from something like
30 to 70 percent PCS.

              That causes a problem, because when you put that into an incinerator or something
like this, there is  obviously a problem in defining its performance.

              So, we are going to try and develop a method where we can control that with a
surrogate. That work is not completed yet. Finding a suitable surrogate is going to be difficult.

              Slide 33.  The method will encompass...a method that has already been published
for ashes, stack effluents and  so on which is available  from us.  We  are going to basically
incorporate all this into the one method.

              One of the points that has been raised to us is well, this  will stop people using
screening. No, we see screening as a very valuable tool.  There are many, many people have to
test PCBs in oil.  A lot of companies just do it as habit, because they don't want to be held up
for any liability.

              So, what we will say is if you want to use a GC/ECD for a simple  screen, that is
fine, but if you are working at one of the regulatory limits, then you had better be very sure that
that method is accurate and precise, because if we take a sample and we decide to prosecute,  we
will be using our  method based on GC/MSD as written for the basis of that prosecution.

              Slide 34.  I think there are some conclusions that we can draw.  We believe that
this performance-based methodology is a key to future successful regulation, and it will be  the
approach that we  will try and adopt in all methods, particularly complicated methods where you
have very low levels of detection required as for dioxins or you have naughty components such
as PCBs, but we think this can be applied right across the spectrum, and we will  be doing that.

              The method must be defined very well as far as quantitation steps.  That does not
mean that you cannot use different columns, different detectors, but there has to be some way
of assessing that quantitation.  We like the use of surrogates.

              We certainly believe that you should have complete freedom as to the choice of
extraction and cleanup, and I think that the reference method that should be published should cite
a typical method.  We like to use the broadest-based method in the sense of one technique that
is the most widely available so  it becomes a typical method that should be performed well in  the
hands of most competent analysts.

              I thank you.

                                        MR. TELLIARD:  Thank you.


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652

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                        QUESTION AND ANSWER SESSION

                                       MR. TELLIARD:  Any questions?

                                       MR. COCHRAN: Jack Cochran, Hazardous Waste
Center. Does Canada regulate polychlorinated naphthalenes, and if so, do they have methods and
congener standards available?

                                       MR. TURLE:  I believe we do regulate them, but
I don't think we actually have a method.  I know we don't have a method.

             Perhaps I could at this point...in actual fact, believe it or not, in Canada at the
federal level, we only have about 20 methods actually specified in the regulations.  We don't
really have a method for polychlorinated naphthalenes.  It doesn't mean they are not regulated,
though.  (Added in proof - polychlorinated naphthalenes are not regulated in Canada.)

                                       MR. COCHRAN: Do you see the PCNs when you
do your analysis?

                                       MR. TURLE:  In what sort of matrix?

                                       MR.  COCHRAN:  I am just curious as to how
widespread they are  when you do, say, PCB analysis or even dioxin analysis.

                                       MR. TURLE:  I am not with you. We do find them
in environmental samples.  For example, in wildlife, I think they can be found if you look for
them.

                                       MR. COCHRAN: So, if they are regulated and you
find them, how do you measure them, then, I guess is my question, if you don't have standards
available?

                                       MR. TURLE:  We don't have a method available.
There is a difference.  We buy the standards from the same places  you guys get them.

                                       MR. COCHRAN: As far  as I know, we don't have
standards available for PCNs.

                                       MR. TURLE:  I don't  know.  I have  not done any
PCN analysis.

                                       MR. RICE:  I am curious about...and this applies to
Conlon's paper as  well, but you both have discussed the absolute necessity of having a reference
method. When compliance data may be subject to litigation as to the validity of it, for example,

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and the reference method I assume...and you correct me if I am wrong, but the reference method
would be the final arbiter. Is that true, and, if so, why then would anyone run anything but a
reference method?

                                        MR. TELLIARD:  The reference method, Jim, is
the floor.  In other words, we don't want to just give you a method spec and tell you to go out
there and do it.  If your method has met the checklist as far as the data qualifications and the
method specifications, there is no reason...we are not going to say they are equivalent, but there
is no reason to disallow that data?

                                        MR. TURLE:  Can I make a point? In the Canadian
context, if a company had used a laboratory which had used a method different in the sense of
different from the reference method as published but had produced  data  which met the
performance criteria, I think their argument would be that they had used what in Canadian law
is called the due diligence argument.  That would be their  standing.

             What we are interested in is we have not actually prosecuted anybody underneath
these regulations.  I expect a lot of fun and games the first time where it actually happens.

                                        MR. RICE:  That answers part of my question.

                                        MR. CONLON:  Jim, to answer your question on
behalf of the Drinking Water Office, once we get these kinds of changes into rules, then any
analytical results that are documented according to the requirements of the regulation would be
just as equivalent as those generated by the reference method if you can prove it.

             Now, obviously, the rubber is going to meet the road when the auditors sit down
and the  analyst from one lab looks at the other guy's  data. People are going  to go through it
very, very carefully, but, obviously, I think we are trying to create a field where you can actually
use alternative methods.

                                        MR. TELLIARD:  The answer also, too, is that if
you want to use the, quote, reference method and feel warm and fuzzy and it make you happier,
of course, that is a logical approach, but what  we find is that people make what we would call
insignificant changes and  get themselves in trouble, because it  was no big deal until they get
audited or because they get in trouble.

             This system allows you presently to do that as long as you document it. Let us
know what you are doing. Not necessarily call me personally, but somewhere in that lab book
there has got to be some documentation  of what you are doing.

                                        MR. TURLE:  Can I just add to that?  Underneath
the dioxin regulations, mills have to submit data to Environment Canada, and we are auditing the
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results that are coming in from the private labs.  I would say the majority have no problems
meeting our performance criteria.

                                     MR. TONDEUR: Richard, you mentioned GC/MSD.

                                     MR. TELLIARD: Tell us who you are.

                                     MR. TONDEUR:   Oh,  sorry.   Yves Tondeur,
Triangle Labs.

                                     MR. TELLIARD: Thank you.

                                     MR. TONDEUR:  You said that the method would
have to be done using GC/MSD or low resolution.  Does that mean that you have to use an MSD
to do it, or can you use another type of mass spectrometer that can be operated in low resolution
mode?

                                     MR. TURLE: Yes, any sort of low resolution mass
spectrometer.  We just thought we would take the worst case example for our own experience.

            One of the arguments that we had initially when we proposed this  is people said
well, we don't have the equipment available.  We found out that was not true, but we are using
one of our older MSDs, because it has a slightly poorer performance than newer ones.

                                     MR. TONDEUR: So, we're not restricted to MSDs?

                                     MR. TURLE: No, no.

                                     MR. TONDEUR: And if, for instance, the lab were
to run into a humpogram like the one you showed for  the pentas and decided to solve this
problem by running into GC/MS using a high resolution of the mass spectrometer and that takes
care of the humpogram problem, would the analysis be considered valid?

                                     MR. TURLE: Yes, I believe so.

                                     MR. TONDEUR:  Okay, thanks.
                                      655

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656

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 Environment Canada's Approach
 to Performance Based Methods
K Richard Turle, Chung Chiu, Gary Poole, & Bob
 Thomas,

          Chemistry Division
River Road Environmental Technolgy Centre
  ,» ,     Environment Canada
               Ottawa
           Canada K1AOH3
CANADA'S GKEEN
                657

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         ',  Environment Canada's Approach
           to Performance Based  Methods
         ; • Richard Turle, Chung Chiu, Gary Poole, & Bob
         !  Thomas,

         ;            Chemistry Division
         ! River Road Environmental Technolgy Centre
                    Environment Canada
                          Ottawa
                      Canada K1A OH3
1;
oo
                                Consequence:

          ' Establish analytical methods
           -with appropriate detection levels
           -established accuracy and precision
           -broad acceptability
           -widely available equipment
           -reflecting generally established
             procedures
                      Why regulate?

• Protect the Environment
» Bring about new technologies
• Basis for enforcement
• Ensures level playing field within industry
• Regulatory Authority is the Canadian
 Environmental Protection Act
                                    Possible Approaches:
                      • 1. Rigid, strictly defined method
                       -highly detailed - assumes if procedure
                        followed explicitly then accurate results
                         must follow
                       -eg US EPA methods
                      » 2. Performance based method
                       -performance criteria defined
                       -flexible methodology as long as criteria
                         met
                       -eg Environment Canada approach

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      Performance based methods
• can be built around
 -defined recoveries of surrogates
 -comparison with SRMs
   - limited number of suitable RMs
 -eg
   - for Pb in gasoline
   - common water parameters
                          Examples
' Dioxins and furans for pulp and paper
 industry
 -2,3,7,8-TCDD and 2,3,7,8-TCDF
' PCBs for
 -waste disposal
 - new products
Limitations to performance based
             approach
• where method defines the analyte
 -egAOX,
•where a surrogate is impossible
 -eg analysis of vinyl chloride
   Dioxins and furans for pulp and
                     paper industry
' Regulated because of effects of dioxins on
 fish and birds especially in British Columbia
 and
                                                          exp

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ON
ON
O
                                    Regulation

         • effluents must not contain a "measurable
           concentration" of 2,3,7,8-TCDD
         • or a "measurable concentration of
           2,3,7,8-TCDF times 0.1 (TEF factor) which
           exceeds 5 ppq
         « how to define?
         » used "Limit of Quantitation" as the level to
           regulate
         « LOQ (ACS definition) is 10 x SD near the
           blank
                  Process to determine LOQ

         • Drafted reference method - labs had to
           follow - based on high resolution GC-MS
           -covers tetra- through octa-PCDDs and
            PCDFs
           -uses surrogate C-13 standards for
            assessment of performance
         » Obtained composite effluents for LOQ study
         • Invited labs to participate
         « Submitted samples
         • Analyzed data
                                                                                        Definition of LOQ
  Region of Quantitation

ALIMIT OF QUANTITATION
•Sb+ IDs
  Region of less certain quantitation
  LIMIT OF DETECTION
  Region of High Uncertainty
V 3s
• S b  (zero)
                      Method Summary

    • A 1 litre sample of effluent is spiked with
    isotopically labelled PCDD and PCDF
    standards.{ It is then separated into phases
    by filtering. Solid phase is soxhleted. Liquid
    phase is extracted with DCM. Concentrated
    extracts are cleaned up on (1)
    acid/base/silver nitrate/silica column (2) a
    basic alumina column (PCDD/F eluted with
    50% DCM/hexane) (3) 2nd alumina or
    carbon/silica column.} Adjusted to volume,
    then analyzed using GC-MS.

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           Sample preparation for LOQ study

           • PAPRICAN assessed effluent data from 47
            bleached chemical pulp mills
           • identified 9 mills as possible sources of
            effluent samples with TCDD and TCDF near
            estimated LOQ - 2 mills selected
           » 210 litres of composite effluent were
            collected & homogenized - split into 180
            bottles
           • Homogeneity confirmed using suspended
            parti culate
           • SD <= 5%  (n=5)
CTs
                                         Results
           « 8 labs produced useful data
           • 2 labs data rejected since they failed to
            meet initial calibration criteria
           » Only 3 labs met all the criteria
           • No more than 2 labs failed to meet any
            performance criterion
           « One lab failed to DL criteria of 4 ppq
           » Two labs failed to  meet 40% recovery
            criteria
           « Proof rinses and method blanks indicate
            contamination not a problem
  Study design -10 labs across N.
                             America

• Each lab received 8 one litre samples of 2
 effluents - blind samples
• Set of PCDD & PCDF C-13 standards
« Four GC-MS calibration standards from
 0.25 to 25 pg/uL
« Two sets of fortifying solutions (one was
 blank)
                       Data analysis

< Grubb's & Dixon's  tests indicated at 5%
 level that one lab had an outlier for TCDD
 and a second lab had one outlier for TCDF
• Inter-lab comparisons indicated one lab had
 mean values significantly higher or lower
 than other labs - also precision  was poor
 for both TCDD & TCDF

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           -Data analysis (cont'd)
> Maximum difference between lab mean and
 inter median was 35% for effluent 1 (21
 ppqTCDD)
' One lab had a mean value for TCDD 92%
 higher than inter-lab median for effluent 2 -
 due to lower concentration in this effluent (
 4 ppq v 21 ppq in effluent 1)
                          Effluent 2
  •TCDD
   - mean = 4.31 ppq
   > SD = 1.152
   - DF = 42, RSD = 27%
  -TCDF
   * mean = 28.58 ppq
   - SD = 2.432 ^	
   - DF = 47, RSD = 8.5%
                            Results
• Effluent 1
 -TCDD
   •• mean = 21.53 ppq
   - SD- 1.825 ~*	
   - DF = 48, RSD = 8.5
 -TCDF
   » mean = 33.75 ppq
   - SD = 2.744 ^	
   - DF = 42, RSD = 8.1
                                LOQ
• Pooling SD for both effluents resulted in a
 SD for TCDD of 1.543 ppq (1 litre sample)
• LOQ of 15 ppq adopted for both
 2,3,7,8-TCDD & TCDF
»incorporated into final Reference Method
» Reference Method "gazetteted" as part of
 regulation

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OS
                      Canadian Federal PCB
                             regulations cover

           ' waste disposal
           > new products
           • classification as to acceptable limits
                               PCBs

 ' defined as chlorobiphenyls containing 3 to
 10 atoms of chlorine per molecule
 'Thus
 -monchlorobiphenyl and dichlorobiphenyls
   are NOT PCBs for the purposes of the
   regulation
                  PCB destruction regulation

           > requires
           -releases less than 1mg/kg of PCBs put
             into system
           -i.e. a 1 :1,000,000 destruction efficiency
           -0.5mg/kg of PCBs or 1 ug/kg of PCDD/F
             (measured as TEF equivalents) as a solid
           -5 ug/L of PCBs or 0.6 ng/L PCDD/F
             (measured as TEF equivalents) as  a
             liquid
           PCB treatment systems

 -must reduce PCBs to less than 2 mg/kg
 -allows conversion of 3 to 10 Cl PCBs to
   mono- and dichoro-PCBs
• PCBs
 -must not be released into the environment
   if greater than 50 mg/kg
 -5 mg/kg if used for road oiling

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                      PCBs for new products
           ' must contain less than 2 mg/kg PCB
           ' previous limit set in 1985 was 50 mg/kg
            PCB
Os
                                 Quantitation
          « as Aroclors
          «as homologues
          • as individual congeners to give sum PCB
                PCB measurement
« extraction and clean-up
« quantitation by
 -GC-ECD (packed or capillary)
 -GC-MS (MSD or low-resolution)
                            Aroclors
' generally based on either
 -Webb & McCall procedure (packed or
   capillary)
 -single peaks unique to each Aroclor
 -often inaccurate for complex mixtures
 -useful for rapid screening

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ON
OS
                   Specific congener analysis
           «requires many congener standards
           • difficult to obtain appropriate standards
           * complex calculation to obtain total PCB
                 Clean-up methods evaluated
           • liquid/liquid extraction using DMSO, DMF or
            MeCN to remove oil
           -GPC
           « HPLC using amino-silane columns
           • Column cleanup using
              - acid silica/base silica/neutral
                silica/AgN03 silica
              * Florosil or alumina
           « choice dependent on analyst and sample
            type
                         Homologue
« best applied using GC-MS
• easy quantitation based on characteristic
 ion
• only representative PCB from each group
 required as standards
• total PCB obtained by summing
 homologues
• poor sensitivity of MSD cf ECD
         New Reference Method -1
 ' definitive method for legal purposes
 ' allows a variety of cleanup methods
 • based on GC-MSD
 ' quantitation using homologues
 • DL of 0.4 mg/kg total PCB (limited by MSD)
 • DL of <- 0.2 mg/kg per congener
 > uses C-13 surrogates to ensure adequate
 performance
 • QA based on reference materials such as
 NIST PCBs in Oil

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         New Reference Method - 2

• method for high level PCBs
 -problems with dilution
 -level of surrogate
• methods for ashes, stack effluents etc
 -similar to published method.
• screening method for transformer and
 waste oils
 -based on GC-ECD (megabore)
             Conclusion
' Performance of methodology is key to
 successful regulation
' Methods must be well defined as to
 quantitation
1 Allow choice of extraction  (clean-up)
 techniques
' Define and assess performance (surrogates)
• Reference method cites "typical" method

-------
                                        MR.  TELLIARD:    Thank you  very  much.
Appreciate it.  Mike, Rich, thank you very much for the performance-based methods scenario.

             Now we are going to talk about almost as much fun, a thing that we are all into,
lab accreditation. Kenneth White is going to talk to us. He is with Consultive Services.
                                        MR. WHITE:  Thanks, Bill.

              Hello, Kenn White from AS&M in Hampton, Virginia. I am here representing the
American  Industrial  Hygiene  Association  Environmental  Lead Laboratory  Accreditation
Committee, and I am here to talk about the accreditation program.
              The American Industrial Hygiene Association  is  a professional association
dedicated to the health and safety of workers and the community.

              The association has over 11,000 members now worldwide, 75  local sections
worldwide, has 45 technical committees, and provides professional training worldwide. Further,
we publish a litany of magazines and guides.

              Of interest here is that, based on our latest demographics, half or more of our
membership have at least one master's degree and have more than 5 years of experience in the
industry.

              AIHA offers accreditation and registration programs.  They include the Industrial
Hygiene Laboratory Accreditation Program called IHLAP, the Asbestos Analysts Registry, a
registry of people who, by training and/or documentation, are qualified to perform asbestos
analyses, and now a new program, the Environmental Lead Laboratory Accreditation Program
called ELLAP.

              AIHA offers several proficiency testing programs.  The one that is probably the
most know is the PAT, the Proficiency Analytical Testing program, which includes various
contaminants in air.  The Asbestos Analytical Testing program, the AAT, involves air samples
of asbestos for fiber count.  The bulk asbestos program uses the same source that  the NIST
NAVLAP program uses for its bulk  asbestos  samples.  And now  the new program for
environmental lead.

              AIHA's ELLAP deals with accreditation for analysis of lead in three matrices; lead
in dry film paint, in soil, and  in wipe dust, that is settled dust.  The AIHA considers air
monitoring as an industrial hygiene exposure to be handled by its industrial hygiene laboratory
accreditation program. So, only these three matrices are included in the environmental program.
                                         667

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              The major program requirements include site visits, proficiency testing, an audit
of facilities and equipment, audit of personnel criteria, an audit of the quality control program,
and an audit of documented analytical methods.

              Site visits occur prior to the issuance of accreditation.  They occur every three
years thereafter. They are announced visits.  They are conducted by a trained and experienced
representative of the association.  They use a checklist format.  Since we are dealing only with
analyses of environmental matrices, only these subjects will be addressed during the site visit,
and the site visitor carries a sample into the laboratory to assure that the laboratory indeed can
perform the analysis for which they are accrediting.

              Proficiency testing occurs quarterly. It includes the matrices of interest; dry paint,
soil, and/or dust wipes.  The concentration varies from sample to sample and  from round to
round.  Data  is handled by NIOSH who then reports the results to AIHA.

              Facilities and equipment are reviewed.

              Accreditation is granted to a laboratory; it is not granted to an individual or an
organization.   So, if an individual is operating a laboratory and moves from one site to another,
the accreditation does not follow.

              If a corporation has more than one laboratory, each of those laboratories must, in
their own turn, go through the accreditation process which includes the site visit.

              Mobile  laboratories are allowed,  and  the  committee defines  those  mobile
laboratories as defined internal sites, a volume, the inside of a trailer, the inside of a  mobile
home, et cetera.

              Specific instruments are not required.  The protocol does not demand use of any
specific instrument nor any specific instrument type.  Good housekeeping is, of course, required
in the laboratory proper.

              Personnel criteria.  The following people are defined as personnel in the accredited
laboratory:  a technical manager, by whatever title; a quality assurance coordinator, again by
whatever title; and analysts.  Further, accreditation requires that management  staff must be on
site at least half-time and must be full-time employees of the entity being accredited.

              Personnel criteria, in particular the technical manager: The technical manager must
have a college degree in chemistry or a related science, must have a minimum of two years of
analytical chemistry experience and must have a minimum of at least  six months of metals
analysis  experience.

              There are two options for the QA coordinator. The QA coordinator should have
a college degree in a basic science and a minimum of one year of analytical chemistry  experience


                                           668

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and documented training in statistics; or, have a minimum of four years of analytical chemistry
experience and, again, documented training in statistics.

              Those personnel performing the analyses are titled analysts.  The analysts must
complete either an internal or an external training course in metals analysis.  This training must
be documented  and those records available  for  examination.   Further,  the  analysts must
demonstrate their ability to produce reliable results through the successful  analysis of SRMs,
proficiency samples that we have mentioned before, and/or quality control samples manufactured
internally.

              The quality assurance program must include in-house training. There must be a
written QA manual. Instrument calibration procedure is required in that manual. QC checks are
required.  We will talk about those a little later.

              Statistical quality control must be used as part of the quality control checks. There
must be a written corrective  plan of action.  There must be analysis  documentation for  each
analysis performed, and there must be calculation and  report review within the laboratory.

              Quality control checks include instrument calibration verification, blanks that must
be analyzed at the rate of 1 in 20, spike samples that must be analyze at the rate of 1 in 10, and
duplicates of real samples must be analyzed at the rate of 1 in 10, 10 percent.

              The analytical  methods must be listed in the manual. None are specified.  One
can use whatever method  one decides to  use as  long  as it is documented.   The lab must
demonstrate, though, that this method will yield adequate performance  by documenting the
detection limit and accuracy and precision measures, and the method must be documented in the
methods manual and be available to those who are actually performing the analyses.

              Further, the method must be reviewed periodically by management.

              The AIHA ELLAP proficiency program  has begun. November, 1992 the first set
was sent out.  It included analyses for lead in paint chips, in soil, and in dust wipes.  It will
continue quarterly with  four samples per matrix. It was supported by a partial grant from the
EPA and  again  supported through results handling and data handling through  NIOSH.  The
samples went out December 1st with results due by January 15th of '93.  The final report was
issued on February 19 of'93.  All told, there were 110  laboratories participating in the program,
but only 104 of those 110 actually did report results in the time period.

              Concentrations in samples ranged as follows:  paint  chips ranged from 0.089 to
5.5 percent by weight.  Mass of lead in soils ranged from  133 to 3370 mg/kg,  and dust wipe
samples ranged from 38 to 4400 ug/sample.
                                          669

-------
              Relative standard deviation based on reference laboratory analysis ranged for paint
chips from 7 to 15 percent, for soils from 8 to 12 percent, and for dust wipes from 10 to 14
percent.

              Outliers,  defined as equal to  or greater than three  standard deviations  of that
reported by reference laboratories, ranged as  follows:  Paint chips 9.4 percent; a little less than
10 percent of the 404 analyses performed were outside the acceptable range.  For soils, it was
7.7 percent of the 336 analyses that were reported.  For dust wipes, it was 8.5 percent of 364
analyses reported.  Overall 8.6 percent were outliers.  These are the failed analyses of 1104
analyses reported.

              Acceptable results.  For paint chips, 88 of the 101 laboratories reported acceptable
results; for soils, 77 of 84 laboratories for 92 percent.  On dust wipes, 82 of 91 for 90 percent.
We were very pleased with this response.

              The various programs are available through AIHA, and AIFIA has moved to a new
office in Fairfax, Virginia.

              That  ends  my  report  to you  on  the first round  of ELLAP.   I  will entertain
questions.
                                            670

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                        QUESTION AND ANSWER SESSION

                                        MR. TELLIARD:  Questions?  Kenn, how often do
they do the site visits?
                                        MR. WHITE:  The site visits occur once prior to
accreditation and then are repeated every three years thereafter.  In the case where a complaint
is listed against the laboratory for cause, fraud, failure to report data, failure to pay one's bills,
et cetera, a site visit can occur unannounced.  Usually, the site visits occur with two or three
months prior notice.  We try not to sneak up on anyone.

                                        MR. TELLIARD:  Sneaking is good.

                                        MR. WHITE: Sneaking is good when you need to
do it.

                                        MS. MOORE:   Marlene  Moore with Advanced
Systems. A question. Who all  is conducting site visits? Is only AIHA  doing this?

                                        MR. WHITE: There are two...the EPA is currently
in negotiation for a memorandum of understanding for certification of laboratory accreditation
for  analysis for lead from  environmental sources.  The two organizations are the American
Industrial Hygiene Association  and the American Association for  Laboratory Accreditation,
A2LA.

             We have an agreement with A2LA concerning  site visitor personnel.

                                        MS. MOORE: Okay, thank you.

                                        MR. SMITH:  Keith Smith, Analytical Services,
Atlanta, Georgia. Are you requiring your inspecting personnel to be competent in these methods?
Can they pass the methods themselves?

             I am sure your inspecting people know the paperwork and have their checklist, but
are  they capable...do  you require them to actually be able to perform the method?

                                        MR. WHITE:  Yes.  When  the site visitor arrives
on site, he  or she carries a  sample that they observe during the time that they are there being
handled (as far as the paperwork is concerned), prepared, and analyzed.

             Now, they are not  worried too much about the data that comes out from that
analysis. All that carry-sample is for is to see what the process is within the laboratory and the
fact that they can run the type of analysis for which they are being accredited.
                                          671

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                                       MR. CONLON: Mike Conlon with EPA.
Maybe you mentioned this and I just missed it, but are there other compounds that you certify
laboratories for?

                                       MR. WHITE: Are there other analyses that AIHA
certifies laboratories for?

                                       MR. CONLON: Yes.

                                       MR. WHITE:   AIHA has an industrial hygiene
laboratory accreditation program that accredits laboratories for analysis of metals, a general group
of metals in air, for asbestos in air by fiber count, for organics in air, and for silica in air.

                                       MR. CONLON:  It is fair to presume that the
requirements generally as you described them here also apply to all those other things that are
covered by the certification program?

                                       MR. WHITE: Yes, sir. In fact, ELLAP programs,
this accreditation program, is formed around the industrial hygiene program, but the industrial
hygiene program has specific requirements dealing with man monitoring.

                                       MR. CONLON: Thank you.

                                       MR. TELLIARD:   Thank you very much, Kenn.
Appreciate your time.
             A little round of applause for our speakers, and you get a five-minute coffee break.
Let's get back out and get back in.

(WHEREUPON, a brief recess was taken.)
                                          672

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"The American Industrial
  Hygiene Association
  Environmental! Lead
Laboratory Accreditation
Program (ASHA/ELLAP)B1
   Kenneth T. White
MS, MBA (MM), CM, CSP
        AS&M
     Hampton, VA
          673

-------
         The
AMERICAN INDUSTRIAL
HYGIENE ASSOCIATION
    is a Professional
Association Dedicated to
the Health and Safety of
    Workers and the
     Community
         674

-------
The American (Industrial
  Hygiene Associaf eon
 Has >10,000 members
  worldwide
 Has 75 local sections
  worldwide
 Has 45 standing
  (technical) committees
 Provides professional
  training worldwide
 Publishes
          675

-------
AIHA Accreditation and
Registration Programs
 Industrial Hygiene
  Laboratory Accreditation
  Program (IHLAPH
 Asbestos Analysts
  Registry (AAR1)
 Environmental Lead
  Laboratory Accreditation
  Program (ELLAP)
         676

-------
AIHA Proficiency Testing
   (Quality Assurance)
        Programs
 - Proficiency Analytical
   Testing (PAT) Program
 - Asbestos Analytical
   Testing (AAT) Program
 - Bulk Asbestos Program
 - Environmental Lead
   Proficiency Analytical
   Testing (ELPAT) Program
           677

-------
AIHA Environmental Lead
 Laboratory Accreditation
    Program (ELLAP)
 - Accreditation for analysts
   of lead in:
   + paint chips (drv filmi
    soil
   + wiped dust (settled)
           678

-------
    Major Program
    Requirements:;
- Site Visits
- Proficiency Testing
- Facilities and Equipment
- Personnel! Criteria
- Quality Assurance
  Program
- Analytical Methods
         679

-------
       Site Visits
- Prior to Accreditation
- Every 3 years thereafter
- Announced visits
- Trained and experienced
  AIM A Representative
- Checkiist format
- Sample analysis required
  during visit
          680

-------
  Proficiency Testing
- Quarterly
 Paint chips, Soils and/or
  Dust Wipes
 Varying concentration
  leveSs
 Data/Results handled by
  NIOSH
          681

-------
Facilities and Equipment
 - Laboratory is accredited
   not an Individual or
   organization
 - Mobile laboratories are
   allowed
  Specific instruments not
   required
 Good housekeeping
   required
           682

-------
   Personnel Criteria
- Technical Manager
 Quality Assurance
  Coordinator
- Analyst(s)
 Management iis on-site
  >50% of the time
        683

-------
   Personnel Criteria
- Technical Manager
  •s- college degree iin Chemistry
     or related scaence5 and
  + a minimum of 2 years of
     analytical chemistry
     experience, and


  + a minimum of 6 months of
     metals analysis experience
            684

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  Personnel Criteria
Quality Assurance
 Coordinator
 •f college degree an a basic
    science, and
 * a minimum of one year of
    analytical chemistry
    experience, and
 -r traininq in statists
  * a minimum of 4 years of
    analytical chemistry
    experience, and
  + training in statistics
           685

-------
 Personnel Criteria
+ completion of a training
   program in metals analysis
   (internal or external), and


-r demonstrated ability to
                  */
   produce reliable results
   through successful analysis
   of blind SRMs, proficiency
   testing samples, and/or QC
   samples
          686

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 Quality Assurance
       Program
In-house training program
 required
Written QA Manual
Instrument calibration
 required
QC checks required
Statistically derived
 control limits required
 for QC checks
Written corrective action
 plan required
 i       n
Analysis documentation
 required
Calculation and report
 review required
        687

-------
Quality Controk Checks
 Instrument calibration
  verification
 Blanks analyzed at rate of
  one in 20 (5%)
 Spiked samples analyzed
  at rate of one iin 10 (10%)


 Duplicate samples
  analyzed at rate of one in
  10 (10%)
         688

-------
 Analytical Methods
No specific method is
 required
Laboratory must
 demonstrate acceptable
 performance of and by
 the chosen method (e.g.
 LOD, LOQ5 accuracy,
 precision)
Method must be
 docurnentated in a
 methods manual that is
 accessible to analysts
 and is reviewed
 periodically by
 management
         689

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AIHA/ELPAT Program
Began November 1992
Matricies are dry paint
 chips, soils, and dust
 wipes
Rounds occur quarferfly,
             n      r* '
 with 4 samples per
 matrix
Is EPA supported
Data/Results handled by
 NIOSH
         690

-------
  ELPAT Roood 001
Samples sent: Dec 1 1992
Results due: Jan 15,1993
Report issued: Feb 19,
 1993
Labs participating: 110
Labs submitting results:
 104
        691

-------
  ELPAT Round 001
Concentration Ranges
 Paint chips: 0.089% to
  5.5% by weight Pb
 Soils: 133 mg Pb/kg to
  3370 mg Pb/kg
 Dust wipes 38 ug Pb to
  4400 ug Pb
         692

-------
   ELPAT Round 001
   Relative Standard
       Deviation
(Reference Laboratories)
 - Paint chips: 7% to 15%
 -Soils: 8%to 12%
 - Dust wipes: 10% to 14%
          693

-------
   ELPAT Round 001
        OutHiers
        (>3 SD)
- Paint chips: 9.4% of 404
- Soils: 7.7% of 336
- Dust wipes: 8.5% of 364
-Overall: 8.6%of 1104
          694

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   ELPAT Round 001
  Acceptable Results
   (acceptable on all
       samples)
- Paint chips: 88 of 101 labs
- Soils: 77 of 84 labs (92%)
 Dust wipes 82 of 9H abs
  (90%)
         695

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696

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                                       MR. TELLIARD:  Can we bring your coffee and
soda in?  We are in the stretch, gang.  Come on, we can do it.

             Our next speaker is going to talk to us on the use of immuno chemistry and x-ray
fluorescence methods for a site investigation, and this is from Woodward-Clyde Federal Services.

             I only knew of Woodward-Clyde-Envircon. I guess that was the same thing.  And
this is Alex Tracy.

             You are on.
                                        697

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698

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           AN INTEGRATED APPLICATION OF FIELD SCREENING TO
           ENVIRONMENTAL SITE INVESTIGATIONS:  A CASE STUDY

                      Tina Cline-Thomas, William Mills, Alex Tracy
                    Woodward-Clyde Federal Services, Rockville MD
Abstract
       A base in the Washington D.C. area was  slated to undergo  facility expansion.  This
expansion was to include construction of a commissary  and parking lot, along with movement
of an existing sports field and a playground to new areas.  Immediately prior to the start of the
construction, information became available which indicated that a landfill  had  existed in the
general area slated for construction activities.  The exact  location and extent of the landfill were
not known.  Woodward-Clyde Federal Services (WCFS) was retained by the Baltimore District
of the U. S. Army Corps of Engineers (COE) to perform an investigation of the area to determine
the extent of the landfill and the health risk to construction workers and playground users. Due
to the construction schedule, the project work had to be completed in an 8-week time period.
Normally this type of project would require up to 6 months. In order to meet  both time and
budgetary constraints, an intensive field sampling effort was undertaken in conjunction with the
use of field screening methods.  Several field screening methodologies were employed to more
fully characterize the site during the time between field sampling and lab analysis: 22 metals by
portable X-Ray Fluorescence Spectrometry (XRF) and  Polychlorinated Biphenyls (PCB) and
Aromatic Hydrocarbons (AH) by immunoassay.  The field screening was used to:

          •  direct field sampling efforts by delineating contaminated areas
          •  prioritize samples for laboratory analysis
          •  provide the laboratory with information on the expected range of contaminants

    In total, approximately 130 samples were screened in  the field and approximately 30 of those
samples had results verified by lab analysis.  The  metals results for XRF and  lab analysis
generally corresponded to each other, provided samples were thoroughly homogenized. Although
some false positives were observed by field screening for PCB and AH, no false negatives were
observed.  This presentation will discuss time and budgetary savings, QA/QC procedures and
comparability of the field screening and lab results.

Introduction

    Woodward-Clyde Federal Services  (WCFS) was charged with the  task of clearing a site for
construction activities within 8 weeks while ensuring that sufficient samples had been taken  to
characterize the site and that those sample results  were  accurate.  In addition to the historical
information which indicated the presence of a landfill whose size and contents were unknown,
there was the possibility that the landfill  area contained   burn pits where PCB  transformer
carcasses had been disposed.   Some preliminary work indicated elevated levels of PCBs,
miscellaneous other organics and metals in the areas where the present playground was located
and where the athletic field was to be relocated (Figure  1).
                                         699

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                   Figure 1:  Site Map Showing Proposed Construction
   As a result of health and safety concerns for construction workers and future residents a site
clearance was undertaken.  Since the construction contract had already been awarded and the
government would face penalties if construction was delayed the time frame available for the
investigation was very short.

   Lab analysis takes 3-4 weeks at normal turnaround times.  Faster turnaround times are
possible at premium rates but even the fastest analysis requires 24-48 hours before results can
be reported.  The approach that was developed for this project involved field screening and lab
analysis with five day turnaround. Lab analysis was required to verify field screening results and
to provide the quantitative information required for the health-based risk assessment  samples.
Field screening  was  performed on  soil  samples for PCB and  aromatic  hydrocarbons (the
Petrorisc1" immunoassay which was chosen is designed to provide total petroleum hydrocarbon
data but is very sensitive to bi and tri-cyclic polyaromatic hydrocarbons) using  immunoassay
technology, and 22 metals using a field portable X-Ray fluorescence (XRF)  spectrometer. The
field screening methods were used to prioritize samples for lab analysis, provide information to
the lab on the approximate concentration range expected to minimize  reanalysis and provide
extent of contamination information for the areas being investigated.

Methods

Immunoassay technologies are well established within the medical lab industry where they have
been  used provide rapid, accurate test results for medical professionals.  In recent years this
technology has also started to emerge in the environmental analysis field. The two parameters
                                          700

-------
analyzed by immunoassays for this project were PCB, using the Envirogard"" immunoassay by
Millipore and aromatic hydrocarbons using Ensys1 Petrorisc1"1 immunoassay kits.  Soil samples
were analyzed for 22 metals using the Spectrace 9000 field-portable XRF. The Spectrace 9000""
XRF uses a mercuric iodide (HgI2) detector along with a fundamental parameters algorithm to
qualitatively and quantitatively identify the metals.

   A lab facility was set up on base for sample log-in and analysis.  All samples were labeled,
logged into a sample tracking system on and screened at this location.  A portable computer was
used for sample tracking as well as to store both the results and the spectra produced by the
XRF.   All  immunoassay data, including balance calibration, extraction weight and the
absorbencies of both the samples and standards were recorded in bound lab notebooks.

 Immunoassays-General

   As both immunoassay kits used methanol as their extraction solvent and immunoassay tests
are quite specific for their target compound(s), one extraction was performed on each sample and
the extract was refrigerated in a labeled screw-top vial.  This ensured any re-analysis would be
performed on the same aliquot of each environmental sample. The analysis reagents were added
according to each manufacturer's instructions1'2'3'4 and all samples were run immediately following
calibration of the test  kit.   A spectrophotometer set  to  450  run  was used  to  record the
absorbencies of both the standards and  samples.

Aromatic Hydrocarbons (AH)

   For the Petrorisc11" immunoassays, sample  absorbencies were determined relative to a low
standard (0.7 ppm m-Xylene, which is equivalent to 100 ppm gasoline) which served as the
threshold of detection.  Two  aliquots of the methanol extract were  analyzed relative  to this
standard:  the first represented the sample without any dilution and the second was the same
extract  at  a ten-fold  dilution.   In  this  manner, approximate  concentrations of petroleum
constituents can be determined with relative ease. While the petroleum kits were calibrated using
m-Xylene, they were sensitive to a variety of compounds found in petroleum products including
bi- and  tri-cyclic  aromatics.1>2  WCFS  utilized  the Petrorisc"" kits' sensitivity  to aromatic
hydrocarbons to indicate burn areas where these aromatic hydrocarbons remained as products of
incomplete combustion.

Because the Petrorisc"11 kits are sensitive to a  variety of compounds,  the immunoassay results
correlated well with the hot spots as defined by lab analysis.  Data on the  correlation between
the two methods is shown in Table 1.
                                          701

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              Table 1:  Comparison of Lab and Field Values for Petrorisc"
Sample Number
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Sample 6
Sample 7
Sample 8
Sample 9
Sample 10
Sample 11
Sample 12
Sample 13
Sample 14
Sample 15
Sample 16
Sample 17
Sample 18
Sample 19
Sample 20
Sample 21
Sample 22
Sample 23
Sample 24
Sample 25
Sample 26
Sample 27
Sample 28
Sample 29
Petrorisc011 Value
ND
ND
ND
ND
ND
Detect
Detect
ND
Detect
Detect
Detect
ND
ND
ND
ND
ND
ND
Detect
ND
ND
ND
ND
ND
Detect
ND
ND
ND
ND
ND
Sum of PAH Values*
ND
ND
ND
ND
ND
ND**
>1 ppm
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>1 ppm
ND
ND
ND
ND
ND
>1 ppm
ND
ND
ND
ND
ND
*Sum PAH=Sum
"Dilution at lab
of all detects for compounds listed in SW-846 Method 8100.
prevented proper quantitation.
                                               702

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    The protocol for performing analysis dictated that the difference between duplicate standards
(Delta Std) could not exceed 0.2 absorbance units (a.u.) or the calibration would be considered
invalid and the samples would be re-analyzed. Although the precision data for the petroleum kits
was acceptable, the use of a repeat pipettor rather than dropper bottles would have improved the
precision. (All figures showing precision data are scaled to equal size, so a visual comparison
may be made.) Ensys will supply the reagents either in dropper bottles or in bulk (for use with
a pipettor), but for this project the dropper bottles were used.  A Shewart plot of Delta Std for
aromatic hydrocarbon analysis is shown in Figure 2.
                  Figure 2:  Precision Data for Petrorisctm Immunoassay
                     1  2  3  4  5  6 7  fl  9  1D 11  12  13 H 15 16 17 IB 19 20 21  22 33 31 35 36 37 2B


                     	Delia Sta         	Upper Warning Limit    __	Loner Warning unit

                     	 Upper Control Limit    	 Lower Control Limit
Polychlorinated Biphenyls (PCB)

    For the PCB kits3'4 (Envirogard""), the concentration of the two calibration standards (2 and
10 ppm Aroclor 1248) were used and a linear dose-response was assumed between those two
points in order to calculate an approximate Aroclor 1248 concentration.  As Aroclor  1260 was
the PCB  found at  the  site,  Aroclor 1248 concentrations  were converted to Aroclor 1260
concentrations using relative response data for the two Aroclors provided by Millipore3'4.  The
PCB kits were used to delineate the volume of the burn pits  being investigated and the samples
taken for lab analysis in those areas was directed by the field screening results. Correlation data
is presented in Table 2.
                                            703

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Table 2: Comparison of Lab and Field Values for PCB
Sample Number
Sample 1
Sample 2
Sample 3
Sample 4
Sample S
Sample 6
Sample 7
Sample 8
Sample 9
Sample 10
Sample 11
Sample 12
Sample 13
Sample 14
Sample 15
Sample 16
Sample 17
Sample 18
Sample 19
Sample 20
Sample 21
Sample 22
Sample 23
Sample 24
Sample 25
Sample 26
Sample 27
Sample 28
Sample 29
Sample 30
Sample 31
Sample 32
Immunoassay Value
ND
ND
ND
ND
Detect
ND
ND
ND
ND
Detect
ND
ND
ND
ND
Detect
Detect
ND
Detect
ND
ND
Detect
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
PCBs by Method 8080
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND*
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                       704

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Sample Number
Sample 33
Sample 34
Sample 35
Sample 36
Sample 37
Sample 38
Immunoassay Value
ND
ND
ND
ND
Detect
ND
PCBs by Method 8080
ND
ND
ND
ND
ND
ND
   "Dilution at lab prevented proper quantitation

   Reagents were added using an Eppendorf repeat pipettor, which allowed for rapid analysis
with good accuracy and precision.  Typically a total of twenty tubes were analyzed per run:
assuming analysis performed in duplicate, three standards and seven samples could be analyzed
in one run. A  Shewart plot (Delta Std) for both the low and high standards is provided in
Figures 3 and 4.
                      Figure 3:  Precision Data for PCB Low Std.
D 3
0 2
D 1
Q
-D 1
0 I
0 3

-

^ 	 	
S \ /-^.^ f 	 v ^ 	 	
" ~ 	 \ / \/
V
-
1 2 3 1 5 6 7 B 9 10 11 12 13 11 15 16
	 Delia Sid 	 Upper iBrnins Limit 	 Lo^er laming Limn
	 Upper Control Limit 	 U*«r Control Limn

                                           705

-------
                      Figure 4:  Precision Data for PCB High Std.

0 2
0 1
0 1
0 2

,-
_X""«^
——/ "~\ ^—^
\__^— — - — . 	

-
1 2 3 1 5 6 1 8 9 ID 11 12 13 11 15 16
	 Delta Std 	 Upper Naming Limit 	 lower Warning Limit
	 Upper Control Limit 	 Lower Control Limit

Field-Portable XRF

   All samples were first air dried and sieved through a 10-mesh sieve and sample descriptions
were recorded for all samples. If a significant amount of material would not pass through the
sieve, the material remaining in the sieve was retained and labeled as the exclusion products of
that environmental sample.  The dried samples were then placed in 32mm sample cups and
covered with Mylar film.5-6  Each sample cup was labeled with the field sample number and
retained for re-analysis, if necessary.  At the end of each day, both the results and spectra were
downloaded to a laptop computer for storage and data processing.

   A mid-range standard reference material (SRM) and  a quartz blank were run daily prior to
any samples, after every 10 samples and at the end of the analytical run (10% frequency). This
standard was an environmental sample which  had been certified using traditional wet prep
techniques followed by GFAA and ICP analysis.  Both the SRM and blank were used to confirm
instrument stability during the project. The standard was less homogeneous than was initially
assumed at the start of the project:  approximately a week after the XRF screening had begun,
particles where discovered in the sample cup which would not have passed through a 10-mesh
sieve.  As there was a week of data on the standard it was not re-prepped.  Particle-size effects
from  these  large particles were believed  to introduce some variability  in the standard as
illustrated in the Shewart plots for the standard.  The samples were believed to be  more
homogeneous because all samples were dried and sieved prior to analysis. A plot of the Pb
results (Pb was one of the elements which had poor precision relative to most of the analytes)
for the standard over the course of the project is shown hi Figure 5 and a table of the accuracy
and precision data is shown hi Table 3.
                                         706

-------
                       Figure 5:  Precision Data for XRF Std (Pb)
                    1  2  3  1  5  6  7  B  9  10 11  12  13  H 15 16 17 IB  19  20 21 ?2 ?3


                   . PO Concenlraion (mg/lg)    	 Upper Varning Limit      	Loner Warning Limit

                   .Upper Con t ro I L im 11      —
       Table 3:  Accuracy and Precision Data for XRF Standard Reference Material

Average (mg/kg)
True Value1
Percent Recovery
Std. Dev.
Relative Std. Dev.
Cr
184170
160287
114.9%
2263
1.2%
Ni
16014
13105
122.2%
423
2.6%
Cu
2787
2946
94.6%
144
5.2%
Pb
115
141
81.6%
19
16.9%
Cd
387
292
132.6%
65
16.9%
Conclusion

Method-Specific:  Immunoassay

The staff of two chemists performing analysis in the field lab was able  to screen approximately
20 samples per day for metals, PCBs and aromatic hydrocarbons. The use of a repeat pipettor
is  recommended both to speed immunoassay  analysis and  to  achieve better precision  and
accuracy. The correlation between lab and field data was good, but the difference in detection
limits and sample heterogeneity sometimes make it difficult to directly compare immunoassay
and lab data.  However, the regions indicated as contaminated by field screening correlated very
well with the  areas indicated as contaminated by lab analysis, historical data,  and  PID/OVA
results of samples taken hi the field.
                                          707

-------
Method-Specific: XRF

The  use of an  independent standard which  was certified by traditional metals techniques
(GFAA/ICP) gave the data produced by  the XRF an additional level of confidence.  The
instrument showed good stability over the course of the  project and 16.9% was the worst
relative standard deviation for any of the certified analytes (Cr, Ni, Cu, Pb, and Cd). Had the
standard reference material been completely homogeneous, the standard deviation would
probably have been considerably lower:  Shewart plots showed only  a few values which were
close to the control limit (Average+/-[3*Std. Dev.]).  If these values were considered outliers
and removed, the standard deviation decreased markedly. XRF analysis of the standard reference
material correlated very well with its certified values: the average percent recovery (defined as
[XRF value/True Value]*100)  was 109.2% with a high of  132.6% for Cd and a low of 81.6%
for Pb.

OA/OC Issues

   Field screening can provide either Level I  or Level II data9:   for this project the field
screening data was regarded as Level I data and the laboratory analysis was used to make all
final decisions regarding site contamination. Specific guidelines for producing Level II data may
vary from site to site, and the  sampling and analysis program must address the  problems of
sample  heterogeneity, matrix effects, interfering compounds, and sample contamination as a
result of improper handling or preparation7.

   Although field screening can present additional challenges to the field team, there are many
instances  where the  additional  data  produced from the lower-cost  field  screening tests  can
significantly reduce  the  sampling error  in site investigations.  Analytical error (bias  and
variability introduced in the lab) typically accounts for only 15% of  the total error introduced
in the site investigation process. The remaining 85% of the error in site investigations results
from insufficient samples or samples which do not accurately represent the contamination at the
site8.  Field screening allows for rapid  analysis following sample collection, which reduces
problems in sample handling, preservation and transport, and gives the field team the flexibility
to employ an iterative sampling strategy to fully characterize the contamination.

Effect on Sampling & Lab Analysis

   Through the integrated use of field screening WCFS completed the site clearance on-time,
better delineated the extent of contamination and helped to direct the activities of the field crew.
In addition to the data provided by the lab, historical information such  as aerial photos were used
to identify the  area occupied by  the former landfill (Figure  6).   While XRF has been used
successfully in site investigations in the past, new advances in detector technology will provide
field teams with an instrument which is both portable and sensitive.   At the time of this project
(April-May 1992), none  of the immunoassay techniques had been recognized as methods by
EPA.     Subsequently  EPA  has  granted  SW-846  third  update  numbers   of 4010
(pentachlorophenol), 4020 (PCB), and 4030 (Total Petroleum Hydrocarbons) for immunoassay
screening techniques.
                                          708

-------
   In keeping with the DQO development process defined by EPA9, the project should be
planned with field screening in mind from the outset, and a chemist familiar with the technology
to be employed should be involved during the planning stage. The overall effectiveness of field
screening will depend on project-specific needs. It is recommended that the actual screening
analysis  be carried out by,  or under the supervision of, a qualified chemist  to minimize
resampling and  reanalysis and to  ensure that results are not used  inappropriately.   Both
immunoassay and XRF are mature screening technologies, which, when used properly can be
very cost-effective tools hi the site investigation process.
     Figure 6:  Site Contamination as Delineated by Field Screening and Lab Results
                                                                  Federal Se
                                          709

-------
                                    References
'PETRO RISctm User's Guide, Ensys Inc, 1992.

2"Soil Screening for Petroleum Hydrocarbons by Immunoassay," Draft Method 4030, USEPA
SW-846 Third Update, July 1992.

3Envirogard Tests Kits User's Guide, Millipore Corporation, 1992.

4"Soil Screening for Polychlorinated Biphenyls by Immunoassay," Draft Method 4020, USEPA
SW-846 Third Update, July 1992.

5Spectrace 9000 User's Guide. TN Technologies

6Donald E. Leyden, Fundamentals of X-Ray Spectrometry as Applied to Energy Dispersive
Techniques: Tracor Xray, 1984.

7Kevin J. Nesbitt, "Application  and QA/QC Guidance USEPA SW-846  Immunoassay-Based
Field Methods 4010, 4020 & 4030;" Ensys Inc, 1992.

8Francis Pittard, Principles of Environmental Sampling: A Short Course Presented Prior to the
8th Annual Waste Testing & Quality Assurance Symposium, July 11-12,  1992.

9USEPA, Data Quality Objectives for Remedial Response Activities. EPA/540/G-87/003, March
1987.
                                        710

-------
Integrated Application of Field Screening
               A Case Study

              Tina Cline-Thomas
                William J. Mills
                  Alex Tracy
        Woodward-Clyde Federal Services
              Rockville, Maryland
                           Woodward-Clyde

-------
K)
               Disclaimer

This presentation has not been subject to peer
review by the U.S. Army Corps of Engineers
(USAGE) and therefore, does not represent USAGE
opinion or endorsement. The mention of trademarks
in this presentation is provided for documentation
purposes and does not constitute endorsement by
Woodward-Clyde.

-------
          Introduction
U.S. Army base in Washington, D.C. area
Planned construction of a new commissary
and parking lot
Relocation of sports fields and playground
to other areas

-------
          Introduction
             (continued)

Prior to construction, information became
available that a former landfill existed in
general area
Extent of landfill is not known
Some preliminary information available -
PCBs, VOCs, metals were observed
Concerns about worker and playground
users' health
Site clearance required

-------
            The Problem
Perform a site clearance investigation
Very little information on landfill available
Determine extent and location of former landfill
Determine health risk to workers and users
Extremely tight timeframe

-------
      Site Map Showing Proposed Construction
-o
ON


-------
           Solution

Intense sampling effort
Implement field screening as part of site
investigation process
Field screening for PCBs, aromatics,
metals (soils only)
Lab analysis to provide backup of field
screening and more detailed information
for health risk assessment
One week TAT for most lab analyses

-------
                 Field Screening
        Used to:
-o
oo
Direct sampling efforts
Provide information to labs on sample
concentration range expected
Prioritize samples for lab analyses
Provide extent of contamination information
while awaiting lab results

-------
 Field Screening Methods
PCBs    	**  Immunoassay
Aromatics 	^ Immunoassay
Metals  	*-   X-ray fluorescence

-------
             Field Screening Setup
K)
O
 Field lab setup on base:
- Sample log in
- Sample analysis
- Packaging of samples for shipment to lab
- Tabulation of results
- Planning of sampling effort

-------
         Immunoassays
 General
- Immunoassays in chemical diagnostic use
  since -1965
- Immunoassays being applied to pollutant
  testing in 1990's
- Immunoassays offer:
  • Selectivity
  • Sensitivity
  • Speed of analysis
  • Concentration range information

-------
 Soil Sample
1.  Weigh out
2.  Solvent
   extraction
                       1
                     Extract
                                    Add extract to
                                 antibody coated tube
                                                     Incubate
1
                                                      Decant off
                                                       extract
                                                                        \
                                                                     Add
                                                                  conjugate
                                                              Incubate
                                      Incubate
                                                                  Decant off
                                                                  conjugate
Compare to standards
Color is inversely
proportional to
concentration of
analyte
                                      f
                                                      Add
                                                   substrate
                    Measure
                  absorbence
                                   Quench

-------
                  PCB Analysis
to
Millipore Envirogard™ kits used
2 ppm and 10 ppm concentration ranges
Calibrate with Arochlor 1248
Methanol extraction

-------
                 Precision Data for  PCB  Low Std.
           0.3
           0.2
           0. 1
                              3K-
to
               A	A-
           -0.1
   -o	e	©	o	e	©——©	o	©-
                                                           o	e	e	o
          -0.2 -
-0.3 I	1	L
                          J	1	I	I	I	I	I	I	I	\	I	I	L
                   23





                  De I ta Std .





                  Upper Control Limit
4    5   S   7   8   9   10





        0  Upper Warning Limit





       —0— Lower Control Limit
                                         11   12   13
                                           Lower War n)ng Limit
                                                       15   16

-------
                  Precision  Data for PCB High  Std.
             0.3
             0.2
to
             0 1
                 A.	A-
            -0.1
                               -$	$	9	9	9-
                 o	e	e	e-
-e	e-
                                                       X	X-
                                                                  -a	B-
-e-
-e	e	e	o
            -0.2
            -0.3
                 J	L
                                           _L
                                               J	I	I	L
                                                                      J	L
                  B_ Delta Std





                  ^— Upper Control Limit
 7   8    9   10





Upper Warning Limit





Lower Control Limit
                                                       11   12   13  14  15





                                                       ^ Lower Warning Limit
                                                                          16

-------
           Aromatic Hydrocarbons
to
Ensys Petro Rise ™ kits
100 ppm gasoline
Sensitivity to bi- and tricyclic aromatics
Methanol extraction

-------
N)
-O
        Precision Data for Petrorisc™ Immunoassay
         0.3
         0 2
         0.1
        -0. 1
        -0.2
        -0.3
             *—*—x—xxx—*—*—x-—*—*—*—x—x—x—x-—*—x—*—x-—*—*—x—*—x x x
             »-*-
           -oooooooooooooooooooooooooooo
I  I  I  I  I I  I  I  I  I  I  I  I  I  I I  I  I  I  I  I  I  I  I  I  I I  I

1  2  3  4  5 B  7  8  9  10  11  12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
                DeIta Std.


                Upper Control Limit
                   Upper Warning Limit


                   Lower Control Limit
Lower Warning Limit

-------
          Immunoassays Discussion
to
oo
Able to use one extract for two types of analyses
Fast
Semi-quantitative
Very little temperature effect observed
Good correlation with lab results (30-40 samples)
No false negatives

-------
             XRF
 Spectrace 9000 Field Portable XRF
 Hgl2 detection
- No cooling
- Resolution
 Different sources available
 Wide variety of metals analyzed
 All data stored in computer

-------
           200
                    Precision Data for XRF Std. (Pb)
o
           180
           160
           140
           120
           100
            80
            60
                o—G—©—e—©—©—©—©—©-
-e—0—0—©—©—©—©—©—©—o
            40 I	1
                             i  -i.
                                        i  I   I   I  I   I   i
         I - L
                                                                     I   I  I   I
                1  2  3  A  5  6  7  8  9  10  11 12 13  14 15  16  17 18  19  20 21  22  23 24





               Pb Concentralon Ci^J/kaJ    —«/- UpPer  Warning Limit        A Lower Warning Limit




               Upper Control Limit        r> Lower  Control Limit


-------
         XRF Discussion
Excellent stability
Good performance for SRM
Ease of use
Ability to reinspect specific results and spectra
Good correlation with lab results

-------
                  EPA QA/QC Levels
KJ
 Level I
- Screening objective - rapid, preliminary field assessment
 Level II
- Screening objective - field methods or quick lab methods
  with a portion of results verified by rigorous lab analysis
 Level III
- Rigorous objective - lab methods with assessment of
  accuracy and precision of each analytical determination

-------
Level I Field Screening QA/QC
    XRF and immunoassays
   - Sample documentation
   - Calibration or performance check

-------
     Level II Field Screening QA/QC
 XRF and immunoassays
- Sample documentation
- Calibration
- Blanks
- Matrix background
- Performance evaluation
  samples
- Matrix spikes
- Duplicate sample analysis
- Laboratory confirmation
- Size fractioning of soil
  sample

-------
     Project Conclusions

130 samples field screened over a two
and one-half week period
Many samples analyzed in duplicate
Many samples backed up by lab analysis
No false negatives, some false positives
Data produced was Level 1.5
Project completed successfully to meet
client needs

-------
              General Conclusions
ON
Rapidly developing area
Definite application to environmental
site investigation
Actual application will depend on
project needs
Can provide cost-effective answers

-------
              General Conclusions
                     (continued)
U)
Speeds up information transfer to
project manager
Different levels of QA/QC possible
Most methods should be operated under
supervision of a qualified chemist

-------
            Site Contamination as Delineated
           by Field Screening and Lab Results
                                BUHN PIT AREA
-o
u>
oo

-------
            Acknowledgements
OJ
Ensys
Millipore
Spectrace
U.S. EPA
U.S. Army Corps of Engineers

-------
740

-------
                                        MR. TELLIARD:  Our last speaker of the day is
Mike Kravitz from the Office of Water.  Mike is going to talk about QA/QC guidance that the
office has generated for the analysis of dredge materials and evaluation thereof.

             Mike just arrived.  He was a little late.  Gave me a little heartburn, but he is
armed.
                  QA/QC Guidance for Dredged Material Evaluations
                                        MR. KRAVITZ:  My name is Mike Kravitz, and I
am with the EPA's Office of Science and Technology (OST).

              For the past few years, the Risk Assessment and Management Branch of OST has
been working on issues pertaining to the evaluation of dredged material. We are working closely
with the Army Corps of Engineers to produce a number of national
documents.

              One of these, the draft "Inland Testing Manual" is a national document for the
evaluation of potential contaminant-related impacts of dredged material proposed for discharge
into freshwater, estuarine and near coastal waters of the United States.  It provides guidance on
the kinds of tests that need  to be performed by dredging permit applicants.

              Along with this guidance, it is very important that we have good quality assurance
and quality control.   This  is, to some extent, built into the document, but to  ensure that
evaluations are conducted in a consistent manner around the country, we are producing "Quality
Assurance/Quality Control Guidance for Sampling and Analysis of Sediments, Water and Tissues
for Dredged Material Evaluations." Let me go into a little more detail.

              The purpose  of the document is twofold.  One is to provide guidance on the
development of QA project plans for ensuring the reliability of physical, chemical, and biological
testing data gathered to evaluate dredged material proposed for discharge under the Clean Water
Act (CWA) or the Marine Protection, Research, and Sanctuaries Act (MPRSA).  (Essentially, the
CWA regulates the discharge  of  dredged  material within the baseline  of the territorial sea,
whereas MPRSA governs transportation of dredged material seaward of the baseline for discharge
purposes.) The second purpose is to outline procedures that need to be followed when sampling
and analyzing sediments, water, and tissues.

              The QA guidance document serves as a companion document to the draft Inland
Testing Manual (mentioned at the  start of this talk) and the  1991 Ocean Testing  Manual for
evaluating dredged material proposed for discharge into CWA or MPRSA waters, respectively.
                                         741

-------
              When dredged material is evaluated, it is evaluated for whether or not it can be
discharged into open water without management actions, in other words, without capping or other
control measures.  If the material "passes", then it is okay to dispose of the material  as long as
it complies with other regulations.

              The testing procedures in the Inland and Ocean testing manuals are arranged in
a series of tiers, or levels of intensity (and cost) of investigation.  The first tier is an analysis of
historical data, and it  is important that the data be of good quality in order that we can use it in
the evaluation. The second tier is concerned with chemical analyses. It is here that you compare
the dredged material  discharge  to water  quality criteria or standards,  depending on whether
disposal will occur in ocean or inland waters.  The third tier involves biological tests (bioassay),
i.e. toxicity  and bioaccumulation tests.  The fourth tier allows for case-specific laboratory and
field testing, and is intended for use  in unusual circumstances.

              Most  of the sediment  and water chemistry  analyses takes place  in  tier 2.
Validation of the chemistry data ensures that objectives for data precision and bias were met, that
data generated in accordance with the QA project plan and standard operating procedures, and
that data are traceable and defensible.  Figure  1, from the QA document, provides  evaluation
criteria that  could alert a project manager to potential problems with data  acceptability.

              Figure  2 shows the contents of the QA document.  The main  emphasis is on
drafting a quality assurance project plan; the elements listed here are typical.  We also include
a fairly comprehensive list of references.

              The document includes a number of useful appendices (Fig. 3), such as examples
of various checklists; an example statement of work for the laboratory; description of calibration,
quality control checks, and widely used  analytical methods; and example  standard operating
procedures (SOPs).

              One thing that is very  important is we are using a performance-based approach in
the development of this document even though we do recommend methods that should be used
for  various  analyses.    Performance-based   goals for  accuracy   (precision and  bias),
representativeness,  comparability, and  completeness, as well as  the  required  sensitivity of
chemical measurements should be defined in project-specific  Data Quality Objectives.

              With respect to required  sensitivity of chemical measurements, the QA guidance
contains recommended "target detection limits" (TDLs) that are judged to be feasible by a variety
of methods, cost effective, and  to meet the requirements for dredged material evaluations.  If
significantly higher or lower TDLs are required to meet rigorously  defined data quality objectives
for a specific project, then on a project-specific  basis,  modification to  existing  analytical
procedures may be necessary. Such modifications must be documented  in the QA Project Plan.
                                           742

-------
              The TDL should not be confused with MDL or PQL or any of those kinds of
detection limits.  The TDL is a perofrmance goal set between the lowest, technically feasible,
detection limit for routine analytical methods and  available regulatory criteria  or guidelines
("effects levels") for evaluating dredged material.  For example, some metals have relatively high
target detection limits, whereas dioxin has a low detection limit. The QA guidance document
recommends target detection  limits for sediments, water, and tissues.

              Much of the information in the QA guidance is in tabulated form.  These (Fig. 4)
are some of examples of the type of information  covered. We include a list of PCB congeners
recommended for quantification as potential contaminants of concern. We also list octanol/water
partition coefficients for organic compound priority pollutants and pesticides. This is important
because analytes having a  high octanol/water partition coefficient are likely to bioaccumulate in
animals.  Of particular usefulness  is the summary of recommended procedures  for sample
collection, preservation, and storage.

              The QA document is being developed in two phases.  The first phase, planned for
distribution this fall, is concerned with chemical evaluations.  The second phase will  cover
biological evaluations, including bioassays (bioaccumulation and toxicity tests). EPA is currently
standardizing a number of bioassay  tests.

              In  summary,   the  dredged  material  evaluations  can  be very  comprehensive,
involving measures of sediment and water chemistry as well as biological evaluations.  The
present QA guidance, along with the national testing manuals, should allow for technically
appropiate and consistent  assessments of potential contaminant-related impacts associated wiht
the discharge of dredged material in U.S. waters.

              Any questions?

                                        MR.  TELLIARD: Any questions?
(No response.)

                                        MR.  TELLIARD: Thank you.
                                          743

-------
744

-------
INFORMATION
   SOURCE
EVALUATION
  CRITERIA
 TECHNICAL
CONCLUSION
MANAGEMENT
    ACTION
    Analytical
 Data and Supporting
  Documentation
                             Detection
                               Limits
                             Acceptable
                                9
                                                                              Accept
                                                                            Data for Use
                                                    Within Limits
                                                     Marginally
                                                   Outside Limits
                                                                           Accept Data with
                                                                             Appropriate
                                                                            Qualifications
                                                                            Consult Expert
                                                     Severely
                                                   Outside Limits
                                                    Reject Data
                                                    (and consider
                                                     reanalysis)
         Figure 1.  Guidance for data assessment and screening for data quality.
                                                                                     C965 Or 02 0193

-------
CONTENTS




1. INTRODUCTION




   - Government  (Data User) Program




   - Contractor  (Data Generator) Program




2. DRAFTING A QUALITY ASSURANCE PROJECT PLAN




   - Introductory Material




   - Quality Assurance Organization and Responsibilities




   - Quality Assurance Objectives




   - Standard Operating Procedures




   - Sampling Strategy and Procedures




   - Sampling Custody




   - Calibration Procedures and Frequency




   - Analytical Procedures




   - Data Screening, Validation, Reduction, and Reporting




   - Internal Quality Control Checks




   - Performance and System Audits




   - Preventive Maintenance



   - Calculation of Data Quality Indicators




   - Corrective Actions




   - Quality Assurance Reports to Management




   - References




3. REFERENCES




4. GLOSSARY




APPENDICES








                             Figure 2
                            746

-------
                        APPENDICES


- Example QA/QC Checklists, Forms, and Records

- Example Statement of Work for the Laboratory

- Description of Calibration,  Quality Control Checks, and
  Widely Used Analytical Methods

- Standard Operating Procedures

- EPA Priority Pollutants and Additional Hazardous Substance
  List Compounds

- Example Quality Assurance Reports

- Analytical/Environmental Laboratory Audit Standard Operating
  Procedure

- Format for the Sediment Testing Report
                         Figure  3
                              747

-------
         MUCH OF INFORMATION IS IN TABULATED FORM:
- Checklist of Laboratory Deliverables for the Analysis of
  Organic Compounds

- Checklist of Laboratory Deliverables for the Analysis of
  Metals

- Routine Analytical Methods and Target Detection Limits for
  Sediment, Water, and Tissue

- Levels of Data Quality for Historical Data

- Summary of Recommended Procedures for Sample Collection,
  Preservation, and Storage

- Example Calibration Procedures

- Polychlorinated Biphenyl Congeners Recommended for
  Quantification as Potential Contaminants of Concern

- Octanol/water Partition Coefficients for Organic Compound
  Priority Pollutants and 301(h) Pesticides

- Bioconcentration Factors of Inorganic Priority Pollutants

- Levels of Data Validation

- Example Warning and Control Limits for Calibration and
  Quality Control Samples

- Sources of Standard Reference Materials
                          Figure 4
                         748

-------
                                CLOSING REMARKS
                                       MR. TELLIARD: Thanks to all of the speakers and
to all of you for your attention and cooperation.

             I would also like to thank the County Court Reporters, Inc. for taking down all
your golden droppings of knowledge; Jan Sears who made this happen and facilitated it; and
Dale Rushneck  for planning and coordinating the program.

             I hope we are still trying to meet the purpose of this meeting which is to exchange
information, not only on analytical work but also  on the policies and direction of the Agency.
We are trying to let the world out there know that there are changes afoot. We change slowly.
The wheels of government do not blind you with their quickness. But we are also trying to keep
this an open forum, and we would like input.

             I have asked for suggestions on the oil and grease issue. Many of you have come
up to me and said you will be sending me information.

             Bob April requested some information on the metals, and we will be sending you
out those questions. If you would give it a little thought going home on the plane, train, bus or
the goat cart and come up with some information  and send it back, we would appreciate it.

             Thank you again for your attention.  We hope to be back here next year, barring
some unforeseen disaster.  In  the meantime, if you have any suggestions for program sessions
or whatever, please feel free to give  me a call.  Thanks again for a great meeting!

(WHEREUPON, the proceedings were concluded at 4:00 p.m.)
                                         749

-------
750

-------
               16th  Annual EPA Conference on Analysis
                  of Pollutants in the  Environment
                            May  5-6,  1993

                           List of Speakers
Bob April
Office of Science and Technology
US EPA, Office of Water
401 M Street, S.W.
Washington, DC  20460
Telephone No: 202-260-6322
Nicholas Bloom
Senior Scientist
Frontier GeoSciences, Inc.
414 Pontius North, Suite F
Seattle, WA  98109
Telephone No: 206-622-6960
Marielle Brinkman
Batelle Memorial Institute
505 King Avenue
Columbus, OH  43201
Telephone No: 614-424-5277
Hazel M. Burkholder
Research Chemist
Batelle Memorial Institute
505 King Avenue
Columbus, OH  43201
Telephone No: 614-424-5311
Bruce Colby
Pacific Analytical
349 Paseo Del Lago
Carlsbad, CA  92009
Telephone No: 619-438-3100
Dave Demorest
Core Laboratories
A division of Atlas International
420 West First Street
Casper, WY  82601
Telephone No: 307-235-5741
James M. Conlon
Drinking Water Standards
Office of Ground Water and
Drinking Water
US EPA, Office of Water
401 M Street, S.W.
Washington, DC  20460
Telephone No: 202-260-7575

Mike Kravitz
Office of Science and Technology
US EPA, Office of Water
401 M Street, S.W.
Washington, DC  20460
Telephone No: 202-260-8085
Yan Liu
California Operations
Midwest Research Institute
625-B Clyde Avenue
Mountain View, CA  94043
Telephone No: 415-694-7700
Ed Marti
Triangle Labs of RTF, Inc.
P.O. Box 13485
Research Triangle Pk, NC  27709
Telephone No: 919-544-8353
Theodore D. Martin
Environmental Monitoring
Research Laboratory
Chemistry Research Division
26 W. Martin Luther King Dr.
Cincinnati, OH  45268
Telephone No: 513-569-7312
Dr. Harry B. McCarty
Hazardous Waste Methods
Support Division
SAIC
7600-A Leesburg Pike
Falls Church, VA  22043
Telephone No: 703-821-4709
                                  751

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John McGuire
Measurements Branch
US EPA
Environmental Research Laboratory
Athens, GA  30613-7799
Telephone No: 706-546-3185
Joe Raia
15402 Park Estates
Houston, TX  77062
Telephone No: 713-486-4354
Ileana Rhodes
Senior Research Chemist
Shell Development Company
P.O. Box 1380
Houston, TX  77251
Telephone No: 713-493-8215
James K. Rice
17415 Batchelor's Forest Road
Olney, MD  20832
Telephone No: 301-774-2210
Richard Rivera
Shell Development Company
P.O. Box 1380
Houston, TX  77251
Telephone No: 713-245-7904
George Stanko
Senior Staff Chemist
Shell Development Company
P.O. Box 1380
Houston, TX  77251
Telephone No: 713-493-7702
William A. Telliard, Director
Analytical Methods Staff
Office of Science and Technology
US EPA, Office of Water
401 M Street, S.W.
Washington, DC  20460
Telephone No: 202-260-7185
Alex Tracy
Woodward-Clyde Federal Services
One Church St., Suite 700
Rockville, MD  20850
Telephone No: 301-309-0800
Richard Turle
Technology Centre
Environment Canada
Chemistry Division
River Road Environmental
Ottawa  Ontario  K1A OH3, CANADA
Telephone No: 613-990-8559
Kenneth T. White
Consultive Services
4428 Ironwood Drive
Virginia Beach, VA  23462
Telephone No: 804-499-4420
Zhouyao Zhang
Department of Chemistry
University of Waterloo
200 University Avenue, West
Waterloo  Ontario  N2L 3G1, CANADA
Telephone No: 519-885-1211
                                  752

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                       16th Annual  EPA Conference on
                Analysis  of  Pollutants  in the Environment
                               May 5-6,  1993

                             List of Attendees
Amos Lee Adams
Chemist
Petroleum Testing Lab
Fleet & Industrial Supply Center
Building W
388 Virginia Avenue
Norfolk VA 23511
804-444-2761

Merrill Anderson
Navy Public Works Center
9742 Maryland Ave
Code 900
Norfolk VA 23511-3095
804-445-8850
Merrill Anderson
Navy Public Works Center
9742 Maryland Ave
Code 900
Norfolk VA 23511-3095
804-445-8850
Steve Arpie
QC Supervisor
Absolute Standards, Inc.
498 Russell Street
New Haven CT 06513
203-468-7407
David E. Ashkenaz
MW Regional Mgr.
Varian Sample Preparation Products
388 Forest Knoll Drive
Palatine IL 60067
708-705-9629
Federico Asmar
Laboratory Manager
High Technology Lab.
PO Box 3964
Guaynabo PR 00970-3964
809-790-0251
Charley W. Banks
Env. Engineer Sr.
VA DEQ
4900 Cox Rd.
Glen Allen VA 23060
804-527-5087
Thomas Barber
Group Leader
CIBA-GEIGY
41 Swing Road
Greensboro NC 27409
919-632-7297
Sarah Barkowski
Senior Research Chemist
Boise Cascade Corp, R & D
4435 N. Channel Ave.
Portland OR 97217
503-286-7441
Bob Beimer
Lab Manager
S-Cubed
3398 Carmel Mtn. Road
San Diego CA 92121
619-587-8848
                                     753

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S. Mark Benfield
Manager
Wet Chemistry Laboratory
Webb Technical Group, Inc.
4325 Pleasant Valley Rd.
Suite 110
Raleigh NC 27612'
919-787-9171

Julie M. Blackwell
Chemist
GZA GeoEnvironmental
320 Needham St.
Boston MA 02164
617-630-6108
John Bernard, Jr.
Lab Manager
Alexandria Sanit. Auth.
P. O. Box 1987
Alexandria VA 22313
703-549-3381
E. Blank
Complete Analysis Labs.
1259 Route 46
Bldg. 4
Parsippany NJ 07054-4909
201-335-CALI
Daniel Bolt
Environmental Products Mgr.
Cambridge Isotope Labs., Inc.
20 Commerce Way
Woburn MA 01801
617-938-0067
Petra Bott
Chemical Tech.
HRSD
1432 Air Rail Ave.
Virginia Beach VA 23455
804-460-2261
Paul Bouis
J.T. Baker
222 Red School Lane
Phillipsburg NJ 08865
908-859-2151
Keith Bounds
Tech. Lead Environmental
Sverdrup Technology, Inc.
Building 2423
Stennis Spa Ctr MS 35929
601-888-3158
John Bourbon
US EPA, Region 2
Environmental Service Division
Building 10
2890 Woodbridge Avenue
Edison NJ 08837
908-321-6729
Bettie J. Bradley
Navy Public Works Center
9742 Maryland Ave
Code 900
Norfolk VA 23511-3095
804-445-8850
Patrick Bradley
Environmental Scientist
Dept. of Navy
Atlantic Division
1510 Gilbert Street
Norfolk VA 23511-2699
804-445-2930
Parry Bragg
Lab. Supervisor/Sr.Chm.
Marine Chemist  Service
11850 Tugboat Lane
Newport News VA 23606
804-873-0933
                                     754

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Ronald Brenton
Supervisory Chemist
US Geological Survey
5293 Ward Road
Arvada CO 80002
303-467-8215
Don W. Brown
EQ Superintendent
City of Danville, WPCP
Riverview Industrial Park
229 Stinson Drive
Danville VA 24540
804-799-5137
Nancy Broyles
Advanced Chemist
Technical Center
Union Carbide Corporation
3200 Kanawha Turnpike
South Charleston WV 25303
304-747-4729
Leslie Bucina
Organic Laboratory Manager
Kemron Environmental
109 Starlite Park
Marietta OH 45750
614-373-4071
Barbara Brumbrugh
Sr. Environmental Insp.
VA DEQ
Water Division
287 Pembrook Office Park
Pembrook 2, Suite 310
Virginia Beach VA 23462
804-552-1174

Patrick A. Buddrus
Manager
Organics Laboratory
CHESTER LabNet - Portland
12242 SW Garden Place
Tigard OR 97223
503-624-2773
Lisa M. Burgesser
Chemist
Environmental Resource Associates
5540 Marshall Street
Arvada CO 80002
303-431-8474
Anne Burnett
Quality Control Officer
Environmental Test.  Svcs.
888 Norfolk Square
Norfolk VA 23502
804-461-3874
E. A.  (Tony) Burns
Contract Administrator
Quality Assurance Laboratory
6605 Nancy Ridge Drive
San Diego CA 92121
619-552-3636
Carrie Buswell
Environmental Scientist
DynCorp - Viar, Inc.
300 North Lee St., #200
Alexandria VA 22314
703-519-1385
Bill Castle
Petroleum & Chemical Lab
State of California
Dept. of Fish & Game
1995 Nimbus Rd.
Rancho Cordova CA 95670
916-355-0142
Dan Caudle
Conoco, Inc.
Suite DU2002
PO Box 2197
Houston TX 77252
713-293-1246
                                     755

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Krishna Chakravorty
Defense General Supply Center
8000 Jefferson Davis Hwy.
Richmond VA 23297-5685
804-279-4097
Shin-Ling Chang
Director of Analytical Testing
Commonwealth Technology, Inc.
2520 Regency Road
Lexington KY 40503
606-276-3506
                          Terry N.  Chamberlain
                          Supy. Envir.  Engineer
                          Environmental Prot.  Dept.
                          Fleet & Industrial Supply
                          Installation Services
                          Suite 600
                          Code 71
                          Norfolk VA 23511
                          804-444-5446

                          Rich Chrostek
                          Technical Sales Rep.
                          Vairan Sample Prep.  Prod.
                          24201 Frampton Avenue
                          Harbor City CA 90710
                          800-421-2825
Ida Church
Navy Public Works Center
9742 Maryland Ave
Code 900
Norfolk VA 23511-3095
804-445-8850
                          Roger Claff
                          Environmental Scientist
                          American Petroleum Inst.
                          1220 L Street,  N.W.
                          Washington DC 20005
                          202-682-8324
David Clampitt
Environmental Affairs Director
Institute of Industrial Launderers
1730 M St., NW, Suite 610
Washington DC 20036
202-296-6744
                          Joy G.  Clark
                          Organics Section Chief
                          HydroLogic,  Inc.
                          130 Placid Valley Road
                          Gaston SC 29053
                          803-750-0913
Louis C. Clay
Lab Director
Continental Cement Co.,
3000 Highway 79S
PO Box 71
Hannibal MO 63431
314-221-1740

Alyson Cockrell
Technician
HydroLogic, Inc.
100 Ashland Park Lane
Suite E
Columbia SC 29210
803-750-0913
Inc.
Jack Cochran
Sr. Organic/Analy. Chem.
IL Hazardous Waste Res.
Information Center
One E Hazelwood Drive
Champaign IL 61820
217-244-8910

Tracey L. Colbert
Group Leader
NUS Laboratory
5350 Campbells Run Road
Pittsburgh PA 15205
412-747-2533
                                     756

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Martin K. Collamore
Laboratory Supervisor
City of Tacoma
2201 Portland Ave.
Tacoma WA 98421
206-591-5588
Susana Comte-Walters
Research Specialist
Westvaco Corporation
5600 Virginia Ave.
N. Charleston SC 29411
803-745-3711
Sandra Conley
Chemist
Arlington County WPCD
3401 S. Glebe Rd.
Arlington VA 22202
703-358-6832
Steve Connor
Consulting Health Phys.
Haliburton-NUS Corp.
900 Trail Ridge Road
Aiken SC 29803
803-649-7963
William E. Corl, III
Navy Public Works Center
9742 Maryland Ave
Code 900
Norfolk VA 23511-3095
804-445-8850
B. Rod Corrigan
Quality Assurance Officer
Environmental Consultants
391 Newman Avenue
Clarksville IN 47129
812-282-8481
Jack Criscio
President
Absolute Standards, Inc.
498 Russell Street
New Haven CT 06513
203-468-7407
Raymond J. Crowley
Project Manager
Sample Prep.
Millipore Corporation
34 Maple Street
Milford MA 01757
508-478-2000
Joanna Culver
Supervisory Chemist
Norfolk Naval Shipyard
Code 130
Portsmouth VA 23709
804-396-9307
Ann T. Davis
Analytical Chemist
Eastman Kodak
Kodak Park
Rochester NY 14652
716-722-5328
T.L.  Dawson
Group Leader
Technical Center
Union Carbide Corporation
3200 Kanawha Turnpike
South Charleston WV 25303
304-747-4729
Deborah DeBiasi
Environmental Engineer
VA DEQ
PO Box 11143
Richmond VA 23230
804-527-5073
                                     757

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Gerald J. DeMenna
Consultant
Chem-Chek Laboratories
594 Dial Avenue
Piscataway NJ 08854
908-752-7793
Jane Dennison
Organic Lab Manager
Princeton Testing Lab
3490 US Rt.l
Princeton NJ 08543
609-452-9050
Ashok D. Deshpande
Research Chemist
NOAA, NMFS, NEFSC
US Dept. of Commerce
Sandy Hook Laboratory
Highlands NJ 07732
908-872-3043
Frank Dias
Waste Management
Environmental Monit. Lab.
2100 Cleanwater Drive
Geneva IL 60134
708-208-3112
Ann Dombrowski
Env. Contain. Analysis Lab Coord.
Applied Marine Research Lab
1034 West 45th Street
Norfolk VA 23529
804-683-4787
Willard Douglas
Tech. Lead Environmental
Sverdrup Technology, Inc.
Building 2423
Stennis Spa Ctr MS 35929
601-888-3158
Jan D. Dunn, PhD
Director
EML,  Inc.
Environmetrix Research
59 N. Plains Industrial Park
Wallingford CT 06492
203-284-0555
Robin Y. Eaton
Group Leader, GC/MS
Lancaster Laboratories
2425 New Holland Pike
Lancaster PA 17601-5994
717-656-2301
Bethany Ann Ebling
Group Leader, Water Quality
Lancaster Laboratories, Inc.
2425 New Holland Pike
Lancaster PA 17601
717-656-2301
Andrew Ecklund
Act. Laboratory Director
Free-Col Labs
PO Box 557
Cotton Road
Meadville PA 16335
814-724-6242
Kenneth Edge11
Section Chief
The Bionetics Corporation
16 Triangle Park Drive
Cincinnati OH 45246
513-771-0448
Stephen P. Ellis
Laboratory Manager
Ecolochem, Inc.
4545 Patent Road
Norfolk VA 23502
804-855-9000
                                     758

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Paul S. Epstein
Director
NSF International
3475 Plymouth Road
Ann Arbor MI 48105
313-769-8774
Valerie Evans
WQ Client Svcs. Manager
Triangle Labs, of RTF
801 Capitola Drive
Durham NC 27713
919-544-8353
Kirby Feldmann
Sample Prep Section Manager
Environmental Science & Engr.
8901 N. Industrial Road
Peoria IL 61615
309-692-4422
Conrad Ferro
Laboratory Supervisor
City of Jacksonville
Public Util/WW Div.
2221 Bucknow St.
Jacksonville FL 32206
904-630-4210
Tom Fieldsend
Project Mgr.
Environmental Survey Associates
PO Box 867
Ramsey NJ 07446
201-934-1102
Gary Folk
Technical Officer
IEA, Inc.
3000 Weston Parkway
Gary NC 27513
919-677-0090
Jack David Fox
Chemist
9219 Main Street
Apartment 16
Woburn MA 01801-1256
617-932-4743
Drew Francis
QA Officer
HRSD
PO Box 5911
Virginia Beach VA 23455
804-460-2261
Kay Gamble
Director of Analytical Services
McGinnes Laboratories
4168 Westroads Drive
West Palm Beach FL 33458
407-842-2849
A. J. Gilbert
Technical Director
V.G. Masslab
Crewe Road, Wythenshawe
Manchester M23 9BE
ENGLAND
061-946-1060
Jenny Goeglein
QA Chemist
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1278
Michael Goergen
President
Fire & Environmental
Consulting Labs
1451 East Lansing Drive
Suite 222
East Lansing MI 48823
517-332-0167
                                     759

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Russell W. Grice
Lab Manager
City of Columbus
Sewer & Drains
900 Dublin Road
Columbus OH 43215-1170
614-645-7016
Zoe Grosser
Sr. Marketing Specialist
The Perkin-Elmer Corp.
761 Main Ave.
MS-219
Norwalk CT 06859
203-761-2874
John P. Gute
Laboratory Supervisor
LA County Sanitation District
1965 Workman Mill Road
Whittier CA 90601
310-699-0405
David W. Haddaway
Senior Chemist
City of Portsmouth
105 Maury Place
Suffolk VA 23434
804-398-0682
Donald J. Haertel
Laboratory Manager
Center for Applied
Engineering, Inc.
10301 Ninth St. N.
St. Petersburg FL 34683
813-576-4171
Jack Hall
Div. Technical Director
IT Corp.
9000 Executive Pk Dr,A110
Knoxville TN 37923
615-690-3211
Jeff Hall
President
Environmental Testing Services
888 Norfolk Square
Norfolk VA 23502
804-461-3874
Pam Hall
Laboratory Technician
Environmental Test. Svcs
888 Norfolk Square
Norfolk VA 23502
804-461-3874
Jeff Halvorson
Chemist
Burdick & Jackson
1953 S. Harvey St.
Muskegon MI 49442
616-726-3171
Scott Hanigan
VA DEQ
PO Box 11143
Richmond VA 23230
804-527-5069
Bob Harrison
Manager of Assay Development
ImmunoSystems
4 Washington Avenue
Scarborough ME 04074
207-883-9900
Jerry Hart
Product Manager
Environmental Applicat.
Fisons Instr./VG Analy.
Floats Road, Wythenshawe
Manchester M23 9LE
ENGLAND
061-945-4170
                                     760

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Ken Hart
Laboratory Director
Free-Col Labs
5815 Airport Road, Suite A-2
Roanoke VA 24012
703-265-2544
Riaz-ul Hasan
Supervisor
Bergen County Utilities
Foot of Mehrhof Road
P.O. Box 122
Little Ferry NJ 07643
201-807-5855
Chuck Haskins
Sales Development Manager
3M Company
3M Center
Bldg. 220-9E-10
St. Paul MN 55144-1000
612-736-2899
Elaine T. Hasty
Sr. Applications Spec.
GEM Corp.
PO Box 200
Matthews NC 28106
704-821-7015
R. E. Hawley
Market Development Manager
Varian Sample Preparation Products
24201 Frampton Avenue
Harbor City CA 90710
310-539-6490
Nathan Heldenbrand
Senior Chemist
Koch Refining
PO Box 64596
St. Paul MN 55164
612-437-0668
Mike Heniken
Chemist
City of Columbus
Sewer & Drains
900 Dublin Road
Columbus OH 43215-1170
614-645-7016
Michael Herbert
Technologist
Baxter Health Care Corp.
120 Wilson Road
Round Lake IL 60073
708-270-4956
Ted Hess
Spectro Analytical Instruments
160 Authority Drive
Fitchburg MA 01420
508-342-3400
Rochelle Hickmott
Envir. Customer Service
Cambridge Isotope Labs.
20 Commerce Way
Woburn MA 01801
617-938-0067
Barbara Hill
Director of Administration
Waste Management
Environmental Monitoring Lab.
2100 Cleanwater Drive
Geneva IL 60134
708-208-3112
Kathy J. Hillig, PhD
Manager
Ecology Analytical Svcs.
BASF Corporation
1609 Biddle Avenue
Wyandotte MI 48192-3799
313-246-6334
                                     761

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Richard L. Hoag, Jr.
Physical Science Technician
Fleet & Industrial Supply Center
1968 Gilbert Street
Suite 600, Code 700
Norfolk VA 23511-3392
804-444-2761
Mary Hoganson
Haliburton-NUS Corp.
900 Trail Ridge Road
Aiken SC 29803
803-649-7963
Pamela Holbrook
Associate Staff
Toyota Motor Manufacturing
Inc., USA
1001 Cherry Blossom Way
Georgetown KY 40324
502-868-2491
Kevin Holbrooks
Chemist
City of Jacksonville
Public Utilities/WW Div.
2221 Bucknow St.
Jacksonville FL 32206
904-721-9529
Dawn Holdren
Analytical Chemist
NASA
PO Box 44
Wallops Island VA 23337
804-824-1761
William T. Holt
Lab Director
Trace Analytical Labs.
2241 Black Creek Road
Muskegon MI 49444-2673
616-773-5998
Ben Honaker
Chemist
US EPA, Office of Water
OST, BAD,  (WH-552)
401 M Street, SW
Washington DC 20460
202-260-2272
Roxane Hook
Gelman Sciences
600 S. Wagner Rd.
Ann Arbor MI 48106-1448
800-521-1520x623
Bob Houser
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-557-5040
Lyman H. Howe III
Research Chemist
TVA Environmental Chem.
1101 Market St.  (CClA-C)
Chattanooga TN 37401
615-751-3711
Dean Howe11
Division Director Quality
Fuels Department
Fleet & Industrial Supply Center
1968 Gilbert Street
Suite 600, Code 700
Norfolk VA 23511-3392
804-444-2761
Danny Hubbard
Graduate Student
Clark Atlanta University
223 James P. Brawley  Dr.
Atlanta GA  30314
404-438-9645
                                     762

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Greg Hudson
Laboratory Director
Enviro Compliance Labs., Inc.
Route 4, Box 2864
Route 1 and Old Keeton Road
Glen Allen VA 23060
804-550-3971
                      Frank Hund
                      Chemist
                      US EPA,  Office of Water
                      OST,  BAD,  (WH-552)
                      401 M Street,  SW
                      Washington DC  20460
                      202-260-7182
Carlton D. Hunt
Senior Research Scientist
Battelle Ocean Sciences
397 Washington Street
Duxbury MA 02332
617-934-0571
                      Ron Isaacson
                      Scientist
                      Weyerhaeuser Company
                      WTC 2F25
                      Tacoma WA 98477
                      206-924-6149
Carol Isenhour
Vice President
James R. Reed & Associates,
11864 Canon Blvd.
Newport News VA 23606
804-873-4703
Inc.
Sohail Jahani
Phoenix Envr. Labs, Inc.
PO Box 418
Manchester CT 06040
203-645-1102
Richard A. Javick
Sr. Research Associate
FMC Corporation
P.O. Box 8
Princeton NJ 08543
609-951-3639
                      James S.  Jones
                      Materials Engineer
                      NASA
                      Kennedy Space Center
                      DM-MSL
                      Kennedy Spa Ctr FL 32899
                      407-867-7051
Phanishushan B. Joshipura
Supervisory Chemist
Fleet & Industrial Supply Center
1968 Gilbert Street
Suite 600, Code 700
Norfolk VA 23511-3392
804-484-6430
                      Kevin W.  Keeley
                      Laboratory Director
                      Great Lakes Analytical
                      1380 Busch Parkway
                      Buffalo Grove IL 60089
                      708-808-7766
Larry Keith
Radian Corporation
PO Box 201088
Austin TX 78720-1088
512-454-4797
                      George D.  Kennedy
                      Environmental Scientist
                      HRSD
                      1436 Air Rail Ave.
                      Virginia Beach VA 23455
                      804-460-2261
                                     763

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R. Michael Kennedy
Laboratory Supervisor
City of Rock Hill
Env. Mon. Laboratory
P.O. Box 11706
Rock Hill SC 29731-1706
803-329-8704
Jerry Kidwell
Ogden Envir.fc Energy
Services Company, Inc.
3211 Jermantown Road
Fairfax VA 22030
703-246-0288
Jim King
Project Manager
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1380
Wendy Kirkeeng
Lab Manager
Davis Analytical Labs.
PO Box 29
Tallevast FL 34270
813-355-2971
Dewey Klahn
Environmental Science Corp.
1910 Mays Chapel Drive
Mt. Juliet TN 37122
615-758-5858
Susan Kopacz
Environmental Analyst
PPB Environmental Labs.
6821 SW Arcfrer Rd
Gainesville FL 32608
904-977-2349
Lawrence J. Korn
President
V.O.C. Analytical Labs., Inc.
877 NW 61st Street, Suite 202
Ft. Lauderdale FL 33309
305-938-8823
Rosanna Kroll
Environmental Specialist
MD Dept. of Environment
2500 Broening Highway
Room 1120
Baltimore MD 21224
410-631-3906
Larry LaFleur
NCASI
PO Box 458
Corvallis OR 97339
503-752-8801
Joan LaRock
Consultant to 3M
LaRock Associates, Inc.
801 Pennsylvania Av. NW
Washington DC 20004
202-628-4322
Cynthia H. Lee
Laboratory Supervisor
Kenvirons, Inc.
PO Drawer V
452 Versailles Road
Frankfort KY 40601
502-695-4357
Nathan Levy
President
Analytical & Envir.
Testing, Inc.
1717 Seaboro Dr.
Baton Rouge LA 70810
504-769-1930
                                     764

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Ronald Lewis
Chemist
Norfolk Naval Shipyard
Code 130
Portsmouth VA 23709
804-396-9307
                      Mark Liner
                      US EPA,  Office of Water
                      OST,  (WH-552)
                      401 M Street,  SW
                      Washington DC  20460
                      202-260-2090
Roger Litow
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1385
                      Barry J.  Llewellyn
                      Supervisor
                      Environmental Water Lab
                      GPU Systems Lab
                      PO Box 15152
                      Reading PA 19612-5152
                      215-375-5494
Vicorica Lopez-Avila
Midwest Research Institute
California Operations
625-B Clyde Avenue
Mountain View CA 94043
415-694-7700
                      Norman Low
                      Product Manager
                      Hewlett-Packard
                      1601 California Avenue
                      Palo Alto CA 94304
                      415-857-7381
Ted W. Lufriu
President
Chesapeake Analytical Lab.,
106 A Rockefeller Ct.
Waldorf MD 20602
301-932-4775
Inc,
Carol Malone
QA/QC Coordinator
Jennings Laboratories
1118 Cypress Avenue
Virginia Beach VA 23451
804-425-1498
Craig Markell
Research Specialist
3M Company
3M Center
Bldg. 209-1W-24
St. Paul MN 55144
612-733-2813
                      Michael  F.  Martin
                      Analytical  Chemist Senior
                      Commonwealth of VA DGS
                      1  North  14th Street
                      Richmond VA 23219-3691
                      804-371-2874
Tom Mascarenas
Analyst
Star Analytical
14500 Trinity Blvd 5-119
Ft. Worth TX 76155
817-571-6800
                      Sandra Mays
                      Instrument Specialist
                      Applied Marine Res.  Lab
                      1034  West 45th Street
                      Norfolk VA 23529
                      804-683-4787
                                     765

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Craig T. McCaffrey
Marketing Manager
Ohmicron Corp.
275 Pheasant Run
Newtown PA 28940
215-860-5115
Helen McCarthy
Supervising Chemist
RI Dept. of Health Labs.
50 Orms St.
Providence RI 02904
401-274-1011
Melinda McDavies
Chemist
Norfolk Naval Shipyard
Code 130
Portsmouth VA 23709
804-396-9307
Barry McKenzie
Research Chemist
Mallinckrodt Spec. Chem.
Paris By-Pass
P.O. Box 800
Paris KY 40362
606-987-7000
Lisa McMillan
Analytical Chemist
VA DEQ
Water Division
PO Box 11143
Richmond VA 23230
804-527-5181
Tom McVicker
QA/QC Officer
Gascoyne Laboratories
2101 Van Deman Street
Baltimore MD 21224
410-633-1800
Rodney T. Miller
Corporate QA Officer
PACE, Inc.
1710 Douglas Drive North
Minneapolis MN 55422
612-525-3465
Robert S. Mitzel
Director of Air Toxics
ALTA Analytical Lab.
5070 Robert J. Mathews Pk
El Dorado Hills CA 95762
916-933-1640
Jennifer L. Molnar
Analytical Chemist
Lockheed Environmental Systems
and Technologies
839 Bestgate Rd.
Annapolis MD 21401
410-266-9180
Marlene O. Moore
President
Advanced Systems, Inc.
P.O. Box 8090
Newark DE 09714
302-834-9796
Reginald D. Morehead
Scientist
Duke Power Company
GSD/ED/MG03A2
13339 Hagars Ferry Road
Huntersville NC 28078
704-875-5399
Pam Morhard
Physical Science Tech.
Norfolk Naval Shipyard
Quality Assurance Office
Code 130.02
Portsmouth VA 23709-5000
804-396-9309
                                     766

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Ken Moura
QA Chemist
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1165
Dierdre Murphy
Environmental Specialist
MD Dept. of Environment
2500 Broening Highway
Room 1120
Baltimore MD 21224
410-631-3906
Robert C. Murphy
Technical Coordinator
Technical Testing Labs
1256 Greenbrier Street
Charleston WV 25311
304-346-0725
Reynold Murray
Clark Atlanta University
University Box 296
Atlanta GA 30314
404-880-8744
Stephen P. Naughton
Environmental Manager
Coyne Textile Services
140 Cortland Ave.
Syracuse NY 13221
315-475-1626
J. R. Nein
Group Leader, Environment
Chesapeake Paper Products
19th and Main Streets
PO Box 311
West Point VA 23181
804-843-5750
Deborah Nelson
Chemist
Hampton Roads Sanitation District
1432 Air Rail Ave.
Virginia Beach VA 23455
804-460-2261
Guenter Niessen
Senior Project Manager
EM Science Division
EM Industries, Inc.
480 Democrat Road
Gibbstown NJ 08024
609-354-9200
Bill Nivens
Laboratory Programs Manager
Water Environment Federation
601 Wythe St.
Alexandria VA 22314
703-684-2400
Babu R. Nott
Project Manager
EPRI
3412 Hi11view Avenue
Palo Alto CA 94304
415-855-7946
Alicia P. Ordono
VA Div. of Consolidated
Laboratory Services
1 North 14th Street
Richmond VA 23113
804-786-3411
Veriti P. Overby
Chemist
Fleet & Industrial Supply
Building W-388, Code 702
Norfolk VA 23511
804-444-2761
                                     767

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Robert G. Owens, Jr.
Analytical Services, Inc.
390 Trabert Ave.
Atlanta GA 30309
404-892-8144
                            Jac  L.  Padgett
                            Vice President
                            EC Labs,  Inc.
                            PO Box  569
                            Farmersburg IN  47850
                            812-696-5076
V. K. Palat
Wayne Analytical and
Environmental Services Inc.
Suite 915
992 Old Eagle School Road
Wayne PA 19087
215-888-7485
                            Lisa Palfey
                            Environmental  Consultant
                            PA Power &  Light
                            2  North 9th Street
                            Allentown PA 18101
                            215-774-5930
Susan E. Park
Treasurer
PPB Environmental Labs.,
6821 SW Archer Road
Gainesville FL 32608
904-377-2349
   Inc.
Jerry L. Parr
Director, QA & Technology
Enseco-Rocky Mountain
Analytical Laboratory
4955 Yarrow Street
Arvada CO 80002
303-421-6611
Patricia Parsly
Project Coordinator
IT Corp.
304 Directors Drive
Knoxville TN 37923
615-690-3211
                            Lisa Kelley Peterson
                            Law Engineering
                            4465 Brookfield Corp.  Dr.
                            Chantilly VA 22081
                            703-968-4700
William F. Pfeiffer
President
Ginosko Laboratories,
17875 Cherokee St.
P.O. Box 8
Harpster OH 43323
614-496-4051
Inc.
James W. Pinson
President
American Labs & Research
Services, Inc.
1008 SE Circle
Hattisburg MS 39402
601-264-9320
Joel A. Pitman
Senior Project Manager
Twin City Testing Corporation
737 Pelham Blvd.
St. Paul MN 55114
612-659-7476
                            James J.  Pletl
                            Environmental Scientist
                            HRSD
                            1436 Air Rail Ave.
                            Virginia Beach VA 23455
                            804-460-2261
                                     768

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Lee N. Polite
Research Chemist
AMOCO Corporation
Box 3011, M/S F-7
Naperville IL 60566
708-420-3110
Marion Poythress
President
Poythress Environmental, Inc.
PO Box 5298
Macon GA 31208
912-994-3527
Glenn Powell
Manager
Environmental Labs.
Webb Technical Group
4325 Pleasant Valley Rd.
Suite 110
Raleigh NC 27612
919-787-9171

Kerry Prescott
Director of Operations
IEA, Inc.
1113 Sawgrass Corp. Pkwy.
Sunrise FL 33323
305-846-1730
Susan M. Price
Sr. Technical Service Chemist
3M Company
3M Center
Bldg. 209-1C-30
St. Paul MN 55144-1000
612-733-3461
Bill Purcell
Inspections Coordinator
VA DEQ, Water Division
PO Box 11143
Richmond VA 23230
804-527-5077
Sarala Rajeshuni
Chemist
Roy F. Weston Inc.
Auburn Chemistry Laboratory
835 N. Gay Street #6
Auburn AL 36830
205-821-8039
Edgar Raker
System Laboratory Supr.
Kentucky Utilities Co.
PO Box 437
Ghent KY 41045
502-347-5361
J. Roberto Ramirez
President
Quantum Laboratories Inc.
PO Box 366950
San Juan PR 00936-6950
809-793-7288
Tom Randolph
Randolph Consulting
PO Box 82860
Baton Rouge LA 70884-2860
504-767-6302
Kenneth T. Raum
Environmental Insp. Supervisor
VA DEQ, Water Division
287 Pembroke Office Park
Virginia Beach VA 23462
804-552-1172
Susan Redding
GS-MS Operations
Davis Analytical Labs
PO Box 815
Edgewater FL 32132
904-428-5720
                                     769

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G. Sudhakar Reddy
Shrader Analytical Labs
3814 Vinewood
Detroit MI 48208
313-894-4440
Edgard Resto, PhD
Associate Professor
University of Torabo
PO Box 3030
Gurabo PR 00656
809-743-7979
Hal Rhodes
Senior Research Assoc.
Texaco R & D
PO Box 1608
Pt. Arthur TX 77641
409-989-6487
Mark Richardson
VA DEQ
PO Box 11143
Richmond VA 23230
804-527-5078
Lynn Riddick
Associate Project Manager
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1385
Nelson Risser
Manager, Pest./Sample
Sample Support
Lancaster Laboratories
2425 New Holland Pike
Lancaster PA 17601-5994
717-656-2301
Patty A. Rollins
Chemist
Hampton Roads Sanitation District
1432 Air Rail Ave.
Virginia Beach VA 23455
804-460-2261
Miriam Roman
Group Leader
WMX Technologies, Inc.
2100 Cleanwater Drive
Geneva IL 60134
708-208-3170
Ann Rosecrance
Corporate QA Director
Core Laboratories
10205 Westheimer
Houston TX 77042
713-972-6316
James R. Roth
Laboratory Manager
Alpha Analytical Lab
8 Walkup Drive
Westborough MA 01581
508-898-9220
Nancy C. Rothman
Chief Organic Scientist
Enseco
205 Alewife Brook Parkway
Cambridge MA 02138
617-661-3111
John T. Roy
Project Leader
Dow Chemical
1602 Chemical
Midland MI 48667
517-638-6912
                                     770

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Anna M. Rule
Chief, Laboratory Div.
Hampton Roads Sanitation District
PO Box 5911
Virginia Beach VA 23455
804-460-2261
Dale Rushneck
Interface, Inc.
PO Box 297
Ft. Collins CO 80522-0297
303-223-2013
Gautam Saha
Clark Atlanta University
University Box 296
Atlanta GA 30314
404-880-8744
Ed Saltzberg
Senior Vice President
DynCorp - Viar, Inc.
300 North Lee St., #200
Alexandria VA 22314
703-519-1200
Cheryl G. Sawyer
Mgr. of Environmental Affairs
Cogentrix, Inc.
3105 American Legion Rd., Ste B
Chesapeake VA 23321
804-484-9008
Aisling Scallan
Marketing Manager
EnSys, Inc.
P.O. Box 14063
RTP  NC  27709
919-941-5509x129
Robert B. Schaffer
Mgr. Eastern Region
Ogden Environmental & Energy
Services Company, Inc.
3211 Jermantown Road
Fairfax VA 22030
703-246-0274
George A. Schmitt
Business Development Mgr.
3M Company
3M Center
Bldg. 220-9E-10
St. Paul MN 55144-1000
612-733-0307
William C. Schnute, Jr.
979 Azalea Drive
Sunnyvale CA 94086
408-736-6265
David Schreiner
Chemist
City of Phoenix
2301 West Durango St.
Phoenix AZ 85009
602-495-5974
Christine Schwerdtferger
Radian Corporation
300 N. Sepulveda Blvd., Ste 1000
El Segundo CA 90245
310-640-0045
Janice Sears
Project Manager
Ogden Envir. & Energy
Services Company, Inc.
3211 Jermantown Road
Fairfax VA 22030
714-589-4301
                                     771

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Jim Seeger
Chemist
US Army Environmental Hygiene
Agency, OECD/PAB
Building E2100  (EA)
Aberdeen Proving Ground MD 21010
410-671-8304
Andy Sendelbach
Sales Manager
Varian Sample Prep. Prod.
1829 Grande Oaks Rd.
Durham NC 27712
919-477-1015
Christopher Shane
Laboratory Supervisor
Technical Testing Laboratory
4643 Benson Avenue
Baltimore MD 21227
410-247-7400
C. Philip Shank
Director of Technology
Mallinckrodt Spec. Chem.
Paris By-Pass
P.O. Box 800
Paris KY 40362
606-987-7000
Robert Shirey
R&D Chemist
Supelco, Inc.
Supelco Park
Bellefonte PA 16823
814-359-5706
Jennifer Sieger
Chemist
US Army Envir. Hygiene
Agency, RICO/MAB
Building E2100 (EA)
Aberdeen Proving Ground
MD  21010
410-671-8304
Cindy Simbanin
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1386
Kate Simmons
Tighe & Bond, Inc.
53 Southampton Road
Westfield MA 01085
415-572-3210
Rachael Simms
Clark Atlanta University
University Box 296
Atlanta GA 30314
404-880-8744
Louis Slapshack
Research Manager
Anheuser-Busch
1101 Wyoming Street
St. Louis MO 63118
314-577-2638
Joe Slayton
US EPA, Region 3
841 Chestnut Building
Philadelphia PA 19107
215-597-9800
John Sledge
Lab Manager
Burlington Research Inc.
PO Box 2481
Burlington NC 27215
919-584-5564
                                     772

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Peggy S. Sleevi
Director of Quality Assurance
Enseco
2612 Olde Stone Rd.
Midlothian VA 23113
804-378-1851
Dewey W. Smith
Applications Manager
Antek Instruments, Inc.
300 Bammel Westfield Rd.
Houston TX 77090-3508
713-580-0339
James S. Smith
Pre s i dent/Chemi st
Trillium, Inc.
7A Grace's Dr.
Coatesville PA 19320
215-383-7233
Roy-Keith Smith
Analytical Services Inc.
390 Trabert Ave.
Atlanta GA 30309
404-892-8144
Terry Smith
Section Manager GCMS
USPCI Analytical Services
4322 South 49th West Avenue
Tulsa OK 74107-6100
918-446-1163
Tom Smith
QA Chemist
DynCorp - Viar, Inc.
300 North Lee St., #200
Alexandria VA 22314
703-519-1279
Patrick Spink
WindowChem Software, Inc.
1955 West Texas Street, Suite 7-288
Fairfield CA 94533-4462
408-956-9666
Bruce Staples
Physical Science Tech.
Norfolk Naval Shipyard
Quality Assurance Office
Code 130.02
Portsmouth VA 23709-5000
804-396-9309
Douglas L. Stevenson
Chemist
Labratory Support Division
Rocky Mountain Arsenal
Attn-AMXRM-L5
Commerce City CO 80022-2180
303-289-0217
William P. Stork
Chemical Analyst
Environmental Analysis
3278 North Highway 67
Florissant MO 63033
314-921-4488
Ed Stuber
Pace
RD #6 Robinson Lane
Wappingers Falls NY 12590
914-227-2811
Louise Stunkard
Physical Science Tech.
US Army Envir. Hygiene
Agency
Building E2100
Aberdeen Proving Ground
MD 21010
410-671-3269
                                     773

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Mark Taylor
G.C. Product Specialist
Shimadzu Scientific Instruments
7102 Riverwood Drive
Columbia MD 21046
410-381-1227
Dawn Thomas
Sr. QA Specialist
PSI,  Inc.
6913  Highway 225
Deer Park TX 77536
713-479-8307
Marion K. Thompson
Environmental Prot. Spec.
US EPA, Office of Water
OST, EAD, (WH-552)
401 M Street, S.W.
Washington DC 20460
202-260-7117
James C. Todaro
Lab Director
Matrix Analytical
106 South Street
Hopkinton MA 01748
508-435-6824
David Tompkins
President
ETS Analytical Services
1401 Municipal Rd.
Roanoke VA 24012
703-265-0004
Yves Tondeur
V.P. Technology
Triangle Laboratories
6320 Quadrangle Dr.
Suite 240
Chapel Hill NC 27514
919-493-0877
Allan M. Tordini
President
Quality Works, Inc.
8 Strafford Circle Road
Medford NJ 08055
609-953-9163
Felicitas Trinidad
Sr. Scientist/Supervisor
Hoffmann La Roche
340 Kingsland Road
Nutley NJ 07110
201-235-3131
Dion Tsourides
Product Manager - ICP
Spectro Analytical Instruments
160 Authority Drive
Fitchburg MA 01420
508-342-3400
Teri L. Tumolo
Mgr., Inorganic Analyses
Killam Associates
100 Allegheny Drive
Warrendale PA 15086
412-772-0200
Mark E. Tuttle
Program Director
ENTER Manufacturing
1632 NW Vicksburg Avenue
Bend OR 97701
503-389-4525
Richard Ungvarsky
Chemist
Akzo Salt Inc.
Abington Executive  Park
Clarks Summit  PA 18411
717-587-9403
                                     774

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Jim Vance
Product Line Manager
Horiba Instruments
17671 Armstrong Ave.
Irvine CA 92714
714-250-4811x170
Yupha Vatcharapijarn
Clark Atlanta University
University Box 296
Atlanta GA 30314
404-880-8744
Joe Viar
Chairman
DynCorp - Viar, Inc.
300 North Lee St., Suite 200
Alexandria VA 22314
703-519-1000
Albert F. Vicinie
Supr., Industrial Lab
DeYor Laboratories, Inc.
7655 Market Street
Youngstown OH 44512
216-758-5788
Joseph S. Vitalis
Chemical Engineer
US EPA, Office of Water
OST, BAD,  (WH-552)
401 M Street, SW
Washington DC 20460
202-260-7172
Tracy R. Volpe
V.O.C. Analytical Labs
877 NW 61st St., #202
Ft. Lauderdale FL 33309
305-938-8823
Leonard Voo
US EPA, Region 2
Environmental Service Division
(N5230)
2890 Woodbridge Avenue
Edison NJ 08837
908-321-6710
Bruce Wagner
Lab Manager
IT Corporation
304 Directors Drive
Knoxville TN 37923
615-690-3211
Jack Wahlstrom
Lab Manager
GCWDA
10800 Bay Area Boulevard
Pasadena TX 77507
713-474-4111
Tonie M. Wallace, RPR
President
County Court Reporters
124 E. Cork Street
Winchester VA 22601
703-667-0600
Claudia Walters
QA Officer
US EPA, Region 3
Chesapeake Bay Program
410 Severn Avenue, Suite 109
Annapolis MD 21403
410-267-0061
Randy Ward
Chief Chemist
Envir. Science Corp.
1910 Mays Chapel Rd.
Mt. Juliet TN 37122
615-758-5858
                                     775

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Spence Ward
Chemist
Norfolk Naval Shipyard
Quality Assurance Office
Code 130.02
Portsmouth VA 23709-5000
804-396-9309
John Whitescarver
Vice President
Carter-Burgess
PO Box 16525
Washington DC 20041
703-777-9384
Robert Wichser
Chief Utility Engineer
Richmond Dept. of Public Utilities
600 East Broad St., Room 831
Richmond VA 23219
804-780-5202
Ann Wilkes
Lab. Regulation News
1350 Connecticut Ave., NW
Suite 1000
Washington DC 20036
202-862-0916
David F. Williams
President
Kenwill Environmental Laboratory
505 East Broadway
Maryville TN 37801
615-977-1200
David S. Williams
Product Manager
Zymark Corperation
Zymark Center
Hopkinton MA 01748
508-435-9500
Allison Wilson
Chief Chemist
Hampton Roads Sanitation District
1432 Air Rail Ave.
Virginia Beach VA 23455
804-460-2261
Hugh E. Wise
Environmental Scientist
US EPA, Office of Water
OST, BAD,  (WH-552)
401 M Street, SW
Washington DC 20460
202-260-7177
Michael W. Woods
Mgr., Environmental Services
Technical Services Laboratories
1612 N. Lexington Ave.
Springfield MO 65802
417-864-3195
John E. Young
Principal Scientist
Westinghouse
Building 773-A
Savannah River Tech. Ctr.
Aiken SC 29808
803-725-3565
Steve Zajicek
Laboratory Operations Manager
PDC Laboratories, Inc.
PO Box 9071
Peoria IL 61612-9071
309-676-4893
                                     776

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