905480001
     QUALITY ASSURANCE  PROGRAM
   GUIDELINES AND SPECIFICATIONS
      CRITERIA AND PROCEDURES
              REGION  V
U.S.  ENVIRONMENTAL  PROTECTION AGENCY
      QUALITY ASSURANCE OFFICE
 SURVEILLANCE AND ANALYSIS DIVISION
         CHICAGO, ILLINOIS
          JANUARY 15, 1980

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                           TABLE OF CONTENTS
                                                                   PAGE

1.  Identification of Office of Laboratory Submitting'QA Plan	1

2.  Quality Assurance Policy Statement,  Region V	3

3.  Objectives and Milestones	5

4.  Quality Assurance Management	7
    4.1    I ntroducti.on	7
    4.2    Quality Assurance Management  Plan	8
    4.2.1  Assignment of Responsibilities	9
    4.2.2  Flow of Information..	11
    4.2.3  Identification of QA - Related Committees  or Meetings	12
    4.2.4  Description of Needs	13

5.  Personnel	14

6.  Facilities, Equipment and Services	17

7.  Review of Program Plans, Project Plans or Study Plans	18

8.  Data C ol 1 ecti on	20
    8.1      Sampling Plan	,	20
    8.2      Sampling Methodology	21
    8.3      Analytical Methodology	32
    8.3.1    Maintenance of Up-To-Date File of Measurement Methods...37
    8.3.2    Alternate Test Procedure Program	40
    8.3.2.1  Elements of an Application  for a National  Pollutant
               Discharge Elimination System (NPDES) of Section 106
               Alternate Test Procedure	41
    8.3.2.2  Elements of an Application  for a Safe Drinking
               Water Act (SDWA) Alternate Test Procedure	48
    8.3.2.3  Processing of Case-By-Case  Alternate Test Procedure
               in Region V	51
    8.3.2.4  Procedures for Equivalent Test Procedure Under the
               Clean Air Act	53
    8.4      Instrumental on	53
    8.5     Calibration and Standards	54
    8.6      Preventive Maintenance and  Inspections	55
    8.7      Quality Control Procedures	57
    8.7.1    Intra-Laboratory Quality Control Procedures	57
    8.7.1.2  Intra-Field Quality Control Procedures	63
    8.7.1.3  Additional Intra-Laboratory Quality  Control
               Procedures for Specific Groups of  Parameters	65
    8.7.2    Inter-Laboratory Quality Control Procedures	71

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                      TABLE OF CONTENTS (CONTINUED)
                                                                    PAGE

     8.7.2.1  Management of the Accuracy and Performance
                Audi t Programs	72
     8.7.2.2  Management of the On-Site System Evaluation of Total
                In-House, Federal, State and Local Agency,
                Contractor, Grantee Monitoring Program	76

 9.  Data Processi ng	78
     9.1  Data Handling Transmission and Storage	78
     9.2  Data Validation and Verification	86
     9.3  Data Reduction (Including Software QC Considerations)	92

10.  C orrecti ve Acti ons	93
     10.1  QA Management	95
     10.2  QC  Management	95

11.  Data Quality Assessment	97
     11.1  Accuracy Assessment	98
     11.2  Preci si on Assessment	98
     11.3  C ompl eteness Assessment	98
     11.4  Represent! veness Assessment	98
     11.5  Overall  Data Quality Assessment	99

12.  Data Quality Reports (QC and QA)	99
                            »
13.  Chain of Custody	100

14.  Speci fi c Gui dance	106

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                               APPENDICES
APPENDIX 1     Quality Assurance Office FY 80 Work  Plan
APPENDIX 2     Relationship of the Quality Assurance Function to
               Other Regional  Program Functions
APPENDIX 3     The Organizational  Structure of Region V
APPENDIX 4     State of Wisconsin Department of Natural Resources,
               Bureau of Air Management, Air Monitoring Section,
               Quality Assurance Manual - Procurement
APPENDIX 5     Sample Collection Containers, Preservatives  and Holding
               Times for Sample Collection in the 106, 208, 404(b)(l)
               and the Great Lakes National Monitoring Programs
APPENDIX 6     EPA Official Analytical  Methodology - Priority Pollutant
               Measurements
APPENDIX 7     EPA Official Analytical  Methodology - Hazardous Waste
               Measurements
APPENDIX 8     Sample Collection, Preservation,  and Holding Times  -
               Ambient Air Samples
APPENDIX 9     EPA Official Analytical  Methodology - Water  Quality
               Measurements
APPENDIX 10    EPA Official Analytical  Methodology - Radiation Methods
APPENDIX 11    EPA Official Analytical  Methodology - Ambient Air
               Measurements
APPENDIX 12    EPA Official Analytical'Methodology - Source Air
               Measurements
APPENDIX 13    EPA Offical Analytical Methodology - Public  Water   '
               Supply Methods
APPENDIX 14    Sample Collection Containers, Preservatives, and Holding
               Times for Samples Collected in the 1412 Monitoring  Program
APPENDIX 15    Approved Alternative Analytical Methods - Nationwide  Use.
                                  111

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                         APPENDICES (Continued)
APPENDIX 16    Performance Tests for the Evaluation of Computerized
               Gas Chromatography/Mass Spectrometry Equipment  and
               Laboratori es
APPENDIX 17    Life Cycle of an On-Site System Evaluation
APPENDIX 18    Elements for a Section 106,  208,  404(b)(l) and  Great
               Lakes Program Monitoring Quality Assurance Program
APPENDIX 19    Summary of Guidelines for Station Siting and Probe
               Placement
GLOSSARY

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1.  IDENTIFICATION OF OFFICE  OR  LABORATORY  SUBMITTING QA  PLAN
    Document Title:
    Units Full  Name
      and Address:
    Individual
      Responsible:
    Individual
      Responsible
      for QA:
    Plan Prepared By:
    Calendar Year
      Covered:
Quality Assurance Program
Guidelines and Specifications
Criteria and Procedures
Region V
Ref. NO.:
EPA-905/4-80-001
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604

John McGuire
Regi onal Admi ni strator
Region V
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
(FTS)353-2000

William H. Sanders III
Di rector
Surveillance and Analysis Division
U.S. Environmental Protection Agency
Region V
536 South Clark Street
Chicago, Illinois 60605
(FTS)353-3808

James H. Adams, Jr.
Chief
Quality Assurance Office
Surveillance and Analysis Division
U.S. Environmental Protection Agency
Region V
536 South Clark Street
Chicago, Illinois 60605
(FTS)353-9604
    Submission Date:      January 15,  1980
Interim document will be used pending finalization
of Agency Quality Assurance Plan.
    Summary of environmental  monitoring  or measurement  activities  performed
    by Region V:

    Quality assurance activities  have  been planned  for  1980  in Air
    Quality Monitoring,  Air Enforcement,  Dredge  and Fill,  Ambient  Water
    Quality Monitoring,  Water Quality  Enforcement,  Public  Water  Supply
    Management and Great Lakes Monitoring.   There are also special
    studies, contracts and other  activities that require evaluation
    for quality assurance.

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INTRODUCTION

Environmental  Protection Agency (EPA)  Policy,  enunciated  in  memoranda
of May 30 and June 14, 1979, requires  participation in a  centrally-managed
Quality Assurance Program by all  EPA Regional  Offices, Program Offices,
EPA Laboratories, and the States.  This includes  those monitoring  and
measurement efforts mandated or supported by EPA  through  regulations,
grants, contracts, or other formalized agreements.   The Quality Assurance
Programs for the States in Region V will  be cooperatively developed  with
them and implemented through the Regional Office.

The Office of Research and Development (ORD) has  been  given  the responsi-
bility for developing, coordinating, and directing  the implementation
of the Agency Quality Assurance Program.   In addition, an Agency Quality
Assurance Advisory Cornrnittee, chaired  by ORD and  with  representatives
from the Program Offices, Regional  Offices, Staff Offices, and the
States, has been established to coordinate this effort.

At this point, the distinction between two concepts — quality assurance
and quality control — becomes relevant.   "Quality  Assurance"  is defined
here as an organization's total program for assuring the  reliability
of data it produces.  A QA Plan is a document presenting  the policies,
objectives, management structure, and  general  procedures  which comprise
this total program.  "Quality Control" refers to  the detailed  and
specific procedures used to ensure the quality of data produced by a
particular measurement activity.   For  example, a  QA Plan  for laboratory
instruments would state that calibration needs to be addressed as  an
element of data collection activities.  It would  not,  however, give
instructions about how to do this calibration; these instructions
represent quality control.

As an initial  step in implementing this policy, Quality Assurance
Plans (Programs) must be prepared by all  EPA-supported or -required
environmental  monitoring and measurement activities per the  specifications
of EPA's guidance document MQA 001-79.

EPA policy is quite clear that the Agency Quality Assurance  Program
encompasses all environmentally related measurement activities undertaken
by the Regional Offices, Program Offices, State Program Offices, and
Laboratories;  supported by these divisions through  contracts,  grants,
or other formalized agreements; or required by them through  regulations.
A very broad definition of "environmentally related measurement
activities" has been adopted.  It includes all field and  laboratory
investigations which generate data. The measurement of chemical,
physical or biological parameters in the environment;  health and
ecological effects studies; clinical and epidemiologic investigations;

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    studies involving laboratory measurements  or  simulated  environmental
    events are covered under this definition  and  all  such activities  must
    be covered by a Quality Assurance Plan.

    This document describes the Quality Assurance Program for  Region  V,
    U.S. EPA, that will  produce a numerical estimate  of the reliability of
    all data values reported or used by the Region.

2.  QUALITY ASSURAKE POLICY STATEMENT. REGION V

    It is the policy of EPA, Region V that there  shall  be sufficient
    quality assurance activities conducted within the Region to  assure
    the collection of data which meet the requirements  of the  Environmental
    laws and regulations that require implementation  by EPA in Region V.

    The Regional  Administrator has the overall  responsibility  for
    implemenation of the Agency's quality assurance program for  valid
    data quality.  The Director of the Surveillance and Analysis
    Division (S4A), through the Chief of the Quality  Assurance Office
    (CQAO), assures that quality assurance objectives are met  for  each
    monitoring project conducted within Region V.  This responsibility
    also includes external monitoring activities  of States, local
    agencies, contractors and others covered by the Agency  quality
    assurance plan.

    The immediate objective of the Quality Assurance  Office is to  insure
    that the quality of data collected, reported  or used by the  Agency
    is properly documented and that the data are  sufficiently  accurate
    and precise to meet  the Agency's quality assurance  objectives.

    The following activities shall  be carried  out in  accordance  with
    Agency mandates specified in document MQA  001-79, and existing
    Agency regulations.

         The Quality Assurance Program will consist of:
              1.   An adequately trained staff  for implementation of the
                  Region's quality assurance program  as approved by ORD.

              2.   Equipment procurement and maintenance shall  meet
                  specifications required by regulations, approved
                  methodology, or appropriate  EPA guidelines and shall
                  be approved by the CQAO.  These requirements shall
                  appply to all  Region V  monitoring activities and to
                  State  and local  agencies when Federal  funds  are
                  expended.

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3.  Analytical  methods and procedures for all  monitoring
    programs shall conform to EPA approved methodology
    when applicable, and shall include quality control
    measures.  All methods and procedures shall be
    documented "cookbook fashion" and reviewed and approved
    or revised as required by Agency regulations and
    guidelines.  Their revisions and updates shall be
    by the appropriate Agency mechanism, based on
    recommendations from the CQAO.

4.  The Regional Administrator, based upon recommendations
    from the CQAO, through the Director, Surveillance and
    Analysis Division, shall approve State and local agency
    Quality Assurance policies and programs.

5.  Region V and State and local laboratory and field
    monitoring facilities shall perform system and
    performance audits.  These facilities shall participate
    in inter!aboratory audits managed by the AQAC and
    coordinated with EMSL-RTP, EMSL-Cincinnati and EMSL-Las Vegas.

6.  Data processing shall be documented, reviewed and
    revised as required by the Region's Quality Assurance
    Program and approved by the Office of Research and
    Development.  Quality control measures must assure
    accurate data from analysis by Region V, State and
    local agencies.  Data shall be validated according
    to criteria which shall follow EPA guidelines and
    regulati ons.

7.  Directors of the several divisions in Region V have
    responsibilities for the quality of data collected
    and used in the performance of tasks required.  These
    responsibilities are corroborated under this policy.
    The CQAO will coordinate the implementation criteria
    for validation of required data.

8.  Standard operating procedures for air monitoring
    activities in Region V, State and local agencies for
    site selection, audits, evaluations, maintenance and
    enforcement shall be developed, documented and
    reviewed per the requirements of 40 CFR Part 58.


9.  The CQAO shall report continuously on all Quality
    fl««nranrp rurnnramc fn nrnnram mananpr^-
Assurance programs to program managers.

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                       CHief, Quality Assurance t)ffice,           *     Date'^
                       Surveillance & Analysis Division,
                       Region V
                       Director, Surveillance & Analysis               Date
                       Di v/HsT-on , Jteqi on .V
                        egional  Administrator                         Date
                       Region V
   COfCURRBCE
   APPROVED
3.  OBJECTIVES AND MILESTONES

    The primary goal  of the Region V,  quality assurance  program is  to
    define and improve the reliability (accuracy and  precision)  of
    data generated and used by the Region,  per Headquarters'  mandate
    and Agency regulations.  There must be  a mechanism for so doing.
    In order to measure or estimate changes in data quality,  the
    quality must be expressed in measurable (numerical)  terms.   There-
    fore, the_ first priority in the Region  V_Quality  assurance  program
    is toestablish and 1mo1emen~ e nstnodto define  and ouantitate
    the program product -data oua]1iv.This includes data from fiegional
    programs, State and local agencies, grants and contracts.   Each
  -  program that collects data is to be quality assured  by a  comprehensive
    evaluation and review process such that all  of the activities that
    influence the quality of data are  performed by appropriated  trained
    staff, by methods acceptable to EPA on  instruments that are  approved
    and maintained and each data collection activity  has a documented
    quality controlled program.

    MILESTONE 1:  Interim Region V Quality  Assurance  Program  will be
    developed by the  QAO by January 15, 1980.   This program will be
    amended and updated to meet the Agency's final QA requirements  for
    1981 within 90 days after final  guidance from Headquarters  becomes
    available.

    MILESTONE 2:  All Regional  Program Offices that are  engaged  in  a
    field sample collection activity shall  prepare a  field sampling
    and quality control  manual  which documents their  methods  of  sample
    collection, preservation, field custody, field instrument calibrations
    and field quality control protocol, plus any other requirements
    specified in Section 8 of this document, by  April 15,  1980.  These
    documents will  be submitted to the QAO  for review and  recommendations
    to the Regional Administrator for  approval  by Sampling programs

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Included are air, hazardous waste, toxic substances,  priority pollutants,
public water supply, ambient surface and ground water,  NPOES and
Great Lakes.  Programs are to be updated per the requirements of
new Agency regulations or guidelines.

MILESTONE 3:  All Laboratories in the Surveillance and  Analysis
Division engaged in analysis of samples shall  document  their
methodology and quality assurance/control  program per the specifications
in Section 8 of this document, by April IS,  1980 and  submit  such
documentation to the QAO for review and recommendations to the Regional
Administrator for approval.  Programs are to be updated per  the
requirements of new Agency regulations or guidelines.

MILESTONE 4:  All State's Water Agency(s)  shall document their field
and laboratory methodology and quality assurance/conrpl program per
the specifications in Section 8 of this document according to the
dates specified in each State's 106 grant condition by  the Regional
Administrator.  These documents are to be forwarded to  the respective
State Coordinator for processing through the media manager and the
SSA Division to the OAO for review and recommendations  to the
Regional Administrator for approval as required by Agency regulations.

MILESTONE 5:  All State and Local Air Agency(s) shall document
their field and laboratory methodology and quality assurance/control
program per the specifications in Section 8  of this document by
January 1, 1980 to the respective State Coordinator for processing
through the respective media managers and the SSA Division to the
QAO for review and recommendations to the Regional  Administrator
for approval.

OBJECTIVE:  Manage the quality assurance functions in Region V that
impacts all factors that influence data quality in the  Region's
FY 80 program plan.  The factors to be considered are personnel,
equipment, procurement, methodology, legal requirements, organizational
responsibilities where QA policies must be carried out  and other
factors.  The implementation of an effective program will  insure
objectivity, self review and documentation so  that cost effectiveness
in the program is assured.  Objectives have  been identified  for each
program decision unit for FY 30, which are depicted in  Appendix 1.

MILESTONE 1:  Key action steps(milestones) have been finalized
with due dates for objectives listed under each decision unit for
FY 80, which is also depicted in Appendix 1.

OBJECTIVE:  To establish an interraction at  all levels  of management
such that QA principles are implemented.

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    MILESTONE 1:  These interractions are in place and are illustrated
    in Appendix 2.

    OBJECTIVE:  To have QA resources assigned to QAO in proportion to
    need, rather than programs controlling resources by which priorities
    in those programs preclude resource commitment to QA as the program
    planning process specifies and the National  QA program mandates.

    MILESTONE 1:  During the planning process for FY 81, the QAO will
    identify all activities that have QA requirements.  Assess resource
    needs for enumeration of those QA activities.  Formulate FY 81 QAO
    Zero Based Budget activities with QA committments.  This resource
    assessment will encompass implementation of the Region's FY 81 QA
    plan (program) as approved by ORD.

4.  QUALITY ASSURANCE MANAGEMENT

    4.1  Introduction
         The current quality assurance program that is functional  in
         Region V during FY 80 evolved from the program planning process
         and is carried out under restrictions which are placed on QA
         by resource commitments and priorities that are established
         by programs which provide those resources.  The organizational
         structure of Region V which relates to data collectors and
         decision making based on results of collected data is shown
         in Appendix 3.

         A description of the Organization for present QA related
         activities follows:

         WATER DIVISION: Has responsibilities in the public water  supply,
         ambient surface and ground water and wastewater programs.
         The administration of these programs through grants results
         in data collection by State and local  personnel.   Resources
         (Appendix 1) for quality assurance are  provided through Decision
         Units B-224 (Ambient Water Quality Monitoring)  and C-215
         (Public Water Supply Management).

         AIR AND HAZARDOUS MATERIALS DIVISION:   Has responsibilities
         for air programs, hazard waste management, pesticide and  toxic
         substances.  Programs are managed  through grants  and contracts.
         Technical  and field support is provided by the  SSA Division
         through activities of the District Offices,  Technical  Support
         Branch and the Central  Regional  Laboratory.   Resources  for
         quality assurance are provided through  Decision Units  A-235
         (Air Quality Monitoring), A-305  (Air Enforcement),  and  A-305
         (Air Enforcement  Unleaded Gas  Inspections).

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                               3

     ENFORCEMENT DIVISION:   Has responsibilities  for enforcement
     action in the various  programs  for compliance with Agency
     regulations.   QA of data  collection is  important to the
     validation of data  so  that it can  be defended in legal processes.
     Resources are provided for QA in the A-305 Decision Unit for
     PSD monitoring.   However, QA support is provided in the B-303
     Decision Unit by the QAO  without resources being provided by
     the Enforcement  Division.

     PLANNING AND MANAGEMENT DIVISION:   Maintains data processing
     facilities and handle  data for  special  studies and STORET.
     Although the data unit processes data collected by other
     organizations, it produces final reports from data which
     may require summary or collation for final data reporting.
     Thus, it is in the  overall process, a data producer.   QA
     has no resource  support for this division.   QA programs have
     not been employed.

     S4A DIVISION:  Is responsible for  surveillance and analysis in
     the various water,  air, waste and  toxic substance programs.
     Technical support,  monitoring and  project studies are  earned
     out for the program offices.  Resources for  QA in these various
     functions of the S&A Division are  those described under the
     other divisions. S&A  Division  branches support QA programs by
     auditing, sample collection, and special  studies.

     GREAT LAKES NATIONAL PROGRAM OFFICE: The Great Lakes  are monitored
     under this program  through grants  and contracts for sample
     collection and shore laboratory analysis, as well as,  the
     operation of the ship  for open  waters and shipboard analysis
     by contract.  Technical and field  support is also provided by
     the S&A Division through  activities of  the District Offices,
     Technical Support Branch  and the Central  Regional Laboratory.
     Resources for QA is provided under Decision  Unit B-241 (Great
     Lakes).

4.2  Quality Assurance Management Plan
     In this context  the implementation of a quality assurance
     program is deemed as a management  endeavor which attempts to
     interface all activities  which  impact data quality, be they
     management, technology, statistics, monitoring or maintenance.
     In order to assure  the data quality, each of the numerous
     activities must  respond to the  basic needs from which  data
     becomes possible.

     When one realizes that the simplest item may become a
     critical item in data  collection,  it then becomes apparent

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       how the many disciplines work in concert.   The QA program
       will not presume that certain activities occur.   It will  require
       that documentations and controls be implemented and evaluated
       for effectiveness on a prescribed frequency basis.   These
       evaluations describe deficiencies and corrective actions
       requi red.

       In the formulation of the QA plan for Region V the  mandates
       for carrying out QA are documented in the Quality Assurance
       Policy (Section 2).  In this policy, management has designated
       responsibilities and the individual who bear those  responsibil-
       ities.  The organizational  structure into which the QA management
       interacts is established by this policy (Appendix 2).   Adminis-
       tratively, the QAO may be shown in a different relationship.

4.2.1  Assignment of Responsibilities
       The Quality Assurance Office located in the Surveillance  and
       Analysis Division has the responsibility of managing Region
       V's quality assurance program.

       The Quality Assurance Office (QAO) establishes policies
       and guidelines for regional, state and local  quality assurance
       programs, and conducts independent audits.   Quality control,
       i.e., quality and documentation of data used by regional/state/
       local personnel, is the responsibility of the data  generator.
       The mission of the QAO is to ensure through implementation of the
       quality assurance program so that the quality of data  collected,
       reported or used by the Region is properly documented  and that
       the data are sufficiently accurate and precise to meet Regional
       program needs.  The Quality Assurance Office is  responsible
       for developing and implementing procedures (programs)  to
       insure the re Liability of laboratory data  supporting the
       air, pesticides,-solid waste and toxic substances programs
       in the Air and Hazardous Materials Division,  the public
       drinking water, ambient surface and ground water, and  industrial
       and domestic wastewater programs in the Water Division;
       enforcement actions in the  Enforcement Division;  the Inter-
       national  Joint Commission,  the harbor dredging programs in
       the Great Lakes National  Program Office,  and all  other programs
       generating environmental  data for the Region.

       QAO conducts annual on-site system evaluations.   The  '
       evaluations are of the quality assurance  and quality control
       programs  of State laboratories and monitor? ng  facilities  that
       carry out testing under the Clean Air Act,  Clean Water'.'Act,

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Resource Conservation and Recovery  Act,  Safe Drinking Water
Act and the Toxic Substances Control  Act.   In  some instances
local agencies are evaluated where  state responsibility has
been delegated.  QAO identifies  deficiencies,  recommends
corrective action and monitors effectiveness of action taken.

The QAO reviews state program  plans for  compliance with Agency
requirements for quality assurance  and analytical methodology
used in laboratories and field operations.  The QAO coordinates
quality assurance programs with  Agency regulations, program
guidance and media strategy.

The on-going management of the laboratory certification program,
pursuant to the Safe Drinking Water Act, is the responsibility
of the QAO.  This function also  involves continued quality
assurance activities for certified  laboratories; an overview
of state certification programs  for certification of local
laboratories and the performance of State certification officers.

The Quality Assurance Office manages  an  interlaboratory audit
program which provides an extensive reference  and quality
control sample program for cooperating Federal, Canadian,
State and local agencies, and  private laboratories in Region V.

Approximately 123 laboratories participate  in  this program.
Up to 316 different parameters are  analyzed on a regular
basis.  The audits cover air,  public  water  supply, ambient
water (large lakes included), wastewater, dredging (sediments)
and toxic pollutant laboratory analytical activity.  These
audits are extremely important for  the determination of accuracy
of laboratory performance.  Results are  evaluated and recommendations
made for corrective actions for  any deficiencies identified.

The management of the alternate  test  procedure program for
compliance with the Safe Drinking Water  Act, National Pollution
Discharge Elimination System and other regulations, is the
responsibility of the QAO.  This function includes technical
interepretation of the regulations  relating to test procedures,
coordination of applications,  evaluation of applicants' technical
data for equivalency and recommendations for approval or
disapproval.

The QAO participates in quality  assurance activities for
the International Joint Commission  Water Quality Board's
monitoring'activities on the Great  Lakes.   This function includes
critical reviews of technical  reports, maintenance of approved

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        analytical  methods and methods under consideration  for approval,
        official interpretations of method equivalency for  regulatory
        actions and defends regional  data generated  by approved procedures.

        The QAO is  responsible for providing, as  requested,  review
        and technical  assistance concerning Agency analytical  methodology
        and quality assurance requirements for State and  local  environmental
        agencies, NPDES dischargers,  public water supplies,  source
        emissions,  etc.  The QAO interprets National and  Regional  EPA
        policies in the areas of analytical methodology and  quality
        assurance.

        The QAO is  responsible for the management of the  quality
        assurance requirements for all Region V external  projects
        involving collection and analytical measurements, which includes,
        but is not  limited to, grants, contracts, cooperative  agreements,
        and interagency agreements.  The QAO's primary function is to
        insure that all analytical measurements conducted with  Regional
        funding results'in usable data of known quality that is acceptable
        for Region  V's purposes.  The air responsibility  includes
        maintenance and primary calibration of field and  laboratory
        equipment relative to air pollutants measurements,  and  step-by-step
        demonstrations of all facets  of instrument maintenance, calibration
        and operation.

4.2.2.  Flow of Information
        The QAO is  assigned activities under decision units  which
        require evaluation of data producing systems.  The  S&A  Director
        establishes priorities and delegates resources to the  various
        tasks.  These  tasks are identified in the annual  work  plan.
        The QAO identifies goals to accomplish the objectives  of the
        decision units per the specification from Headquarters  program
        guidance from  the Regional media programs, (for example, evaluation
        of QA programs for air monitoring in State Agencies).   The QAO,
        through the S&A Director, establishes contact with  State Agencies and
        arranges for information about the State's program  and  an  on-site
        visit.  Information obtained  prior to an  on-site  visit  is  evaluated,
        the on-site evaluation is performed and an evaluation  report is
        prepared.  The evaluation is  reported through the S&A  Director
        to the State,  to the Regional  Air Program Office  and the State
        Coordinators.   Corrective action, deficiencies and recommendations
        are reported.   States report  corrective action taken or give
        reasons for not taking action to the QAO.  Should the
        corrective  action be of such  a nature that an on-site
        visit is required to verify that the action  was appropriate.
        A visit is  requested through  the S&A Director.  The  on-site visit

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                                 12

       is reported in a similar manner to the original  evaluation  report
       stating the findings and indicating satisfactory or non-satisfactory
       results and recommending future action as  required.

       When problems exist in which no correction is made and a  dispute
       results, the findings with recommendations are reported to  the
       Program Office and to the State Coordinators  for resolution.
       If a State program is involved and the program office  is  unable
       to resolve the problem and an impasse is  reached, the
       Regional Administrator makes a final  determination of  the
       unresolved issue based on recommendations  from the QAO and
       program office.  Basically two major types of reports  are
       generated by the QAO.  They are accuracy  and  performance  audits
       and on-site system evaluation reports. The content of these
       reports are outlined in Section 8.7.2 and  Subsection 8.7.2.1
       of this document.

       Based on the frequency identified in the  QAO  program plan
       (Section 12), the QAO will write interpretative reports to
       management.  These reports will be made on a  regular basis
       and will identify areas of work that could be improved and
       areas that are being performed properly or in an exceptional
       manner.  These reports will be based on information obtained
       during on-site evaluations, from reviews  of performance sample
       analyses and from evaluations of routine  quality control
       audit data.

4.2.3  Identification of QA - Related Committees  or  Meetings
       Quality assurance requirements/information are transmitted
       within Region V through meetings called by the QAO with affected
       Regional media personnel.  These are on an as needed basis.
       Documentation is also provided by way of  memoranda.

       Quality assurance requirements/information are transmitted
       to State and local agency laboratory directors and quality
       assurance coordinators by written communcations from the  Quality
       Quality Assurance  Office on a as needed  basis.  QA information
       is also disseminated through the audit and on-site evaluation of
       Regional, State and local agency monitoring activities during
       the frequencies specified in the QAO's FY  80  program plan
       (Appendix 1).

       The QAO will conduct two workshops in FY  80 for public water
       supply analysts.  The workshops will  be for standardizing metal
       analyses and for upgrading organic analyses for public water
       supply laboratories.  The Central Regional Laboratory  will

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                                 13

       provide technical  support  to the QAO in this endeavor by making
       their laboratory  facilities available and having their personnel
       participate in the workshops.

       The QAO has identified  State and local air program agencies
       that are in need  of technical  assistance in the area of quality
       assurance and  laboratory capability.  Through a contract that
       EMSL-RTP has in place,  the QAO will work with the contractor
       to upgrade those  agencies  that are in need of technical assistance.
       This activity  will comnence the 2nd quarter of FY 80.

       A workshop for audits of air monitoring sites will be conducted
       by QAO and RTF at Region V in  March 1980 for Region, State
       and local agency  personnel engaged in auditing air monitoring
       sites.

       The Quality Assurance Office participates in the Agency's
       regularly scheduled semi-annual QA coordinator's meeting where
       the Agency's QC concerns are addressed.  The QAO participates in
       national short term QA  tasks as requested by the National Program.

       The Chief, QAO has been appointed to the Data Quality Work
       Group, Surveillance Sub-Committee, International Joint Commission,
       Water Quality  Board. The  Data Quality Work Group has the
       responsibility of assun'ng the quality of data from participating
       laboratories engaged in the Surveillance Sub-Committee's Great
       Lakes Surveillance Plan.   All  IX QA activities are implemented
       through the Data  Quality Work  Group.  The Work Group meets
       monthly.

4.2.4  Description of Needs
       The following  resources are required to accomplish the QA
       objectives and milestones  identified in the interim QA program
       for Region V.

       A.   Staff - Twelve man years  of effort is required to fully
            implement the Quality Assurance Program for Region V.
            Sixty-six (66) percent of staff is in place.  Present
            staff consist of the  Office Chief, 1 secretary, 2 professional
            chemists, 1  professional  microbiologist, 1 professional
            physical  scientist, 1 journeyman organic chemist and
            1 journeyman electronics  technician.  Professional organic
            chemistry support  is  provided to the QAO on an as needed
            basis from the CRL (this  support will continue for the
            "hands on" experience).   The type of additional staff
            required  (34%) is  1 professional organic chemist, 1
            statistician (or chemist  with a good statistical background)
            and 2 journeyman inorganic chemists.

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         B.    Monetary -  The  QAO  needs  approximately $120,000 for
              contracts.   These contracts  are to  be used to develop
              software EDP capability for  measurement methods and
              statistical  data evaluation  for minimum turn around
            .  time.   Data quality problems could  be identified much
              faster and  larger volumes of data can be evaluated.
         C.    Time - If all resources identified  in Section 4.2.4 are
              granted the QAO, the program described in this document
              could be fully  implemented in 90 days after receipt of
              resources.

         D.    Training Seminars - The QAO  is providing workshops for
              standardizing metal analyses and upgrading organic
              analyses performance for  Region V and State laboratory
              personnel during the second  quarter of FY 80.  A workshop
              for audits  of air monitoring sites  will also be provided
              Region V, State and local agency personnel.  Travel funds
              will be required to getr personnel to these workshops
              when their  agency can not afford to send them.
              Approximately $2,000 is required for this travel.

5.  PERSONNEL

    Key personnel of the  Quality  Assurance Office must have sufficient
    administrative and technical  stature to be considered a peer to
    the Managers of monitoring activities  within  the Region and to the
    Managers of Region V  State and local laboratories.  This staff
    must have a professional  knowledge/training and understanding of
    chemical/microbiological  principles, concepts, practices, established
    methodology and measurement (instruments) systems.  The individual
    must have at least two years  of bench  experience in his/her speciality,
    particularly in an environmental  laboratory.   The individual must
    have experience in developing and implementing intralaboratory
    quality control  programs. Regional QAO personnel must have knowledge
    of Federal laws, Agency regulations and guidelines pertaining to
    quality assurance and analytical  procedures related to the Agency's
    regulatory monitoring programs.  The individual must be experienced
    in meeting and dealing with Regional,  State and local government
    officials and other Federal Agencies.

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                               15

Analytical  operations in the laboratory can be  graded  according
to the degree of complexity.  Some analyses require  no sample
treatment,  and the measurement can be performed in minutes  on  a
simple instrument.  Other determinations require extensive  sample
preparation prior to complex instrumental  examination.  Consequently,
work assignments in the laboratory should be clearly defined.
Each analyst should be completely  trained and should fully  understand
all the assignments of his job before being given new  responsibilities.
In this regard, all analysts, subprofessional or professional, should
be thoroughly instructed in basic  laboratory operations,  according
to the extent of professional maturity.  Some of the basic  operations
that will be reviewed with laboratory personnel during the  on-site
evaluation follow.

a.  -SAMPLE LOGGING: Routine procedure for recording of samples
     entering the laboratory and assigning primary responsibility
     should be emphsized.  The information that is required and  the
     routing of the samples to the analyst is then established.  The
     stability, preservation, and  storage of samples prior  to
     analyses are then discussed.

b.   SAMPLE HANDLING:  The analyst should understand thoroughly  at
     which points in his procedures the sample  is to be settled,
     agiated, pipetted, etc., before he removes it from the original
     contai ner.

c.   MEASURING:  The analysts, especially new employees and sub-
     professionals, should be instructed in the use  of volumetric
     glassware.  The correct use of pipettes and graduates  should  be
     emphasized.

d.   WEIGHING:  Because alsmost every measuring operation in the
     analytical laboratory is ultimately related to a  weighing
     operation, the proper use of the analytical balance should  be
     strongly emphasized.  Maintenance of the balance, including
     periodic standardization, should be repeatedly  emphasized to
     all personnel.

e.   GLASSWARE:  All glassware should be washed and  rinsed  according
     to the requirements of the analysis to be  performed.  Not only
     must the personnel assigned to these tasks be instructed, but
     also all lab personnel should know the routine for washing  and
     special requirements for particular uses of glassware.  In
     addition, the precision tools of the the laboratory such  as

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                               16

     pi pets,  bursts,  graduates, and  tubes  should  be  inspected  before
     use for cleanliness,  broken delivery  tips, and  clarity  of
     marking.  Defective glassware should  be  discarded  or  segregated.

f.   INSTRUMENTATION:   Operation and maintenance  of  analytical
     instrumentation  is of primary consideration  in  the production
     of valid data.   All instruments must  meet the requirements
     specified in Agency regulations, be properly calibrated,
     quality-control  checks documented, and standard curves  verified
     on a routine basis.  References on instrumental  quality control
     are presented in Section 8.4 and 8.5  of  this document.

g.   DATA HANDLING AND REPORTING: ' As with sample logging, the routine
     procedure for recording results of analyses  and pertinent
     observations, including quality control  checks, should  be
     emphasized.  Analytical data should be permanently recorded  in
     meaningful, exact terms and reported  in  a form  that permits
     future interpretation and unlimited use.  Details  are discussed
     in Section 9 of  this  document.

h.   QUALITY CONTROL:  The need to continuously assess precision and
     recovery values  of methodology  is a prime responsibility  of  the
     analyst.  Self-evaluation through the analyses  of QC  samples,
     replicates and recovery of spikes from samples  representative
     of the daily workload provides  confidence and documentation
     of the quality of the reported  data.

i.   SAFETY:   Laboratory safety should be  discussed  on a continuing
     basis with all  employees, but it should  be emphasized when an
     employee is assigned to perform new duties.

j.   IMPROVEMENT:  In summary, quality control begins with basic
     laboratory techniques.'  Individual operator  error and laboratory
     error can be minimized if approved techniques are consistently
     practiced.  To insure the continued use  of good technique, lab-
     oratory supervisors should periodically  review  the basic  techniques
     and point out areas of needed  improvement with  each analyst.

     Continuing improvement of technical competence  by all laboratory
     personnel is, of course, the  final responsibility of  the
     laboratory supervisor.  In a well-organized  laboratory, however,
     a big-brother attitude of higher ranking to  lower grade personnel
     should be encouraged; each person should be  eager to  share
     experience, tricks of the trade, special skills, and  special
     knowledge with subordinates.   Obviously, efficiency and results
     will improve.

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                                   17

    k.   SKILLS:   The cost of data production in  the  analytical  lab-
         oratory is based largely upon two factors: the pay  scale  of  the
         analyst, and the number of data units produced per  unit of time.
         However, because of the large variety of factors  involved,
         estimates of the number of measurements  that can  be made  per
         unit of time are difficult.  If the analyst  is pushed to  produce
         data at a rate beyond his capabilities,  unreliable  results may
         be produced.  On the other hand, the analyst should be  under •
         some compulsion to produce a  minimum number  of measurements  per
         unit of time, lest the cost of data production become prohibitive.
         In table 5-1, estimates are given for the number  of determinations
         that an analyst should be expected to perform on  a  routine basis.
         The degree of skill required  for reliable performance is  also
         indicated.

         The time limits presented in  the table are based  on use of
         approved methodology.  A tacit assumption has been  made that
         multiple analytical units are available  for  measurements  requiring
         special  equipment, as for cyanides, phenols, ammonia, nitrogen,
         and COD.  For some of the simple instrumental  or  simple volumetric
         measurements, it is assumed that other operations such  as
         filtration, dilution, or duplicate readings  are required; in such
         cases the number of measurements performed per day  may  appear
         to be fewer than one would normally anticipate.

6.  FACILITIES. EQUIPMENT. AND SERVICES

    The QA program makes Facilities, Equipment and Services  a major
    component of the program.  The recognition is made that  no data
    can be collected without the appropriate equipment that  is functional.
    To assure the operation of that equipment all  facilities, equipment
    and services must work as a composite in a smooth orderly manner.
    The items that are necessary are:

    A.  Laboratory facilties, building, utilities, equipment and maintenance.

    B.  Field facilities, housing for  equipment,  transportation  require-
        ments, utilities, supplies, communications and maintenance.

    C.  Analtytical equipment, required methods,  operation and calibration
        manuals,  maintenance, parts and supplies.

    D.  Procurement procedures, that require purchase of the required
        equipment with warrantees,  demonstrated satisfactory performance
        prior to  payment, service arrangements, availability of  spare
        parts, evaluation of equipment from information of prior users,
        costs evaluation and comparisons against  competitive equipment.

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                                       TABLE  5-1
                  SKILL-TIME  RATING  OF  STANDARD ANALYTICAL OPERATIONS
Measurement
Simple Instrumental:
pH
Conductivity
Turbidity
Color
Dissolved Oxygen (Probe)
Fluoride (Probe)
Simple Volumetric:
Alkalinity (Potentiometric)
Acidity (Potentiometric)
Chloride
Hardness
Dissolved Oxygen (Winkler)
Simple Gravimetric:
Solids, Suspended
Solids, Dissolved
Solids, Total
Solids, Volatile
Simple Colon' metric:
Nitrate N (Manual)
Nitrate N (Manual)
Sulfate (Turbidi metric)
Silica
Arsenic
Complex, Volumetric, or Colon metric:
BOD
COD
TKN
Ammoni a
Phosphorus, Total
Phenol (Distillation Included)
Oil and Grease
Fluoride (Distillation Included)
Cyanide .
Special Instrumental:
TOC
Metals (by AA), No Preliminary Treatment
Metals (by AA), With Preliminary Treatment
Organics (by GC), Pesticides, Without Cleanup
Organics (by QC), Pesticides, With Cleanup
Skill Required
(Rating No.)1

1
1
1
1
1,2
1,2

1
1
1
1
1,2

1,2
1,2
1,2
1,2

2
2
2
2
2,3
2,3 .
2,3
2,3
2,3
2,3
2,3
2,3
2,3
2,3

2,3
2,3
2,3
3,4
3,4
Number
Per Day

100-125
100-125
75-100
60-75
100-125
100-125

50-75
50-75
100-125
100-125
75-100

20-25
20-25
25-30
25-30

75-100
40-50
70-80
70-80
20-30
215-20
25-30
25-30
25-30
50-60
20-30
15-20
25-30
8-10

75-100
150
60-80
3-5
2-4
•••Skin-required rating numbers  are defined  as  follows:
     1 - aide who is a semiskilled subprofessional  with minimum background or training,
         comparable to GS-3 through GS-5.
     2 - aide with special  training or professional  with minimum training with background
         in general laboratory  techniques and  some  knowledge  of chemistry, comparable to
         GS-5 through GS-7.
     3 - experienced analyst capable of following complex  procedures with good background
         in analytical techniques, professional, comparable to GS-9 through GS-12.
     4 - experienced analyst specialized in highly  complex procedures,  professional,
>>„ ^  .,  comparable to GS-11 through GS-13.
2Rate depend! on type of samples.

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                                   13

    E.    Preventive Maintenance  policies  and  procedures.

    F.    Service and Repair procedures.

    6.    Audit and Evaluation requirements.                      '•''>

    H.    Safety.
         A protocol for procurement testing is  described  in  Appendix 4
         which establish guidelines for equipment  that  are based on
         EPA guidelines, good laboratory  practices and  pertinent information
         from industries and governmental  agencies where  similar concerns
         are part of the art of  good management and quality  assurance.
         As with other operations,  the effectiveness of facilities are
         determined by independent  evaluations.

7.  REVIEW OF PROGRAM PLANS. PROJECT PLANS. OR  STUDY PLANS

    As  a statement of policy, the QA program  requires a review of all
    program project and study plans for Region  V,  including  the S&A
    Division study plans.  It is essential that these plans  are evaluated
    from the beginning so that the  appropriate  measurement method is
    selected that will produce the  data the user needs.  Many, if not
    all, projects require data that lead  to decisions that have an
    economic impact as well as technologic impact.  The prevention of
    loss in monies, resources and time weighs heavily upon the plans
    that lead to program or project development.  If those plans incorporate
    unapproved, and inappropriate methodology which in  turn  produce
    data that are not pertinent  to  the program  or project or do not
    have acceptable precision, accuracy,  representiveness or completeness,
    then the efforts are lost, lead to wrong  decisions, or cause equivocation.

    Since the review of plans has not  been customary in the  past, it
    will be necessary to develop programs that  accomplish this preliminary
    review process.  The various divisions and  program  units and QA
    must work together to initiate  this process as a Standard Operating
    Procedure.  The details that need  to  be accomplished  are:

    A.    Directives to Program,  Project or study offices  requiring QA
         review of scope and plans  at  the earliest data of the planning
         process.

    B.    Request of QA review requirements must be in writing.  This
         request should give some estimate of the magnitude  of study.

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                               19

C.   QAO, immediately upon initiation of the review process, would:
      1.  determine expertise required
      2.  technology

D.   Having established plans for review, the QA review would proceed
     and results would be reported.  The evaluation would declare
     feasibility with respect to provisions that assure the appropriate
     methodology, precision, accuracy, representativeness and completeness.
     Should factors be inappropriate or deficient, corrective measures
     would be stated to the project officer.

The Agency's protocol for evaluation of QA plans in extramural
projects and contracts will be used as soon as the document is
available.

QAO will investigate the needs for developing guidelines which
would be used to evaluate statistical, modeling, and other aspects
of environmental studies.  The location of expertise and at times
technology for unusual projects will require national concern.  Thus
these needs will be formulated as they become appropriate.

A review of programs, projects or study plans would determine what
QA plans are to be incorporated in those plans.  The various activities
and items that must be identified are:

     o. Staffing (personnel in numbers, qua!ifiication and training).

     o Methods (EPA approved methods must be used where required).
       Procedures must be documented and made available for review
       prior to use.

     o Quality control measures must be described in detail.
       This would explain the frequency of duplicate, spike or
       performance samples.  Control measures used in sample
       collection, with frequency of duplicate sampling prescribed.
       Audits by inter!aboratory, peer group, systems audits and
       performance audit must be described as to frequency and source
       of audit.  Control limits must be determined and the
       required measures that must be taken when out of control
       limits have been exceeded should be described.

     o Sample collection and preservation should be described
       in detail.  The calibrations of analytic methods and
       equipment must be according to the requirements of the
       approved methods.  Standards used for calibrations must
       be of the highest purity and referenced to NBS standards
       whenever possible.  Calibration procedures and tracability
       must be documented.

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                                   20

    The QA plans must appear early in  the  planning  process because
    without these QAO will  not  have suitable  information to move forward
    in the evaluation process.

    Suitable, procedural  information for developing  QA  plans based on
    the items discussed above are available in  the  references cited
    in Section 14 of this document.

8.  DATA COLLECTION

    Data quality changes occuring during data collection can come
    from six major activities:  a) formulating sound objectives for the
    sampling program, b) collecting representative  samples, c) maintaining
    sample integrity through proper sample handling and preservation,
    d) adhering to appropriate  sample  identification and, where needed,
    chain of custody procedures,  e) practicing  quality assurance pro-
    cedures in the sample transportation,  storage,  and preparation
    processes, and f) using proper analytical techniques complete with
    appropriate quality control  activities to generate the actual data.

    8.1  Sampling Plan
         The objectives of the  sampling program affect all the
         other aspects of the sampling program.   Sampling program objectives
         are determined by the  following activities: (a) planning (areawide
         or basin), (b) permits,  (c) compliance, (d) enforcement, (e) design,
         (f) process control, and (g)  research  and  development.  The types
         of sampling programs to  be employed, depending on suitability to
         program objectives, include reconnaissance surveys, point-source
         character!"zation,  intensive surveys; fixed-station-network monitoring,
         ground-water monitoring, ambient  air monitoring and stationary
         source emission monitoring, and special  surveys involving chemical,
         biological, microbiological,  and  radiological monitoring.

         Factors that must  be considered in meeting the objectives of
         the sampling program are the  extent  of the manpower resources, the
         complexity of the parameters  of interest,  the duration of the survey,
         the number of samples, the frequency of sampling, the type of
         samples (grab or composite),  and  the method of sample collection
         (manual or automatic).

          The media activity will identify the  need for a sampling activity
          in Region V.  A person  with  lead responsibility in the media activity
          is also identified to coordinate the  project for the media activity.

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                               21

      The identified need  is  transmitted  to the S&A Division.  The
      Technical  Support  Branch  coordinates the formulation of
      objectives and goals for  the  sampling activity with the
      Central  Regional  Laboratory and  the appropriate District Office.
      Once goals have been formulated  to  accomplish objectives
      (including the six major  activities listed  under 8 above),
      the proposal  is then reviewed by the QAO to insure that all
      quality assurance  requirements for  producing valid data have
      been included.  If any  QA changes are needed, the QAO will
      specify the changes  needed.   Once the QA changes are made
      (if need be), the  QAO will concur.  The S&A Division Director
      will transmit the  study proposal  to the Director of the
      requesting media program  for  review and see if the defined objectives
      and goals meets the  program needs.  If not, revision will be made
      (NOTE - QA is not  to be compromised).  Once the Director of the media
      program concurs in the  proposal, the appropriate S&A Division
      Office/Branch or other  Divisions will initiate the proposal.

8.2  Sampling Methodology
     The objective of sampling  is to obtain a representative
     portion of the total  environment  under investigation.  The
     sampling plan shall contain, as a minimum, the following
     factors for concurrence  by the QAO (Item 8.1 above) in formulation
     of the sampling plan.

     A.  Water and Wastewater

        .  o Site Selection

          The location of  the sampling site is critical in obtaining
          representative data.   Preferably, water sampling sites for
          point sources  of pollution from municipal and industrial
          effluents are  located at  points of highly turbulent flow
          to insure good mixing; however, inaccessibility, lack of
          site security, or power unavailability  may preclude use
          of the best sites,  but these impediments should not be
          used as reasons  for collecting  samples  at unacceptable
          locations.  Loctions  of sampling sites  for streams,
          lakes, impoundments,  estuaries, and coastal areas vary,
          but in general occur  in the  following bodies: (a) in
          water bodies for sensitive uses (swimming and drinking water
          supply), (b)  in  major impoundments or reservoirs near the mouths
          of major tributaries  and  in  the rivers  entering and leaving the

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                     22

impoundments, (c)  in water bodies polluted by man's  activities,
(d) in rivers upstream and downstream from tributaries,  and
(e) where hydrological  conditions change significantly.

o Sample Type

The basic types of water and wastewater methods  are  grab
sampling and composite sampling.   Composite sampling may be
conducted manually or automatically.   The six methods
for forming composite samples,  all of which depend on
either a continuous or periodic sampling mode, are the
following: (a) constant sample  pumping rates, (b) sample
pumping rates proportional to stream  flow rates, (c) constant
sample volumes and constant time intervals between samples,
(d) constant sample volumes and time  intervals between samples
proportional to stream flow rates, (e) constant  time intervals
between samples and sample volumes proportional  to total stream
flow volumes since last sample, and (f) constant time intervals
between samples, and sample volumes proportional to  total  stream
flow rates at time of sampling.  The  choice of using the grab
sampling method or one of the six compositing sampling methods is
determined by program objectives and  the parameters  to be sampled.

o Use of Automatic Samplers

The use of automatic samplers eliminates errors  caused
by the human element in manual  sampling, reduces personnel
cost, provides more frequent sampling than practical for
manual sampling, and eliminates the performance  of routine
takes by personnel.  Criteria for brand selection of
automatic samplers include evaluations of the intake
device, intake pumping rates, sample  transport lines,
sample gathering systems (including pumps and scoops), power
supplies and power controls, sample storage systems, and
additional desirable features to fit  particular  sampling
conditions.  There are many commerically available automatic
samplers; however, because no single  automatic sampler
is ideally suited for all situations, the user should
carefully select the automatic  sampler most suited for
the particular water or wastewater to be characterized.
Precautions must be taken in regard to using certain
types of samples in potentially explosive atmospheres.

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                     23

o Flow Measurements

An essential part of any water or wastewater sampling
survey as well as a necessary requirement of the National
Pollution Discharge Elimination System (NPDES)  permit
program is accurate flow measurements.  Flow measurement
data may be instantaneous or continuous.

For continuous measurements, a typical system consists
of primary devices such as weirs and flumes and secondary
devises such as flow sensors, transmitting equipment,
recorders, and totalizers.  The improper installation
or design of a primary device or malfunction of any part
of a secondary device results in erroneous flow data.
The accuracy of flow measurement data also varies widely,
depending principally on the accuracy of the primary
device and the particular flow measurement method used.
In any case, measurements should be within £10  percent
of the true values.

As part of a monitoring activities'  QA program, a written
step-by-step procedure for the use of each type of flow
equipment employed by the monitoring activity shall be
available.  The write-up is to include the protocol for
installation of the measuring device (if appropriate),
maintenance and verifiction of calibration of the measuring
device in the field.  Documentation must also be maintained.
All mechanical and electronic type current meters'  calibration
are to be traceable through an unbroken chain (supported
by documentation to some untimate or national reference
standard (i.e., NBS or NOAA).

o Statistical Approach to Sampling

Four factors must be established for every sampling program:
(a) number of samples, (b) frequency of sampling, (c) parameters
to be measured, and (d) sampling locations.  These factors
are usually determined in varying degrees by details of
the pertinent discharge permits or are more arbitrarily
set by the program resource limitations.  Nevertheless,
the nature of the statistical methods selected  and scientific
judgment should be used to establish the best procedures.

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                          24

     o Special  Sampling Procedures

       Special  sampling procedures  should be  employed  for
       hazardous wastes, toxics, municipal, industrial,  and
       agricultural  waters,  and surface waters  as  well  as
       bottom sediments and  sludges,  and for  biological,
       microbiological, and  radiological  studies.

B.   Air

     o Sampling Site Selection Considerations

     The need for an air quality monitoring program usually
     is related to one or more of the following objectives:

     1.  To judge compliance with and/or progress  made toward'
         meeting ambient air quality  standards.

     2.  To activate emergency control  procedures  that prevent
         or alleviate air pollution episodes.

     3.  To observe pollution trends  throughout a  region,
         including nonurban  areas.

     4.  To provide a data base for research  evaluation  of
         effects; urban, land use,  and transportation  planning;
         development and evaluation of abatement strategies;
         and development and validation of diffusion models.

     Sampling site and equipment requirements are  generally
     divided into three categories, consistent  with desired
     averaging times:

     1.  Continuous—Pollutant concentrations determined with
         automated methods and recorded or displayed continuously.

     2.  Intermittent—Pollutant concentrations determined with
         manual or automated methods  from integrated hourly  or
         daily samples on a  fixed schedule.

     3.  Static—Pollutant estimates  or effects determined from
         longer-term (weekly or monthly) exposure  of qualitative
         measurement devices or materials.

     Air quality monitoring  sites that employ automatic  equip-
     ment to continually sample and analyze  pollutant  levels
     may be classified as primary.   Primary monitoring stations

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                     25

are generally located in areas  where  pollutant concentrations
are expected to be among the  highest  and  in the  areas of
highest population density and, as  such,  are  often employed
in health effects research networks.   In  addition, these
stations are designed as a part of  the air pollution
episode warning system.

o Network Design Considerations

In designing an air quality monitoring activity, the
following four criteria  for locating  sites should be
considered, either singly or  in combination,  depending
upon the objective of sampling:

1.  Orient monitoring sites to  measure the impacts of
    known pollutant emission  categories on air quality.

2.  Orient monitoring sites relative  to population
    density to measure receptor-dose  levels,  both short
    and long-term.

3.  Orient monitoring sites to  measure the impacts of
    known pollutant emission  sources  (area and point) on
    air quality.

4.  Orient monitoring sites to  obtai-n measurements
    representative of areawide  air  quality.
                                                           *
In order to select locations  according to these  criteria,
it is necessary to have  detailed information  of  the location
of sources of emission,  the geographical  variability of
ambient pollutant concentrations, meteorological conditions,
and population density.

o Representative Sampling

Assuring the collection  of a  representative air  quality sample
depends on the following factors:

1.  Locating the sampling site  and  determining network size
    consistent with monitoring  objectives.

2.  Restraints on the sampling  site imposed by meteorology.

3.   Restraints on the sampling site  imposed  by  local topography,
     emission sources, and physical constraints.

4.   Sampling schedules  consistent  with monitoring objectives.

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                                            26

                       o Locate Sampling Site and Determine  Network  Size

                       Consistent with monitoring objectives previously noted,
                       networks are designed to meet  at  least one  of four major
                       objectives.  The following tabulation presents examples
                       of currently implemented networks applicable  to each  of
                       these "objectives" categories:
     Obiecti ve
       Network
     Comment
Compliance
monitoring
Emergency
episode monitoring
Trend monitoring
Research
monitoring
SIP (State Imple-
mentation Plan)
SIP/1 oca! agency
emergency control
program


NASN (National
Air Sampling
Networks)

CWMP (Community
Health Air Monitor-
ing Program)
To demonstrate attainment
or maintenance of Air
Quality Standards

To activate immediate,
short-term, emission
controls for prevention
of episodes

To fulfull mandate of
Federal legislation
To determine long-term
pollutant trend in
selected areas with
respect to health effects
                       o Compliance Monitoring

                       The information required for selecting sampler location is
                       essentially the same as that for determining the number of
                       samplers, i.e., isopleth maps, population density maps,
                       and source locations.  Following are suggested guidelines:

                       1.  The priority area is the zone of highest pollutant
                           concentration within the region.  One or more stations
                           are to be located in this area.

                       2.  Close attention should be given  to densely populated areas
                           within the region, especially when they are in the  vicinity
                           of heavy pollution.

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                     27

3.   For assessing the quality of air entering the region,
     stations must also be situated on the periphery of the
     region.  Meteorological fetors such as frequencies
     of wind direction are of primary importance in locating
     these stations.

4.   For determining the effects of future development on the
     environment, sampling should be undertaken in areas of
     projected growth.

5.   A major objective of surveillance is evaluation of progress
     made in attaining the desired air quality.  For this purpose,
     sampling stations should be strategically situated
     to facilitate evaluation of the implemented control
     tactics.

6.   Some information of air quality should be available to
     represent all portions of the regions.

Some stations will be capable of fulfilling more than one of
the  functions indicated; e.g., a station located in a densely
populated area can indicate population exposures and also document
the  changes in pollutant concentrations resulting from control
.strategies employed in the area.

o  Emergency Episode Monitoring

For"episode avoidance purposes, data are needed quickly—
in no less than a few hours after the sensor is contacted
by the pollutant.  While it is possible to obtain data
rapidly by on-site manual data reduction and telephone
reporting, there is a trend toward automated monitoring
networks.  Obviously, the severity of the problem, size
of the receptor area, and availability of resources influence
both the scope and sophistication of the system.

It is necessary to utilize continuous air samplers because
an episode lasts only a few days and the control actions
taken must be based on "real-time" measurements correlated
with the decision criteria.  Based on alert criteria now
in use, 1-hour averaging times are adequate for surveillance
of episode conditions.  Shorter averaging times provide
information on data collecting excursions but increase
the  need for automation because of the bulk of the data
obtained.  Averaging times longer than six hours are not
desirable because of the delay in response this imposes.

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                     28

Collection and analysis must be accomplished rapidly if the
data are to be useful immediately.   There is no time to
check out the methods, run blanks,  calibrate, etc.,
after the onset of episode conditions.   In order for the
instrument to be maintained in peak operating condition,
personnel must be stationed at the sites during the
episode or automated equipment must be  operated that can
provide automatic data transmission to  a central location.

Episode conditions threaten human welfare, and monitoring
sites should be located in areas where  this welfare is
most threatened:

1.  In densely populated areas.

2.  Near large stationary sources of pollutants.

3.  Near hospitals.

4.  Near high-density traffic interchanges.

5.  In homes for the aged.

A network of sites is useful in determining the range of
pollutant concentrations within an area.  Although the most
desirable monitoring sites are not necessarily the most
convenient, consideration should be given, for reasons
of access, security, and existing communications, to the
use of public building: schools, firehouses, police
stations, hospitals, and water or sewage plants.

o Trend Monitoring

As typified by the National Air Surveillance Network (NASN),
trend monitoring is characterized by locating a minimal
number of monitoring sites across as large an area as
possible.  The program objective is to  determine, in a
broad sense, the extent and nature of air pollution as
well as determine the variation in the  measured levels
of atmospheric contaminants in respect  to geographic,
socioeconomic, climatologic and other factors.  The data
acquired are useful in planning epidemiological investigations
and also provide the background against which more intensive
community and state-wide studies of air pollution can be
conducted.

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                   •  29

Urban sampling stations are usually located  in the  most
densely populated areas of a region.   In most  regions
there are several urban sites.

Nonurban station loctions include various topographical
categories such as farmland, desert,  forest, mountain,
and coastal.  The nonurban stations are not  specifically
selected to be "clean air" control  sites for urban  areas,
but they do provide for a relative comparison  between
some urban and nearby nonurban  areas.

In interpreting trend data one  must consider the limitations
imposed by the network design.   Even though  precautions are
taken to ensure that each sampling site is as  representative
as possible of the designated area, it is impossible to
be totally certain that the measurements obtained at a
specfic site are not sometimes  unduly influenced by
local factors.  Such factors might include topography,
structures, and sources of pollution in the  immediate
vicinity of the site, and other variables, the effect  of
which cannot always be accurately anticipated  but which
should be considered in network design.  It  must be kept
in mind that when comparisons are made among pollution
levels for various areas, they  are valid only  insofar  as
the sites are comparable.
                                       •

o Research Monitoring

An example of a research-oriented air quality  monitoring
effort is the EPA's Community Health  Air Monitoring
Program (CHAMP), which is providing data to  develop
criteria for both short- and long-term air quality  standards.
Air monitoring networks related to health effects are
composed of integrating samplers for determining
pollutant concentrations for 24 hours, or longer for
developing long-term (_> 24 hours) ambient air  quality
standards.  These studies require that monitoring points
be located so that the resulting data represent the
population group under study.  The monitoring  stations
are therefore established in the center of small, well-
defined residential areas within a community.   Data
correlations are made between observed health  effects
and observed air quality exposure.

Requirements for aerometric monitoring in support of
health studies are:

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                 30

1.  Station must be located in or near the population under
    study.

2.  Pollutant sampling averaging times must be sufficiently
    short to allow for use in acute health effects  studies
    that form the scientific basis for short-term standards.

3.  Sampling frequency should be sufficient to characterize
    air quality as a function of time, usually daily.

4.  System should be flexible and responsive to emergency
    conditions with data available on short notice.

o Meterological Factors that Affect Representative  Sample
  Collection

Meteorology must be considered in determining not only
the geographical location of a monitoring site, but  also
such factors as height, direction and extension of  sampling
probes.  Meteorological parameters having the greatest
influence on dispersion of pollutants are the direction,
speed, and variation of wind.

Wind direction provides an indication of the general  movement
of pollutants in the atmosphere.  Review of available data  can
indicate mean wind direction in the vicinity of the  major sources
of emissions.

The effects of wind speed are two-fold.  First, wind speed
determines the travel time from source to receptor.   Second,
wind speed affects dilution in the downwind direction,
i.e., concentration of air pollutants is inversely  proportional
to wind speed.

o Topographical Features that Affect Representative  Sample
  Collection

The transport and diffusion of air pollutants is complicated
by topographic features.  Minor topographic features may exert
small influence; major features, such as deep river
valleys or mountain ranges, may affect large areas.
Before final site selection, topography of the area
should be reviewed to ensure that the purpose of monitoring
at that site will not be adversely affected.

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                     31

Final placement of the monitor at a selected  monitoring
site depends on physical  obstructions  and activities  in
the immediate area, accessibility, availability  of  utilities
and other support facilities,  correlation with the  defined
purpose of the specific monitor,  and monitor  design.
Because obstructions such as trees and fences can significantly
alter air flow, monitors should be removed from  such
obstructions.  It is important that air flow  around the
monitor should be representative  of the general  air flow
in the area to prevent sampling bias.

Network designers are to avoid sampling locations that
are unduly influenced by down-wash or  by ground  dust,
such as a rooftop air inlet near a stack or a ground-level
inlet near an unpaved road.  In the latter case, either
elevate the sampler intake above  the level of maximum
ground turbulence effect or simply place it reasonably
far from the source of ground dust.

o Sampling Schedules Consistent with Monitoring  Objectives

Current Federal regulations specify the frequency of
sampling for criteria pollutants  to meet minimum SIP
surveillance requirements.  Continuous sampling  is
specified except for 24-hour measurements of  total
suspended particulate matter and  24-hour integrated
values for S02 and N02.  The high-volume and  gas impinger
measurements are required at least once every six days,
equivalent to about 61 random samples  per year.  Twenty-
four-hour samples should be taken from midnight  (local
standard time) to midnight and thus represent calendar
days to permit direct utilization of the sampling data
with standard daily meteorological summaries.

o Sample Preservation and Holding Times

During and after collection, if immediate analysis  is not
possible, the sample must.be preserved-to maintain  its
integrity.  Proper handling of the samples helps insure
valid data; consideration must also be given  to  care  of
the field container material and  cap material, cleaning,
structure of containers, container preparation for  determination
of specific parameters, container identification, and
volumes of samples.

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                               32

          Sample collection  containers,  preservatives and holding
          times for samples  collected  in the  106, 208, 404(b),
          1412 and the Great Lakes  National Monitoring Programs
          shall be those  specified  in  Appendix  5.

          Sample collection, containers  and preservation of industrial
          effluents for priority pollutants protocol shall be those
          specified in Appendix 6.

          Sample collection  and preservation  protocol for hazardous
          waste samples shall  be those specified in Appendix 7.

          Sample collection  and preservation  protocol for ambient
          air samples shall  be those  specified  in Appendix 8.

          Sample collection, preservation and holding time protocol
          for the 1412 monitoring  (public water supply) program
          shall be those  specified  in  Appendix  14.

8.3  Analytical Methodology
     The analytical laboratory provides  qualitative and quantitative
     date for use in decision making.  To be  valuable, the data must
     accurately describe  the characteristics  and concentrations of
     constituents in the  samples submitted to the laboratory.  In many
     cases, because they  lead to faulty  interpretation, approximate or
     incorrect results are"worse than  no results at all.

     Many analytical methods for environmental  pollutants have been
     in use for many years and are  used  in most environmental lab-
     oratories.  Widespread  use of  an  analytical method in environmental
     testing usually indicates that the  method  is reliable, and
     therefore tends to support the validity  of the reported test
     results.  Conversely, the use  of little-known analytical
     techniques forces the data user  to  rely  on the judgment of
     the laboratory analyst, who must  then defend his choice of
     analytical technique as well  as  his conclusions.

     Uniformity of methodology within  a  single  laboratory as well
     as among a group of  cooperating  laboratories is required to
     remove methodology as a variable  when there are many data
     users.  Uniformity of methodology is particularly important
     when several laboratories provide data to  a common data bank
     (such as STORET) or  cooperate  in  joint field surveys.  A
     lack of uniformity of methodology may raise doubts as to the
     validity of the reported results.  If the  same constituents
     are measured by different analytical procedures within a

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                          33

single laboratory, or by a different  procedure  in  different
laboratories, it may be asked which  procedure is superior,
why the superior method is not used  throughout, and  what
effects the various methods and procedures  have on the  data
values and their interpretations.

Physical and chemical measurement  methods  used  in  environmental
laboratories should be selected by the following criteria:

a.   The selected methods should measure desired constituents
     or environmental samples in the presence of normal  inter-
     ferences with sufficient precision and accuracy to meet
     the environmental data needs.

b.  The selected procedures should use equipment and skills
    ordinarily available in the average environmental  laboratory.

c.  The selected methods should be sufficiently tested  to
    have established their validity.

d.  The selected methods should be sufficiently rapid to
    permit repetitive routine use  in the examination of large
    numbers of water samples.

The restriction to the use of EPA  methods  in all laboratories
providing data to EPA permits the  combination of data from
different EPA programs and supports  the validity of  decisions
made by EPA.

The QAO requires that the methodology be carefully documented.
In some reports it is stated that  a  standard method  from an
authoritative reference was used throughout an  investigation,
when close examination has indicated, however,  that  this was
not strictly true.  Standard methods may be modified or entirely
replaced because of recent advances  in the state of  the art
or personel preferences of the laboratory  staff.   Documentation
of measurement procedures used in  arriving at laboratory data
should be clear, honest, and adequately referenced;  and the
procedures should be applied exactly as documented.

Reviewers can apply the associated precision and accuracy of
each specific method when interpreting the laboratory results.
If the accuracy and precision of the analytical methodology
are unknown or uncertain, the data user may have to  establish
the reliability of the result he or  she is interpreting before
proceeding with the interpretation.

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                          34

As part of any monitoring program's  quality control  program, the
analytical methodology must be included for review and  approval
by the Quality Assurance Office.   The format and minimum
requirements for method documentation are listed below:

1.   Parameter that the method measures.

2.   Principle - A brief description of the method.

3.   Optimum Concentration Range  - The analytical  range from
     the lowest concentration to  the highest concentration
     in which a substance is measured.  The sample may  be
     concentrated or diluted so that the substance can  be
     detected within this range.

4.   Sensitivity - The slope of a curve of concentration
     versus instrument response (such as absorbance).

5.   Detection Limit - The lowest quantity which may be
     be distinguished from zero with an acceptable degree
     of confidence.

6.   Reference - The source of the analytical  method.   In
     addition all variances of the original  procedure are
     documented here.

7.   Matrix - The general composition of the sample that the
     method is capable of handling,  e.g., water (potable,
     ambient, wastewater), solids (leachates,  sediments,
     sludges), air (filter particulates, bubbler solutions,
     casette trap).  Fluids (solvents, hydrocarbons, oils).

8.   Analysis Procedure
     a.  Description - The analytical procedure is described
         for normal conditions.  Sample pretreatment (if
         required) and preparation protocols are also
         described here.  The language used to describe
         the method is to be detailed enough (cookbook
         fashion) so that a technician with experience  in
         the respective type of analysis would clearly
         understand every step of the procedure.   Analytical
         techniques that employ a great deal  of instrumentation
         such as atomic absorption and automated analysers are
         briefly described since  instrument manuals  are
         available which detail the  use of the instrument.
         However, auto analyzer manifolds are  to be  depicted.

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                     35

b.  Instrument parameters -  A description  of the  instrument
    and all  the instrument settings  that are necessary
    to setup the instrument  for normal  conditions.

c.  Routine performance tests - A test  of  the instrument
    performance which is separate from  a calibration  procedure,
    and is a gross indication of the instrument's response.
    This test is performed and documented  each time a
    batch of samples is processed or else  on a da'ily
    basis.  The frequency chosen for instrument
    response check is dependent on the  analysts'
    confidence of instrument stability.

d.  Calibration standards -  The calibration standards
    are described in terms of the range of concentrations
    used in the normal procedure and in terms of
    composition (preparation of standard  solutions)
    employed for various matricies.

e.  In-house quality control standards  - There are
    standards which are different from  calibration
    standards.  Quality Control standards  are meant
    to be a control procedure by which  to  judge
    whether the procedure is in-control or out-of-control
    after the various instrument checks have been
    satisfied.  Wherever used, at least one quality
    control  standard is determined with each batch of
    samples.  The information is then documented.

    1.  one wheel of samples - for auto analyzer
        techniques.

    2.  a number of samples  that is  determined
        continuously without an interuption such  as
        a coffee or lunch break or a change of
        instrument settings  - for atomic  absorption
        techniques, manual techniques,  and gas
        chromatographic techniques.

f.  Data calculations - Describe the computations and
    manipulations that must  be used  to  convert raw
    data to a final analytical results.

g.  Instrument log book - An indication of where  the
    instrument log book is located.   The  instrument

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                           36

          book  is  to  contain,  as  a minimum, the  following
          sections:

          1.   Name, Model  Number, Serial  Number

          2.   Does the identification  verify that the instrument
              is EPA  approved, if required

          3.   Instrument  history

          4.   Service record

          5.   Routine performance test -  This section includes
              a space for the  date,  initials of  analyst,
              comments, and other instruments parameters
              if applicable.

 9.   Interferences - When interferences  are suspected or
      indicated by other  tests, the  specific procedures for
      dealing with these  interferences are described here.

10.   Precision and Accuracy
      The statistical precision and  accuracy results for the
      parameter generated by the  laboratory are  to be
      documented.

11.   Quality Control
      a.  Internal Quality Control - In-House Quality Control
          Standards,  in addition  to  being controls, are to be
          used  as  a measure of precision  under ideal
          conditions.  Frequency  of  use is to be specified.
          Reagent  Blanks  are to be determined to collectively
          check for possible contamination from  the sample
          container,  preservative, glassware, and laboratory
          reagents.   Frequency of use  is  to be specified.
          The use  of  replicate analysis of real  samples to
          measure  precision is viewed  as  a product of the
          laboratories.  This  information is meant for use
          in interpreting analytical results and is of some
          use to the  laboratory for  evaluating the reported
          detection limits and detecting  possible interferences
          that  might  not  be documented in the original method.
          The use  of  replicates is dependent on  the parameter-
          (the  number of  samples  with  positive values) and the
          analytical  method.  Frequency of use is to be
          specified.   The use  of  real  sample spikes (positive

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                                 37

                or negative)  is also dependent  on the convenience
                with which they fit into the analytical  procedure.
                Spike are useful  for evaluating recovery in
                addition to precision.   Frequency of use is to
                be described.

            b.  External Quality Control -  Participation in various
                comparative analytical  programs and frequencies
                outside of the laboratories are cited here.

8.3.1  Maintenance of Up-To-Date File of Measurement Methods
       The Central Regional Laboratory (CRL) currently uses
       over 200 approved reference methods  to analyze over 500
       different environmental pollutants.   It  is known from recent
       on-site inspections that the nine principal  State laboratories
       in the Region use many analytical methods not used by the CRL
       and that they have made "minor"  variations in methods in
       common use by EPA.  The variety of new methods in use by the
       other Federal and local laboratories is  not yet known, but  it
       is expected that the total number of agency approved laboratory
       methods the QAO will be evaluating will  number well  over
       1,000.

       In addition to the laboratory methods, the QAO must monitor the
       performance of sampling procedures used  by the monitoring  programs
       conducted by Region V  and a wide variety of field measurements.
       These include measurement of the common  water parameters such
       as temperature, flow,  dissolved  oxygen,  pH,  etc., as well  as
       the measurement of air pollutants using  both continuous monitors
       and grab sampling techniques.

       Each of the above methods must be technically evaluated and a
       decision made for each method as to  whether or not the method is
       legally approvable for use in one or more of the many programs
       administered by EPA.  For example, is the inductively coupled
       argon plasma procedure used by the CRL to analyze for metals
       significantly different from the approved atomic absorption
       procedure to prohibit  it use in  the  analyses of public drinking
       water samples.  A conservation QAO opinion would answer yes
       and therefore require  the CRL to either  use  the manual method
       or obtain an alternate test procedure approval  pursuant to
       the Safe Drinking Water Act.  Either action  would require  at
       least 0.5 man years of effort which  clearly  identifies the  importance
       of making the correct  decision for each  method-program combination.
       It should be again emphasized that the QAO program requires that
       each approved measurement  method contain a complete  description
       of all quality control audit procedures  and  the frequency  and
       control limits to be used  to insure  reliability of reported

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                          38

data.  Therefore, when a method is approved, the quality
control program associated with that method will also be
approved.

In summary^- this function is not a "bookkeeping" job and is
probably tn'e most difficult work performed by the QAO.   It
requires in-depth technical and program skills as well  as a
great deal of organizational ability and diplomacy to negotiate
satisfactory resolutions to the many problems currently facing
the QAO in this area.   QAO's initial approach toward completing
this task is described below.

1.   Program Guidelines and Implementation Plans
     a*  The Reference Methods described in the various EPA
         regulations will serve as the basis for all method
         evaluations.   Results obtained using the reference
         methods will  be taken as the officially correct results
         even though it is known the result may not, always
         accurately measure the contaminant concentration of
         interest.

         EPA offical analytical methodology for water quality
         measurements are given in Appendix. 9.  Radiation
         methods are shown in Apendix 10.  Ambient air
         measurement methods .are shown in Appendix 11.   Source
         air measurements analytical methodology are shown in
         Appendix 12.   Public water supply measurements
         analytical methodology are shown in Appendix 13.
         Recommended analytical methodology for priority
         pollutants is referenced in Appendix 6.  Sample
         preparation and analysis for hazardous waste are
         those specified in Appendix 7.

         Analytical measurements for ecological evaluations of
         proposed discharge of dredged or fill material into
         navigable waters are listed in Miscellaneous Paper
         D-76-17, titled Interim Guidance for Implementation of
         Section 404(b)(l) of Public Law 92-500 (FWPCA Ammendments
         of 1972), compiled by the U.S. Corps of Engineers.

     b.  A unique number will be given to each method as it is
         approved.  This will permit the QAO to more easily
         use computers to quickly retrieve information related
         to the method.  The unique number will contain the
         following intelligence.

         o Laboratory using method

         o Sample type (air, water, sediment, biological)

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                     39
    o Parameter class (biological, organic, inorganic)
    o Parameter (zinc, aldrin, TSP)
    o Reference or alternate method
    o EPA programs method may be used to support
c.  Software programs will be written which will associate
    other information with each approved method using the
    method number as a cross index.  Some of the related
    information will be as follows:
    o QAO file folder where the "official" method description
      is maintained.
    o A list of literature references supporting the method.
    o The STORET, SARAD, etc., numbers related to the method.
    o The appropriate reference method if the method is an
      alternate test procedure.
    o All quality control audit data.
    o A comment space for user remarks pertaining to method
      performance.
d.  A cross-indexing system will be established in which one
    can obtain a list of approved laboratory-method combinations
    for each EPA program and a list of programs for which
    each laboratory is approved to use each of its
    described analytical  methods.
e.  All approved methods will be reviewed at least once
    each year (January - March) to insure that they are
    properly classified relative to any regulatory or
    technical changes thay may have occurred during the
    year.
f.  A numerical  description of the performance of each
    method will  be obtained from the group evaluating the
    inter!aboratory quality control  audit data.   These

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                                  40

                 numbers will  be evaluated,  interpreted  and  a  description
                 win  be prepared explaining the  performance of the
                 method for non-technical  personnel.   It will  provide
                 references to related methods.

             g.   The out-puts  will  be:

                 o An up-to-date list of all approved  and some unapproved
                   (those being processed, but  not  formally  approved)
                   methods for making any measurement.   Each of these
                   methods will  have  a list  of  programs  which  may
                   be used to  support the reference method,  the proper
                   number to use for  storage of results  (STORET, SARAD),
                   the units of measure, the method performance data
                   (detection  limit,  working concentration range,
                   precision and accuracy) and  laboratories  approved to
                   use the method.

                 o A copy of any approved method(s) and  any  approved quality
                   control program(s).

                 o An evaluation of methods  which were not approved  for  use
                   by the QAO  in the  proposed program  wTOT justification
                   for non-approval.

             h.   Relationship  to other QAO functions
                 These official  measurement  methods will form  the
                 foundation of the QAO program  for  monitoring  data
                 reliability.   They will be the "contract agreement"
                 between the QAO and  all media  offices and will  provide
                 the written communication link for use  in legal and
                 technical challenges.  They will provide a  management
                 structure for-evaluating and documenting differences
                 in method and laboratory performances resulting from
                 "minor" changes in analytical  methods and laboratory
                 operating procedures.

8.3.2.  Alternate Test Procedure Program
        The Code of Federal Regulations (40  CFR 136,
        40 CFR 35, 40 CFR 141, etc.), specifies that  specific  analytical
        methods be used to monitor compliance with  several regulations
        administered by EPA.  In each instance, the regulations provide
        a mechanism by which an alternate analytical  procedure can be
        used in place of the specified reference procedure if  it is
        first documented that  the proposed alternate  procedure is
        equivalent or better than the reference method.   Unfortunately,

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                                   41

         the different  EPA programs specify  different  analytical mthods
         to be used to  analyze for a given contaminant and  different
         mechanisms for obtaining  approval to  use  an alternate test
         procedure.  This requires EPA  to maintain records  for all
         programs (NPDES, SDWA, etc.)-method (Flame AA,  ICAP, Flameless
         AA, etc.)-laboratory combinations to  insure that reported data
         can be used for regulatory purposes.

         For Region V,  the QAO is  responsible  for  processing  all alternate
         test procedure applications in the  water  program areas.  Depart-
         ment E, EMSL-RTP, Research Triangle Park, North Carolina, has
         sole national  responsibility for implementing designated
         reference and  equivalent  methodologies  for the air programs
         as specified by 40 CFR 53.1.   The Region  V alternate test
         procedure protocols are described below by program.

8.3.2.1  Elements of an Application for a National Pollutant  Discharge
         Elimination System (NPDES) or  Section 106 Alternate  Test
         Procedure
         40 CFR 136, "Guidelines Establishing  Test Procedures
         for the Analysis of Pollutants", specifies approved  test
         procedures for NPDES self-monitoring  and  data submitted to
         condition an NPDES permit.

         Appendix H to  40 CFR 35,  specifies  approved test procedures
         be used by a pollution control agency to  show compliance or  non-
         compliance with an NPDES  permit.  Other monitoring programs
         (ex. - PCB toxic pollutant monitoriag)  specify the use of 40
         CFR 136 test procedures.

         40 CFR 136 selects specific documented  test procedures from
         "Standard Methods", EPA's "Methods  for  Chemical Analysis of
         Water and Wastes", and "ASTM,  Part  31", on a  pollutant-by-
         pollutant basis, for the  analysis of NPDES effluents.  Based
         on the knowledge available to  EMSl-Cincinnati, EPA,  these
         test procedures were selected  as the  best available  test
         procedures for effluent analysis -  physical,  chemical or
         microbiological.

         40 CFR 136.4 and 136.5 specifies that alternate test procedures
         may be used if approval either is obtained from the  Regional
         Administrtator on a case-by-case basis, or from the  U.S. EPA
         Administrator  on a nationwide  basis.  Alternate test procedures
         are justified  by, but are not  limited to, increased  analytical
         performance and increased cost effectiveness  to the  approved
         method(s), or  are proposed because  they are promising new

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                          42

methodologies.  Alternate test procedure applications  are
processed by U.S. EPA if an applicant can justify their use
for NPDES monitoring.

The Regional Administrator approves alternate test procedures  on
a case-by-case basis for specific NPDES permits within the specific
U.S. EPA REgion and specific laboratories (public agency and
commercial) receiving NPDES samples from a finite portion  of
an EPA Region.  Appendix H to 40 CFR 35 specifically provides
authority to the Regional Administrator for approval of alternate
test procedures in State laboratories.

a.   NPDES Alternate Test Procedures for Nationwide Use
     Contact the Director, Environmental  Monitoring and Support
     Laboratory (EMSL)-Cincinnati, EPA, Cincinnati, Ohio 45268,
     phone (513)684-7301 or phone FTS 684-7301 for the protocol
     concerning alternate test procedures for nationwide use.

b.   Elements of an NPDES Alternate Test Procedure Application on a
     Case-by-Case Basis
     Until and unless printed application forms are made available
     from the U.S. EPA, any person may apply to the Regional
     Administrator in the Region where the discharge(s) occurs,
     through the Director of the State Agency having authority
     to issue NPDES permits within such State.

     An application should be made in triplicate to the Regional
     Admi ni strator and shal1:

     o Provide the name, address, and telephone number of  the
       responsible person, firm or public agency making
       application.

     o Identify the pollutant(s) for which approval is sought.

     o Specify the applicability of the proposed test  procedure.
       Applicability of an alternate test procedure can be
       sought for (1) one or more specific NPDES permits (in this
       case, the applicable I.D. number(s) must be provided),
       (2) all or certain types of NPDES discharges monitored,
       within a geographical area of the Region, by a  commercial
       laboratory or by a pollution control agency laboratory
       (State or Federal); or (3) all or certain types of
       non-point source monitoring provided by a pollution
       control agency laboratory as part of a Section  106
       or 208 program.

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                     43

o Provide a justification for use of the proposed  method.
  This can be, but is not limited to, increased  analytical
  performance or cost effectiveness.

o Provide a detailed description of the proposed alternate
  test procedure.  This should be written in sufficient
  detail that another laboratory could reproduce the
  applicant's equipment and instrumentation.  This is  a
  necessary part of the application, since final approval
  can only be given for a documented test procedure
  description.  Suggested formats for a detailed description
  can be found in "ASTM, Part 31", "Standard Methods", or
  EPA's "Methods for Chemical Analysis of Water  and Wastes".

o Provide the concentration range of interest for  the
  pollutant(s) identified in the above item. "In the case
  of specific NPDES permits, present and expected  effluent
  limitation concentrations shall be documented.  In the
  case of non point source waters, the criteria  or
  standards, which the monitoring program is to  assess,
  shall be documented.

o Provide the detection limit, and its definition  for  the
  proposed alternate test procedure.

o Provide copies of, or cite reference to any published
  studies, if available, on the applicability of the
  alternate test procedure to the NPOES effluent types in
  questi on.

o Provide data, using sample aliquots of representative
  waste effluents (and untreated or raw wastes,  if
  appropriate), showing the proposed method yields
  results comparable in equivalency and precision  to the
  reference method, or one of the reference methods,
  specified by 40 CFR 136.  The comparability data
  protocol listed in one of the following two items
  will be used.

o For an NPDES discharger, with one to four effluents
  of the same waste characteristic, provide comparability
  data by the following protocol.  Select at least eight
  different effluent aliquots, collected over a  representative
  time period, to provide varying concentration  levels of the
  pollutant of interest.  Determine or measure the
  pollutant of interest by the proposed test procedure

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                   44

and by a reference method.  Specify the reference method
used.  Spike each of 8 aliquots, described above, with
the pollutant of interest.  Select spike concentrations
so that the present spike recovery can be calculated
from the amount of spike added.  The chemical  compound,
selected to use as a spike material should assess the
complete proposed test procedure or be representative
of the chemical compounds or products of interest in the
industrial or municipal process of interest.  For example,
organic nitrogen or phosphorus compounds should be
selected as a spiking material for a Kjeldahl  nitrogen
or total phosphorus test procedure in order to include
assessment of the digestion steps.  Orthophosphate or
ammonia compounds would only assess suitability of the
final measurement step.  After spiking of the  waste
aliquots, determine the pollutant concentrations by
both the proposed method and by the reference  method
of choice.  Calculate percent recovery on the  basis of
the amount of spike added.  Specify the chemical
compound used as a spike material.

If it is expected that the average percent recovery
for the spike added will be between 95% and 105S, that
the chemical compound selected for spiking is  appropriate,
and that significant concentrations of the pollutant of
interest is present in the waste effluent aliquots, it
will be unnecessary to analyze spiked samples  by the
reference method.  If inadequate spike recovery by the
proposed method is obtained, spike recovery by the
reference method must be provided for comparative
purposes.

If it is expected that there will be undetectable
amounts of the pollutant present, either by the proposed
method or by the reference method in unspiked  samples,
then equivalency data must be provided using both
spiked and unspiked samples by the two test procedures.

Provide precision data for comparability of the two
methods, either by analyzing the above eight effluent
aliquots in duplicate by the two methods or by selecting
a single waste aliquot of representative and detectable
pollutant concentration and analyzing at least eight
replicate values by each method.

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                     45

  Tabulate the above date to  show equivalency  of  the
  proposed method with  a reference method,  comparability
  or adequacy of spike  recoveries and  comparability of  the
  two method's precision and  accuracy.   Each effluent
  aliquot selected for  comparability data  should  be
  uniquely identified and described as  to  appropriate
  NPDES Permit Number.   All data collected  during the
  comparability studies  must  be provided.   Provision of
  comparability data can not  be made on a  selective
  basis.

o For an NPDES discharger laboratory,  State laboratory,
  commercial laboratory, or U.S. EPA laboratory seeking
  approval for use of an alternate test procedure for a
  variety of NPDES permits, for all  NPDES  permits within
  a finite geographical  area  of EPA, Region V, or for all
  NPDES permits for specific  industrial or municipal
  categories in a finite geographical  area  of  EPA,
  Region V, comparability data will  be provided by the
  fol1owi ng protocol.

  Provide equivalency data, by both the proposed  and
  reference methods, using 15 to 25 aliquots.   The aliquots
  selected must be representative of the applicability
  specified above.

  Provide spike recovery data, as appropriate, for the
  above 15 to 25 aliquots. Specify the chemical  compound
  used as a spike material as discussed above.

  Provide precision data for  comparison purposes,
  either by analyzing the above 15 to  25 aliquots in
  duplicate by the two  methods, or by  providing eight or
  more replicate analyses of  at least  three or more  of  the
  15 to 25 aliquots by  the two methods.

  Tabulate all of the above data for comparative  purposes.

  Until or unless printed application  forms or a
  national U.S. EPA policy for a comparability data
  protocol is implemented, a  case-by-case NPDES alternate
  test procedure application  in Region V will  contain the
  above items.  It is impossible to specify a  comparability
  data protocol that is applicable in  all  situations.
  Applicants seeking a  case-by-case approval  are  encouraged

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                     46

  to contact the appropriate State  pollution  control  agency
  or the Quality Assurance Office,  Region  V,  EPA,  prior  to
  initiation of comparability studies  which do  not fit
  the protocols provided in above items.   Examples of this
  are proposed test procedures for  suspended  solids which
  do not allow spiking, pollutants  whose test procedure
  defines the pollutant (BOO, oil and  grease, suspended
  solids, fecal col1 form, etc.).  and alternative sample
  preservation techniques or holding times.   A  protocol
  for obtaining approval of an alternative preservation
  technique or holding time, for  limited applicability,
  1s described below.

  Requests are often made to monitor a certain
  parameter or pollutant in lieu  of a  pollutant specified
  by a NPDES permit (ex. - to monitor  chemical  oxygen
  demand to show BOD permit compliance, after a correlation
  factor has been established).   It is the policy  of  the
  Quality Assurance Office, Region  V,  not  to  process  these
  requests as alternate test procedure application.
  They should be processed as a request to modify  an  NPDES
  permit and should be directed to  the Enforcement Division,
  Region V.

Elements of an NPDES Alternative  Sample Preservation  or  Holding
Time Application on a Case-by-Case  Basis
NPDES alternate test procedure applications are applicable
to replacement of a preservation  technique or to extending
a holding time specified by a reference method  cited  by
40 CFR 136.  Applications for such  requests are made  to
the Regional Administrator in the Region where  the discharge(s)
occurs, through the Director of the State  agency having
authority to issue NPDES permits  within such  State.

An application should be made, in triplicate, to the  Regional
Administrator and shall:

o Provide the name, address and telephone  number of the  person,
   firm or public agency making the request.

o Identify the pollutant(s) for which  approval  is  sought.

o Specify the applicability of the  proposed test procedure -  i.e.,
  specific NPDES Permit Numbers.

o Provide present and future NPOES  effluent limitations  in
  concentration units.

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                     47

o Provide a justification for use  of the  proposed  preservation
  technique - ex.  - cost effectiveness.

o Provide a detailed description of the  proposed alternative
  preservation technique or holding time.   This is quite
  necessary since  final  approval can only be  given for  a
  documented test  procedure.   Suggested  formats for a
  detailed description can be found in,  "ASTM, Part 31",
  EPA's "Methods for Che'mical Analysis of Water and
  Wastes", and "Standard Methods".

o If available, cite references or provide copies  of published
  studies showing  the applicability of the proposed technique.

o Provide data, using sample aliquots or representative waste
  effluents (and untreated or raw  waste,  if appropriate),
  showing the proposed preservation technique or holding
  time yields results comparable in equivalency  (not
  biased against the approved technique)  and  in precision
  to the approved  preservation procedure.

o For a single NPDES permitted effluent,  provide comparability
  data by the following  protocol.

Select at least fifteen  different  effluent aliquots,
collected over a representative time period,  to provide varying
concentration levels of the pollutant of interest.

Each aliquot of waste should be split into four separate
sample bottles at  time of collection.

Two aliquots are to be analyzed by an approved test
procedure using the approved preservation technique. The
remaining two aliquots are to be analyzed, by the  same  test
procedure, using the proposed preservation technique or
holding time.  The test  procedure  is to  be specified.
If the proposed preservation technique uses an extended
holding time, then the maximum holding time,  specified
in the proposed preservation techniques  detailed test
procedure description, should be used.

Pollutant values should  be tabulated for each of the four
waste aliquots along with the corresponding dates  of sample
collection, dates  of analysis using the  proposed technique,
and dates of analysis using the approved  preservation technique.

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                                   48

              All  analysis  values  determined  should  be reported.  Data
              can  only be discarded on  the  basis  of  quality control audit
              or control  solution  values  showing  a specific set of analyses
              to be out-of-control.

              All  analyses, using  the two preservation techniques, should
              be performed  in a  single  laboratory using  a  single analytical
              methodology.

    d.   Section 106 of Public Law 92-500 Alternate  Test Procedure Program
         If approval of a NPQES  alternate test  procedure is given to
         to a State laboratory,  then approval will also  be given for
         remaining non-point source measurements  in  the  State's Section
         106 monitoring program, if so  requested. The NPDES alternate
         test procedure's working  concentration range should be appropriate
         for the needs of the Section 106 program.

         If a State requests approval of  an alternate test procedure  for
         non-NPDES monitoring, it  may do  so without  providing  complete
         comparability data so long as  a  documented  test procedure
         description is provided,  there are sufficient published studies
         provided  to demonstrate its utility, and/or there are sufficient
         intralaboratory quality control  data in  existence to  document
         its utility.  The  Regional  Administrator shall  determine the
         need for  additional comparability  data upon the recommendations
         of the Quality Assurance  Office, Region  V.

8.3.2.2  Elements  of an Application for a Safe  Drinking  Water  Act
         (SDWA) Alternate Test Procedure
         The National Interim Primary Drinking  Water Regulations (NIPOWR),
         40 CFR 141, implementing  the SDWA, specifies test procedures
         to use for NIPOWR  contaminants.  40 CFR  141.27  states that
         with the  approval, both of a  primacy State  and  of the EPA
         Administrator, a laboratory may  use  alternate test procedures.
         This authority has been delegated  to the Regional Administrator.

         A memorandum of March 10,  1977,  from the Ofice  of Water Supply
         (OWS), EPA, specifies the mechanisms for obtaining approval  of
         SDWA alternate test procedures.  Final approval is either
         given by  the Regional Administrator  on a case-by-case basis
         to specific water  utilities, and State,  Regional  EPA, and
         commercial laboratories or by  the  OWS  on a  nationwide basis.
         The alternate test procedures  for  nationwide use  should be
         published in the Federal  Register.

         The mechanism specified by the March 10th memo  is extramly
         cumbersome, but it does designate  who  has authority for final
         decision  making.

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                          49

The Regional  Administrator is responsible  for final  determination
of alternate test procedures  for approved  water utility,  State,
commercial, and Regional  EPA  laboratories.   EMSL-Cincinnati  and
OWS, both of EPA, are responsible for the  determination  of
alternate test procedures for nationwide use.   Alternate  test
procedures approved, as of September 1978,  for nationwide
use, are contained in two OWS memorandums  of September 1,
1977, and March 9, 1978 (Appendix 15)

If approval of an alternate test procedure has been  given by the
Regional Administrator on a case-by-case basis, to a private or
public laboratory for NPDES monitoring, approval  for monitoring
of the same pollutant as a SDWA contaminant will  also be
given by the Regional Administrator, upon  request, so long  as
the original  NPDES application clearly documents  the alternate
test procedure's working concentration range is applicable  to
measurement at the Maximum Contaminant Level  (M3L) specified
by the NIPDWR.

a.  SDWA Alternate Test Procedure for Nationwide  Use
    Contact the Director, Environmental Monitoring and Support
    Laboratory (EMSL)-Cincinnati, EPA, Cincinnati, Ohio
    45268, phone (513)684-7301 or phone FTS 684-7301, concerning
    the protocol for SDWA alternate test procedures  for  nationwide
    use.

b.  Elements of a SDWA Alternate Test Procedure Application
    on a Case-by-Case Basis
    Approval  of an alternate  test procedure can be requested
    by a water utility, public, or private laboratory that  has
    made application for, or  has, Interim  Laboratory Certification
    under an existing State or Federal SDWA laboratory approval
    program in Region V, EPA. '

    Application for use of an alternate test procedure,  on  a
    case-by-case basis, is made in quadruplicate  to  the  Regional
    Administrator, through the State water supply program for
    those State which have accepted primacy for the  SDWA.  In
    non-primacy States, application is made directly to  the
    Regional  Administrator.

    Until or unless printed application forms are made available
    from the U.S. EPA on a national basis,  a case-by-case
    application in Region V,  EPA shall:

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                     50

o Provide the name,  address and telephone  number of the
  responsible person making application.

o Identify the SDWA  contaminant(s)  for which  approval  is
  sought.

o Specify the applicability of the  proposed test procedure
  either for a specific utility, or utilities,  or for  a
  specific public agency or commerical  laboratory doing
  work for utilities.

o Provide a justification for use of the proposed method-
  ology instead of a reference methodology.

 "Provide a detailed description of the proposed test  pro-
  cedure.  See "ASTM, Part 31", EPA's "Methods  for Chemical
  Analysis of Water  and Wastes", or "Standard Methods",
  for suggested formats.

 "Provide data showing the proposed method yields results
  comparable in equivalency and precision  to  a  reference
  method or an alternate test procedure approved for
  nationwide use, in the concentration range  of the
  NIPOWR PCL.  Comparability data for 1 to 4  utilities,
  of equivalent water characteristics,  shall  be provided
  using the NPDES protocol for eight effluent aliquots.
  If approval is sought by a commercial or public agency
  laboratory for use for all utilities  in  a State, then
  the NPDES comparability data protocol using 15 to 25
  different water utility aliquots  should  be  utilized.
  Sample aliquots will have to be spiked,  at  or near the
  contaminant's NCL, and should be  measured by  both the
  proposed and approved methods. Organo arsenic and
  organo mercury compounds shall be used as spiking
  compounds for these two contaminants, because their
  reference methods  contain specific digestion  procedures.
  For a wide applicability, sample  aliquots,  selected
  for comparability  measurements must be a wide cross-section
  of the potable water in a State.

o Provide the proposed method's detection  limit and precision
  at the contaminant's MCL.  The terms  detection limit and
  precision shall be defined by the applicant.

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                                   51

8.3.2.3  Processing of Case-by-Case Alternate  Test  Procedure  in Region V
         T.A NPDES discharger,  water utility,  or  laboratory should
             make application in  triplicate, for use  of a  case-by-case
             alternate test procedure, to  the  Regional  Administrator,
             through the responsible State authorities  having authority
             to enforce the National  Pollutant Discharge Elimination
             System (NPDES) program or the Safe  Drinking Water Act
             (SDWA).  An extra application copy  is  provided State
             authorities.  If the State does not have appropriate
             enforcement authority, then application  is made, in triplicate,
             directly to the Regional  Administrator.

         b.  Application for nationwide use of an NPDES or SDWA
             alternate test procedure is made  directly  to  the Director,
             EMSL-Cincinnati, EPA, Cincinnati, Ohio 45268, in accordance
             with EMSL-Cincinnati's protocols.

         c.  For a case-by-case application, the State  authorities
             will forward three copies of  the  application  to  the Regional
             Administrator with the States'  recommendations.   The
             regulations specify  the State agency Director shall
             forward this application to the Regional Administrator.
             Guidance from the Office of Water Supply (OWS),  EPA,
             specifies this shall be done  by an  appropriate State Official.

         d.  Upon receipt of the  application with State recommendations,
             (when the application is applicable to a State with delegated
             enforcement responsibility),  the  Regional  Administrator
             will forward the application, in  triplicate,  to  the Quality
             Assurance Office (QAO), Region V, for  processing.  Upon
             receipt of the application, the QAO, Region V, will acknowledge
             receipt of the application- to the applicant.  This starts
             the time cycle for action on  the  request so that a final
             determination on the request  can  be made within  90 days
             by the Regional Administrator.

         e.  If a State with enforcement responsibility for the SDWA
             or NPDES program recommends disapproval  of the proposed
             test procedure, the  Regional  Administrator shall deny  the
             application.  Copies of this  disapproval will be sent  to
             the appropriate State agency  and  to its  State Laboratory
             Director, to the Director, EMSL-Cincinnati, and  in the
             case of SDWA applications to  the  Office  of Water Supply
             (OWS), EPA.

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                          52

f.  The QAO will  review the application for the  following:

    o A clear understanding of the applicability of the  proposed
      test procedure.

    o A test procedure documented in sufficient  detail that  another
      laboratory could reproduce the results of  the applicant's
      laboratory.

    o Comparability data in sufficient quantity  and consistency with
      the proposed applicability of the alternate test  procedure.

    o Consistency with the data quality needs of the SDWA, NPOES
      program, and other monitoring programs as  appropriate.

    If any of the four elements are missing, the QAO will  request
    the necessary information from the applicant within  one
    month of receipt of the application.  When the applicant
    provides this information to the QAO, a new  90 day  cycle
    will be initiated.

g.  If the application is complete, the QAO will forward a
    copy to the Director, EMSL-Cincinnati for his technical
    review and recommendations, within two weeks of receipt
    of the alternate test procedure application.

h.  At the discretion of the QAO, a copy of the  application
    will be forwarded to the Water Supply Branch, Region V,
    or to the Enforcement Division, Region V, for their recom-
    mendations, if program policies are affected by either
    approval or disapproval of the application.

i.  Within the 90 day time period, the QAO will  receive  all
    appropriate recommendations and prepare a letter for the
    Regional Administrator's signature to notify the applicant
    of approval of rejection, and in some instances specify
    the additional information which is required to deteremine
    whether to approve the.proposed test procedure.  Copies
    of this final determination by the Regional  Admim'strtor
    shall be forwarded to appropriate Regional and State
    program personnel, to the State Laboratory Director(s)
    of the concerned State(s), to the Director,  EMSL-Cincinnati,
    and in the case of SDWA approvals, to the Director,  OWS.
    The QAO will prepare the final determination letter for
    the Regional Administrator so that this determination
    reflects final authority by the Region and is consistent
    with broad national EPA policies.

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                                   53

8.3.2.4  Procedures for Equivalent Test Prodcedure Under the Clean Air Act
         Methods required by the Clean Air Act are designated as  Reference
         of Equivalent Methods according to 40 CFR 53.1.  The use of
         methods which are not so designated must be approved by  Depart-
         ment E, EMSk-RTP.  Procedures for obtaining approval of  a
         non-designated method are described in 40 CFR 53.4 and 40 CFR
         53.14, respectively.  These procedures require that any  user
     i    modifications which are not reference or equivalence must be
         approved by Department E, EMSL-RTP.

     8.4 Instrumentation
         All monitoring equipment and instrumentation pruchased within
         Region V with EPA grant, contract, inter-agency agreement, or
         operation funds are to be evaluated and recommended for  approval
         or rejection by the QAO.  For external monitoring projects,
         including 201 grants used to purchase monitoring equipment,
         the Project Officer will submit the equipment or instrumentation
         request and any justifications to the QAO through appropriate
         channels for review.  Internal office Directors and Branch
         Chiefs (Region V) will submit their proposals and justifications
         through the appropriate Division/ Office Director to the QAO
         through the Surveillance and Analysis Director for review.
         As part of the evaluation and approval process the following
         minimum points are considered.

         o Is there a need, present or future for the item, i.e., does
           present or projected regulations specify tests that this equip-
           ment will be used for.

         o Does the purchaser have equipment in-house that can be
           modified or adapted to perform the necessary function  at a
           less*er cost.

         o Will the purchaser have the necessary auxiliary in-put,
           eg., if G.C. - Mass spectroscopy unit is requested,  will
           library facilities be available.

         o Are there technically competent personnel available to
           operate the equipment.  If not, what plans are available for
           hiring or training such personnel.

         The QAO will forward an official recommendation of approval
         for funding/purchase or a recommendation for not funding/purchase
         to the appropriate project officer, Division/Office Directory
         through appropriate channels.  In the case of xiot recommending
         funding/puchase a justification is also provided.

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                               54

8.5  Calibration and Standards
     Calibration procedures require the application  of primary  or
     secondary standards.   The  standards used,  whether they  are
     apparatus or reagent  standards are to  be certified as being
     traceable to standards of  the National  Bureau of  Standards,
     or other recognized fundamental  standard.   This type of trace-
     ability is possible when standards are generated  in the laboratory.
     Regardless of the type of  calibration  equipment or material,
     an effective QA program requires accuracy  levels  of these
     materials that are consistent with the method of  analysis.
     The calibration policies and procedures outlined  in 8.5 apply
     to all measuring and  test  equipment/instrument  associated
     with a monitoring activity,  including:

     o Sampling equipment  at sampling stations

     o Analytical equipment/instruments in  the  laboratory

     o Flow measuring devices (eg., current meters,  rotameters),
       volume (eg., dry gas meters),  pressure,  vacuum  and temperature
       measurement equipment at the sampling station and in  the laboratory.

     As part of a monitoring activity's (Federal, State, local
     agency, contractor or grantee) QA program  a written step-by-step
     procedure for a frequency  for calibration  of measuring  and test
     equipment/instruments and  use of calibration standards  is  to be
     provided, in order to eliminate possible measurement inaccuracies
     due to difference in  techniques, environmental  conditions, choice
     of higher level standards  and compliance with Agency regulations
     (eg., 40 CFR Part 58, Appendix A and B).   As a  minimum, these
     procedures are to include  the following:

     1.  The specific equipment or group of equipment  (instruments)
         to which the procedure is applieatable.  Equipment  of
         the same type, having  compatable calibration  points,
         environmental conditions, and accuracy requirements, may be
         serviced by the same calibration procedure.

     2.  A brief description of the scope,  principle,  and/or
         theory of the calibration method.

     3.  Fundamental calibration  specification, such as calibration
         points, environmental  requirements, and accuracy requirements.

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                               55

     4.  A list of calibration standards and accessory equipment
         required to peform an effective calibration.   Manufacturer's
         name, model number, and accuracy should be included as
         applicable.

     5.  A complete procedure for calibration arranged in a
         step-by-step manner, clearly and concisely written.

     6.  Calibration procedures are to provide specific
         instructions for obtaining and recording the  test data,
         and include data sheets that are to be used.

     7.  A detailed documented sample of computations  for any
         calibration procedure that requires statistical  analysis of
         results.

     8.  All field and laboratory calibration are to be traceable
         through an unbroken chain (supported by reports  or data
         sheets) to some ultimate or national reference standard.

     9.  An up-to date- report for each calibration standrd used  in
         the calibration system is to be made available for review
         during the QAO's audit or on-site system evaluation of
         any monitoring activity in Region V, funded by EPA.

     All equipment past due for calibration should be  removed
     from service either physically or, if this is impractical, should be
     impounded by tagging or other means.

     The monitoring activity's quality control  official  or other
     individual delegated quality control responsibility  (e.g., Lab-
     oratory Section Chief) has day-to-day responsibility to ensure
     that the monitoring activity maintains the required  accuracy
     in the calibration program.

     The QAO will evaluate the monitoring activity's on going
     calibration and standards activity as part of the audit and  on-site
     evaluation process to ensure valid data is being  .produced.   Problems
     will be identified and recommendations for corrective action provided.
     The QAO cannot validate data that is suspect.  Follow-up to  validate
     and approve correction actions will be QAO's responsibility.

8.6  Preventive Maintenance and Inspections
     As defined here, preventive maintenance is an orderly program
     of positive actions (equipment cleaning, lubricating, reconditioning,

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                           56

adjustment and/or testing) for preventing failure of monitoring
systems OP parts thereof during use.  The most important effect
a good preventive maintenance program has is to increase measure-
ment system reliability and thus increase data completeness.
Conversely, a poor preventive maintenance program will  result
in increased measurement system downtime (i.e., decrease in
data completeness) and in increased unscheduled maintenance
costs; and may cause distrust in the validity of the data.   In
ambient air monitoring, data completeness criteria are used to
validate data.

A responsible individual (i.e., field section Chief, laboratory
Section Chief, (£ Officer) is required to prepare and implement
a preventive maintenance schedule for all equipment and measuring
systems, as part of the monitoring activity's total QC  program.
The planning required to prepare the preventive maintenance
schedule will have the effect of:

1.   Highlighting that equipment or those parts therof that are
     most likely to fail without proper preventive maintenance.

2.   Defining a spare parts inventory that should be maintained
     to replace worn-out parts with a minimum of downtime.

A specific preventive maintenance schedule is to relate to  the
purpose of testing, environmental influences, physical  location
of equipment, and the level of analyst skills.  Checklists  are
to be used as documentation for listing specific maintenance
tasks and frequency (time interval between maintenance).  In
some instances, if calibration tasks are difficult to separate
from preventive maintenance tasks, a combined preventive
maintenance - calibration schedule is advisable.

A record of all preventive maintenance and daily service checks
are to be maintained.  An acceptable practice to follow for
recording completion of task is to maintain a preventive maintenance
calibration multiple copy log book.  After tasks have been  completed
and entered in the log book, a replicate copy of each task  is
removed by the individual performing the maintenance -  calibration
task and forwarded to the appropriate supervisor and QC Officer
for review and conformance with monitoring activity's preventive
maintenance protocol.  The log book is stored by the instrument
for future reference.  The QAO will review these log books
during the audit or on-site systems evaluation activity for
deficiencies.

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                                  57

  8.7  Quality Control  Procedures
       Assuming that all  basic variables  pertaining  to  laboratory
       services (i.e.,  instrumentation, glassware,  reagents,  solvents,
       gases, etc.)  are under control, that  approved methods  are being
       used, and the complete system  is initially under quality control,
       valid precision  and accuracy data  must  initially be  developed
       for each method  and analyst.   Then, to  insure that valid data
       continue to be produced, systematic daily checks must  show that
       the test results remain reproducible, and that the methodology
       is actually measuring the quantity in each sample.   In addition,
       quality control  must begin  with sample  collection and  must not
       end until the resulting data have  been  reported. Quality control
       of analytical performance within the  laboratory  is thus but  one
       vital link in generation and dissemination of valid  data for
       agency use.  Understanding  and conscientious  use of  quality
       control among all  field sampling personnel,  analytical  personnel,
       and management personnel is imperative.  Region  V's  procedures
       are outlined in  the following  Sections  (8.7.1 and 8.7.2).
       Management of QC procedures (how and  by whom) is described in
       Section 10.2.

8.7.1  Intra-Laboratory Quality Control Procedures
       The purpose of 1ntralaboratory QC  programs is to identify the
       sources of measurement error and to estimate  their bias (accuracy)
       and variability (repeatability and replicability).   For manual
       measurement methods, bias and  variability are determined separately
       for sample collection and analysis and  are combined  for determination
       of total method  bias and variability.  For continuous  methods,
       total method bias and variability  are determined directly.
       Some of the potential error sources are the  operator or analyst,
       equipment, the calibration, and the operating conditions.  The
       results may be analyzed by making  comparisons against  each
       other and/or against reference standards.  To maintain a known
       level of competence in daily activities, quality control must
       be implemented in the field and at the  bench, using  a  system of
       checks to determine the accuracy and  precision of results and
       the performance  of measurement systems  and operators.   Intra-
       1aboratory quality control  is  a continuing activity  to insure
       the output of data of known quality.  The specific objectives
       are to devise a  program that:

       o measures and control the  precision  of procedures and instruments.

       o measures and control the  accuracy of  analytical results.

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                           58

o documents, on a continuous basis, the performance of systems
  analysts and operators.

o establishes training needs.

o identifies weak measurement methodology and provides feedback
  to the Quality Assurance Office, where an evaluation can be
  made of the findings and the appropriate EMSL group notified
  so method revisions and/or modifications can be made.

In Region V quality control charts are to be the foundation
of the laboratory's 1nterlaboratory quality control programs.
One form of quality control showing trends is the summation of
the differences squared for replicate samples.  Additional
control charts are recommended where standard deviations are
(d * Vd2/k) for use on a daily basis to establish rapidly if
an analysis is out of control on a given day.  Once precision
and accuracy data are available on the method and the operator/
analyst, systematic daily checks are necessary to ensure that
valid data are being generated.  From these daily precision and
accuracy data, quality control charts can be constructed and
maintained to determine when the method used is producing valid
data, when the data are questionable, or when a trend is detected
which must be investigated and corrected.

Several techniques are available for constructing quality control
charts and plotting subsequent data.  The two techniques currently
used by EPA are the Shewhart technique and/or Cumulative-Summation
technique.  These techniques are depicted in (EPA Publications)
EPA-60Q/4-79-019, Handbook for Analytical Quality Control in Water
and Wastewater Laboratories, March 1979, and Quality Assurance
Handbook for Air Pollution Measurement Systems, Volume I
(EPA-600/9-005), Volume II (EPA-600/4-77-0272a) and Volume III
(EPA-660/4-77-027b).  For both techniques, precision control
charts are constructed from duplicate sample analyses, and
accuracy control charts are constructed from spiked sample
analysis, utilizing standard reference materials (SRM).   SRM's
are substances which qualify as absolute quantities against
which other like substances can be calibrated or measured.  The
SRM, typically produced by organizations like the National
Bureau of Standards (NBS), is used to prepare standard reference
standards (SRS) for routine laboratory and field use.

SRS (also referred to as spiked samples) are preparations of known
amounts of standard reference materials added to an actual environ-
mental samples which has been previously analysed.   The  amount
of the substance found in the sample is a "true" indication of

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                           59

the accuracy of the method for a given  measurement.   The  use  of
the standard reference samples measures the  extent  of interferences
which cannot be obviated.

Following normal  procedures,  the control  chart  must  indicate
the conditions under which it was developed;  i.e.,  laboratory name,
parameter, method of analysis, date of  preparation,  and any other
information unique to the  initializing  data  such  as  range of
concentration and identification of analyst(s)/operator.   A
control chart is not generally applicable under other conditions.

To verify the accuracy and precision of control  charts, the
initializing data should be checked to  be sure  that  none  of the
values exceeds these new control limits.   In  addition, if its
distribution is proper, about 68 percent  of  the initializing
data should fall  within the interval average  percent recovery
plus or minus 2 times the  standard deviation  for percent  recovery.
There is a question of validity of the  control  chart if less
than 50% of the initializing data falls within  this  interval.

In application of the accuracy control  chart, either of the
following two conditions indicates an out-of-control situation.

a.  Any point beyond the control limits.

b.  Seven successive points on the same side  of the  interval
    average percent recovery of the central  line of  the
    completed control chart.

When an out-of-control situation occurs,  analyses shall be stopped
until the problem has been identified and resolved,  after which  the
frequency should be increased.for the next few  percent recovery  QC
checks.  The problem and its  solution must be documented, and all
analyses since the last in-control point  must be repeated or  discarded.

For some parameters it may be necessary to construct low  level and
moderate to high level accuracy QC charts for each  standardization
concentration level sample.

In application of the precision control chart,  the  chart  should
be updated periodically as additional,  or more  current, data
become available, or whenever the basic analytical  system undergoes
a major change.  If any difference between duplicate analyses
exceeds the critical-range value for the appropriate concentration
level, then analyses should be stopped  until  the problem  is
identified and resolved, and  the frequency is to be  increased

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                           60

for the next few precision checks.  After resolution, the problem
and its solution must be documented, and all  analyses since the
last in-control check must be repeated or discarded.

Once the quality control charts have been developed and put in
pi ace, the normal day to day worki ng routi ne requi res the fol1owi ng:

o A new standard curve should be established with each new
  batch of reagents, using at least seven concentration levels.
  The number of level in continuous monitors is 3 levels within
  range.

o With each batch of analyses (10 to 20% of the time), the
  following tests are to be run:

  1. One blank on water and reagents.

  2. One midpoint standard.

  3. One standard reference standard (spike)  to determine
     recovery.

  4. One set of duplicate analysis.

The results from 2 through 4 are to be compared with  previous
in-control data by using the protocol specified above (for a
detailed protocol description refer to Section 6.3 of Chapter 6
of EPA Publication 600/4-79-019).

The following protocol is to be implemented to indisputably
establish the validity of data for each parameter from water
and wastewater projects:

In the following protocol the symbols used represent  the
results of analysis according to the scheme:

     AI a first replicate of sample A

     Ag » second replicate of sample A

      8 3 sample taken simultaneously with sample A

    8$p » field spike into sample B

          laboratory spike into sample B

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                           61

    Dp = field spike into distilled water

    DL - labortory spike into distilled water

     T = true value for all spikes

The laboratory spikes B$L and D|_ are the only analyses that may
not be necessary.   All other analyses must be done simultaneously.

Field personnel should perform the following steps for quality
assurance.

a.  Take independent simultaneous samples A and B at the same
    sampling point.  Depending on the parameter, this might
    involve side-by-side grab samples or composite samplers
    mounted in parallel.

b.  Split sample A into the equal-volume samples AI and fy.

c.  Split sample B into equal volumes and add a spike T to
    one of them; the latter sample becomes sample B$p..
    As with all spikes, the addition of T should approximately
    double the anticipated concentration level.

d.  Add the same spike T to a distilled water sample furnished
    by the alboratory and designate this sample as Dp.

These QC samples must be treated in the same way as 'routine
samples; i.e., the volume, type of container, preservation,
labeling, and transportation must be same for all.

The laboratory pesonnel should perform the following steps for
quality assurance:

a.  Analyze the blank and midpoint standard recommended in
    the normal day-to-day working routine.  If results are
    unsatisfactory, resolve problems before continuing.

b.  Analyze sample Dp.  If the percent recovery of T is
    unsatisfactory (see accuracy protocol), create a
    similarly spiked, distilled-water sample Dj_ and analyze
    to test for a systematic error in the laboratory or
    fundamental problems with the spike.  If the percent
    recovery of T from D[_ is satisfactory, any systematic
    error occurred before the samples reached the laboratory.

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                           62

c.  Analyze samples B and B$p.   If B  is  below the  detection
    limit, or if B is greater than 10T or less and O.IT,
    disregard the remainder of this step and  proceed  to
    step d.  If the percent recovery of  T from B$p is
    unsatisfactory (see accuracy protocol), spike  an  aliquot
    of sample B the same way in the laboratory so  that a
    similar recovery can be anticipated.  Analyse  this sample
    8$L t° test f°r immediate sample interferences or a
    bad background result B.  If the percent  recovery from
    B$i  fs satisfactory, then the interference must require
    a longer delay before analyses, or other  special  conditions
    not present in the laboratory, in order to have a
    noticeable effect upon recovery of the spike.

d.  Analyze Aj and A2«  If the absolute  (unsigned) difference
    between these results exceeds the critical  value  (see
    precision protocol), then test of precision is out of control.

e*  Calculate the absolute difference between Ai and  B.   If
    1t is unsatisfactory (see precision  protocol), the field
    sampling procedure did not provide representative samples.

If initial results at each of the laboratory  steps were  satisfac-
tory, then the validity of the related data has been  indisputably
established.  If results at any step are unsatisfactory,  resolution
depends upon the problem identified.   Laboratory problems may
just require that the analyses be repeated, but field problems
will usually require new samples.  Figure 8.7.1 is intended to
clarify the interdependence of the preceeding laboratory  steps
b through e.

In figure 8.7.1 it must be noted that there is no  way to  identify
additive sample interferences; i.e., those that have  an  equal effect
upon the background-plus-spike results (B$p or B$L) and  the background
result B.  Recovery of a spike will not  show  such  interferences.

Problems causing systematic errors that  may occur  in  the  field
include the following:

a.  Contaminated preservative, distilled water, or containers

b.  Contamination by sampling personnel

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       NO
                      100DF/T WITHIN QC LIMITS?
                                        YES
 100DL/T WITHIN OC  LIMITS?
     Yes
1
                         B10T?
No
SYSTEMATIC
ERROR IN
THE FIELD
    SYSTEMATIC
    ERROR IN THE
    LABORATORY
    OR BAD SPIKES
                           Yes
    No
                       Al  -   2
                       WITHIN QC
                       LIMITS?
                                            Yes
100(BSF - B)/T
WITHIN QC LIMITS?
                                          A!  -  B
                                          WITHIN  QC
                                          LIMITS?
                                        No
                                              No
                                            EXCESSIVE
                                            DEVIATION
                                            BETWEEN
                                            REPLICATE
                                            ANALYSES
                                                            No
                                                                           100(BL  -  B)/T
                                                                           WITHIN  QC  LIMITS?
                                                               No
                                                                                Yes
                      EXCESSIVE DEVIATION
                      BETWEEN SUMULTANEOUS
                      SAMPLES
                                          IMMEDIATE MULTIPLICATIVE]
                                          SAMPLE INTERFERENCES
                                          OR BAD B/tKGROUND RESULT]
                                                              MULTIPLICATIVE SAMPLE  INTERFERENCES
                                                              THAT REQUIRE A LONG TIME  PERIOD
                                                              OR SPECIAL CONDITIONS  TO  HAVE  A
                                                              NOTICEABLE EFFECT UPON RECOVERY
                                                              OF THE SPIKE
                       Figure 8.7.1  Procedure for evaluating QC  data from a monitoring study.

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                                    63

         c.  Deterioration through excessive holding time or use of an
             ineffectual  preservation technique

         d.  Use of,a bad field spiking procedure

8.7.1.2  Intra-Field Quality Control  Procedures
         Quality control  programs for sampling equipment and for field
         measurement procedures (of such parameters  as temperature,
         dissolved oxygen, pH and conductance) are necessary to insure
         data of the highest quality.  A field quality control  program
         administered by a quality assurance coordinator should contain
         the following documented elements:

         a.  The analytical methodology; the special sample handling
             procedures;  and the precision,  accuracy, and detection
             limits of all analytical methods used.

         b.  The basis for selection of analytical and sampling
             methodology.  For example, all  analytical methodology
             for NPDES permits shall  be that specified by the Agency
             or shall consist of approved alternative test procedures.
             Where methodology does not exist, the quality assurance
             plan should state how the new method will be documented,
             justified, and approved for use.
          •
         c.  The amount of analyses for quality control  expressed as
             a percentage of overall  analyses, to assess the validity
             of data.  The complete quality  control  program is  to
             specify 5% as a minimum for time assigned to field QC.
             The plan should include a shifting of these allocations
             or a decrease in the allocations depending upon the degree
             of confidence established"for collected data.

         d.  Procedures for the recording, processing, and reporting
             of data; procedures for review  of data  and invalidation
             of data based upon QC results.

         e.  Procedures for calibration and  maintenance of field
             instruments  and automatic samplers.
         f.  A performance evaluation system, administered through the
             quality assurance coordinator,  allowing field sampling
             personnel to cover the following areas:

             (1)  Qualifications of field personnel  for a particular
                  sampling situation.

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                           64

    (2)  Determination of the best representative  sampling
         site.

    (3)  Sampling technique including  location  of  the  points
         of sampling within the body of water,  the choice of
         grab or composite sampling, the type of automatic
         sampler, special  handling procedures,  sample
         preservation, and sample identification.

    (4)  Flow measurement, where applicable.

    (5)  Completeness of data, data recording,  processing,
         and reporting.

    (6)  Calibration and maintenance of field instruments and
         equipment.

    (7)  The use of QC samples such as duplicate,  split, or
         spiked samples to assess the  validity  of  data.

g.  Training of all  personnel involved in any function
    affecting the data quality.

Quality assurance in sample collection is to be implemented to
minimize such common errors as improper sampling methodology,
poor sample preservation,  and lack of  adequate  mixing  during
compositing and testing.

At selected stations, on a random time frame, duplicate  samples  are
collected from two sets of field equipment installed at  the site,
or duplicate grab samples  are collected.  This  provides  a check
of sampling equipment and  technique for precision.

A representative subsample from the collected sample is  removed
and both are analyzed for the pollutants of interest.  The  samples
may be reanalyzed by the same laboratory or analyzed by  two
different laboratories for a check of  the analytical procedures.

Known amounts of a particular constituent are added in the  field to
an actual sample or to blanks of deionized water at concentrations
at which the accuracy of the test method is satisfactory.   The
amount added and frequency is coordinated with  the laboratory.
This method provides a proficiency check for accuracy  of the
analytical procedures.

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                                    65

         Acids and  chemical  preservatives  can  become  contaminated after a
         period of  use in the  field.  The  sampler  should  add the same
         quantity of preservative  to some  distilled water as normally
         would be added to a wastewater  sample.  This preservative blank
         is sent to the laboratory for analysis of the same parameters
         that are measured in  the  sample and values for the blank are
         then subtracted from  the  sample values.   Liquid  chemical
         preservatives should  be changed every 2 weeks, or sooner,
         if contamination increases above  predetermined levels.

         A minimum  of seven sets each of comparative  data for duplicates,
         spikes, split samples, and blanks should  be  collected to define
         acceptable estimates  of precision and accuracy criteria for data
         validation of field parameters.

         Protocol is to be developed and implemented  for  calibrating all
         field analysis test equipment and calibration standards to include
         the following: (a)  calibration  and maintenance intervals, (b) listing
         of required calibration standards, (c) environmental conditions
         requiring  calibration, and (d)  a  documented  record system.
         Written calibration procedures  should be  documented and should
         include mention of the following:

         a.  To what tests the procedure is applicable.

         b.  A brief description.of the  calibration procedure.

         c.  A listing of the  calibration  standard, the reagents, and
             any accessory equipment required.

         d.  Provisions for indicating that the field equipment is
             labeled and contains  the calibration  expiration date.

8.7.1.3  Additional Intralaboratory Quality Control Procedures for
         Specific Groups of Parameters

         a.   Microbiology intralaboratory quality control.
              A quality assurance  program  for  microbiological analyses must
              emphasize the control of laboratory  operations and analytical
              procedures because the tests measure living organisms that
              continually change in response to their environment.
              Further, because true values cannot  be  provided for the
              microbial parameters, microbiologists do not yet have the
              advantages of analytical standards,  QC  charts, and spiked
              samples available to other disci plies for measurement of

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                           66

     accuracy.   Because known  values  cannot be  applied, it  is
     important  that  careful  and  continuous control be exerted
     over sampling,  personnel, analytical methodology, materials,
     supplies,  and equipment.

     A documented inter!aboratory  QC  is to address the following
     areas as a minimum:

     o An Operating  Manual  shall be prepared which describes the
       sampling techniques,  analytical methods,  laboratory  operations,
       maintenance and quality control procedures.  Specific details
       are given on  all procedures and quality  control checks made
       on materials, supplies, equipment, instrumentation and
       facilities.   The frequency  of  the checks, the person
     •  responsible for each  check  (with necessary back-up assignments)
       the review mechanism in the QC program to be followed, the
       frequency of  the review and the corrective actions to be
       taken are specified.  A copy is provided to each analyst.

     Part V of EPA Publication EPA-600/8-78-017  describes the
     normal day-to-day microbiology interlaboratory QC routine,
     to be implemented by Region V microbiology laboratories.
     A record is to  be maintained  of  the daily  QC checks and
     procedures.  If there is  no proof of performance, and
     evidence for future  reference, for practical purposes,
     no QC program is in  operation.

     o A Sample Log  shall be maintained which records,
       chronologically, information on sample identification
       and origin, the necessary chain of custody information,
       and analyses  performed.

     o A Written Record shall  also be maintained of all analytical
       QC checks: positive and negative culture controls, sterility
       checks,  replicate  analyses  by  an analyst, comparative data
       between analysts,  use-test  results of media, membrane
       filters  and laboratory  pure water, replicate analyses done
       to establish  precision  of analysts, or of methodology used
       to determine  non-compliance with bacterial limits established
       by Agency regulations.

b.   Aquatic Biology Interlaboratory  Quality Control
     Inter!aboratory QC procedures for aquatic  biology programs
     are fully described  in EPA  Publication, EPA-679/4-73-001.

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                       67

 An operating manual  shall  be prepared,  addressing  the
 following essential  elements as  a  minimum:

 1.   An understanding and  acceptance  of the  importance
      of quality control  (QC) and a commitment  on the
      part of the biology staff to  fully integrate  QC
      practices into  field  and laboratory operations.

 2.   Staff needs with adequate formal  training and
      experience and  proper specialization to meet
      program needs.

 3.   Adequate field  equipment, storage and laboratory space,
      instrumentation, and  taxonomic references.

 4.   Protocol for preparation and  design of  field  and
      laboratory studies.

 5.   Documentation of approved methodology,  where  available,
      and protocol  for consideration of the tehcnical
      defensibility of the  methods  and their  application.

 6.   Protocol for use of  replication  in sample collection
      and analyses where feasible,  and determination of  the
      accuracy and precision of the data.

 7.   Protocol for frequent calibration of field and
      laboratory instruments.

 8.   Protocol for proper  sample  identification and handling
      to prevent mi sidentification  or intermixing of samples.

 9.   Protocol for blind, split,  or other control samples
      to evaluate performance.

10.   Procedures for  development  and regular  use of in-house
      reference specimen collections,  and use of outside
      taxonomic experts to  confirm  or provide identifications
      for problem specimens.

11.   Procedures for  meticulous,  dual-level review  of the
      results of manual arithmetical data manipulations  and
      transcriptions  before the data are used in reports
      or placed in BIO-STORET.

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                         68

,  Organic Chemistry Interlaboratory Quality Control
  Most  of the quality control program described above in
  Section 8.7 of this document cannot easily be adapted to
  the methods for organic compounds.  Therefore, the Agency
  .has developed a series of tests and protocols whose purpose
  is to describe the performance of the computerized gas
  chromatography - mass spectrometry systems and the analysts(s).
  The complete protocol procedure is listed in Appendix 16.
  A summary of these performance tests follows:

  I.  Spectrum Validation Test - Uses decafluorotriphenyl
      phosphine (DFTPP) to deteremine whether the system gives
      a 70 ev electron ionization fragmentation pattern similar
      to that found in the historical mass spectrometry data
      base, and the required mass resolution and natural
      abundance isotope patterns.  The spectrum of DFTPP must
      meet the criteria given in Table 2 of Appendix 16.

  II.  System Stability Test - Uses DFTPP to test moderate term
      (20-28 hours) system stability.  The criteria given in
      Test I must be met.

 III.  Instrument Detection Limit Test - Uses DFTPP to measure the
      full and valid spectrum detection limit at a defined and
      tolerable noise level.  At a signal/noise » 5, the
      required instrument detection limits are 50 nanograms
      for systems used in the anlaysis of industrial or municipal
      wastes, and 30 nanograms for systems used in the analysis
      for ambient or drinking water.

  IV.  Saturation Recovery Test - Uses DFTPP and jj-bromobiphenyl
      to simulate a frequently encountered situation with
      real samples.  The spectrum of DFTPP, measured within
      two minutes after the elution of a 250 fold excess of
      j>bromobiphenyl, must not contain significant contributions
      from the ions attributable to jj-bromobiphenyl.

  V.  Precision Test - Uses a variety of typical environmental
      pollutants to determine precision from filling a syringe
      to peak integration.  The mean relative standard deviation
      for the compounds used in the test which elute as narrow
      peaks must be 7% or less using either peak areas in
      arbitrary units or ratios of peak areas.  For broad
      peaks the mean relative standard deviation must be 13%
      or less.

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                          69

  VI.  Library Search Test - Uses data  from Test  V  to  evaluate  the
       speed and completeness of the minicomputer library  search
       algorithm.  The mean search time,  including  background
       subtraction, must be one minute  or less,  and all  test
       compounds must be identified as  most probable except
       isomers with very similar spectra  should  not be counted
       as incorrect.
                                              •
 VII.  Quantitative Analysis with Liquid-Liquid  Extraction - Uses
       a variety of environmental pollutants to  measure quantitative
       accuracy and precision of the total  analytical  method.
       The mean of the means of the percentages  of the true
       values observed must be in the 68-132% range with a
       mean relative standard deviation of 38% or less using
       either internal or external standards. This test also
       evaluates laboratory performance.             .   -

VIII.  Quantitative Analysis with Inert Gas Purge and  Trap - Uses a
       variety of compounds to measure  quantitative accuracy and
       precision of the total analytical  method.   The  mean of   -
       the mean method efficiencies must  be 70%  or more.
       Chloroform efficiency must exceed  90% and all compounds
       must exceed 30% efficiency.  The spectrum of jj-bromofluoro-
       benzene must meet the criteria given in Table 7,  Appendix 16.
       The mean of the means of the percentages  of the true
       values observed must be in the range of 90-110% with a
       mean relative standard deviation of 19% or less using
       either internal or external standards.

  IX.  Qualitative Analysis with Real Samples -  Uses a real sample
       to evaluate the ability of the system to  deal with  real  sample
       matrix effects and interferences.   All compounds must
       be correctly identified except isomers with  nearly
       identical mass spectra should not  be counted as incorrect.
       This test also evaluates laboratory performance.

   X.  Solid Probe Inlet System Test (Optional)  - Uses cholesterol
       to evaluate the spectrum validity  achievable with a
       solid probe inlet system.  The spectrum of cholesterol
       must meet the criteria given in  step three of the test.

   The performance tests are intended for use in  the evaluation
   of the system initially and on a long  term basis.  All
   tests are to be initially performed  with correction being

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                       70

made to meet the criteria established in Appendix 16  for
the respective test.   The results and corrections are to be
documented.

Test I performance is to be revalidated on a daily basis.
Test IV, V, VII, VIII, and IX performance are to be revalidated
on a specified frequency identified in the documented intra-
laboratory QC protocol.

The normal day-to-day QC routine is divided into three separate
categories.  Data generated from each category is documented.
Problems identified must be corrected and documented.  When
out of control situations occur, analyses shall  be stopped
until the problem has been identified and resolved.

The first category represents the determination of purgeable
compounds.  This determination is performed in a closed
analytical system; the complete analysis can be performed
in 1 h; and the number of theoretically possible interferences
is somewhat limited.   The second category represents  liquid/liquid
partition methods in a regulatory situation.  Here a  very
limited number of compounds are being measured;  there is a
high occurrence of positive results; and it is important to
establish that the method works satisfactorily on the particular
sample matrix.  The third category represents liquid/liquid
partition methods in a monitoring situation.  Here a  large
number of compounds are often being measured simultaneously;
there is a low occurrence of positive results; and each sample
matrix may be different.  Quality assurance is aimed  at
establishing that the laboratory is using the method  correctly.

The purgeable methods are unique among organic methods because
the standards are treated in exactly the same way as  the samples,
and there is no inherent method bias.  The methods are amendable
to a variety of quality assurance programs.  The approach
that has been found applicable to all types of samples and
provides the maximum data for the expended effort consists
of the addition of one or more internal standards to  the
matrix before purging.  Data generated in this program
provide a continuous monitoring of the equipment and  establishes
matrix applicability for the test.

For liquid/liquid extraction methods in a regulatory  situation,
the emphasis is placed on duplicates and dosed samples.  Both
field duplicates and laboratory duplicates are used in the
program to establish sampling and subsampling validity.

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             The  dosing  of  samples to establish method accuracy for the
             matrix  is an integral part of this program.  Where the
             analytical  program will extend over a long period of time
             the  construction of control charts is recommended.

             When the liquid/liquid extraction methods are used for monitoring,
             the  emphasis is placed on an external control series.  A standard
             laboratory  matrix is developed.  With each series of samples the
             matrix  is dosed and analyzed with the samples.  Data generated
             over a  period  of time can be used to monitor the performance
             of the  equipment and the analyst, with relatively tight
             specifications to define problems that arise.  Control
             charts  can  be  constructed to alert the analyst to problems,
             but  there is no provision for rejection of results for
             samples of  this type.

  8.7.2  Inter-laboratory Quality Control Procedures
         An inter-laboratory quality control  program serves to select and
         evaluate methods,  characterize their precision and accuracy, and
         provide  data for evaluating both laboratory and analyst performance.
         Specific objectives of this program  are to:

         o Measure the precision of reproducibility of methods of analysis
           within various programs.

         o Identify  interference in different sampling environments.

         o Measure the precision and accuracy of results between laboratories.

         o Provide a mechanism for evaluation and/or certification of lab-
           oratories and analysts.

         o Detect weak,  improper, or impractical methodology.

         o Detect training  needs and upgrade  laboratory performance.

         o Assist laboratories or programs in obtaining new resources.

         The inter-laboratory quality control program is referred to as the
         Accuracy and Performance Audit* Programs by the Quality Assurance Office:
         Region V.  This program was briefly  referred to in Section 4.2.1.

*Audit - A check  made by the QAO or its' representative to determine the
         reliability of  a specific step in a  measurement.  For example, a
         check  on the flow  of a Hi-Vol air sampler, the sensitivity of a
         spectrometer detector and the ability to analyse a blind unknown
         sample are  all  audits.
*System Evaluation - An  on-site inspection and review of the total quality
         assurance and quality control program.  The inspection will be
         made by  the QAO or its representative.

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                                     72

8.7.2.1  Management of the Accuracy and Performance Audit Programs
         The number of programs in water, waste,  air and special  projects
         are several.  The number of measurement  parameters which are
         utilized in these several programs are numerous.  QAO presently
         manages this program by manual means.   All data is evaluated
         manually, which requires a considerable  amount of time.   As soon
         as the last Milestone on page 7 of this  document is met  the
         QAO will manage an audit program utilizing ADP programs  which will
         provide the needed level of audits that  will assure quality data
         adequate for the requirements of the data user.

         The areas of activities which are covered under this audit program
         are described below:

         1.  Audits are to be performed according to frequencies  and
             procedures  required by Federal Regulations, EPA Guidelines
             or Region V Policy (e.g., air audits shall conform to the
             requirements of 40 CFR Part 58, Appendix A and B).  The scope
           .  of audit must be determined for each measurement parameter
             (analyte).  A performance audit for the measurement  of a
             given analyte in.drinking water would be carried our by mailing
             a reference sample to a laboratory.   The reference sample
             would contain the analyte in a concentration known to QAO,
             but unknown to the analyst.  The analyte would be measured
             and the value reported back to QAO.   A similar type  audit
             would be performed for sewage treatment plants, laboratories
             analyzing water from lakes and streams, etc.  On the other
             hand, an audit of a Hi-Vol Sampler would require an  individual
             going to a sampling site, measuring flow rates using two or
             more reference plates and examine the equipment for maintenance
             and operating conditions, recording temperature, pressure and
             other information.

         2.  Audit materials are available from EMSL-Cincinnati,  EMSL-RTP,
             EMSL-LV and commercial sources.  Audit materials may be prepared
             as needed by QAO in conjunction with Central Regional Laboratory
             and/or contractors.  A repository of reference materials will
             be maintained by QAO for special substances, substances obtained
             by contract and from other sources when not available from
             EMSL.  A central reference file will be developed which can
             be accessed by Automatic Data Processing (ADP).  This file
             will give the facility providing the reference material, the
             concentration or weight per unit and method used to  establish
             reference value.  Reference materials will be referenced to the
             highest standard available, preferably to National Bureau of
             Standards.  Materials which have assay values which  have been

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                            73

    verified by Best Available Technology (BAT)  are referred to
    as SRM's and those which have been assayed by MBS are NBS-SRM.
    Federal Regulations and EPA Guidelines will  be followed in
    determination of the appropriate SRM.  Other materials will
    be measured by BAT and designated as reference samples.

3.  Studies will be conducted as specified in QAO's program plan
    to accomplish certain objectives relative to audits, reference
    materials, and methods.  Determination of the "true value" of
    an analyte is at time tenuous.  Only an estimate of the "true
    value" can be made for some analytes.  The determination or
    estimation of the value for a reference material will be
    derived from collaborative testing.   These studies will use
    data from studies such as:

    a.  The methodology within the International Joint Commisipn
        (IX) group of analytic systems  is not uniform and various
        methods may be used to measure a given analyte.  The
        results for a reference material analyzed by a variety of
        methods will be less predictable and the estimate of
        "true values" less precise.   The studies must discern the
        overall reliability of the methods and identify methods
        which tend not to measure the analyte.  Studies will be
        used to establish procedures which are uniform for a given
        measurement principal.  The data from such studies require
        statistical, evaluation and at time sophisticated matrix
        solutions.  These statistical evaluations will be processed
        on ADP.

    b.  Methods may be used which are not designated as reference
        or equivalent methods.  Methods  for many analytes have not
        had suitable evaluations and accuracy is not known.
        Thus, studies will be made by QAO to provide data files
        on BAT when such information can be obtained.  Data files,
        data systems such as Comnet.  EMSL-Cincinnati, etc., will
        be accessed through a Tektronix  4014 terminal.

    c.  Laboratories will be evaluated by performance audits and
        system evaluations which will include methodology, calibration,
        training, maintenance and other  operations.   Audit data and
        production records will  provide  a measure of the effectiveness
        of the quality control program.

4.  Independent audits for determination of measurement accuracy
    will be managed by QAO.  The individuals performing audits may
    be located at the Region V,  QAO  or in the various S&A district

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                            74

    offices.  The audit procedures will be prepared by QAO or if
    audits are performed by personnel other than QAO those procedures
    will be approved by QAO.

State and local agencies will develop their audit procedures.
Conformance with Federal Rgulations and EPA Guidelines will be
determined by QAO.  Audit procedures must be reviewed by the
appropriate agency on an annual basis and revised as appropriate.
Revisions must be approved by QAO.

Each instrument will require an independent audit performed by a
State agency, Region V or by contract.  The frequency of audits is
to be based on requirements of regulations, EPA guidelines or
Region V policy.

Some audit results may be reported by ADP terminal as soon as ADP
is functional, to QAO for storage in suitable data files.  These
audit reports would provide date, time, auditor, analyte, method,
instrument (reference method, equivalent non-equivalent), agency
name, site number, temperature, pressure, all pertinent technical
data and values observed.  A written report to the agency and the
respective Region V media program manager will be made indicating
acceptability of performance and/or corrective action required
and expected time required to meet compliance.

The operating agency will acknowledge corrective action and reply
by indicating that corrective action was taken or would be completed
by a given date.  Where corrective action can not be made with
existing equipment, intended action must be indicated.  The QAO
will review the operating agency response for acceptability.

A re-audit will be scheduled by QAO and effectiveness of
corrective action verified.  Verification will be made by an
appropriate QAO staff member or appropriate auditor and reported
to QAO.

The final audit report is written up and reported formally.  The
time of reporting will conform to the QAO program plan requirements.
The recipiant of the audit report is the operating agency with copies
sent to the respective media program manager.

Reports of unacceptable audits sent to the QAO will automatically
be flagged for the particular instrument.  Data will be invalidated
or held in storage as invalid until corrective actions are completed.
This system will improve on the data analysis over the present system
because audits are not presently correlated with the data until after

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                            75

summaries have been prepared.   Thus,  it  is  necessary  to  go  backwards
and delete invalid date at a later date.  There  has not  been  a
systematic method for correlating  audits  with  site data.

Types of instrument audits which will be made  are:

a.  Ozone calibration audits.   These  are resource intensive since
    a calibration system must  be maintained with strict  quality
    control measures.  The method  of.measurement must be by the
    reference method.  The audit requires transporting a primary
    calibration or a transfer calibrator to a  monitoring site.
    Multi-level calibration checks are made which may require as
    much as 3 to 4 hours operating time.  These  audits will be
    performed by auditors located  in  the district offices and
    verified by QAO, or performed  by  QAO.

    Audit results for all systems  in  the Region  are correlated to
    estimate a "true value" to define accuracy of ozone  measure-
    ments in Region V.

    Frequency of ozone audits  and  the acceptable limits  are
    defined in 40 CFR 53, Appendix A. State and local agencies
    will be audited with a minimum number of audit frequencies
    described in the Appendix A of the regulations.   Greater
    frequencies are encouraged to  the limit of cost effectiveness.
    Present auditing levels in Region V  are greater than the
    minimum required in proposed  regulations.  These  levels of
    audits are considered justified since they improve cost
    effectiveness.  Quicker turn  around  time on  audit reports
    and improved operations might  suggest a lesser frequency, but
    demonstration of the appropriate  levels will result  from  the
    evaluations established in this program.

b.  Hi-Vol Sampler audits are resource intensive requiring  travel
    to monitoring sites, measurement  of  several  flow  rates  and
    evaluation of operations and equipment.  Personnel who  audit
    the Hi-Vol Samplers are from the  District  Offices.  Audit is
    verified by the QAO.  Frequency of audits  are determined  by
    QAO based on regulations,  EPA  guidelines or  Region V policy.
    Hi-Vol Samplers are audited by Region V, State and local
    agencies on a frequency which  is  greater than that required by
    40 CFR 53, Appendix A.  Acceptable limits  applied in Region V
    are tighter than required by  Appendix A.

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                                     76

             Audit reports are transmitted to the QAO  for verification.
             A copy of the report will  be provided to  the Agency audited
             and to the appropriate media program manager in  Region  V.
             The report records temperature,  pressure, unusual  instrument
             findings, site number, Agency name and two or more observed
             flow rates using reference plates.   Reference plates are
             calibrated by equipment which has been referenced  to the
             highest standards available.

         c.  Calibration equipment: QAO will  procure,  operate and maintain
             calibration equipment required for all measurement parameters.
             Procedures, specifications, operation manuals, maintenance
             manuals and spare parts lists will  be compiled for use  with
             this equipment and made available for Regional,  State and
             local agency use/or information from the  Central Reference
             Files.  List of vendors will be documented for ready reference
             in order'to expedite replacement of equipment.  Calibrations
             will be made on various instruments for measurement of  critical
             pollutants, particularly continuous monitors.  QAO will maintain
             quality control records on these instruments.

         d.  Audits on detector sensitivity for spectrometers,  pH meter
             accuracy, etc., will also be made on an instrument-by-instrument
             basis.

8.7.2.2  Management of the On-Site System Evaluation of Total In-House,
         Federal, State and Local Agency, Contractor,  Grantee Monitoring
         Program

         The Quality Assurance Office has total  responsibility  for managing
         the system evaluation program.  A system evaluation  is an on-site
         inspection and review of the quality control  program used for the
         total measurement system for each specific monitoring  program
         conducted by a Federal, State or local  agency.  For  convenience,
         some items that each quality control plan must contain (discussed
         elsewhere in this document) and which will be evaluated are repeated
         below:

         1.  Organization and Responsibility - Is the  quality control
             program operational?

         2.  Sample Collection - Are written procedures available for sample
             collection and are these followed as documented?

         3.  Sample Analysis - Are written analysis procedures  available
             and are procedures followed as written?

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                            77

4.  Data Validation - Is a list of criteria for data validation
    available and it it used?

5.  Calibration - Are written calibration procedures available and
    are procedures followed as written?

6.  Performance Evaluations - Are control charts for performance
    evaluations reviewed and corrections made when indicated?

7.  Intralaboratory Tests - Are results from intralaboratory testing
    reviewed and corrections made when indicated?

8.  Preventive Maintenance - Is the preventive maintenance schedule
    being followed as recommended in the QA plan?

The results of the system evaluation is documented by the QAO
for presenting a visual picture of the performance of the program
to see if the minimum requirements of the Region's Quality Assurance
Plan are being met.  If not, deviations are identified and
recommendations made for corrections.  If corrections are not
made, recommendations are made to the appropriate program director
for action (eg., withholding grant or contract funds, etc.).

Appendix 17 depicts how the system evaluation program will function.

A system evaluation will be conducted at all laboratories in
Region V funded by EPA engaged in the Clean Water or Clean Air Act,
the Safe Drinking Water Act, the Toxic Substance Control  Act, and
other pertinent Acts.  All parameters analyzed for, will  be evaluated.
The minimum QC elements for these laboratories for several major
programs are listed in Appendix 18 and 19 and will be evaluated
for compliance with these minimum requirements.  The minimum QC
elements for the above laboratories engaged in the Clean  Air Act
monitoring activities are listed in EPA publications 600/9-76-005,
600/4-77-027a, and 600/4-77-127b, "Quality Assurance Handbooks
for Air Pollution Measurement Systems", and 40 CFR Part 58, Appendix
A and B.  Laboratory evaluations will be based on compliance with
minimum requirements contained in these documents.

The on-site evaluation programs will be administerd as separate
operations.  These will be evaluations of the:

a.  State principal laboratories and offices (water and wastewater).
                                                                     ..i
b.  State principal laboratories and offices (air).

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                                     78

         c.  Local  laboratories  analyzing  public  water supply  samples.

         d.  Local  air agency offices.

         e.  Contract laboratories.

         This division of work is required because of the  administrative
         separation of the programs.

9.  DATA PROCESSING

    The term "data  processing" is used to  include handling,  validation,
    verification, transmission and storage, and  reduction, including
    software QC  considerations as described below.   Just as  samples and
    specimens can be destroyed,  data  can be lost, distorted, misinterpreted,
    incorrectly transcribed,  improperly  transposed, overlooked,  or subject
    to other distortions, unless suitable  QC  procedures are  used to protect
    its integrity.

    To obtain meaningful  environmental data,  the  representative  sample
    must be delivered unchanged  to the analyst who will develop  the
    needed data by  performing the prescribed  analysis.  The  completed
    (i.e., calculated) results need verification  calculations  to eliminate
    outliers or extraneous results and the conversion of acceptable results
    to some final form for permanent  recording of the analytical  data in
    meaningful exact terms.  These results are then transferred  to a data
    storage facility for future  interpretation and use.  All quality
    control plans must document  the mechanism to  deal  with those requirements
    listed in 9.1.  9.2 and 9.3.   Those mechanisms shall be as  stringent as
    those specified below.

    9.1  Data Handling Transmission and  Storage
         Measurements of the  concentration of pollutants,  either in the
         ambient environment  or  in the emissions  from stationary sources,
         are assumed to be representative  of  the  conditions  existing at
         the time of the sample  collection.  The  extent to which this
         assumption is valid  depends  on  the sources of error and bias
         inherent in the collection,  handling, and analysis  of the sample.

         Besides the sampling and^analytical  error and bias, human error
         may be introduced any time between sample collection  and sample
         reporting.  Included among the  human errors are such  things as
         failure of the operator/analyst to record pertinent information,
         mistakes in"reading  an  instrument, mistakes in calculating results,
         and mistakes in transposing  data  from one record  to another.

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                            79

Data handling systems involving the use of computers  are  susceptible
to keypunching errors and errors involving careless handling  of
magnetic tapes and other storage media.  Although  it  cannot be
completely avoided, human error can be minimized.

Data reporting techniques and error sources depend on the type of
sensor measurement system.   Measurement sensors for pollutant
concentration may be classified by their sample collection principle
into two categories:  (1) Integrated,  and (2) Continuous.  Pollutant
measurement systems may be either integrated or continuous, whereas
ambient measurement systems are normally always continuous.

In the integrated sample collection principle,  a discrete sample
is collected in some medium and is normally sent to a laboratory
for analysis.  The sampler, field operator and  the laboratory
analyst can make errors in data handling.

In the continuous sample collection principle,  an  analytical  sensor
produces a direct and continuous readout of the pollutant concentration
parameter.  The readout may be a value punched  or  typed on paper
tape or recorded on magnetic tape.  In addition, some continuous
measurements systems may also use telemetry to  transmit data  to a
data processing center.  Both human and machine errors can occur
in data handling in this type of system.

a.  Data errors in integrated sampling - For ambient  monitoring,
    the sampler or operator records information before and after
    the sample collection period.   For source emission testing,
    the operator records information during the sample collection
    period in addition to before and after it.   Acceptance limits
    should be set for data pertaining  to flow rates,  etc., and
    the operator/analyst should invalidate or "flag"  sampling
    data when values fall outside these limits. Questionable
    measurement results may indicate the need for  calibration or
    maintenance.

    The analyst in the laboratory reads measurements  from balances,
    colorimeters, spectrophotometers,  and other instruments;  and
    records the data on standard forms or in laboratory notebooks.
    Each time values are recorded, there is a potential for incorrectly
    entering results.  Typical  recording errors are transposition
    of digits (e.g., 216 might be incorrectly entered as  126) and
    incorrect decimal point location (e.g.,  0.0635 michg  be entered
    as 0.635).   These kinds of errors  are difficult to detect.
    The supervisors must continually stress  the importance of
    accuracy in recording results.

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                            80

    Acceptance limits  contained  in  the measurement method write-up
    and those shown in the method activity matrix should be  used
    by the analyst to  invalidate or "flag" analysis data when
    values fall  outside these limits.

b.  Data errors  in continuous analyses - Continuous monitoring
    systems may  involve either manual or automated data recording.
    Automated data recording may involve the  use of a data logging
    device to record data on paper  tape or magnetic tape at  bench
    or the remote sampling station, or the use  of telemetry  to
    transmit data on-line to a computer at a  central facility.

    Manual reduction of pollutant concentration data from strip
    charts can be a significant  source of data  errors.  In addition
    to making those errors associated with recording data values
    on record forms, the individual who reads the chart can  also
    err in determining the time  average value.  Usually the  reader
    estimates by inspection the  average concentration.  When the
    temporal variability in concentration is  large, it is difficult
    to determine an average concentration.  Two people reading
    the same chart may yield results that vary  considerably.

    Persons responsible for reducing data from  strip charts  should
    be given training.  After a  person is shown how to read  a
    chart, his/her results should be compared with those of  an
    experienced  analyst..  Only after he/she has demonstrated the
    capability to obtain satisfactory results should a analyst be
    assigned to  a data reduction activity.

    Periodically the senior analyst or section  chief should  check
    strip charts read  by each analyst.

    Up to 10 percent of all data reported by  each analyst is to
    be checked by the  Quality Assurance Coordinator for errors.
    If an individual is making gross errors,  additional training
    is to be provided.

    Because manual chart reading is a tedious operation, a drop
    in productivity and an increase in errors might be expected
    after a few hours.  Ideally, and individual should be required
    to spend only a portion of a day at this  task.

    The use of a data  logging device to automate data handling
    from a continuous  sensor is  not a strict  guarantee against
    data recording errors.  Internal validity checks are necessary
    to avoid serious data recording errors.   There are two sources

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                            81

    of error between  the  sensor  and  the  recording medium:  (1) the
    output signal  from the  sensor  and  (2) the  errors in  recording
    by the data logger.

    The primary concern about  the  sensor output  is to ensure that
    only the sensor analog  signal  and  not electronic interferences
    be converted to a digital  readout.   Internal validity  checks
    should be planned to  "flag"  spurious data  resulting  from
    electronic interferences.

    For a system involving  the use of  telemetry, it is also necessary
    to include a validity check  for  data transmission.

c.  Errors in computations  - To  minimize computational errors,
    operators and analysts  should  follow closely the formulae,
    calculation steps, and  examples  given for  each method, using
    the calculation instructions and forms  provided in the method
    write-up.

    The senior analyst should  check  the  computations of  each analyst.
    Up to 10% of all  data reported computations  are to be  checked
    by the QA Coordinator for  errors.

d.  Control charts -  Procedures  for  reviewing  data at the  operational
    as well as the managerial  levels are to be implemented by data
    generators (lab and field).  Review  of  measurement results
    from control samples  used  during analysis, for example, can
    indicate out-of-control conditions that would yield  invalid
    data from subsequent  analyses, if  the conditions are not
    corrected immediately.   At the managerial  level, periodic review
    of data can indicate  trends  or problems that need to be addressed
    to maintain the desired level  of precision and accuracy.  One
    common tool for statistical  analysis of data at both the
    operational and the managerial levels is the control chart.
    The major steps in constructing  the  control  chart were outlined
    in Section 8.7.1.

    The control chart provides a tool  for identifying the  systematic
    variation (assignable cause) from  the system indeterminate
    variation (random).  This  technique  displays data in a form
    that graphically compares  the  variability  of all test  results
    with the average or expected variability of  small groups of
    data.

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                                       32

               The steps to consider 1n the application of control charts
               are the following:

'"»              1.  Select critical characteristics in the measurement system to
                   audit.

               2.  If audit (reference) standards are used, obtain the necessary
                   materials.

               3.  Select the data quality objective to audit:

                   a.  Precision - A measure of mutual agreement among
                       individual measurements of the same property, usually
                       under prescribed similar conditions.

                   b.  Accuracy - The difference between an average value
                       and the true value when the latter is known or assumed.

               4.  Choose the audit size and frequency:

                   a.  Size - i.e., for air analysis, the analysts will often be
                       dealing with samples of 2, which will form most subgroups.

                  •b.  Frequency of subgroup sampling - Changes are detected more
                       rapidly as the sampling frequency is increased.  Audit
                       rates of 7-10 percent are recommended for many
                       characteristics shown in the method activity matrices.

               5.  Set control limits,  Control limits (CL) are to be set at
                   2 times the standard deviation for P

               6.  The control charts are to be maintained either by the
                   operator/analyst or the supervisor.  The control chart
                   should be kept up to date.  The QA coordinator is to
                   review the charts on some established frequency.  After
                   establishing 15 to 20 data points, the control limits
                   should be reestablished on the basis of these data.  If
                   the new control limits are narrower than those recommended,
                   the former is to be used.  After this initial calculation,
                   control limits should be recalculated every 3 to 6 months,
                   or whenever significant data trends or shifts become
                   obvious.

                   The control chart is actually a graphical presentation of
                   quality control effectiveness.  If the procedure is

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                        83

    "in control",  the results will  almost  always  fall  within
    the established control  limits.   Further,  the chart  will
    disclose trends and cycles from assignable causes  that
    can be corrected promptly.

Report Forms - The analytical  information  reported should
include the measured parameters;  the details of the analyses
such as burette readings,  absorbance, wavelength, normalities
of reagents, correction factors,  blanks; and the  reported
data values.  To reduce errors in manipulation of numbers
a general  rule is  to reduce  handling and transposition of
date to an absolute mini num.  Ideally, a report form includes
preliminary information about the sample and its  analysis,
and the same form  is used  for the final  reporting form for
entering of data into a computer.  However, if such a  set-up
is not available the protocol  below is to  be used to record
finalized data.

1.  Loose Sheets - Reporting of data onto  loose or ring-binder
    forms is a means'of recording data that allows easy  addition
    of new sheets, removal  of older data,  or collection  of
    specific data  segments.   However, the  easy facility  for
    addition or removal also permits loss  or misplacement of
    sheets, mixups in date sequence, and ultimately questionable
    status of the  data for formal display  or presentation as
    courtroom evidence.  Loose sheets are  not  encouraged.

2.  Bound Books -  The use  of bound books is an improvement
    in data recording that tends  to result in  a chronological
    sequence of data insertion.  Modification  beyond a simple
    lined book improves its  effectiveness  with little  additional
    effort.  Numbering of pages encourages use of data in
    sequence and also aids in referencing  data through a
    table of contents ordered according to time,  type  of
    analysis, kind of sample, and identity of  analyst.

    Validation can be easily accomplished  by requiring the
    analyst to date and sign each analysis on  the day  completed.
    This validation can be strengthened further by providing
    space for the  laboratory supervisor to witness the date
    and the completion of the analyses.

    A further development  of the  bound notebook is the
    commerically available version designed for research-type
    work.   These notebooks are preprinted  with book and  page
    numbers, and spaces for  title of project,  project  number,

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                        34

    analyst signature, witness  signature,  and  dates.   Each
    report sheet has a detachable duplicate  sheet that allows
    up-to-date review by management  without  disruption of the
    notebook in the laboratory.

    Bound notebooks can and should be used in  routine
    analytical laboratories.  The need for repeated  information
    on sampling and analyses  can be  answered by  use  of preprinted
    pages in the bound notebook.

Preprinted Report Forms - Most  field laboratories and
installations repetitively analyzing fixed parameters  develop
their own system of compiling laboratory data  that may include
bound notebooks, but a means  of forwarding data  is also required.
Usually, laboratories design  forms to fit  a  related  group of
analyses or to report a single  type  of analysis  for  a  series
of samples.  As much information as  possible is  preprinted  to   -
simplify use of the form.  With loose-sheet, multicopy forms
(using carbon or PCR paper) information can  be forwarded on
the desired schedule while also allowing retention of  data  in
the laboratory.  Still, the most common means  for recording
data in rough form are internal bench sheets or  bound  books.
The bench sheet or book never leaves the laboratory  but serves
as the source of information  for transfer  of data to appropriate
report forms.

In most instances the supervisor and anlayst wish to look at
the data from a sampling point  or station  in relation  to other
sampling points or stations on  or in a particular AQCR, river
or lake.  This review of data by the supervisor  prior  to
release is a very important part of  the QC program of  the
laboratory; however, such reviews are not  easily accomplished
with bench sheets.  For review  purposes, a summary sheet can
be prepared that displays a related  group  of analyses  from  a
number of stations.  The form should contain space for all  of
the information necessary for reporting data,  the completed
form can also be used to complete the data forms forwarded  to
the computer storage and retrieval system.

The forms used to report to storage  systems  provide  spaces
for identification of the sampling point,  the  parameter code,
the type of analysis used, the  reporting terminology.   Failure
to provide the correct information can result  in rejection  of
the data, or insertion of the data into incorrect parameter
fields.  As sample analyses are completed, the data  values
are usually reported in floating decimal form  along  with the
code numbers for identifying  the parameter data  fields and
the sampling point data fields.

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                        85

Plastic-Coated Labels and Forms -  A recent  addition  to  good
sample handling and data management is  the  availability of
plastic-coated (blank or preprinted)  labels,  report  forms,
and bound report books.   These materials  are  waterproof, do
not disintegrate when wet or handled, can be  written on while
wet, and retain pencil or waterproof ink  markings  though
handled when wet.

Digital Readout - Instrumental  analyses,  including automated,
wet-chemistry instruments such as  the Technicon Auto Analyzer,
the atomic absorption spectrophotometer,  the  pH meter,  and the
selective electrode meter, provide digital  readout of concen-
trations, which can be recorded directly  onto report sheets
without further calculation.  Programmed  calculators can be
used to construct best-fit curves, to perform regression
analyses, and to perform a series  of calculations  leading to
final reported values.

Keypunch Cards and Paper Tape - Because much  of the  analytical
data generated in laboratories is  first recorded on  bench
sheets, then transferred to data report forms, keypunched,
and manipulated on small terminal  computers (or manipulated
and stored i n a 1arger data storage system),  there i s a danger
of transfer error that increases with each  data copy.  The
analyst can reduce this error by recording  data directly from
bench sheets onto punch cards that can  be retained or forwarded
immediately to the data storage system.  Small hand-operated
keypunch machines are available.

Automated Laboratory Systems - The use  of digital  readout,
keypunch cards, and paper tape have been  overshadowed by the
development of customized,'fully automated  online  computer
systems that make measurements, calculate results, perform
qulaity control, and report analytical  data simultaneously
from a full range of laboratory instruments.   Such systems
can contain the following functions:

a.  Manual or automatic sampling and testing  of a  series of
    samples, standards, replicates and  check  samples.

b.  Detection of the measurement signals  from the  series of  samples.

c.  Conversion of signals to concentrations,  generation of a
    standard curve, and calculation of  sample values in final
    units.

d.  Calculation of the deviation and recovery values of the
    results and indication of acceptance  or nonacceptance
    based on limits established by the  analyst.

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                                 86

         e.   Provision of the  output  in  a  form designated by the analyst:
             dial,  paper recording chart,  digital  readout, cathode ray
             tube,  or printed  report  form.

     The degree of  hands-on operation required in  the system is specified
     by the  analyst.

     If an automated  system is properly  designed and operated, most
     calculation and  transposition errors  are avoided and the proper
     level of quality control  is  automatically exerted.

9.2  Data Validation  and Verification
     Data validation  is the process whereby  data are filtered and
     accepted or rejected based on a  set of  criteria.  This involves
     a critical review of a body  of data in  order  to isolate and locate
     spurious values.  It may  involve only a cursory scan to detect
     extreme values or a detailed evaluation requiring the use of a
     computer.  In  either situation,  when  a  spurious value is located,
     it is not immediately rejected.   Each questionable  value must be
     checked for validity.  Records of values that are either judged
     invalid or are otherwise  suspicious should be maintained.  These
     records are, among other  things, a  useful source of information for
     judging data quality.  Validation methods can be manual or by
     computerized techniques.

     a.  Manual - Both the analyst and the laboratory supervisor should
         inspect integrated environmental  quality  monitoring data.
         At  regular intervals, daily  or  weekly, results  should be
         scanned for  questionable values.  This type of  validation is
         most sensitive to extreme values, i.e., either  unusually high
         or low concentrations.  These are sometimes called outliers.

         The criteria for determining an extreme value are derived from
         prior data obtained at the particular sampling  site (or a similar
         site if no previous data are available for a site).  The data used
         to determine extremes may'be the  minimum  and maximum concentrations
         for all prior data from  a site.  The decision criteria might
         also be based on minimum and maximum for  each season, each
         month, or each day.

         An  audit level of 7-10 percent  should be  established for
         checking data, i.e.,  checking 7-10  out of every 100 values.

     b.  Computerized Techniques  - A  computer can  be used not only to
         store and retrieve data  but  also  to validate data.  Any
         system for checking extreme  values  in manaul techniques also

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                        87

apply here.  The criteria for extreme values  can  be  refined
to be specific for individual hours  during  the  day.   For
example, with this procedure, an hourly  average concentration
for carbon monoxide of 15 ppm may not be considered  an  extreme
value for 8:00 a.m. but could be tagged  as  questionable if it
appeared at 2:00 am.

Another indication of possible spurious  data  is a large difference
in concentrations reported for two successive time intervals.
The difference in concentrations, which  might be  considered
excessive, may vary from one time to another  for  the same
pollutant.  Ideally this difference  in concentration is
determined through a statistical analysis of  historical data.
For example, it may be determined that a difference  of  0.05
ppm in the S02 concentration for successive hourly averages
occurs rarely (less than 5 percent of the time).   But at the
same station the hourly average CO concentration  may change
by as much as 10 ppm.  The criteria  for  what  constitutes an
excessive change may also be linked  to time of  day and  pollutant
relationships, e.g., high concentrations of SOg and  03  can
not co-exist and these data should be considered  suspect.

Criteria for Determining Acceptability of Data  -  Reading strip
charts is a tedious job subject to varying  degrees of error.
A procedure for maintaining a desirable  quality for  data
manually reduced from strip charts is important.   One procedure
for checking the validity of the data reduced by  a analyst is
to have another analyst or the supervisor check the  data.
Because the values have been taken from  the strip chart by
visual inspection, some difference in the values  derived by
two individuals can be expected.  When the  difference exceeds a
specified amount and the initial areading has been determined
to be incorrect, an error should be  noted.  If  the number of
errors exceeds a predetermined number, all  data for  the strip
chart are rejected and the chart is  read again  by a  technician
other than the one who initially read the chart.   The question
of how many values to check can be answered by  applying one
of two techniques.

1.  Application of Acceptance Sampling Techniques -  Acceptance
    sampling can be applied to data  validation  to determine the
    number of data items (individual  values on  a  strip  chart)
    that need to be checked to determine with a given probability
    that all the data items are acceptable.  The  supervisor
    wants to know, without checking  every data  value, if a
    defined error level has been exceeded.  From  each strip

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                            88

        chart with N data values,  the  supervisor can  randomly
        inspect n data values.   If the number  of erroneous  values
        is less than or equal to c, the rejection criteria, the
        values for the strip chart are accepted.   If  the;number
        of errors is greater than  c, the values  for the  strip
        chart are rejected,  and another analyst  is asked to read
        the chart.

    2.  Sequential Analysis  Test Procedure  - The typical approach
        used in performing a statistical test  of hypothesis
        requires the collection of a sample of a fixed size.   A
        statistic is then computed from the sample data  and compared
        with some critical values  for  that  statistic.  A decision
        is then made to accept  the hypothesis  (H0) or to accept
        some alternative hypothesis (H^).   With  such  a procedure
        it is necessary to collect the specified sample  of  observations
        regardless of the results  that may  be  obtained from the
        first few observations.

        Sequential analysis  requires that a decision  be  made
        after each observation  or  group of  observations.  This
        procedure has the advantage that, on the average, a decision
        can be reached with  fewer  observations than a fixed sample
        size requires.

d.  Data Validations Procedures and Criteria for the  Agency's
    National Aerometric Data Bank  (NADB)

    The NADB is a computer storage and retrieval  system  for
    aerometric data collected by Federal, State  and local air  agencies.

    40 CFR Part 58.35 specifies the NAMS data  submittal  requirements
    to NADB which are 1 sited below:

    a.  The requirements of this section apply only to those
        stations designated  as  NAMS by the  network description
        required by §58.30.

    b.  The State shall  report  quarterly to the  Administration
        (through the appropriate Regional Office)  all ambient  air
        quality data and information specified by AEROS  Users
        Manual (EPA-450/2-76029, OAQPS No.  1.2-039) to be coded
        into the SAROAD Air  Quality Data forms.   Such air quality
        data and information must  be submitted on either paper
        forms, punched cards, or magnetic tape in the format of
        the SAROAD Air Quality  Data forms.

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                        89

c.  The quarterly reporting periods  are January  1-March  31,
    April 1-June 30, July 1-September 30,  and October 1-December 31
    The quarterly report must:

    1.  Be submitted within 90  days  of the end of  each reporting
        period, and

    2.  Contain all data and information gathered  during the
        reporting period.

d.  The first quarterly report  will  be due on or before
    June 30, 1981, for data collected during the first quarter
    of 1981.

e.  Air quality data submitted  in the quarterly  report must
    have been edited and validated so that such  data are
    ready to be entered into the SAROAD data files.   Procedures
    for editing and validating  data  are described  in AEROA
    Users Manual (EPA-450/276-029, OAQPS No. 1.2-039).

f.  This section does not permit a State to exempt those
    SLAMS which are also designated  as NAMS from all of any  of the
    reporting requirements applicable to SLAMS in  §58.26.

Highlights from the above documents  for data validation are
described below:

1.  Screening Criteria - In order to draw correct  conclusions
    from the data, validity checks are built into  the data
    handling system.  The data  must  meet predetermined standards
    with respect to representativeness, instrument averaging
    time, duration of sampling, and  comparability  before
    they are incorporated into  NADB.  A discussion of each
    criterion follows:

    a.  Representativeness - Data from each monitoring site
        should characterize ambient  levels in an area or
        neighborhood.  For example,  a daily average of carbon
        monoxide calculated from values collected  only during
        the morning rush hour would  hardly reflect the true
        daily averages.  The data must be relatively complete
        over the time interval  of interest (for example, day,
        season, or year) so that such biases can be avoided.

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                        90

    b.  Instrument Averaging Time -  The  data must  represent  a
        sample interval  of 1 hour or more.  Thus,  no more
        than 24 values per day per pollutant are stored.
        Data for intervals of less than  1 hour  are converted
        to hourly averages before storage.

    c.  Duration - The data must  be  collected over a time period
        of no less than 3  consecutive months so that at least
        quarterly summary  statistics can be calculated.

    d.-  Comparability -  Aeromatic data must be  maintained in
        consistent units to permit data  submitted  by various
        agencies to be combined into nationwide summaries and
        evaluation reports.   The  data must have been acquired
        by application of  standard methodologies.

    These four criteria  are pertinent to developing meaningful
    information from the data collected  from any monitoring  network.

2.  Criteria for Completeness. The  raw  data entering the NADB
    are checked for completeness  (representativenesss).  With
    continuous measurement, the criterion for completeness is
    that at least 75 percent of the  total possible number of
    observations be present.  Figure 9.2 presents  the number
    of observations required by the  NADB before summary results
    are calculated.

    The data within the NADB resulting from intermittent sampling
    are summarized only if there  are at  least five samples
    per quarter.  An additional stipulation is  that if a
    month contains no samples each of the other 2  months in
    the quarter must contain at least 2  samples.   Any other
    distribution of samples over  the quarter is acceptable.
    This is a minimum criterion based on a random  biweekly
    sampling schedule.  A  more stringent criterion should be
    applied when the sampling schedule is every third or
    sixth day.

3.  Criteria for Accuracy  and Precision  - Accuracy and precision
    data reported with aerometric data are not  used to validate
    data before entry into NADB but  are  used to interpret the
    data.

4.  Criteria for Handling  Data Values below Minimum Detectable
    Limits - Concentrations below the limit of  detection of
    the instruments employed result  in the problem of determining
    how to report such values so  that summary statistics can

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                      Continuous  measurement  criteria  for  completeness
   Time interval            "                        Minimum  number  of  observations

3-hour running average                          3  consecutive  hourly  observations
8-hour running average                          6  hourly  observations
24-hour                  "                       18 hourly observations
Monthly                        •            ••   •  21 daily  averages
Quarterly                                       3  consecutive  monthly averages
Yearly                                          9  monthly averages with  at  least
                                                  two monthly  averages  per  quarter
               Figure 9.2   Criteria for completeness for continuous  ambient
                            air monitors for NADB

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                        91

    be calculated.   The choice of data  values  is  complicated  by
    the fact that zero, the most likely value  to  be  supplied,
    cannot be used, especially if geometric  parameters  are  to
    be calculated.

    This problem is handled by inserting a constant,  approxi-
    mately equal to one-half the minimum detectable  limit,
    for each method and analysis technique.  This value was
    chosen after examining  the lower end of  the cumulative
    distributions for the various pollutants.   Seldom did the
    log-normal distribution (the distribution  most often
    applied to air pollution data)  accurately  describe  this
    portion of the data.   This may be due in part to  the
    existence of a background level  for each pollutant.  Use
    of the midpoint between zero a-nd the detectable  limit as
    the substitute value for concentration levels below the
    detection threshold seems reasonable.  In  order  to  permit
    consistency from year to year,  one  minimum detectable
    value is used for each  pollutant even if the  minimum
    detectable limit is changed, unless there  is  a change by
    an order of magnitude.   Figure 9.2.1 provides an  example
    of the current minimum  detectable limits as used  by the
    NADB for each pollutant and the value to be inserted for
    each value below the minimum detectable  limit.  These
    minimum detectable limits are reviewed periodically and
    changed as required.   Each laboratory should  determine
    its own set of minimum  detectable .limits,  based  on  its
    own analytical  techniques and instruments, to generate
    pollutant information.

    One additional  point should be mentioned concerning the
    use of substituted values for values below the threshold
    of the method.   When more than 25 percent  of  the  measured
    levels are below the minimum detectable  quantity, no
    statistics are computed from the data.   This  contraint  guards
    against the possibility of biasing  the computed  statistics.
    Furthermore, at least 50 percent of the  measurements in a
    set of data must be above the minimum detectable  concentration
    before a frequency distribution of  the values can be
    prepared.

5.  Criteria for Handling Data with  Negative Values - For the
    purpose of generating true pollutant values,  negative
    pollutant concentrations imply that there  is  not  enough
    of the pollutant present for the instrument to detect

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     Pollutant
    Method of Analysis
Minimum
detectable
limit, ug/m3
Substitution
factor
ug/m3
Suspended particulate
Fluoride
Nitrate
Sulfate
Carbon monoxide
Sulfur dioxide
Sulfur dioxide
Ozone
Total oxidant
Nitrogen dioxide
Nitrogen dioxide
Nitrogen dioxide
Nitrogen dioxide
Gravimetric
Specif ion electrode
Reduction-dizao
Colori metric
Nondispersive infrared
Pararosaniline, bubbler
Pararosaniline, continuous
Chemi luminescence
Colori metric
Arsenite, bubbler
TGS-ANSA, bubbler
Chemiluminescence, continuous
ColorimetMc, continuous
    1.0
    0.05
    0.05
    0.5
  573
    5
   26
   20
   20
    5
    5
    9
    9
  0.5
  0.025
  0.025
  0.025
286
  2.5
 13
 10
 10
  2.5
  2.5
  4.5
  4.5
                         Figure 9.2.1   Minimum detectable limits,  by  pollutant  and  method of
                                        analysis, used in NADB In 1975

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                                 92

             above the noise limit  specified  for the  instrument.
             When negative values occur,  they should  be  regarded  as
             being below the detection  limit  for the  method  and treated
             in the same manner,  i.e.,  assigned  a value  one-half  the
             minimum detectable limit.

9.3  Data Reduction (Including Software QC Considerations)
     The effectiveness of the quality assurance  program  will  be
     determined by monitoring improvements in the reliability
     of reported QC data.  On a regular basis, the QAO will  critically
     evaluate all reported QC data  for  each  reporting unit.   It is
     believed that this approach  will provide a  data  base to  more
     accurately evaluate and improve measurement performance.  The QAO
     will use a number of statistical techniques and  ADP to  measure
     performance, which are briefly  described below.  These  techniques
     have been reviewed extensively  elsewhere in this document.

     a.   Summary Statistics - Summary  statistics such as the mean
          and the standard deviation will be  used to  simplify the
          presentation of data and  at the same time to summarize  essential
          characteristics.

     b.   Frequency distributions -  Frequency distributions  such  as
          normal and log-normal distributions will be used to present
          relatively large data sets, such as the daily  concentrations
          of suspended particulates  in  ambient air over  a long period
          of time, i.e., six months.

     c.   Estimation and testing  procedures - Statistical estimation
          and testing procedures  will be  used to make inferences
          concerning the conceptual  population of measurements made
          under the same conditions  based on  a small  sample  of data.
          An example would be the estimation  of  the average  pH of a
          large number (population)  of  filters based  on  a sample  (lot)
          of pH readings for seven  filters.

     d.   Outliers - Outliers, i.e., unusally large or small  values,
          are identified by appropriate statistical tests for outliers.
          These statistical tests are useful, for example, in identifying
          gross errors in data handling procedures.

     e.   Audit data - Statistical methods for treating  performance
          audit data and for presenting the  results in terms  of bias
          and precision will be used.

     f.   Replication, repeatability, and reproducibility tests - The
          identification of sources  of  measurement error within and

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                                     93

               among  laboratories  is  one of the important functions of the
               Quality  Assurance Office.  Statistical methods will be used
               to  identify  these measurement errors.

          Quality  control audit data  from up to 50 laboratories using
          several  hundred different methods to monitor several hundred
          different contaminants must be monitored on a continuing basis.
          This  workload requires extensive use of computer technology and
          considerable  skill  in interpreting the results.  The statistical
          software package  that has been identified in the description of
          needs, once developed and implemented will be able to handle this
          large volume  of data and generate reports that describe data
          quality  in  non-technical language for the data users.  Reports
          will  also be  produced for laboratory and field personnel describing
          their performance relative  to that of other groups using similar
          measurement procedures.  It is intended that these reports will
          generally be  in a graphical format and include a listing of all
          supporting  results.

          The QAO  data  files  will  be  protected in the ADP system per the
          file  protection protocol for the ADP system.  Files will not be
          accessible  to other offices.  Programs will be stored as "Declared
          Files".   The  original documentation of the software programs will
          be placed in  the  permanent  files of the QAO in case there is ever
          a need to refer back to  this documentation.  Updated print-outs
          will  also be  maintained  on  all file data in case the data is lost
          due to some hardware malfunction of the ADP system.

10.   CORRECTIVE ACTIONS

     Corrective actions are of two types:

     a.   On the spot  or immediate  - This is the process of correcting
         malfunctioning equipment.

         In a quality assurance program, one of the most effective means
         of preventing  trouble is  to  respond immediately to reports from
         the operator of suspicious data or equi-pment malfunctions.  Application
         of proper corrective actions at this point can reduce or prevent
         the collection of  poor quality data.  Established procedures for
         corrective actions are available in the methods if the performance
         limits are found to  be exceeded (either through direct observation
         of the parameter or  thrqugh  review of control charts).  Specific
         control procedures,  cali-tiration, pre-sampling or pre-analysis
         operational  checks,  etc., are designed to detect instances in

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                              94

    which corrective action is necessary.   A  check-list  for  logical
    alternatives for tracing the  source  of a  sampling  or analytical
    error is provided to the operator.   Trouble  shooting guides
    for operators (field technicians  or  lab analysts)  are generally
    found in instrument manufacturer's manuals.   On-the-spot
    corrective actions routinely  made by field technicians or  lab
    analysts should be documented as  normal operating  procedures,
    and no specific documentation other  than  notations in operations
    logbooks need to be made.  However,  logbooks are to  be made
    available to QAO for review during any audit or on-site
    system evaluation.

b.  Long-term Corrective Action - The purpose of long-term corrective
    action is to identify and eliminate  causes of nonconformance or
    noncompliance with Agency QA  requirements,   Hopefully, they
    will be eliminated permanently.   To  improve  data quality to
    an acceptable level and to maintain  data  quality at  an acceptable
    level, it is necessary that the quality assurance  system be
    sensitive and timely in detecting out-of-control or  unsatisfactory
    conditions.   It is equally important that, once the  conditions of
    unacceptable data quality are indicated,  a systematic and  timely
    mechanism is established to assure that the  condition is reported
    to those who can correct it and that a positive loop mechanism
    is established to assure that appropriate corrective action
    has been taken.  A system of  reporting deficiencies  and
    verifying corrective actions  identified during the audit and
    on-site sytem evaluation process  has been identified earlier
    in this document and will not be  repeated here.

    1.  Closed-loop Corrective Action System  for Major Problems -
        Experience in Region V has been  that  most problems will
        not disappear until.positive  action has  been taken by
        management.  The significant  characteristic of any good
        management system is the  step that closes the  loop—the
        determination to make a change if the system demands it
        (this is mandated by the  Agency's QC  requirements and  QA
        regulations).

    The following discussion outlines the considerations and procedures
    necessary to understand and implement an  effective closed-loop
    corrective action system for major problems.  Effective
    corrective action occurs when many individuals and media
    programs cooperate in a well  planned program.  There are
    several essential steps that  must be taken to plan and implement
    a corrective action program that  achieves significant results.

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                                 95

      Corrective actions should be a  continual  part  of  the  laboratory
      system for quality, and they should  be  formally documented.
      Corrective action is not complete  until  it  is  demonstrated that
      the action has effectively and  permanently  corrected  the  problem.
      Diligent follow-up is probably  the most important requirement  of
      a successful  corrective action  system.

      Figure 10.1 illustrates the sequence of activities involved
      in operating a closed-loop corrective action system.

10.1  QA Management
      Sections 1 and 8.7.2 describes  the management  responsibility
      for Region V's Quality Assurance Program.   Feedback channels
      are identified for keeping informed  of  the  performance  of all
      monitoring systems in Region V  funded by EPA.  Procedures are
      also identified to monitor the  performance  of  the monitoring
      systems.  Elements of the program  have  been developed from the
      QAO Functional Statement, Agency Regulations and  requirements
      which serve as the foundation of Region V's policy statement,
      have been approved by the Regional Administration, making this
      program binding on the Region.  Goals have  been identified (including
      resources) to accomplish the objectives of  this program.

10.2  QC Management
      Each monitoring activity shall  document and implement a quality
      assurance policy approved by management to  assure that  sufficient
      quality control activities are  maintained to assure data
      credibility for each monitoring project.  Each monitoring project
      shall designate a Quality Assurance/control coordinator (preferably
      full-time) to be responsible for the environmental  QC program,
      coordinators can be appointed for  specific  monitoring activities,
      i.e., Air coordinator, water coordinator.

      a.  Qualifications
          1.  The coordinator should  have  as  a minimum  a bachelor's
              degree in physical  science,  chemistry, biology  or microbiology,
              with  at least five years of  experience in his respective
              discipline.   In addition,  the coordinator must  have
              actively worked in a environmental  quality laboratory
              for at least two years.  Experience in statistical quality
              control techniques and/or  academic  courses in mathematics
              and statistics is also  highly desirable.

          2.  The coordinator maintains  close liaison with  the
              appropriate EPA Regional Analytical Quality Assurance
              Coordinator, and is responsible for the overall quality

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ORIGINATOR
RECORDS DETAILED
EXPLANATION ON THE
CORRECTIVE ACTION
REQUEST
       A^
     TAKES ACTION TO
     CHANGE  THE SYSTEM
     (LEVEL  I CORRECTION)
                                  OR
AND
DETERMINES THAT
ACTION IS NOT
REQUIRED
  /torn
THE FORM IS RETURNED
FOR RECORDS ANALYSIS.
REPORTS AND FOLLOW-UP BY
CORRECTIVE ACTION ANALYSt
             OR
     )ETERMINES  THAT ACTION
     IS REQUIRED BUT BEYOND
     FHE SCOPE OF  HIS AUTHORITY
          IF
ANALYSIS OF DATA RE-
PROTS  INDICATES THAT
ACTIONS IS NOT BEING
TAKEN  OR IS NOT EFFECTIVE
         THEN
DETERMINATION OF
RESPONSIBILITY IS
MADE AND ACTION
IS REQUESTED
AND
                                     Figure 10.1   Ac
                              PROPER LEVEL OF
                              MANAGEMENT  IS
                              NOTIFIED
                                        AND
MANAGEMENT REVIEWS
THE CAUSE AND DETER-
MINES THE PROPER ACTION
                                   AND
                              TAKES  ACTION  TO CHANGE
                              THE  WAY  OF  DOING BUSINESS
                              (LEVEL II CORRECTION)
                                                             OR
                                   DETERMINES THAT ACTION
                                   SHOULD  NOT BE TAKEN
                                                             OR
                              RETURNS THE PROBLEM
                              TO LEVEL I
                                                         AND
                              RECORDS DETAILED
                              EXPLANATION ON THE
                              CORRECTIVE ACTION
                              REQUEST
                          NL
                                                                       AND
THE FORM IS RETURNED
FOR RECORDS ANALYSIS.
REPORTS AND FOLLOW-UP BY
CORRECTIVE ACTION ANALYST
                                                                       IF
ANALYSIS OF DATA
REPORTS INDICATES THAT
ACTION IS NOT BEING
TAKEN OR IS NOT
EFFECTIVE
                                                                                                 THEN
                                                            DETERMINATION  OF
                                                            RESPONSIBILITY IS
                                                            MADE  AND ACTION IS
                                                            REQUESTED
                                 osed-loop  corrective action  system

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                            96

        assurance program in his  laboratory.  The coordinator
        should report  to  the appropriate  level:  It is highly
        desirable that this  function  not  be subordinate to an
        individual responsible  for direct conduct of sampling or
        analyses.  This arrangement is  workable, however, if the
        individual responsible  for sampling and  analyses maintains
        an objective viewpoint.   While  the overall program workload
        will  determine whether  this position  is  a full-time or
        part-time responsibility, it  should,  in  most cases be
        full-time.

b.  Duties and Responsibilities
    The coordinator is responsible for  developing and implementing
    an inter-and-intralaboratory  quality  control program.  Specific
    duties include, but are  not necessarily limited to:

    1.  Participating  in  the overall  quality  control plan.
        This  includes  all elements of the sampling and analytical
        programs.  The coordinator carries out this activity
        within EPA quality control and  methodology guidelines.
        Other recommended and accepted  procedures can be used to
        supplement these  guidelines.

    2.  Administering  the inter!aboratory quality control
        program as a continuing .in-house  activity to ensure the
        integrity and  validity  of analytical  data.

    3.  Measuring the  precision and/or  accuracy  of analytical
        results.  Providing  on-line quality control of samples,
        i.e., reference samples,  duplicates,  control charts,
        spiked, and audit samples.

    4.  Providing a permanent record  of instrument and analyst
        performance as a  basis  for evaluating data.

    5.  Identifying training needs and  technical methodology
        gaps.

    6.  Upgrading the  overall quality of laboratory performance
        by recommending procedural and  personnel changes, as  required,
        to ensure the  validity  and integrity  of  the data.

    7.  Coordinating the  inter-and-intralaboratory quality control
        program with the  QAO, Region  V, and other governmental and
        commercial laboratories.   This  involves  participating in

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                                     97

                  round-robin  methodology  studies, providing quality control
                  check  samples,  and  performance of check  samples to requesting
                  laboratories.

              8.   Evaluating and  discussing the results  of activities
                  outlined  in  Paragraphs 1 through 7 with  the appropriate
                  individuals  involved.  When  an analysis  is out of control
                  or a  discrepancy  is noted, the coordinator should be
                  notified  and appropriate corrective action should be
                  taken.

          c.   Competence of Personnel
              The coordinator  should  develop a training  program to
              ensure a  minimal  level  of  proficiency.  He must recognize
              variations in ability and  provide training to ensure that
              professional  skills are appropriate to the task.  Training
              programs  should  be  administered  in order to  develop that
              level  of  competence which  is necessary to  carry out assigned
              functions.  Moreover, these  programs should  be carried out in
              full  cooperation with EPA  Region V, Quality  Assurance Office.

          d.   Basic  facility and  Equipment Requirements
              The coordinator  should  establish basic requirements
              (equipment, proper  facilities, etc.) for operating an
              environmental laboratory.  These requirements should not be
              included  as part of the quality  assurance  budget.  Laboratory
              facilities should provide  an environment free from atmospheric
              contaminant levels  which can affect the desired analyses.
              The laboratory should be clean,  air conditioned and/or heated,
              and have  a well  lighted work area.  Safety features and
              other facilities consistent  with opeational  requirements
              should be provided.

          e.   Initial On-Site  Laboratory Evaluation
              The coordinator  will  implement his planned quality assurance
              program with  an  initial on-site  laboratory evaluation.
              Subsequent performance  of  analysis on audit  samples and
              participation in split  sample program with the EPA regional
              office should also  be required.

11.    DATA QUALITY ASSESSMENT

        The assessment  of data quality is  the  end result in a comprehensive
        QC/QA program.   Data quality  assessment has four basic components:
        1) accuracy, 2)  precision,  3) completeness, and  4)  representativeness.

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                              98

Each of these Items is quantifiable and when suitably combined can
produce a numerical coefficient which is numerically proportional  to
data quality.

A complete assessment of data quality, in terms of the four
components, is not possible at this time.  However, this is the
primary goal of this QA effort.  Air data is more advanced that
water and wastewater data at this time for such a comprehensive
assessment of data quality.  However, with the implementation of
this plan during FY 80, a numerical assessment will be factored
into the FY 81 QA program plan activity.  The primary key in this
activity is to get all quality control programs developed, approved
and implemented.

The four basic components of data quality assessment have been
elaborated on in great detail and their requirements are listed
elsewhere in this document, but will be summarized below.

11.1  /CCUR/CY ASSESSMENT

      The QA Plan shall require that the accuracy of environmental
      data be determined and reported provided that certified
      reference materials are available or that measurements can
      be traceable to a national standard.

11.2  PRECISION ASSESSMENT

      The Region V QA Plan requires that the precision of
      environmental data be determined on a routine basis and
      reported to the suitable management authority as spelled out
      in the QA and QC Management Section of this document (11.1 -
      11.2).

11.3  COMPLETENESS ASSESSMENT

      The Region V QA Plan requires that the completeness of
      environmental data be assessed on a routine basis and reported
      to the suitable management authority based on approved methodology.
      Where the method is unapproved an alternate test procedure
      approved by the Regional Administrator, shall be used.  In
      certain specific cases where methodology does not exist, the
      QAO will request EMSL to specify a methodology for the Agency's
      use.

11.4  REPRESENTATIVENESS ASSESSMENT

      The Region V QA Plan requires that the representativeness of
      environmental data be assessed on a routine basis and reported

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                                      99

              to the suitable management  authority  using  approved method-
              ology.  Where the method is unapproved, the same  protocol
              specified in 11.3 is  to  be  followed.

        11.5  OVERALL DATA QUALITY  ASSESSMENT

              Overall data quality  assessments  are  to be  included with
              each data report for  water  and wastewater at the  start of  FY
              81.  The overall data quality assessment for air  data is
              presently being reported.

12.   DATA QUALITY REPORTS (QC AND  QA)

      The following types of QC, QA reports are to  be prepared  by each
      monitoring group. These reports  serve as  a indicator of the monitoring
      group's progress in implementing its Quality  Assurance Program, which
      monitor the various subunits1  performance of  quality control procedures
      and achievement of quality assurance goals.

      1.  Analytical reports.  To maintain the  required- flow of QA and QC
          information within a monitoring group, individual analysts, operators
          and laboratories need to  prepare QC reports on  their  monitoring
          and measurement activities.   These reports are  forwarded to the
          QA coordinator, who then  writes a QA  report for the entire laboratory
          organization.

      2.  Field Location reports.  QC  data for  remote monitoring sites
          must be developed and transmitted, either individually or grouped
          by location (i.e., sectional or regional), to the QA  coordinator.

      3.  Instrument inspection, calibration and. maintenance reports.  How
          the instruments used in monitoring or measurement procedures are
        •  inspected and maintained  should be explained in a report to the
          QA coordinator.

      4.  Reference materials and standards reports.  The reference materials
          used and standards followed  must be stated.  These reports should
          cover not only, for example, the purity of chemical reagents,
          but biological materials  (such  as a discussion  of the availability
          of a particular plant needed in experiments) as well.

      5.  Training reports (personnel).   Who was given quality  assurance
          and/or quality control training? Did this training take place
          in-house? How much did this  training  cost?  The training reports
          will answer these questions.

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                                     100

      6.   Certification reports.   These reports  will  be  generated only
          for the public water supply laboratory certification program.
          The procedures for performance  evaluation  and  certification of
          both laboratories  and personnel  will be detailed in these  reports.

      7.   Quality assurance  reports.   Reports  detailing  the  unit's quality
          control and quality assurance activities should be published on
          a quarterly basis.

      Distribution of and follow-up to these  reports for corrective  action
      will be the same as that described  for  all other types of  reports
      described elsewhere in this  document.

13.    CHAIN OF CUSTODY

      The following procedures have been  used  successfully,  and  are
      presented as suggested procedures insofar  as they  fulfill  the  legal
      requirements of the appropriate State legal authority.

      a.   Procedures
          Quality assurance  should be stressed during all compliance
          monitoring and when reviewing self-monitoring  programs, no matter
          what the reason for the  spot check  or  inspection.  Successful
          implementation of  a compliance  monitroing  program  depends  heavily
          on the capability  to produce valid  data, and on clearly demonstrating
          such validity.  No other environmental monitoring  area requires
          more rigorous adherence  to  validated methodology and quality
          control measures.

          It is imperative that laboratories  and field operations involved
          in collecting primary evidence  prepare written procedures.  These
          procedures should  be used whenever  evidence samples are collected,
          transferred, stored, analyzed,  or destroyed.   A primary objective of
          these procedures is to create an accurate  written  record which can  be
          used to trace possession of the sample from the time it is collected
          through its introduction into evidence.

      b.   Preparing Samples
          The evidence-gathering portion  of a survey is  characterized by an
          absolute minimum number  of  samples  required to give a  fair
          representation of  the effluent  or water body sampled.  The quantity
          and location of samples  are determined before  the  survey.

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                               101

    Prepare chain-of-custody record  tags  before  actual  field  survey
    work.   Ensure tags contain all possible  information to minimize
    clerical  work by field personnel.   Also  write  the  source  of each
    sample on the container before starting  any  field  survey  work.

    Field logsheets used to document field procedures  and chain-of-
    custody,  and to identify samples,  should be  pre-filled in to the
    extent practicable to reduce repetitive  clerical field entries.
    The sampler or project leader should  maintain  custody during
    sampling, using the logbook.  Any information  from previous
    studies should be copied (or removed) and filed before the logbook
    is returned to the field.

    Follow explicit chain-of-custody procedures  to maintain the
    documentation necessary to trace sample  possession from the time
    the sample is taken until  the evidence is introduced into court.
    A sample  is in your custody if:

    o It is in your physical  possession;  or

    o It is in your view, after being in  your physical  possession; or

    o It was  in your physical  possession  and you locked it in a

      tamper-proof container or storage area.

    All survey participants should receive a copy  of the study plan
    and should be familiar with its  contents before the survey begins.
    A pre-survey briefing should be  held  to  inform all  participants
    of the survey objectives,  sample locations and chain-of-custody
    procedures.  After all chain-of-custody  samples are collected, a
    debriefing should be held  in the field to verify that chain-of-custody
    procedures have been followed, and to determine if additional
    evidence  samples are required.

c.  Collecting Samples

    1.  Ensure that the smallest possible number of people handle
        the sample.

    2.  Obtain stream and effluent samples using standard field
        sampling techniques.   When using  sampling  equipment,  assume
        it is in the custody of the  source being sampled.

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                           102

3.  Attach chain-of-custody record tag to the sample  container
    when the complete sample is collected.   Ensure  the  container
    has the fallowing information: sample number, time  taken,
    date taken, source of sample (include type of sample  and
    name of firm), preservative, analyses required, name  of
    person taking sample, and witnesses.   The front side  of the
    card (which has been prefilled)  is signed, timed, and dated
    by the person doing the sampling.   Tags  must be legible and
    filled out in ballpoint (water-proof  ink). Secure  individual
    sample containers or group of sample  containers using a tamper-
    proof seal.

4.  Take blank samples.  Include one sample  container without
    preservative, and containers with  preservatives.  The laboratory
    will analyze these contents to verify that no containers are
    contami nated.
                                                    a
5.  Maintain an up-to-date Field Data  Record Logbook.   Record
    field measurements and other pertinent information  necessary
    to refresh the sampler's memory if, later on, he takes the
    stand to testify regarding his actions during the evidence-
    gathering activity.  Maintain a separate set of field notebooks
    for each survey; store them in a safe place where they can
    be protected and accounted'for at  all  times.  Standard formats
    have been established to minimize  field  entries; these include
    the date, time, survey, type of sample taken, volume  of each
    sample,  type of analysis, sample number, preservatives,
    sample location and field measurements (temperature,  conductivity,
    DO, pH,  flow), and any other pertinent information  or observations.

    The field sampler signs the entries.   The survey coordinator
    is usually responsible for preparing  and conserving the field
    logbook  during the survey.   Once the  survey is complete,
    field logs will be retained by the survey coordinator or his
    designated representative,  as a  part  of  the permanent record.

6.  The field sampler is responsible for  the care and custody
    of the collected samples until  they are  properly dispatched
    to the receiving laboratory, or turned over to an assigned
    custodian.  The field sampler should  verify that each container
    is in his physical  possession or in his  sight at all  times,
    or is locked so that no one can  tamper with it.

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                               103

    7.   Colored slides or photographs  are  often taken  to  show the
        outfall sample location and any visible water  pollution.
        Written documentation on the back  of the  photo should include
        the photographer's signature,  and  the time,  date,  and site
        location.   These photographs can be  used  as  evidence, and
        are handled by chain-of-custody procedures to  prevent alteration.

d.  Transfer of Custody and Shipment

    1.   When transfer!ng the possession of samples,  the transferree
        signs, dates, and times the reverse  side  of  the chain-of-
        custody record tag or record.   Custody tranfers,  if made to
        a sample custodian in the field, are made for  individual
        samples.  The chain-of-custody tag or card must be dated and
        signed by the second person who takes custody. If a third
        person takes custody, he must  follow the  same  procedure.  An
        additional  chain-of-custody tag or card is completed by
        persons who thereafter, take custody. It is apparent, from
        this chain, that the number of custodians should  be minimal.
        Additional  tags or cards should be numbered  consecutively.

    2.   If a custodian has not been assigned, the field custodian
        or field sampler is usually responsible for  properly packaging
        and dispatching samples to the proper laboratory  for analysis.
        In that case, the "Dispatch of Sample" portion of the chain-
        of-custody record tag or card  should be properly  filled out,
        dated, and signed.

    3.   Ensure that samples are properly packed in shipping containers
        (for example, ice chests) to avoid breakage.  Ensure that shipping
        containers are padlocked for shipment to  the receiving laboratory.

    4.   Include a "Sample Transmittal  Sheet" with all  packages.
        The original, and one copy generally accompany the shipment.
        Mail copies directly to the laboratory, to data management
        personnel, and to any other responsible agent. The survey
        coordinator usually retains one copy.

    5.   If the package is sent by mail, ensure that  it is  registered
        with return receipt requested.  If package is  hand-delivered,
        record delivery in the logbook. Send receipts from post
        offices and bills of lading to the laboratory  custodians for
        retention as part of the permanent chain-of-custody documentation.

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                           104

6.  When samples are delivered to the laboratory,  and  appropriate
    personnel are not there to receive them,  samples should be
    locked in a secure, tamper-proof area.  The  same person must
    unlock the samples and deliver custody  to the  appropriate
    custodian.

LABORATORY CUSTODY PROCEDURES

The following procedures are to be used by  Region  V monitoring
activities to provide the chain of possession and  custody of any
sample offered for evidence, and for which  analytical  test
results amy be introduced into evidence in  any environmental case.

The primary objective of these procedures is  to  create an accurate
written record which can be used to trace the possession and
handling of the sample from the moment of collection through
analysis and its introduction as evidence.

1.  The laboratory director will designate  one full-time employee
    (usually the laboratory supervisor) as  a  sample custodian,  and  one
    other person as an alternate.  In addition,  the laboratory  must
    provide a sample storage area that is secure and can be locked.

2.  All samples will be handled by a minimum  possible  number of
    persons.

3.  Only the custodian will receive incoming  samples.   If he is
    absent, the alternate will indicate receipt  by signing the
    sample transmittal sheets and, (as appropriate), the sample
    tags which accompany the .samples.  The  alternate will retain
    the transmittal sheets as permanent records.

4.  The custodian shall ensure that heat-sensitive, light-
    sensitive samples, radioactive, or other  sampe materials having
    unusual  physical characteristics, or requiring special handling,
    are properly stored and maintained prior  to  analysis.

5.  Distribution of samples to the section  chiefs  who  are
    responsible for the laboratory performing the  analysis
    shall be made only by the custodian.

6.  The laboratory area shall be maintained as a secured area,
    restricted to authorized personnel only.

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                           105

7.  Laboratory personnel  are responsible for the care and  custody
    of the sample once it is received by them and shall  be prepared
    to testify that the sample was in their possession and view
    or secured in the laboratory at all  times from the moment  it
    was received from the custodian until  the time that  the
    analyses were completed.

8.  Once the sample analyses are completed, the unused portion
    of the sample, together with all  identifying labels, must  be
    returned to the custodian.  The returned, tagged sample,
    should be retained in the custody room until permission to
    destroy the sample is received by the custodian.

9.  Samples shall be destroyed only upon the order of the
    Laboratory Director,  in consultation with previously designated
    Enforcement officials, or when it is certain that the  information
    is no longer required or the samples have deteriorated. The  same
    procedure is true for tags and laboratory records.

EVIDENTIARY CONSIDERATIONS

Reducing chain of custody procedures  as  well  as the various
promulgated laboratory analytical  procedures to writing  will
facilitate the admission  of evidence  under rule 803(6) of  the
Federal Rules of Evidence (PL. 93-575).   Under this statute,
written records of regularly conducted business activities" may
be introduced into evidence as an exception to the "Hearsay
Rule" without the testimony of the person(s)  who made the  record.
Although preferable, it is not always possible to have the individuals
who collected, kept, and  analyzed samples testify in court. In
addition, if the opposing party does  not intend to contest the
integrity of the sample or testing evidence,  admission under the
Rule 803(6) can save a great deal  of  trial  time.  For these
reasons, it is important  that the procedures  followed in the
collection and analyses of evidentiary samples be standardized
and described in an instruction manual  which, if need be,  can  be
offered as evidence of the "regularly conducted business activity"
followed by the lab or office in generating any given record.

In criminal cases however, records and reports of matters
observed by police officers and law enforcement personnel  are  not
included under the business record exceptions to the "Hearsay  Rule"
previously cited (see Rule 803(8), P.L.  93-595).  It is  arguable
that those portions of the compliance inspection report  dealing

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                                    106

         with matters  other than  sampling  and analysis results come within
         this exception.   For  this  reason, in criminal actions records and
         reports of matter observed by field investigators may not be
         admissible and  the evidence may still have to be presented in
         the form of oral  testimony by the person(s) who made the record
         or report, even though the materials come within the definition
         of business records.   In a criminal proceeding, the opposing
         counsel may be  able to obtain copies of reports prepared by
         witnesses, even if the witness does not refer to the records
         while testifying, and if obtained,~ the records may be used for
         cross-exami nati on purposes.

         Admission of  records  is  not automatic under either of these
         sections.  The  business  records section authorizes admission
         "unless the source of information or the method or circumstances
         or preparation  indicate  lack of trustworthiness," and the caveat
         under the public records exception reads "unless the source of
         information or  other  circumstances indicate lack of trustworthiness".

         Thus, whether or not  the inspector anticipates that his or her
         compliance inspection report will be introduced as evidence, he or
         she should make certain  that the  report is as accurate and objective
         as possible.

14.  SPECIFIC GUIDAfCE

     American Public Health Association, American Water Works Association,
          and Water Pollution  Control Federation.  1975.  Standard Methods
          for the Examination  of  Water and Wastewater.  14th Edition.
          Washington,  D.C.

     American Society  for Testing and Materials.  1978.  Annual 3ood of
          ASTM Standards, Part 31:   Water.  Philadelphia, Pennsylvania.

     Bieking, C., 01 in,  S., and King, P.   1978.  Procedure for the Evaluation
          of Environmental Monitoring Laboratories.  U.S. Environmental
          Protection Agency, Environmental Monitoring and Support Laboratory,
          Office of Research and  Development, Cincinnati, Ohio.
          EPA-600/4-78-017.

     Codified Federal  Regulations:  40 CFR  Part 35, 50, 51, 52, 53, 58,
          136, 141 and 250.

     Harris, D.J. and  Keffer,  E.J., June 1974.  Wastewater Sampling
          Methodologies  and Flow  Measurement Techniques.  U.S. EPA,
          Region VII,  Kansas City,  Missouri.  EPA-907/974-005.

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                               107

Kulin, Gershon.  May 1975.   A Guide to Methods and Standards for the
     Measurement of Water Flow.  U.S.  Government Printing Office,
     Washington, D.C.  National Bureau of Standards Special
     Publication 421.

lauch, R.P.  April  1975.  Peformance of ISCO Model 1391  Water and
     Wastewater Sampler.  U.S. Environmental Protection  Agency,
     Cincinnati, Ohio.  EPA-670/4-75-003.

Lauch, R.P.  April  1975.  Application and Procurement of Automatic
     Wastewater Samplers.  U.S. Environmental Protection Agency,
     Cincinnati, Ohio.  EPA-670/4-75-003.

Lauch, R.P.  September 1976.  A Survey of Comrnercially Available
     Automatic Wastewater Samplers.  U.S. Environmental  Protection
     Agency, Cincinnati, Ohio.  EPA-600/4-76-051.

Linen, A.L.  1973.   Quality Control for Sampling and Laboratory
     Analysis.  In:  The Industrial Environment—Its Evaluation  and
     Control, pp. 277-297.   U.S. Department of Health, Education,
     and Welfare, Public Health Service, Center for Disease  Control,
     National Institute for Occupational Safety and Health.

Sherma, J.  1979 (1st revision).  Manual of Analytical Quality Control
     for Pesticides and Related Compounds in Human and Environmental
     Samples:  A compendium of Systematic Procedures Designed to
     Assist in the Prevention and Control of Analytical  Problems.
     Prepared for U.S. Environmental  Protection Agency,  Office of
     Research and Development, Health  Effects Research Laboratory,
     Research Triangle Park, North Carolina.  EPA-600/1-79-008

Smoot, C.W.  November 1963.  Orifice Bucket for Measurement  of Small
     Discharges from Wells.  Water Resources Division Bulletin,
     Illinois Water Survey, Champaign, Illinois.

U.S. Army.  Environmental Effects Laboratory.  May 1976.   Ecological
     Evaluation of Proposed Discharge  of Dredged or Fill  Material
     Into Navigable Waters: Interim Guidance for Implementation
     of Section 404(b)(l) of Public Law 92-500 (FWPCA of 1972).
     U.S. Army Engineer Waterways Experiment Station, Vicksburg,
     Mississippi.  Miscellaneous Paper D-76-17.

U.S. Department of Interior.  Bureau of Reclamation.   1974.   Second
     Edition, Revised.  Water Measurement Manual, U.S. Government
     Printing Office, Washington, D.C.

-------
                               108

U.S. Environmental  Protection Agency,   n.d.   EPA Project  Officer's
     Guide (Research 4 Demonstration Grants).   U.S.  Environmental
     Protection Agency, Office of Planning  and  Management,  Office of
     Administration, Grants Administration  Division,  Washington, D.C.

U.S. Environmental  Protection Agency,   n.d.   Guidance Package  for
     Evaluation of State Laboratories  (Source Sampling)—Draft.
     Cincinnati, Ohio.

U.S. Environmental  Protection Agency.   1976.  Minimal Criteria and
     Procedures for the Evaluation  of Ambient Air Monitoring
     Programs—Laboratory and Field.  Draft  III.

U.S. Environmental  Protection Agency,  Enforcement Division.  Office
     of Water Enforcement.   Compliance Branch,   n.d.   NPDES Compliance
     Sampling Manual.  Washington,  D.C.   MCD-51.

U.S. Environmental  Protection Agency.   Health Effects Research Lab-
     oratory.  Environmental Toxicology  Division.  1974,  1977  rev.
     ed.  Analysis of Pesticides Residues in  Human and  Environmental
     Samples:  A Compilation of Methods  Selected for Use  in Pesticide
     Monitoring Programs.  Edited by J.F. Thompson.   Research  Triangle
     Park, North Carolina.

U.S. Environmental  Protection Agency.   Office of Research and  Development.
     Environmental  Monitoring and Support Laboratory.   1976.   Quality
     Assurance Handbook for Ai-r Pollution Measurement Systems:
     Volume I— Principles.   Research Triangle Park,  North Carolina.
     EPA-600/9-76-005.

U.S. Environmental  Protection AGency.   Office of Research and  Development.
     Environmental  Monitoring and Support Laboratory.   1977.   Quality
     Assurance Handbook for Air Pollution Measurement Systems:
     Volume II—Ambient Air Specific Methods.   Research Triangle
     Park, North Carolina.   EPA-600/4-77-027a.

U.S. Environmental  Protection Agency.   Office of Research and  Development.
     Environmental  Monitoring and Support Laboratory.   1977.   Quality
     Assurance Handbook for Air Pollution Measurement Systems:
     Volume Ill—Stationary Source  Specific Methods.   Research
     Triangle Park, North Carolina.   EPA-600/4-77-027b.

U.S. Environmental  Protection Agency.   Office of Research and  Development.
     Environmental  Monitoring and Support Laboratory.   1978.
     Environmental  Radioactivity Laboratory  Intercomparison Studies
     Program, 1978-1979.   Las Vegas, Nevada.  EPA-600/4-78-032.

-------
                               109

U.S. Environmental  Protection  Agency.   Office  of Research  and  Development.
     Environmental  Monitoring  and Support  Laboratory.   1979.   Handbook
     for Analytical  Quality Control  in Water and Wastewater  Lab-
     oratories.   EPA-600/4-79-019.

U.S. Environmental  Protection  Agency.   Office  of Research  and  Development.
     1978.  Manual  for the Interim Certification of  Laboratories
     Involved in Analyzing Public Drinking Water Supplies, Criteria
     and Procedures.  EPA-600/8-78-008.

U.S. Environmental  Protection  Agency.   Office  of Research  and  Development.
     Environmental  Monitoring  and Support  Laboratory.   1979.   Methods
     for Chemical  Analysis of  Water  and  Wastes.   Cincinnati, Ohio.
     EPA-600/4-79-020.

U.S. Environmental  Protection  Agency.   Office  of Water  Planning and
     Standards.   Monitoring and Data Support Division and  Environmental
     Monitoring  and Support Laboratory.  Minimal  Requirements  for  a
     Water Quality Assurance Program,  Cincinnati, Ohio.  EPA-440/9-75-010.

Weber, C.I., ed.  1973.  Biological  Field  and  Laboratory Methods for
     Measuring the Quality of  Surface  Waters and Effluents.  U.S.
     Environmental  Protection  Agency,  National  Environmental Research
     Center, Office of Research and  Development, Cincinnati, Ohio.
     EPA-670/4-73-001.

-------
                                                               APPENDIX 1
                                                       QUALITY ASSURANCE OFFICE
                                                             FY 80 WORK PLANS
                                                                                                                                of  Z3
oiCAMiZATtONi   Quality Assurance Office, S4A Division'
DECISION UMIT(*)I A-235 Air Quality Monitoring
         James H. Adams, Jr.
. SLAMS Metwork Monitoring r *
MLIETTIVII Assure that QA Programs arc a part of. and adequate for' KM EPA grants and contracts which include
" * •' wonltoHnq equipment. ,' .-•-.•
ttl fCflOM BTBTB
: ••••- *• . i -
1. Review six State grant requests and requests •
for equipment. Recommend approval/disapproval.
Monitoring equipment mist meet requirements
specified in the regulations.
' *



2. Review local Agency grant request and request
for equipment. Recommend approval/disapproval.
Monitoring equipment must meet requirements
specified in the regulations.
* * 1
f< ASSM. ',
UfrO|SIBIUTT
.",'*
Yp-ung/Jtocal
f

i ;
* ;
• *
Young/ Koctl
•
.
lom m 101
BUI
BATE3

S 'days
after
receipt
of
request



5 days
after
receipt
of
request

• INra/INTlUl ORCAHIUTIOtlAI.
pinzquisiTES/LiHucu/ASswrnniii , .
i •• • *
QAO's role not addressed in the approved
work plan package. Coordinate with TSB
Air.




4
Coordinate with TSB Air.

•
t
tun
COKr.










UCfOi
cut
•T










b/HONmuMa
COUECTIVX
ACTION









•


-------
                                                            APPENDIX  1  (Continued)


                                                          QUALITY ASSURANCE OFFICE

                                                                FY 80  WORK PLANS
                     Quality Assurance Office. SIA Division
       DECISION UKIT(«)i A-23S Air Quality Monitoring
       HAHACUI  James H. Adams. Jr.    .                ,
IVITT Implement Air Monitoring Quality Assurance' .. .
oBJirrivEi To Insure that the quality of data collected, reported* 'of. used by the Agency is properly documented.
KIT l£T{W 8TYPfl
- " , - .-...- ., ; .-
1. Develop and Implement a interim Regional quality
assurance program for air that has COP capability
for a more efficient approach to data handling and
provide a more accurate database to evaluate and
Improve analytical performance of all Region V,
Federal. State and local laboratories generating
air quality monitoring data. Implement final
revision of National Quality Assurance Plan when
received.
t
2. Evaluate QC policy and programs for all six
Region V States per criteria specified In
40 CFR Part 58. including management and
documentation of the program.

3. Develop system to consolidate TSB/Alr and QAO
reviews of State air Agency monitoring and QA
programs. ' •

••
, m
M^SUJUW
•Young/Adams
• * .



.


•
(
Young/Koran


1
-
Adams




i
•mi
DATM
Target
date of
1/15/80
no
later
than
3/15/80



20 days
after
receipt
of
request
12/30/7





• IHTD/IHIU OBCAHIUTIOHAL
This action step will be performed in
conjunction with DO 8-224. OU 8-303. OU
8-209. DU c-215 and OU B-241. Development
and Implementation of EOF part of program
depends on funding of the software package
(programs) requested in the QAO FY 80
budget. Implementation of National QA
programs depends on receipt from
Headquarters.

Coordinate with TSB/Alr. •



' •
i Crosscut issue with TSB/Alr.

•
•
.

• _
DATl
COHF.
.-




















Mam
cut
n





















B/MOMTI01IlKt
GOBUcnvx
ACTIOM






1

•







• .

1
* •

        r»» m 101
II
I

-------
                                                       APPENDIX 1  (Continued)

                                                     QUALITY  ASSURANCE OFFICE
                                                          FY 80 WORK PLANS
                                                                                                                       Eit« 3  of	Z3_
ORCANIZATIOHI  Quality Assurance Office. SIA Division
DECISION imiT(*)i  A-235 Air Quality Monitoring
MANACOU  Jaries  H. Adams, Jr.     •                .
/urnvmi Implement Air Hanltorlrig Quality Assurance . :• ^ .. .•
KET fCfftti STOF* ..'
- ••: • • . -I - i -
• 4. Review for 'approval or disapproval six Regloa'V
105 grants for Agency quality assurance
requirements.

•
*
•
S. Manage eleven EHSL-RTP Inter-Lab Surveys for
Region V State and local laboratories. Data
Is reviewed and proficiency of lab is
measured. Follow-up letters are provided for
problems Identified to the State and the local
Agency laboratories.
i
:
• • i

.
j * torn fU 101
F ASSM. ';
ujrajsmuTT
i^1"!'* '
• Toung/Horan


•
' : '
i
Young/Horan

,
1

•
I


1
1

!DUE
DATES

5 -days
after
receipt
of
grant


10 days





*





•
• INTO/IHTU ORCANIUTIONAt
•• •
Linkage • TSB/AIr and AIM.





Coordinate with EHSL-RTP. '



•

i •
*
,


TtAcniw/HMrnotnw
tun
COM?.





•












CMC
M


















oouucnvi
ACTIOM





.







•

.


.

-------
                                                            APPENDIX 1  (Continued)
                                                         QUALITY  ASSURANCE OFFICE

                                                               FY  80 WORK PLANS
                                                                                                                              Nn<  at  23
        OICANIZATIONI  Quality Assurance Office. StA Division
        DECISION imiT(«)t   A-235 Air Quality Monitoring
        KAHACHU  James II. .Adams. Jr.                    ,
.CTivini Data Reporting and Analysis '•• •.
OBJtctivii To ensure that all data reported out of .the StA Dlvls(Unja'nd Region V States meets Agency requirements
»e cnollait nut In Hia ironulaHnnt f r Cllfflf Innt nl liHfru : iH cultaKIa nuaKtti
KIT fCTJON Sntt
••
	 :-- -••: l - i -L •••
1. Perform four data Duality assessment audits of* •
the data reporting and analysts function of tha
TSB. Air. This function will be performed on a
quarterly basts with report to management.

• ,



.
. •

* • ' t
1 *
* •
upaismLm
V6ung/Horan
i


§


•
I
• 4
1
1
1
5 WE
DATM
10 days
after
end of
each
quarter







•

• IHTU/INnA ORGANIZATIONAL
QAO's role not addressed In the approved
work plan package. However, part of QAO's
responsibility is evaluating StA
monitoring activities of which data
reporting and analysis is part of any
monitoring project. Resources not
provided for this activity. However. It
will be piggy backed on to other DU A-235
activity that ts funded.

•
•• .


TtACUflG/HOWITOlIM}
DAT!
GOT
•:











cut
n












cotucrm
ACTI6M




i

a


*


••
I
Font ru 101


        ••u

-------
                                                       APPENDIX  I (Continued)

                                                     QUALITY ASSURANCE  OFFICE
                                                           FY 80  WORK  PLANS
ORGANIZATION!   Quality Assurance Office, SftA Division'
DECISION iRUTMi A-235 Air Quality Monitoring
MAHACUU   James H. Adams. Jr.
AcmiTTi Implement Air Monitoring Regulations r- *
outctmt To ttandardlie all air monitoring In Region V States b>: Implementation of 40 CFR Part SB Appendix A.
LOfrp j f*£() | P lfj}{ii I*l*/|l^| r**^ fpfpyPpfp ^n A . rfummn rr.ii*A rtinsiar*;! ft ^/imn*>»«ft
KEI fCTJON STEPS .'
'* >
1. Coordinate and overview fifteen audits of won! tors
operated by State and local Agencies which are to
be provided by EKSL-RTP. Reports and follow-up
will be provided by QAO to the States and local
Agencies. (EHSL-RTP has funds to provide this
technical assistance to Region V. Plan has been
finalized by QAO).
' * "•
•
2. QAO will conduct a auxinuM of twelve additional
audits (as 1 above) with follow-up.


^ • •
f ASSM. •;
UfrOdSItlUTT
Vdung'/Kocal






• •

Voung/Kocal

.

'
row m 101
DUE
DATU
10 days
after
receipt
of RTP
finding




Six in
3rd Qtr
Six In
4th Qtr
•

• IHTU/INTBA OBCANIZATIOHAL rfjta.
This step Is based oh EHSL-RTP following
through on this comnlUient to Region V.
QAO Is seeking to have RTP schedule this
activity the 3rd quarter of FY 80. The
entire effort will be coordinated with
EHSL-RTP.



Report turn around time will be 20 days
after the date of audit.. Completion of
this action step depends* on full funding
of QAO's travel request budget for FY 80
air activity.

TUCUHQ/HQNITOIDU
'DAT!
COM?.
_.














cut
n














comcnvi
ACTION







•
\




•


-------
                                                        APPENDIX
                                                      QUALITY ASSURANCE OFFICE
                                                            FY 80  WORK  PLANS
                                                                                                                            « 6  of  23
ORCAMIZATIOMI    Quality Assurance Office, StA Division
DECISION UMIT(«)i A-235 Air Quality Monitoring
tutucm  James H.  Adams. Jr.
Aciivmi .Implement Air Monitoring Regulations on Quality Assurance
OBJEcmn Implement a system audit program designed to upgrade focal agency nonltoring activities compatabllity
KT fCTI0" 8TB>4
'* 1
' " ' t •:.-• ' -.« . J. -
1. Evaluate and approve local agency monitoring • .
programs for laboratory capability, quality
assurance practices and data validation.
Approximately 30 local Agency's are located in
|Ug Ion V.
•




•
.
.

-
•
• •
• •
. L fora m 101
UfrotSIBIUTf
Youiig/Horan

i
i
*

* »


,
-

'

'WE
PATC4
IS days
after
State
Eval.
21 days
after
local
agency
eval.







*


IKTO/IHTtA OBCiHIZATIOHAL
The QAO will evaluate the State's effort
in evaluating local agency's In their
respective State as part of the State
program evaluation (A-325 Implement Air
Monitoring QA). If deficiencies are
found, an on-stte system evaluation of
the local agency will be conducted. QAO
estimate that deficiencies will be found
In 80S (24) of the local agencies as a
result of the State review which will
entail 24 on-slte evaluations.

Completion of this action step Is based on
QAO receiving the level of travel funds
requested for FV 80 air activity.
*
j
i
' nuuxnu/NONnoina
DATB
coat.













dot
M













coKttcrm
ACTION




•







•
,

-------
                                                         APPENDIX.l  (Continued)

                                                      QUALITY ASSURANCE OFFICE
                                                            FY 80 WORK  PLANS
                                                                                                                     t«i«_7 of  23
ORCAMlZATlONi    Quality Assurance Office, SIA Division
DECISION UHlT(»)iA-305 Air Enforcement
MANACni  Janes M. Adams, Jr.
tCTiyjTi, Case Development Inspections ':.
OBJecrtvxi-A maJ°r function of the QAO is to conduct • vigorous 'auHtt program to Insure data reliability for all
enforcement derail proceedings. ,- • •• '
m fcyjoH stars
.* * •
^ " r •« . V -
. Seven ambient air quality studies have been
identified for FY 80. A maximum of three audits
(on-slte evaluations) will be conducted during
the life of each study for conformance with QA
requirements and for data validity.
•



t
• .

•


: 1
« : •. •
' '* '.
'
•« t
.
• •
M ASSM. ',
UfMElSIBILITT
tkung/Kocal
' * . *
1

*



.
'
•• •
. \

t
i :
*

*


•

" formtU JOI . 1 ^__ _,
•DUI
DATES
30 days
after
onslte
or
20 days
after
receipt
of DO's
audit
report
for
verifi-
cation



•



•


• IMTM/IHTKA ORGANIZATIONAL
PKUQUISlTeS/UHKACIU/ASSUKmntll .. ..
This activity will b'e coordinated with the
DO's, TSB Air and ; the Enforcement Division
A maximum of 21 audits/evaluations will
be conducted. On-slte evaluations (audits
are dependent on QAO receiving the level
of travel funds requested for FY 80 air
activity.


.


•


•

•
•
i

•

TUttijB/HMrnoinw
DATI
COM?
.








.













cat
n























coiucnvs
ACTION









.





•


1 1





-------
                                                     APPENDIX  1  (Continued)

                                                   QUALITY ASSURANCE OFFICE
                                                        FY 80 WORK PLANS
                                                                                                                     r«i»fl  of  23
             Quality Assurance Office. S1A Division '
DECISION imiT(*)i  A-305 Air Enforcement
tuiucui  James II. Adams. Jr.    '                   '
Acnwmi .Unleaded Gas Inspections
OBJECTIVKI- 'Ensure data quality is adequate for enforcement (Iegar)1p;roceed1ngs.
Kit ICTICM flftU
;,,.''•
.1. Review sample data- and qc data for validity.' . . :
Provide follow- up for problem correction where
problems are Identified in the audit process. A
maximum of six audits will be conducted.

*

% •
,
•
•
i
* • *
'• •
* •
BXSVOjfSHIUTI
Viuiifl
• 1 '
'
•

f .
1
\
•
1

•
!

'DOB
DATES
1Q day
after
recelp
of QC
data








•

• mm/iimu OSCANIZATIOHAL
The QAO will coordinate this' activity
with the DO'* and-CRL.
Sample and QC data will be evaluated two
times (2nd and 3rd quarters) for each
00 and the CM..



•

•
'
i

1
tun
COHT
t













raicxu
cut
n














HQ/NOHnomn
couzcnvz
ACTION





•
_•




;-
•


-------
                                                       APPENDIX  I  (Continued)

                                                     QUALITY ASSURANCE OFFICE
                                                           FY 80 WORK PLANS
OKGAMiZATioMi    Quality Assurance Office. StA Dlvlslol
OtcisiOH imrT(«)|A-305.A1r Enforcement
         JMKS II. Adams. Jr.
Acmirti >SD Monitoring *: :-,{...
ourcTlvti 'To Insure monitoring activity conform to the requirements specified In Appendix B, 40 CFR. Part 58.
KIT 4Cf |QM HITS
.•
•*• '. 4 • j. ••
t. PSD monitorfng has* not been addressed. Air ' .
Enforcement has Informed the QAO that there will
be approximately 40 PSD's. The authority for
approving the PSD monitoring can be delegated
to the States. Illinois. Indiana and Wisconsin
have made some progress in this program, no .
authority has been delegated to any Region V
States. Thus, Region V has this responsibility.
PSO permits requires the Implementation of
Appendix B. 40 CFR Part 58. The evaluation of
each PSO Is time consuming. Additionally, there
1s a requirement for audit.

•
i .
•• ; ; :
1
•
. " Fora m 101
[<' ASSN. 'i
ufrofsimm
YOung/Kocal
*


t


•

' 4
• i
*
i
•

1
;

'DOE
HUES
30 days
after
receipt
of
documts
ar
30 days
after
onslte





.



• mra/iimu ORCAHIZATIONAL
ruuquisiTES/LUiMCEa/ASsuKmnui - ..
Coordinate with TS^B/AIr and Air
Enforcement.



Completion of this action step is based on
receiving the level of travel funds
requested for air activity.



•

1
1
.


' nuxsMfiamonm
urn
CGHT.
•'















cut
M









'






OOEUCnVB
ACTIOM








* ,





i
•
.

-------
                                                         APPENDIX  1  (Continued)


                                                       QUALITY ASSURANCE OFFICE
                                                             FY 80 WORK PLANS
•  ORCJUUZATIONI Quality Assurance Office. S»A Division  '
  DECISION UHIT(«)»   B-209 Dredge and Fill
          James H.  Adams. Jr.
"' 	 Manage the QA Activity for the Ecological Evaluation of Proposed Discharge of Dredged or Fill Material
fcmtrtt provide a strong QA program to assure contract laboratqrV(sj are providing quality data for use In dec!:
OBJECT I vi ima jdng (hat accurately describe the characteristics/conccittratlon of constituents in the samples submit
,,._ '..^i '„_„,. 10 tiie laboratory. •"
p^tl Jtfcl 4^^ fl*a*" ,
? • : •-' i -
1. The QAO will, manage an tnteragency agreement with
; the Corps of Engineers in which ona IPA will be
i funded by the Corps for QAO to perform the
complete QA function for a maximum of eight
laboratories under contract to the Corps or •
lesser QC function for a larger number of labs. •
Included In this function are the on-slta
•valuations.
i * '
•

i
: 2. Manage reference sample program. EDP evaluation
of data with follow-up for problems.

,
• ' •
. •
« .
far* ttt 101
|! jus,. ~
upoqsmim
fiv1* •
lfA/Ad.anis
'



.

.
\
*
1

IPA/Adaos





•
'
'DUB

21- days
after
ansite









IS days
after
study
results
are
avail.


• IHTOt/IHTU ORCAHIZmONAL
i **•
This activity Is coordinated with the
North Central Division of the Corps of
Engineers. The first priority is to fill
the IPA slot.





'•


This activity Mill be coordinated with
EHSL-Cinclnnatl.




i
i
tto Navigable Uaters
ion nAaam/mrnoinu
Din
OOMT.




















cut
n




















ottucnn
ACTION








:













-------
                                                             APPENDIX 1  (Continued)

                                                           QUALITY  ASSURANCE OFFICE
                                                                FY  80 WORK PLANS
                                                                                                                            »«• 11 of
       ORCAMIUTIONI   Quality Assurance Office,  SKA Division!
       DECISION inUT(Oi B-224 Ambient Water Quality Monitoring
       KANACHI  James H. Adams, Jr.
'"" State and Internal Quality Assurance iked for Management Decisions
Acrmrri . provye a strong QA program to assure that water quality -monitoring data will meet Agency needs and
OBJECTWi requirements. ,' .'•:••
UT fCTU* *lt?* •
•• t
7 ••• . • •? • j. «•
1. Develop and Implement a Interim Regional quality
assurance program for water and wastewater that
has EDP capability for a more efficient approach
to data handling and provide a more accurate
database to evaluate and Improve analytical
performance of all Region V Federal, State and •
local laboratories generating water quality
monitoring data. Implement final revision of
national quality assurance plan whjsn received.
•

i •
• • f
ton m 101
P ASSN. '.
..; V
Piyne/ Adams
>
I
•
1

1

'DUE
DATES
Target
date
of
No
later
than
3/15/81


•


• iirra/nrm. ORCUHZATIONAL
mUQUISITKS/LIHKAGU/ASSUimflM* . ..
This action step will be performed In
conjunction with OU A-23S. DU B-303,
DU B-209, DU C-215. and DU B-241.
Development and Implementation of EOP
part of program depends on funding of the
software package (program) requested In
the QAO FV 80 budget.
.
•

i
T
un
CQKT.





RAcnn
cm
BT





c/Hwntunw
coEUcnvi
ACTION




• *

••
t

-------
                                                      APPENDIX 1  (Continued)


                                                    QUALITY  ASSURANCE OFFICE
                                                         FY  80 WORK  PLANS
             Quality Assurance Office. SIA Division '
DECISION imrtfOi   B-224 Ambient Water Quality Monitoring
tomcat  Jiffies II.  Adams. Jr.
^cnviTTi . state and Internal Qual ity Assurance used for Management Decisions
OBJECIIVII • . . • • i • '
KIT ^£f)OM 8TOT '
'" • i * •
•« .-. ' .j . »•
2. Review for approval or disapproval six Region V .
State 106 grants for agency QA requirements.
* '

.
3. Evaluate six State laboratories and the CM. for
confonnance with' Agency requirements (Annual
evaluations). Follow-up will be provided in areas
where problems are Identified. Some lab* will
require quarterly follow-up evaluations for
performance improvement. Reports will be
prepared.
4. Evaluate six State 106 quality assurance programs
for approval or disapproval. Follow-up provided
in areas where problems are identified. The CRL's
on-going QA program is also evaluated..
•

*
ufrojsuiun
Pa'yn'e/OPFT
• • '
'


pJne/Sturlno/
Marion
' '


Payne/Marlon


i
:
, font rtl 101
•Mil
turn
10- days
ifter
receipt
>f
ippllc.
30 days
tf
ansltt



10 days
receipt
f
irogram


i
• ma/ium OUUHIUTIOMU.
Coordinate with TSfe/llater.'
*


• •
Coordinate with TSB/Water. Completion of
this action step is based on QA receiving
the level of travel funds requested for
FV 80 ambient water quality monitoring
activity.


•
Coordinate with TSB/Uater. This step Mill
be performed In conjunction with Step 3
of this activity.

!• , .
i

• ,
urn
CCMt
,'













lion
cue
IT





-








B/tarnotna
couicrm





v •






•



-------
                                                         APPENDIX  }  (Continued)

                                                      QUALITY  ASSURANCE OFFICE
                                                            FY  80 WORK PLANS
                                                                                                                        • re   . •    .   i •«•«.»,«• 41
                                                                                                                        gate J 3  of L 2.3^
                                                                                                                                       .••
              Quality Assurance Office. S&A Division!
Decision U«r(«>i  B-22*'Ambient Water Quality Monitoring
KiKACtxi   Janes H. Adams, Jr.
/cmmi . state and Internal Quality Assurance Used for Management Decisions
ouccrivti- ' . ,••. v. '•
tact fCTfQit mwi
ij- •-..'• .} . j ••
5. Manage thef.E. and reference sample program for
Region V 106 laboratories. Data. evaluation will
be conducted.- Follow-up on problem areas
Identified will be provided (5 studies involving
IS State labs, CRL, a undetermined number of
NPDES dischargers and several commercial labs .
engaged In analyzing NPDES samples).

ft
6. Evaluate, approve or disapprove the quality
assurance requirements In all ambient water
contracts, grants and interagency agreements.
Approximately 23 - 208 agencies are involved.
plus any other 106 contracts, grants and Inter-
agency agreements. On-slte evaluation of the
laboratory(s) are conducted to Insure that •
quality assurance plan Is operational and all
equipment, supplies and personnel necessary for
successful completion of the project are
'available. I ;
,
•«
t
, farm tU 101
f<' ACSN. S
Payne/Long
• • '
'




.
Payne/Adams
•
•
1 .

-




<


•
•
•DUI
BAMS
IS- days
ifter
•ecelpt
if data
jval.
from
:MSL

21 days
jfter
•ecelpt
if all
iocumts
ind
mslte
*here
•equtrei
*




i
• IHTW/HrnLA OBCmZATIOHit
reaUCQUlSITES/UMKAGU/ABSUMmnM ., ..
Will coordinate wYth EMSL-Clnclnnatl.
*






Will coordinate with respective project
officer. Cross cut issue with EEB Aban.
Sites and ASIIH Waste Mot. Activities.
Resources for this OU (8-224) totals
2 HV(s) (I PFT, 1 OPFT). This resource
will not be enough to complete all of the
action steps to meet the objective of
this activity. Additional resources will
be needed to complete this action step per
the requirements of the Agency.
Completion of this action step also
depends on total funding of QAO's travel
request for this activity.
i
TUCnHa/MOOTOItW}
tun
aw.
/





















cut
n






















couicrm
ACTION







.












.

.

-------
                                                      APPENDIX i  (Continued)


                                                    QUALITY ASSURANCE OFFICE
                                                          FY 80 WORK  PLANS
                                                                                                                        >«ie H of...M
ORCAHIZATIOMI   Quality Assurance Office, S1A 01vision I
Decision uiflTMi  B'224 Ambient Hater Quality Monitoring
          James II. Adams, Jr.
Acrnrnu . state and Internal Quality Assurance Used for Hanjfge/»ent Decisions
O&JECTIWf * » *' *. , • *
m fcf jou enft (
* "••'. ' '' i '•
7. Hanage the P.E. -and reference sample program
for 208 laboratories. Data evaluation will be
conducted; Follow-up on problem areas
Identified will be provided.
* . *
ft
0. Provide technical review and processing of •
maximum of ten alternate test procedures for
approval or disapproval.
.
(' IfiSH. ',
ufraisiBiun
• Wyne/Long/
• Marlon
i' .
' :
;
Payne
t
i
. ' row m 101 •
•Dili
DATU
IS day
after
receip
of
data
eval.
from
EHSL


10 days
after
receipt
of
EMSL'j
recona.
•

rUUqUISlTES/LlNKACU/AfiSUMPTinN* , ..
Coordinate wiUrEHSL-Cliiclnnatl.

•
Coordinate with CNSL-Clnclnnatl.
i
,
i

nuxac/Hamonm
OATI
COHf





cat
it






coiucnn
tctiou




* *


-------
                                                        APPENDIX  i (Continued)

                                                      QUALITY ASSURANCE  OFFICE
                                                            FY 80  WORK PLANS
                                                                                                                       >«i>!5 of
ORCAMIZATIOMI   Quality Assurance Office. S&A Division!
DECISION UMIT(«)t  B-30J Mater Quality Enforcement
KAMACUU   J«mes H.  Adams. Jr.                    ,
' ' " Surface Cases lor Federal Enforcement*; r
/criviTfi . A major function of the QAO Is to conduct • vigorous .audit program to Insure data reliability for
outer Wr' al, enforcement (legal) proceedings. ,- . . V, '• ;
OT fCf!<* enrt
•
•« •-..-•• .} . £ <•
1. At the req'uest of Enforcement, conduct a
naximum of. ten on- site evaluations for
laboratory(s) engaged in analyzing NPOES samples
for confonnanc* with Agency QA requirements and
data validity.
*
Z. Provide • quality control program for •
maximum of two special studies requested by
Enforcement. Evaluate reliability of reported
data and defend analytical methods.
i
•
V ISSN. •;
ujjogsmuTt
Payne/Marlon
i*
r .
\
•
Payne
1
!
Fora m 101
•tut
IUTK3
21- days
ifter
tnslte

21 days
after
receipt
of
require
documts
•


i
• iHTM/IHiaA ORCANIZATIOHAL
FUUqUISITES/LIHUGES/ASSUfmnNII •. .,
This action step" will be coordinated
with the Enforcement Division and
DO's.
Completion of this action step depends or
total funding of QAO's travel request.

This action step will be coordinated
with the Enforcement Division.
i
I ,
1
•nACxmc/HONnotna
nm





cut
Bl





anucnvi
ACTIOM

'


• *


-------
                                                        APPENDIX  1  (Continued)

                                                      QUALITY  ASSURANCE OFFICE
                                                           FY  80 WORK PLANS
                                                                                                                      *w 16 of  23
ORCAMiUTiOHi   Quality Assurance Office. S&A Division'
Decision imrr(«)i C-215 Public Hater Supply Management
HAiucut   James H. Adams. Jr.                   ,
• • ' " 	 " — Vrovide technical Capability for Implementation of the National Interim Primary Drinking Water ftegulat
^crivini TO insure that laboratories have the capability to perform analytical measurements of all contaminants
OUCCTIVfi specified in the NIPOWft (40 CFR 141 and 142). . • '-. :
w^joMttm
- . , - '., , ..
1. Develop and Implement a Regional quality assurance
program for public water supply that has EDP
capability for a more efficient approach to data
handling and provide a mare accurate database to
evaluate and Improve analytical performance of
•11 Region V federal. State and local
laboratories generating public water supply
nanitortng data. Implement final revision of
national quality assurance plan when received.

• • *


'. ,
••

. .
. ' r°r» m 101
1' ISSH. *i
MfJOISIHUTf
Piyne/Adams
. • * •






•

:
i
*


i
:

BUI
WTM
Target
date of
1/15/80
no
later
than
3/15/80






•




mn/itmu ORCMUUTIOHM.
ruuQumra/utiKACES/AfisuHmniM . .
This action step "will be performed In
conjunction with 'action DU A- 235. DU
B-224 and DU 8-241. Development and
Implementation of EDP part of program
depends on funding of the software
package (program) requested In the QAO's
budget.




' «
• *
• ...
1
'
1
ins
TliCKIMC/HOirrtOknC
OiTB
CGHT.
•'















cue
BY
















COIUCTIVK
ACTJOM








*



• r
,




-------
                                                       APPENDIX  1  (Continued)


                                                     QUALITY ASSURANCE OFFICE
                                                          FY 80 WORK PLANS
OKCANIUTIOMl
	   Quality Assurance Offlct. S&A Dlvlsloni
DECISION UHIT(«)I  C-215 Public Hater Supply Management
HAHACUI  «"™es H. Adams, Jr.
ACTivmi . Provide Technical Capability for Implementation of: -tip .National Interim Primary Drinking Water Regula
KIT fqr fan ima
" , ' ,.S:,: ,; , , ' ,,,,,„,
••. '1 I "
2. Review for approval or disapproval of six (legion
State public water supply grants for laboratory
capability and minimum grant QA requirements.


*
*

•
, 3. Manage certification program for State '
i principal laboratories (16 State labs involved).
j

j
j
1
4. Evaluate six local laboratory certification
.programs, managed by primacy States for
conformance with Agency requirements for local
, certification programs.
»*

.
|'-AKSN. •;
«y.*> . • :,
Payne/Lang
» • *
i



•
i .
Payne.;
i


•
i '

Payne/Marlon





i
r ra» rti lot • "^
'BUI
DATES
Jates
y
jrant
»0

21 days






21 days
fter
onslte





• IHTO/IimA OUUHlZAnONAL
ruUqUISITU/LIMUCU/ABSUHmrMA . ..
Will coordinate With Water Supply Branch.
B *






Will coordinate with Water Supply Branch.
This Is an on-going technical exercise
that may or may not generates report.
Technical assistance is the main objective
until the Agency's final regulations ere
implemented, which then will entail
on-stte evaluations for. compliance.

Will coordinate with Water Supply Branch.
This step Is linked to Step 6 of this
activity. Completion of this step
depends on total funding of QAO's
travel request for this activity..
>
•

— 	 - 	 9 	 ^ —
*T«Acrrnc/KaaTOiDn
DAT!
COHf























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n























co&ticrm
ACTION








*

*^






,
, *(
1
* *



-------
                                                       APPENDIX 1 (Continued)

                                                     QUALITY ASSURANCE OFFICE
                                                           FY 80 WORK PLANS
             Quality Assurance Office, StA Division '
DECISION iMir(«)i  C-21S Public Hater Supply Management
MANAGUI     ' James II.* Adams, Jr. .
ACTIVITTI Provide Technical Capability for Implemenutlon of the National Interim Primary Drinking Water Regulatl
OUICTIVIl • ' , '/-. I1,' Si
tft ^Cf fotf STEM .'
.. *
S. finalize pending Interim certification activity.
for six State principal labs.
i • •


* t


H
€. Provide a minimum of one on-slte evaluation
visit to each Region V State principal
laboratory. Issue reports.
7. Perfona data quality assessment evaluation of the
CRL. This function will be performed on a
quarterly basis (part of QAO's responsibility
Is evaluating StA monitoring activities which
.CftL's analytical activities are part of the
. Division's monitoring activities).



i
. ,
u!ia£mtm;
Payne/Adams
• •
'




i

Payne/Sturino/
Marlon
.
Payne/Long









fora m 101
'Mil
DATES
! I- days
ifter
ill
leflcs.
tave
>een
:orrect


U days
ifter
tnsite
5 days
fter
nd of
ach .
rtr.







• iHTn/IHTBA ORfiANIZATIOIIAL
Will coordinate with Water Supply Branch
. '







Will coordinate with Water Supply Branch.
Also done In conjunction with Step 4
above.
Coordinate with CRL.



,



. i . ,
*

"•l
DATI
COff
.•





















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cat
n










"











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COKUCTIVE
ACTION








•

\





;.
V
I
• 1




-------
                                                       APPENDIX 1 (Continued)

                                                     QUALITY ASSURANCE OFFICE
                                                           FY 80 WORK  PLANS
ORGANSZATIOMI   Quality Assurance Office. S4A Division*
DECISION injR(*)i C-21S Public Water Supply Management
MAMACUI  James II. Adams. Jr.
ACTivrrti Provide Technical Capability for Implementation of the National Interim Primary Drinking Water Regulatl
oBJtcmu ' . •:•:,''•'
HI ACfl
-------
                                                              APPENDIX  1  (Continued)


                                                            QUALITY  ASSURANCE OFFICE

                                                                 FY  80 WORK PLANS
                       Quality Assurance Office. SIA Division*
        Decision intIT(*)i C-215 Public Water Supply Management
        MAHACQU   -•••••
••"••""•"" uanic* it* nu«Hi»t tif • • • .
ACTIVITTI Provide Technical Capability for Inplemtntation of the,. National fntertn Primary Drinking Water Regula
ojuecTiwi . .•?,*!•
m fcficsi mn
• • *
11. Provide workshop for standardizing metal
analyses for Region V public water supply
laboratories.
12. Provide workshop for upgrading organics
analyses for Region V public water supply
laboratories.

13. Process a naxtnun of five alternate test
procedure requests for approval by labs
analyzing. PUS samples.
* • *
• •
!
"
," F' Van KB 101 ' — ~— ' 	
l< ABSM. *
UJFOHSUIUTT
•Pay lie
• • •
t
Payne/Sturino/
Young
i '
Payne -





, .
• •
'DUB
WTJU
3/31/a


4/30/Bl

10 day
after
receip
[HSL's
coamen



• mm/iirnA ORCANIUTIOIUL
rUUquiSITCS/LINlUUiES/AfiSIMmiMII . ..
Coordinate with'CRL
^ *

Coordinate with CftL. Completion of this
step depends on the availability of
Sturino and CftL's organic .facilities.

Coordinate with EHSL-Cincinnati.


1
,

• . .

ons
oin
OOKP
.


•









(ucn
oat
IV













•
M/Mvnotnn
coftucnvi



•





r ' • •

'i

I.
I

-------
  APPENDIX  1 (Continued)

QUALITY ASSURANCE  OFFICE
      FY 80  WORK PLANS
ORCANIZATIOMI   Quality Assurance Office. S4A Division1

MAMACnu JaMk H 8Glat UkeS tOA°'S ™le "°t *ddresse
-------
                                                              APPENDIX I (Continued)

                                                           QUALITY ASSURANCE  OFFICE
                                                                 FY 80 WORK PLANS
          ORGANIZATION*   Quality Assurance Office, SIA Division •
          Decision utUTU)i B-241 Great Lakes
          MANAGOU James II. Ad>ms, Jr.
— , 	 ,. , 	 : 	
£2££j™ Quality Assurance for lake Monitoring • i'.fi'l'
,* .* * -*!
m fcr{oM anri ..'
• « i .
). Manage PE7QC sample program for a maximum of- ,
ten laboratories on a quarterly basis. COP
data review and follow-up provided where
problems are identified.
*

4. Conduct on-slte evaluations of ship board lab
and a maximum of ten contract labs for
compliance with contract/grant QC and method-
ology requirements. Based on previous
problems, sane contract labs will have to be
evaluated on. a quarterly basis.
* •
* *
. l Far* Ml Ifil ' ' " " '
I'ASSM. '
ufrasuiunr
.Piyrt'e/OPFT/ '
•Long •

,
1
Payne/Young/
OPFT-
1
.

• -

DUE
HATES
10 day
after
data
analys


21 day
after
onslte

•
•

• iHm/Tmu ouuMmnoiui.
Coordinate wlth'GUNPO. Linkage with
the Data Quality Work Group, 1JC.



Coordinate with GLNPO. Linkage with the
Data Quality Work Group, IJC.
Completion of this step depends on
total funding of QAO's travel request.




• .
am
OCMT
/










nucra
cue
R











MOT.
couicrm
1CTIOH



*





•

fi'

-------
                                                             APPENDIX 1  (Continued)


                                                          QUALITY  ASSURANCE OFFICE
                                                                FY  80 WORK PLANS
                                                                                                                               »•!•» of  23
         ORCANIZATIOMI   Quality Assurance Of I fee. SKA Division'
         DECISION U)UT(*)i  B-241 Great Lakes
         MAiucui   Jaftes H. 'Adams, Jr.

» r • . -
Acmmi .Quality Assurance for Lake Monitoring " • ••' t-i-f
OBJECTlVKl ' . •'' ! :
m fcffON cms ;
.• •
S. Participate In the activities of the Data- .
Quality Work Group. IJC, These activities
relate to work group round robin appralsale,
meetings on data quility. Quality Assurance*
method standardization and the fish and
sediment program.
•
1 '
..
. .
F ACCM. 'i
Ad'ams
i
•


• ton m 101 •
•DUI
WTM
.





• INTd/Ilim OECiNIUTIOHAL
Linkage with CRL'an'd the GLNPO.

«
*
i
i

tlACUflC/MOKtlOlBa
Din
OCMT






aac
BT






OOKUCTIVK
iCIXOK

*




• l

-------
                  APPENDIX 2

RELATIONSHIP OF THE QUALITY ASSURANCE FUNCTION
     TO OTHER REGIONAL PROGRAM FUNCTIONS  -
±
>— 1 «/)
gg
H- "— •
^^
2. ^»
LU
_! LU
42
u
. ""JJ
RESPONSIBLE FOR THE MANAGEMENT OF THE REGIONS QA PROGRAM INCLUDING, DEVELOPMENT
EVALUATION AND RECOMMENDING CORRECTIVE ACTIONS, IF REQUIRED, AND VERIFYING CORR
Office of the Reqional Administrator
Office of Deputy R. A.

v)f f \ rr of Great Lakes National Prooram

Planning and Management Division



General Services Branch
Air and Hazardous Materials Division

> Wacte Management Branch



Water Division


Fnvi fnnmental Fnni np^ri nn Rrnnrh^il—




Surveillance and Analysis Division




^- " — J 	 1 n-r r-hy-? i— f- n-F-F-r rr>

Enforcement Division
_J3JH r Pnf nrrpmpn^ Rranrh


State and Local Agency Monitoring Programs

within a State)
IX Activity
Data Quality Work Group^ — -
	 ^External Monitoring Contracts (Sampling and Analyses)

RECOMMEND AND ASSIST IN REGIONAL PROGRAM FORMULATION, FOR
IDENTIFYING AND ASSURING AGENCY QA OBJECTIVES ARE ADDRESSED

-------
                                                   APPENDIX 3

                                            ORGANIZATIONAL STRUCTURE
                                                    REGION V
                                      U.S. ENVIRONMENTAL PROTECTION AGENCY
                                             REGIONAL ADMINISTRATOR
                                          DEPUTY REGIONAL ADMINISTRATOR
AIR AND HAZARDOUS
    MATERIALS
     DIVISION
ENFORCEMENT
  DIVISION
MANAGEMENT
 DIVISION
                                                                                 STAFF ELEMENTS
SURVEILLANCE
AND ANALYSIS
  DIVISION
 WATER
DIVISION
                                                                            QUALITY
                                                                            ASSURANCE
                                                                              OFFICE

-------
                                   APPENDIX 3 (Continued)
                              SIEVEILLAfiCE 8 ANALYSIS  OIV1SIOM
                                    U.S. EPA - REGION  V
                                     ORGANIZATION CHART
.-


'entra
esional
aboratory

Director, Sanders
Deputy D1r., Yeatos
Administrative Officer,
' Johanssn

'

1

Environmental
Emergency
Investigations
Dranch



Quality
Assurance
Office
-
Chief. Adaras

Technical'
Support
Branch
•



Central
District
Office

Easter i
01str1c,
Office
-Jnef, Ross
Chief, Townsend
Chief, H
Chief, Vacant   Chief, Wl

-------
           APPENDIX 4
       STATE OF WISCONSIN
DEPARTMENT OF NATURAL RESOURCES
    BUREAU OF AIR MANAGEMENT
     AIR MONITORING SECTION

    QULITY ASSURAICE MANUAL


          PROCUREMENT

-------
                                                          V{A O.^.X.l
                                                          Revision c5
                                                          Page 1 of 28
                    Procurement Testing Procedures
The following guidelines are to be used when evaluating continuous
monitors prior to purchase.  These are not purchase specifications.
Articles relating to vendor responsibility and warranty obligations will
be included in purchase specification guidelines.  This is a description
of parameters that must be considered and tested when evaluating monitors
prior to purchase.

Pre-purchase instrument evaluation tH,H consist of several parts:  1} a
preliminary elimination process based on data gathered by DNR concerning
user experience, vendor provided performance test results, and instrument
advantages and disadvantages; 2) equipment testing of instruments,
selected as a result of screening of data gathered in #1, to assure the
instruments perform as stated - this testing will be performed by DNR
personnel; and 3) final considerations of equipment usability in DNR's
network, vendor cooperation and desirable features, which will further
narrow down the number of instruments.  Monitors to be considered for
evaluation must have been designated by EPA as reference or equivalent
methods.  No equipment will be approved for purchase without first
having completed the evaluation process outlined here.  Final selection
of instruments to be purchased by DNR will be based on the degree to
which the monitor exceeds m-t^mim specifications, the performance test
results, purchase and annual operations costs, and availability and cost
of service/repair by contract/demand.

NEED ANALYSIS

To begin the analysis, the DNR group undertaking the instrument evaluation
must prepare a needs analysis report which analyzes the application for
which the instruments will be used and determines which instrument
characteristics will best fit the application.  For example, will the
instrument be used for background monitoring (list the ambient levels
expected) or point source monitoring (expected ambient levels are higher).
The following parameter needs must be defined in this report:

          1.  expected concentration range
          2.  threshold concentration
          3.  anticipated gas stream composition
          4.  response time
          5.  maintenance requirements
          6.  portability requirements

This report is to be prepared and circulated to each DNR group who will
be affected by the instrument purchase, as well as to the Quality Assurance
Coordinator, for comments.  After comments are received and the report
revised, the specifications and user review can take place.

-------
                                                          QA 6.2.1.1
                                                          Revision d
                                                          Page 2 of 28
SPECIFICATION AND USER REVIEW
This phase of the evaluation is a weeding out process.  As we have    ^\.
neither the manpower nor space for extensive instrument testing, only a
gngll number of instruments will be chosen for such testing.  This
initial evaluation is to be the means of choosing which instruments will
be tested in-house.  If more than one measurement principle is listed as
a reference or equivalent method (as is the case with SO  continuous
methods) at least one instrument from each measurement principle must be
considered in this initial evaluation.  The following information must
be gathered for each instrument that is evaluated, and a report prepared
on the results of this data gathering phase.

     1.   Request instrument operating manuals from each manufacturer
          and review them.  Check and compare measurement principles,
          performance characteristics and relative complexity of operation.
          List advantages and disadvantages of each.

     2.   User experience - The manufacturer will be contacted to supply
          a list of users.  EPA should also be contacted for names of
          any dissatisfied users.  Agencies or industries with prior
          field experience with each particular instrument will be
          contacted for their opinion of the instrument's mechanical,
          electronic and chemical dependability (confidence in instrument
          data), ease of working with the instrument, user experience
          with the vendor, vendor responsiveness, cost of operation, and
          instrument downtime.  At least two users must be contacted for
          each instrument evaluated.  Attached is a copy  (Figure 1) of
          the questions to be covered when talking to the users.

    .3.   Performance testing - Manufacturer shall provide written
          results of their equivalency testing, to be evaluated for
          precision, accuracy, interferences, etc.

     4.   Vendor cooperation - Each vendor will be contacted  and evaluated
          as to his/her:  a) willingness to comply with the terms of  the
          .pre-purchase arrangement  (our in-hour testing)  and  purchase
          contract specs, b) factory  and local representative expertise,
          support, and facilities,  c) instrument warranty terms, d)
          willingness to  supply all information required  to operate,
          maintain and repair the instrument.

     5.   Required support equipment  - Determine what is  needed in  terms
          of supporting electronics,  gas cylinders, etc.,  for each
          instrument evaluated, and the availability  and  cost of  such.
          Which of these  items do we  already have,  their  adequacy and
          their age.  Which  items must be purchased and the cost of the
          purchase should be included.
      6.    Arrp^ai, operating costs - Approximate cost of parts,  reagents,
           electronics,  gas cylinders,  manpower support, and a list of
           high and low motality parts  for each instrument evaluated.  -

-------
                                                          QA 6.2.1.1
                                                          Revision i
                                                          Page 3 of 28
     7.   Conformity of each instrument to existing DNR instrumentation
          systems (both the vans and the permanent continuous monitoring
          stations).

          a.   manifold .
          b.   data acquisition system
          e.   rack mounting
          d.   calibrators
                                                                     «

The information in the report will be organized into tables for purposes
of comparison; each parameter listed above is to be scored (based on its
relative importance as determined 'in the needs analysis) and a summary
chart of comparative scores will be drawn up.  These tables and charts
will be circulated for comment and recommendations to key persons within
the air monitoring program who are knowledgeable with instrumentation.
Any instrument or manufacturer not favorably rated in this phase of
evaluation will be excluded from further testing.  Recommendations for
no more than three instruments to be tested in depth in DNR labs, will
be made by representatives of each monitoring group and the quality
assurance coordinator.

INSTRUMENT TESTING

As a result of the specification and user review, up to three monitors
will be tested in-house by DNR personnel.
the purpose of this testing is to:
     1.   Obtain a working knowledge of each instrument - how easy it is
          to use, how well it performs, and what problems we might
          expect with it.

     2.   Verify that certain crucial equivalency testing parameters are
        •  indeed met;  Equivalency test results are provided to EPA by
          the manufacturer and are not'verified by EPA.  Some users have
          found that the equivalent designated instruments that they
          have purchased are not meeting these performance specifications.

     3.   There are differences in instrument performance among instrument
          manufacturers whose instruments pass the equivalency specifications.
          Some instruments just pass the testing, while others have
          performance that is vastly superior to the equivalency specifications.

The following instrumental tests are to be conducted on "1? continuous
monitors being considered for purchase.  Figure 2 is an example of how
the results of the testing should be reported.
     A.   Definition
       •  .               •                   -  -        QS
          Nominal minimum and maximum concentrations which a method is
          capable of measuring.

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                                                          QA 6.2.1.1
                                                          Revision i
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     B.   Test Procedure
          1.   Allow the instrument to warm up as per manufacturer's
               instructions.

          2.   Construct a calibration curve shoving the test analyzer's
               response over at least 95 percent of the required range.

          3.   Allow the instrument to run for 24 hours before performing
               any further tests.                                    '

II.  Noise Test

     A.   Definition

          Noise is the short-term deviation in output signal which is
          not the result of changes in input concentration.  It is
          essentially -the standard deviation.  Noise is an inherent
          property of an instrument arising from imperfect electronics,
          mechanical stresses, quality of optics, etc.  Noise levels are
          critical as they set limits on useful measurement levels, and
          the lower detectable limit is often defined as twice the noise
          level.

     B.   Test Procedure
                                     *
          1.   Allow sufficient time for the test analyzer to warm up
                   stabilize.
          2.   Connect an integrating-type digital voltmeter (DVM)
               suitable for the test analyzer's output, and accurate to
               three significant digits, to measure the analyzer's
               output signal.  Also connect the analyzer to an appropriate
               strip chart recorder.

          3.   Measure zero air for 60 minutes.  Use the range setting
               specified in Table I.  The recorder should be set for 0
               to 1 volt full scale.  During this 60-minute interval,
               record 25 readings at 2-minute intervals.

          4.   Convert each DVM reading or strip chart recording to
               concentration units (ppm) by reference to the test
               analyzer's calibration curve.  Label the converted DVM
               readings r^, r2» • • •
          5.   Calculate the standard deviation, S, as follows:
                                  2 - 1/25 ^±)

               S(ppm) »
                                 24

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                                                QA 6.2.1.1
                                                Revision i
                                                Page 5 of 28

6.   Let S at zero ppm be So; compare So to the noise specification
     given in Table I.

7.   Repeat steps (3) through (6) using a recorder output of
     either 0 to 1MV or 0 to 5HV.  The baseline on the strip
     chart should be at 50Z of full scale, so that positive
     and negative deviations can be observed.  Compare Sjfy to
     the noise specification as given in Table I.

Lower Detectable Limit

Definition - The minimum pollutant concentration which produces
a signal of twice the noise level.

1.   Test Procedure

     a.   Allow sufficient time for analyzer to warm up and
          stabilize.  Measure zero air for at least 15 minutes
          and record the stable reading in ppm as Bg.

     b.   Generate and measure for at least 15 minutes a
          pollutant test atmosphere concentration equal to the
          value for the lower detectable limit specified in
          Table I.

     c.   Record the test analyzer's stable indicated reading,
          in ppm, as BL«

     d.   Determine the lower detectable limit (LDL) as LDL *
          B]_ - Bj.  Compare B^ - Bj to 2S0.

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'


Table I - EPA Performance Specifications for


Performance parameter Units

1.


2.
3.

4.



5.

6.




7.
8.
9.
10.







Range • Parts
per
million
Noise do
Lower detectable
Unit do
Interference
equivalent
Each interf erent do
Total interferent do
Zero drift,
12 and 24 hour do
Span drift, 24 hour
20 percent of upper
.range limit Percent
80 percent of upper
range limit do
Lag time Minutes
Rise tine do
Fall time do
Precision
20 percent of upper
range limit Parts
per
million
80 percent of
upper range limit do
Sulfur
dioxide

0-0.5


.005

.01


+.02
~~.06

+.02


+20.0

+5.0
To
15
15




.01

.015
Photo-
chemical
oxidants
0-0.5


.005
*
.01


+.02
".06

+.02


+20.0

+5.0
20
15
15




.01

.01

Automated
Carbon
monoxide

0-50


.50

1.0


+1.0
1.5

+1.0


+10.0

+2.5
10
5
5




.5

.5
QA 6.2.1.1
Revision 6
Page 6 of 28
Methods
Nitrogen
dioxide

0-0.5

•
.005

.01


+0.02
.04

+.02


+20.0

+5.0
20
15
15




.02

.03
1. To convert from parts per million to ug/m^ at 25°C and 760 mm Hj
multiply by M/0.02448, where M is the molecular weight of the gas.

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                                                           QA 6.2.1.1
                                                           Revision  «J
                                                           Page  7  of 28
III. Zero Drift,  Span Drift. Lag Time. Rise Time,  Fall Time and Precision
     Test                              „                                \

(Also may indicate voltage variation and ambient temperature sensitivity)

     A.   Definitions

          Zero Drift - This value is the change in response to zero
          pollutant concentration over a 24 hour period of continuous
          unadjusted operation.

          Span Drift - This value is the percentage change in response
          to pollutant concentrations of 802 of scale and 202 of scale
          over a  24 hour period of continuous unadjusted change.

          Lag Time - The time interval between a change in pollutant
          concentration input and a corresponding change in scale readings.

          Rise Time - The time interval between an increase in pollutant
          concentration input and 952 response to a new concentration
          level.

          Fall Tine - The time interval between a decrease in pollutant
          concentration input and 95Z response to the new concentration.

          Precision - Precision is defined as a variation about the mean
          of repeated measurements of the same pollutant concentration
          expressed as one standard deviation about the mean.

     B.    Test Procedure - The monitor should be set up in such a manner
         .that the voltage and temperature may be controlled (or recorded)
          and, if possible,  altered experimentally to levels the monitor
          may be  expected to encounter.  If the instrument is to be
          housed  in a tightly controlled environment, the monitor need
          be tested only in a duplication of that  environment.  This
          test procedure need only be performed once if the instrument
          is to be used in a controlled environment;  at least three test
          runs must be performed at varying environmental conditions if
          the instrument will be subject to voltage and temperature
          fluctuations at a monitoring site.   In either case, more
          testing should be done if the instrument responds irregularly.
          During  this procedure no manual adjustments to the electronics,
          gas or  reagent flows, other than those specified by the test,
          or as part of a required periodic maintenance program, is to
          be performed.
              The  instrument  shall be  operated  at  115 volts  and at
              25°C.

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                                                QA 6.2.1.1
                                                Revision 6
                                                Page 8  of 28
     1.   Allow sufficient time for instrument warm-up and
          stabilization.  Adjust the zero baseline to 5 percent
          of full scale.  Recalibrate if necessary.  (Usually
          if the span check indicates a span drift in excess
          of the value listed in Table I.)

   -  2.   Arrange to generate test atmospheres as follows:

Test Atmosphere          Pollutant Concentration  (Percent)  *

                         URL - Upper range limits
     AQ                 '           Zero gas
     A2Q                           20 + 5 of URL
     A3Q                           30 ± 5 of URL
     Ago                           80 + 5 of URL
     Ago                          ' 90 + 5 of URL

     Set chart speed at 2 inches /hr.

     3.   Measure AQ until a stable reading is obtained.
          Record reading as Zlg.  Note the clock  tine on  the
          strip chart.

     4.   Measure A£Q until a stable reading is obtained.
          Record reading as M^Q.  Note the clock  time on  the
          strip chart.
        *
     5.   Measure Agg until a stable reading is obtained.
          Record reading as S^Q.  Note the clock  time on  the
          strip chart.

     6.   Sample AQ until reading is less than 15 percent of
          full scale.  A stable reading is not required.

     7.   Measure A2Q-  Record stable reading as  P^.

     8.   Sample ASQ.  A stable reading is not required.

     9.   Measure A2Q>  Record stable reading as  ?2-

     10.  Sample AQ.  A stable reading is not required.

     U.  Measure A2Q.  Record stable reading as  P3.

     12.  Sample A3Q.  A stable reading is not  required.

     13.  Measure A2Q.  Record stable reading as  ?4«

     14.  Sample AQ.  A stable reading is not required.

•-.,. • 15.  Measure A2Q.  Record stable reading  as  PS.     -
 .. •  .16.  Sample A3Q.   A stable  reading  is  not  required.

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                                                          Page 9 of 28


               17.   Measure A2o-  Record stable reading as Fg.  Note the
                    clock time on the strip chart.

               18.   Measure AgQ.  Record stable reading as Pj.

               19.   Sample Ago-  A stable reading is not required.

               20.   Measure A80»  Record stable reading as PS.  Set
                    chart speed at 4 inches /hr.
                                                                      «
               21.   Measure AQ. Record stable reading as Lj_.

               22.   Quickly switch test analyzer to measure AgQ.   Mark
                    recorder chart at exact time of switch.

               23.   Measure Agg.  Record stable reading as Pg.

               24.   Sample A^Q.  A stable reading is not required.

               25.   Measure AgQ.  Record stable reading as P^Q.

               26.   Measure AQ.  Record stable reading as I^.

               27.   Measure AgQ.  Record stable reading as P^.

               28.   Sample AQ.  A stable reading is not required.
               29.   Measure AgQ.  Record stable reading as P-^.  Note
                    the clock time on the strip chart.

               30.   Measure AQ.  Record stable reading as Z^.  Note 'the
                    clock time on the strip chart.
               31.   Measure A^-  Record stable reading as Mj_.

               32.   Measure AgQ.  Record stable reading as S^.

               33.   Zero Drift

                       Zero Drift - 2*0 - Z^

               Report the Elapsed Testing Time as Measured in Steps
(3)  and (30).

               34.   Span Drift

                    (a)  at 20Z D5L
                         Span Drift - MO -  Mo  x 100Z
                                         *5
                         where:             6
                                      "a!  £  pi
                                       a  6 i-1       a

               Report the Elapsed Testing Time as Measured in Steps (4) and (17)

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                                             Revision «$
                                             Page 10 of 28
      (b) at 802 URL

          Span Drift
S  -
 n
                                   100%
     o
     12
                  8-1
          where:
     Report the Elapsed Testing Time as Measured in Steps
     (5) and (29).  •

3S.  Lag Tine

     Determine from the strip chart, the elapsed time in
     minutes between the mark made in step 22 and the
     first observable (2 x noise level) response.

36.  Rise Time

     Calculate 95 percent of reading Pg and determine
     from the recorder chart the elapsed time between the
     first observable (2 x noise level) response and a
     response equal to 95Z of .Pg.

37.  Fan Time

     Calculate 95 percent of (P10 - Lj) and determine the
     elapsed time In minutes between the first observable
     decrease in response following PIQ and the response
     equal to 95 percent of (P^j - Ljt.

38.  Precision
     Calculate precision (?2Q and ?80) as follows:

     (a)
         ?on
          •20
               1  fl2     '  1 /12  \Z
               5   £ *i-T[£Pt]
                  Li-7        Vi-7  7_
Obtain a stable zero air reading.  Record.  Introduce a
test atmosphere of 802 of scale.  Allow instrument to run
and record at this level for 24 hours.  At the end of the
24 hour period, return to zero air and obtain a stable
reading.  Report the ppm value for the first hour(X_ ) and
for the last hour
  Report span drift (80Z)
                                                       - X

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                                                                      Revision <5
                                                                      Page 11 of 28
                           After obtaining and recording the zero air reading,
                           introduce a 20% of scale test atmosphere.  Allow instrument
                           to run and record at this level for 24 hours.  Return to
                           zero air and record the stable reading.  Report the ppm
                           value for the first hour (Y^) and for the last hours
                                                                100
                           Report span drift (20Z) as V2 - Yj.
                           Repeat day 2 procedures, except allow instrument to run
                           for 48 to 72 hours.
                           Repeat day 4 procedures, except use zero air.

                      If the instrument will be operated under conditions of fluctuating
                      temperatures and voltages, repeat this test procedure (beginning
                      with Day 1) at least two more times, altering ambient temperatures
                      and voltage levels to settings the instrument is likely to
                      encounter in the field.

,            IV.  Interference Test

                 A.   Definition - Interference is the positive or negative effect
                      of a substance, other than the pollutant being measured, as
                      reflected in instrument response.

                 *•   Test Procedure - The test procedure will vary depending on the
                      instrument and its potential interferences.  The procedures to
                      be used will be written by the QA Coordinator (in conjunction
                      with the testing group) prior to the beginning of the testing
                      phase.

            V.   Flow Rate Measuring Device - Factors to be taken into consideration
            are the accuracy of the device, ease of calibration (either in or out of
            the sampling line), ease of adjustment and flow rate drift.  Data from
            this test should be recorded as in Figure 3.

                 A. N  Test Procedure -

                      1.   Calibrate the flow rate controller, as specified in the
                      instrument operation's manual, with a transfer standard of
                      known high accuracy (such as a wet test meter, soap bubble
                      meter or mass flow meter).  Thereafter, run a daily flow rate
                      check of one or more points to check the flow rate controller's
                      stability.  Report the maximum 7. deviation in the flow rate
                      calibration.

}                     2.   Record the flow rates each day, as indicated on the
                      instrument's flow rate measuring devices for each parameter of

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                                                            QA 6.2.1.1
                                                            Revision i
                                                            Page 12 of 18

          interest (H_ flows, sample flows, etc.).  Report the maximum %
          variability in the flow rate readings for each parameter
          measured.

     For further details regarding any of the above tests, please refer
     to the February 18, 1975 Federal Register - Ambient Air Monitoring
     Reference and Equivalent Methods Part II.

VI.  Calibration Drift
     —————— •—»_                                                 f

When all testing is complete, run a multipoint calibration of the
analyzer.  DO NOT ADJUST ZERO OR SPAN SETTINGS ON THE INSTRUMENT.
Compare with the initial calibration as follows:

     A.   Determine the slope and intercept for each calibration; X -
          ppm, Y » instrument reading.

     B.   Using the slope and intercept for each calibration determine
          the ppm values at each instrument reading from 10 to 1QOZ in
          units of 10 (see Figure 5).

     C«.   Determine the percent differences for each ppm value obtained
          in B.  Assume the initial calibration value is the "true
          value."

     D.   Report the average percent difference as:

                         n

               I Diff - i-1  di             .   •    .
                        absolute values of the percent differences are
     E.   Report the ma-yfTmim percent deviation observed In the region In
          which ambient concentrations will fall.  Report this data on
          Figures 4 and 5.  Instructions for completing Figure 4 precede
          the figure.

A report must be prepared which includes all the original data, strip
charts, calculations and calibrations.  In addition, the calculated
data - span drifts, calibration drifts, etc., should be organized into
tables for purposes of comparison.  The following areas determined in
the "Specification and User Review" and in the "Instrument Testing"
should be Included in this report.

          1.   Vendor Cooperation

               a.   willingness to comply with terms of DNR p repurchase
                    and purchase specifications.
                                             " ~         «
               b.   factory and local representative expertise, support
                    and facilities.  Factory training of technicians who
           •   •      will be required to service and repair equipment.

               c.   possibility of direct factory  (original equipment

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                                                                     Revision i
                                                                     Page 13 of 28


                               supplier) purchase of parts.  Specify parts available
                               only from vendor.
                          d.   instrument delivery tine for all ordered monitors

                          e.   condition of the monitor when received for "instrument
                               testing"

                          f.   warranty terms
                                                                                 <
                     2.   Required support equipment - What is needed in terms of
                          supporting electronics, gas cylinders, etc. and availability
                          of such.  Detail which items we already own and which
                          would have to be purchased.

                     3.   Annual operation's cost - Approximate cost of parts,
                          reagents, electronics, gas cylinders and manpower support.

                     4.   Operations Manual

                          a.   ease of comprehension

                          b.   completeness (including wiring blue prints)

                     5.   Ease of Access for:

                          a.   instrument repair

                          b.   routine maintenance

                          c.   hook up, either free standing or rack mounted

                          d.   routine calibration

                          e.   of knobs, switches, and dials

                     6.   Conformity to Existing Instrumentation Systems

                          a.   manifold

                          b.   data acquisition system

                          c.   rack mounting

                     7.   Aesthetic Appeal

           Consideration of where and how instrument is to be used should be kept
*'•          in mind in making a subjective evaluation.  Where problems are specific
           to a certain use of the instrument (ex. if used in the vans it's a
           problem) specify this in describing the problem.

           The report should be completed within 30 days of the end of the project.
           It should then be circulated for comment and recommendations to key
           persons within the monitoring program who are knowledgeable in this
           area.  The report  should also be forwarded to the Bureau for filing.  A

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                                                          QA 6.2.1.1
                                                          Revision «J
                                                          Page 14 of 23

final decision as to instrument purchase should be made within two
weeks.   The  decision  will be made at a conference (phone or personal)
with representatives of each monitoring group and the QA Coordinator.

NOTE:                           -
               *
When a decision on instrument purchase must be made rapidly, a. shortened
version of this report - just containing the charts and tables from'the
evaluations should be circulated for comment immediately.  The remainder
of the report is still to be written and added .to the tables at a later
date.

A sample copy of a procurement report is available from the Quality
Assurance Coordinator.

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                                                           Revision 4
                                                           Page 15 of 28
                             FIGURE 1
                       AMBIENT AIR ANALYZERS
                          USER FACT SHEET
INSTRUMENT MANUFACTURER AND MODEL NUMBER
COMPANY NAME	  DATE
COMPANY CONTACT 	  PHONE NUMBER	

DNR CONTACT 	.__	



 1.  GENERAL INFORMATION

     a.   How many analyzers do you own?




     b.   How long have you operated Che analyzers?




 2.  MECHANICAL DEPENDABILITY

     a.   In the time since you have owned the instruments, how many
          mechanical breakdowns, on average, have you experienced?
     b.   Do any specific parts give more breakdown problems than
          others?  If so, which ones?

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                                                           QA 6.2.1.1
                                                           Revision «5
                                                           Page 16 of 28
3.  ELECTRONIC DEPEKDABILIT7
         In the time since you have owned the instruments,  how many
         electronic breakdowns, on average, have you experienced?
    b.   Do any specific parts give more breakdown problems than
         others?  If so, vhich ones?
4.  CHEMICAL DEPETOA3ILITT

    a.   What is the average zero and span drift you see on the
         instrument — in ppm/x days or in Z chart/x days?
    b.   How frequently do you perform, zero/span checks?
         How frequently do you have to perform a multipoint cali-
         bration on the analyzer?

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                                                           QA 6.2.1.1
                                                           Revision  i
                                                           Page  17 of 28
         How long does it take to perform the multipoint calibration?
    e.   What is the response tine on the instrument - in minutes or
         seconds - to reach 95Z of scale from the baseline?
5.  EASE OF WORKING WITH THE INSTRUMENT

    a.   Are the control switches and knobs easily accessible to
         the operator?
    b.   Bow easy is it to

         1.   replace boards?
         2.   clean the instrument?
         3.   replace filters or other parts?
         Be specific (example:  flow controllers cannot be reached
         without dismantling...etc.).

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                                                           QA 6.2.1.1
                                                           Revision i
                                                           Page 18  of 23
         How sophisticated must the user be to operate the instrument?
         Can an engineer operate it?  An electronics technician?   A
         chemist?
6.  VENDOR RESPONSIVENESS
         What is the turnaround time on vendor repair of instruments?
         Be specific - in days, weeks, etc.
    b.   What is the quality of the repair work performed by the
         vendor or manufacturer?  Be specific.
    e.   Bow long does it take to get a vendor or manufacturer repair
         person to the field?

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                                                           QA 6.2.1.1
                                                           Revision «5
                                                           Page 19 of 28
    d.   Are vendor representatives knowledgeable about the instrument,
         its operation and' potential problems?
7.  COST 07 OPERATION

    a.   What parts, chemicals or other equipment must be replaced
         frequently?
    b.   How expensive are replacement parts?  Be specific.
    c.   How much time must be spent by repair people, operators,
         electronics people, chemists, etc.,  to keep the instruments
         operational?

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                                                           Revision 4
                                                           Page 20 of 28
8,  INSTRUMENT DOWN TIME
         What percent data capture do you average, or how many hoars/unit
         time (day, month, etc.) are the instruments inoperable?
    b.   What is the major reason for your instrument down time?
9.
    a.   Are there any common interferences (gases in the ambient
       .  air, at the site; temperature variations, etc.)  which affect
         the response of the instrument?  If yes, what are they?
    b.   How badly is the instrument affected by the interferents?
         Be specific.

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                                                            Revision t
                                                            Page 21 of  28
10.  GENERAL INFORMATION
     a.   Have you used any other manufacturer's analyzers?  If yes,
          which ones?
     b.   If you had a choice, would you purchase this analyzer again?
          Why?
     c.   Any other comments not covered above.

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                                                                  Revision si
                                                                  Page 22 of 23
                                    FIGURE 2
                             AMBIENT AIR ANALYZERS
                       INSTRUMENT PERFORMANCE DATA SHEET
Instrument Manufacturer
and Model $
Instrument Serial I
EPA PERFORMANCE SPECIFICATIONS
   Range                  	
   Noise

   Lower Detectable Limit

   Interferent Equivalent


   Zero Drift

   Span Drift

   Lag Time
   Rise Time
   Fall Time
   Precision
24 hrs.
                         Date
                         Pollutant
               .  PERFORMANCE SPECIFICATION RESULTS
                    (Minimum)        ________
                    (Maximum)        	
                    (So)             	
                    (BL-BZ)
                    (2x noise)
                    (Interferents(s))^
                    Result
                    20SURL
                    80SURL
                                              r20
                                              '80
24 hrs 48 hrs 72 hrs
                                     24 hrs 48 hrs 72 hrs

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                                                                  Revision 4
                                                                  Page 23 of 28
                                 .  FIGURE 3

                     PERFORMANCE SPAN AND. FLOW RATS CHECKS
Instrument Manufacturer
and Model Number
Analyzer S/N#
«
C*librat«?r S/N? • Last Generator Calibration
•
Date







*
Rotaaeter
Setting







Flow
ce/nin







Calibration Outwit







*
Analyzer Response







-
Sample
Flow Rate







*Z Diff.







*Z Biff. -/Analyzer Response - Calibration Output \ 1002
                      Calibration Output
Recorder Zero Setting
Zero Setting

Span Setting
Auxiliary Gas Flow Rate
(Specify gas)
      Method(3) of Analyzer Data Retrieval
         Strip Chart ____
         Data Averages _____
         Data Logger 	
         t
      How was sample flow rate determined?
Remarks:

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                                                            Revision 0
                                                            Page 24 of 28
                         CALIBRATION FORM
1.   Instrument manufacturer and model number - The manufacturer's
     name, the model number of the analyzer.

2.   Instrument number - The manufacturer's serial number affixed to
     the analyzer.                                                     *

3.   Initial calibration date - Date of the first calibration of the
     analyzer.

     By - Nam* of person performing the calibration.

4.   Final calibration date - The date of the final calibration of the
     analyzer.

   .  By - The last name or Initials of the person performing the
     calibration.

5.   Generator number - The DNR serial number for the generator used to
     calibrate the analyzer.

6.   Date of last generator calibration - The date the generator was
     calibrated.                                                _  .

7.   Remarks - Any comments on instrument performance that would affect
     the interpretation of the calibration data.

8.   This information is completed for all analyzers.

     a<   Sample flow rate - The sample air rotameter setting.

     b.   Auxiliary gas flow rate — Flow rate of any gases used by
          the analyzer (example:  air, hydrogen, ethylene).

     e.   Zero setting - If the Instrument is so equipped, this is
          the reading on the zero control setting.

     d.   Zero offset - The I chart reading vhen zero volts is applied
          to the recorder.

     •.   Span setting - The reading from the span setting.

9.   Number 3 is completed twice for each instrument calibration.  The
     values for each parameter are entered into the INITIAL column when
     the instrument is first calibrated, and each parameter is  then
     recorded in the FINAL column when the final calibration is com-
     pleted.

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                                                                      Revision i
                                                                      Page 25 of 28
          There are eight columns on the botton half of the form.   These are
'          completed for both INITIAL and FINAL calibrations.

 	    1.   Generator setting - In this column place first the  number on the
               lamp position switch if ozone is used.  After it, place the rotameter
               setting.

          2.   Generator concentration ppra - The output from the generator for the
               zotaaeter setting and position switch setting used.

        '  3.   Initial chart reading.! FS - This column lists the  Z chart reading
               for the pollutant value in column 2 when the instrument h«s the
               span setting found in the INITIAL column.

          4.   Initial instrument reading ppm - This is the instrument reading
               found on the instrument panel when a given quantity of pollutant
               is passed to it.

          5.   Final chart reading Z FS - This column lists the Z  chart reading
               for the pollutant value in column 2 when the instrument has the
               span setting found in the FINAL column.

          6.   Final instrument reading ppm - This is the instrument reading for
               a given quantity of pollutant at the FINAL calibration.

          7.   Percent - This is the percent deviation of the instrument from the
,               true pollutant concentration.  It is calculated twice.  The top
?               half of the column gives the initial percent.  This is defined as:

               Generator ppn - Initial reading z 100         .             -
                         Generator ppn              ...

                              or

               Column A - Column 2 z 100
                     Column 2

               The bottom half of the column lists the final percent.  This is
               defined as:

               Generator ppm - Final reading z 100
                         Generator ppm            .

                              or

               Column 6 - Column 2 z 100
                     Column 2                                 • .

-------
                                      FIGURE 4

                                  CALIBRATION FORM
                                                     Revision 6
                                                     Page 26 of 28
INSTRUMENT MANUFACTURER
AND MODEL NUMBER 	
XHXTXAL CALIBRATION DATS

FINAL CALIBRATION DATE __

GENERATOR NUMBER 	
                                        INSTRUMENT NUMBER

                                       	  BY	

                                               BY
                       DATE OF LAST GENERATOR CALIBRATION
REMARKS:
                                                      INITIAL
                                                      CALLS.
                                                        FINAL
                                                        CALIB.
                                          SAMPLE FLOW RATE

                                          AUXILIARY GAS FLOW RATE
                                          (SPECIF? GAS)

                                          ZERO SETTING

                                          ZERO OFFSET
                                          (Z CHART)

                                          SPAN SETTING

                                          OTHER  (SPECIFY)
  GENERATOR SETTING
 SWITCH
  FLOW
(CC/MIN)
GENERATOR
POLLUTANT
   PPM
   (2)

INITIAL
 CHART
READING
(2 FS)
  (3)
                           INITIAL
                           INSTRU.
                           READING
                             ppb
 FINAL
 CHART
READING!
CZ FS)
  (5)
 FINAL
INSTRU.
READING
  ppb


  (6)
                                                                        FINAL)
                                                                              COMMENTS

-------
                                                               yA o.z.i.i
                                                               Revision «5
                                                               Page 27 of 28
Z INITIAL  -  Col. A-Col. 2
                 Col. 2

Z FINAL  -  Col. 6-Col. 2
               Col. 2

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                                                                  QA 6.2.1.1
                                                                  Revision i
                                                                  Page 28 of 28
                                      FIGURE 5

                               CALIBRATION DRIFT TEST



INITIAL SLOPE	    FINAL SLOPE
INITIAL INTERCEPT	'	    FINAL INTERCEPT
DATE OF CALIBRATION             .         DATE OF CALIBRATION

AVG. Z DIFFERENCE	'
                       INITIAL                FINAL                    Z
Z CHART                 VALUE                 VALUE                DIFFERENCS

 10
   «
 20

 30                   -


 40                                   '             •           ."

 50

 60

 70

 80

 SO                                                               .

100


Z DIFF. - FIKAL VALUE - INITIAL VALUE x 100
                 INITIAL VALUE

-------
                                                            APPENDIX  5

                       SAMPLE COLLECTION CONTAINERS, PRESERVATIVES AND HOLDING TIMES FOR SAMPLE COLLECTION IN
                              TIC 106,  208,  404(b)(l) AND THE GREAT LAKES NATIONAL MONITORING PROGRAMS
    PARAMETER
PRESERVATIVE
    BOTTLE TYPE AND SIZE:
    SPECIAL INSTRUCTIONS
MAXIMUM HOLDING TIME FROM
COLLECTION OF SAMPLE TO START
OF ANALYSIS
Microbiology
General Chemistry
   Acidity
   Alkalinity
   Biochemical
     Oxygen Demand
   Color
   Chromium,
     hexavalent
   Hardness (EDTA)
   Nitrogen, Nitrite
   pfl (LAb)
   phosphorus (ortho)
   Solids (All Forms)
   Specific
     Conductance
.   Sulfite
   Turbidity
   MBAS

Boron
Chloride
Fluoirde
Silica
Sulfate
   Ice
   Ice
   Ice
300ml sterilized glass or plastic
container with 0.2ml of 10% sodium
thlosulfate solution, which will
neutralize 15mg/1 of residual  chlorine

960ml oblong polyethylene bottle
(Monsanto) with a 43-400mm white
polypropylene llneless smooth  edge
cap.  Container Is to remain
closed until time to remove aliquot
for analysis.  Orthophosphate  sample
1s filtered at time of collection
Into a 360ml oblong polyethylene
bottle with a 43-400mm white
flexidome polypropylene cap.
360ml oblong polyethylene bottle
with 38-400mm white flexidome
polypropylene cap.
8 hours
24 hours for all parameters
except turbidity.  Turbidity
may be held for 7 days prior
to analysis. Phosphorus
(ortho) analysis on open lake
samples shall be started
Immediately after collection.
30 days except for open lake
silica analysis which shall
be initiated  immediately
after sample  collection.

-------
                                                  APPENDIX  5 (Continued)
                        SAMPLE COLLECTION CONTAINERS,  PRESERVATIVES AND HOLDING TIMES FOR SAMPLE COLLECTION IN
                               THE 106, 208, 404(b)(l) AND THE  GREAT LAKES NATIONAL MONITORING PROGRAMS
     PARAMETER
     PRESERVATIVE
     BOTTLE TYPE AND SIZE:
     SPECIAL INSTRUCTIONS
 MAXIMUM  HOLDING TIME FROM
 COLLECTION OF  SAMPLE TO START
 OF ANALYSIS
Non-halogenated
  Organic Compounds
Chlorinated
  hydrocarbons

Nutrients, Total
  Carbon, Total
  Organic (TOC)
  Chemical Oxygen
  Demand (COD)

  Nitrogen, Ammonia

  Nitrogen,
    Nitrate/Nitrite
  Nitrogen, Total
    Kjeldahl (TKN)
  Phosphorus (Total)

Nutrients, Dissolved
  Carbon, Dissolved
    Organic
  Phosphorus,
    Dissolved
For compounds other
than the halogenated
pesticides,
preservative is to
be coordinated with
the Chief, QAO, to
meet the needs of
the proposed survey.

None
Sufficient ^$04 to
acidify the sample
to a pH of less
than 2, store at
room temperature.
Sufficient H?S04
to acidify the
sample to a pll
of less than 2,
store at room
temperature
One quart glass bottle with teflon
cap liner.  The number of sample
allquots necessary for specific
organic compounds analysis will
be determined prior to sampling
after consultation with the QAO.
One liter glass with teflon lined
cap.

360ml oblong polyethylene bottle
with a 38-400nin white flex Id one
polypropylene cap.  Sample
allquots that are composited
are to be Iced until composite
Is made and the preservative
1s added.
360ml oblong polyethylene bottle
with a 38-400mm white flexidome
polypropylene cap.  Filter at
time of collection.  Filter
allquots that are to be composited
to be iced until composite 1s
made and the preservative 1s
                                                added.
24 hours
30 days
30 days for COD/TOC
30 days for TKN
60 days for Total P
30 days for N02+N03-N
 7 days for NH3-N sewage
   samples
30 days for Nftj-N surface
   water samples, except open
   lake samples, which are to
   be analysed Immediately after
   collection.
30 days for dissolved organic
  carbon
60 days for dissolved P

-------
                                                APPENDIX  5  (Continued)

                       SAMPLE COLLECTION CONTAINERS, PRESERVATIVES AND HOLDING TIMES FOR SAMPLE COLLECTION IN
                              THE 106,  208, 404(b)(l) AND  THE GREAT LAKES NATIONAL MONITORING PROGRAMS
                                                                                         MAXIMUM HOLDING TIME FROM
                                                                                         COLLECTION OF SAMPLE TO START
                                                                                         OF ANALYSIS
PARAMETER
    PRESERVATIVE
    BOTTLE TYPE AND SIZE:
    SPECIAL INSTRUCTIONS
Oil and Grease
Metals, Total
Al umi num
Arsenic
Barium
Beryllium
C admi urn
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Hardness

Mercury
       Manganese
       Magnesium
       Nickel
       Potassium
       Selenium
       Silver
       Sodi uni
       Tin
       Ti tanium
       Vandami urn
       Zinc
     (calc)
Metals, Dissolved
   Parameters same
   as total metals
Sufficient H2S04  to
acidify the sample
to a pi I of less than
2, ice.

Sufficient HN03 to
acidify the sample
to a pH of less
than 2.
                       5ml of .5* HN03/L
                       and 10ml  of 0.05%
                       Sufficient HN03 to
                       acidify the sample
                       to ptl of less than
                       2.
                                            One quart glass container, with
                                            teflon or aluminum foil cap liner
360ml oblong polyethylene bottle
with a 38-400mm white flexidome
polypropylene cap.  Aliquots for
composite need not be acidified
prior to compositing.  Silver Is
unstable under HN03 preservation.
                      360ml  oblong polyethylene bottle with
                      a 38-400 white flexidome polypropylene
                      cap.   Aliquots for composite must be
                      acidified at time of sample collection.
                                         24 hours
6 months, except for silver.
Silver is unstable with any
preservative.
                                         13 days
                      360ml  oblong polyethylene bottle with     6 months,  except  for silver.
                      a 38-400mm white flexidome polypropylene Silver is  unstable with  any
                      cap.   Filter at time of collection.
                      Acidify immediately after
                      filtration.
                                         preservative.

-------
                                            APPENDIX   5  (Continued)
                   SAMPLE COLLECTION CONTAINERS, PRESERVATIVES AND HOLDING TIMES FOR  SAMPLE COLLECTION  IN
                  	THE 106.  208. 404(b)(l) AND THE GREAT LAKES NATIONAL MONITORING PROGRAMS	
                                                                                     MAXIMUM HOLDING TIME FROM
PARAMETER
                               PRESERVATIVE
                              BOTTLE TYPE AND SIZE:
                              SPECIAL INSTRUCTIONS
                                            360ml oblong polyethylene bottle         14 days
                                            with a 38-400mm white flexidome
                                            polypropylene cap.   If the sample
                                            contains oxidizing agents such
                                            as chlorine, remove  Immediately
                                            after sample collection by
                                            adding an excess of  FeSC>4 or
                                            NaAsOj>.  Allquots for composite
                                            sample are preserved Immediately
                                            after collection.  (For manual
                                            method - 960ml oblong polyethylene
                                            bottle with 43-200mm polypropylene
                                            Uneless smooth edge cap).

                                            360ml oblong polyethylene bottle         7 days
                                            with a 38-400mm white flexidome
                                            polypropylene cap.  Oxidizing
                                            agents such as chlorine decompose
                                            most of the cyanides.  The sample
                                            Is to be dechlorlnated prior to
                                            preservation.  Dechlorination Is
                                            accomplished by the addition
                                            0.06g of ascorbic acid per liter
                                            of sample.  (For manual  method -
                                            960ml oblong polyethylene bottle
                                            with 43-400mm polypropene lineless
                                            smooth edge cap).

                                            360ml oblong polyethylene bottle with    30 days.
                                            a 38-400mm white flexidome polypropylene
                                            cap.  Add the preservative to the
                                            sample bottle, then fill  bottle
                                            completely with sample and cap
                                            Immediately.
COLLECTION OF SAMPLE TO START
OF ANALYSIS
Phenolics
Sufficient HaP04 to
acidify sample to pH
of less than 2.  1.0
gCUS04 per/L, Ice.
Cyanide
Sufficient NaOH to
raise the sample pi I
to 12, ice
Special Samples
  Sulfide
Add 4 drops of 2N zinc
acetate per 100ml of
bottle size.  Ice.

-------
                                                APPENDIX  5  (Continued)
                       SAMPLE COLLECTION CONTAINERS, PRESERVATIVES AND HOLDING TIMES FOR SAMPLE COLLECTION IN
                              THE 106,  208, 404(b)(l) AND THE GREAT LAKES NATIONAL MONITORING PROGRAMS
    PARAMETER	
Bottom Sediments
   Chemistry - Other
   than Pesticides
   and PCB's

Chemistry
   PCB's, Pesticides,
   Phthalate Esters

Microbiology

Peri phyton
   Chlorophyl1
Phytoplankton
   Chlorophyll
    PRESERVATIVE
       Ice
    BOTTLE TYPE AND SIZE:
    SPECIAL INSTRUCTIONS	
360ml oblong polyethylene  bottle
with a 38-400mm white flexidome
polypropylene cap.
MAXIMUM HOLDING TIME FROM
COLLECTION OF SAMPLE TO START
OF ANALYSIS	
30 days
       Ice



       Ice

       Freeze
       Freeze
Macrolnvertebrates
Phytoplankton
70% Ethanol
10ml/L of Lugols
sol.
One quart glass with mouth, hexane       30 days
rinsed bottle with teflon cap liner.
Whirl-Pak plastic bag.                   8 hours

Filter sample through 0.45u              6 months
membrane filter.  Place filter in
small bottle (glass or plastic) and
freeze immediately.  Keep sample in
the dark.

Filter sample through 0.45u membrane     6 months
filter.  Place filter in small bottle
(glass or plastic) and freeze
immediately.  Keep sample in the dark.
If 1t Is not feasible to filter sample
In the field, keep sample in the dark
and Ice until the sample can reach
the laboratory for filtration.

Appropriate size glass or plastic
container.

960ml oblong polyethylene bottle         6 months
(Monsanto) with a 43-400mm white
polypropylene Uriel ess smooth edge
cap.

-------
                         APPENDIX  5 (Continued)

SAMPLE COLLECTION CONTAINERS, PRESERVATIVES AND HOLDING TIMES FOR SAMPLE COLLECTION IN
       THE 106,  208, 404(b)(l) AND THE GREAT LAKES NATIONAL MONITORING PROGRAMS
PARAMETER
Perl phy ton
Zooplankton
PRESERVATIVE
3 to 5% formalin
5% formalin
BOTTLE TYPE AND SIZE:
SPECIAL INSTRUCTIONS
Appropriate size glass or plastic
cental ner.
360ml oblong polyethylene bottle
MAXIMUM HOLDING TIME
COLLECTION OF SAMPLE
OF ANALYSIS
6 months
6 months-1
FROM
TO START

                         with a 38-400mm white flexldome
                         cap.

-------
                                APPENDIX   6

                   EPA OFFICIAL ANALYTICAL METHODOLOGY


                     PRIOROTY POLLUTANT MEASUREMENTS
     Recommended analytical  methods  for priority  pollutants  are described
in "Sampling and Analysis Procedures for Screening  of Industrial  Effluents
for Pn'ority Pollutants"  available from the  Environmental Monitoring  and
Support Laboratory,  EPA,  Cincinnati, Ohio 45268.

     These guidelines for sampling and  analysis of  industrial  wastes  have
been prepared by the staff of the Environmental Monitoring and Support
Laboratory - Cincinnati,  at  the request of the Effluent Guidelines Division,
Office of Water and  Hazardous Wastes, and with the  cooperation of the
Environmental Research Laboratory, Athens, Georgia.   The  procedures represent
the current state of the  art, but improvements are  anticipated as more
experience with a wide variety of industrial  wastes  is obtained.  Users of
these methods are encouraged to identify problems encountered  and to  assist
in updating the test procedures by contacting the Environmental Monitoring
and Support Laboratory, EPA, Cincinnati, Ohio 45268.  These  methods were
first made available in March 1977 and  were  revised  in April 1977.

-------
                                APPENDIX   7

                   EPA OFFICIAL ANALYTICAL METHODOLOGY


                       HAZARDOUS WASTE MEASUREMENTS
     Samples will  be collected in containers  prepared  by  the CRL  and
shipped to the National  Field Investigation Center - Denver, for
extraction.  The extract will be returned to  the CRL lab  for analysis.

     NEIC expects to be  ready to start processing  samples in about
three months.  A safety  manual  for handling these  materials which will
presumably contain information on containers  and shipping is also being
prepared.

     The collection of samples, preparation of containers, etc.,  is
to be coordinated through the Director of the CRL.  Existing Agency
test procedures are to be used until  test procedures specifically for
the hazardous waste program have been finalized by the Agency.

-------
                                         APPENDIX  8

                            SAMPLE COLLECTION, PRESERVATION,  AND
                                       HOLDING TIMES

                                    AMBIENT AIR SAMPLES
   PARAMETER
RECOMMENDED
HOLDING TIME
PRESERVATION METHOD
Particulate Filters
Sulfur Dioxide
(Pararosaniline Method)
Nitrogen Oxides
(Sodium-Arsenite Method)
Fluoride
Indefinite
30 days, if
properly stored
6 weeks
None
Store in controlled
atmosphere of <50%
relative humidity
Store at <4°C after
collection, during
transport, and
before analysis

Samples "are stable
for 6 weeks at room
temperature

Collect and store
in plastic
contai ners

-------
                                                      APPENDIX 9

                                          EPA OFFICIAL ANALYTICAL METHODOLOGY

                                              WATER QUALITY MEASUREMENTS
                                                                                                  PAGE  1  of 8
        PARAMETER
              METHOD.
REFERENCE*
Acidity, as CaC03, mg/1

Alkalinity, as CaC03, mg/1


Ammonia (as N), mg/1


Bacteria
Collform (fecal), no./lOO ml
Collform (total), no./lOO ml
Fecal streptococci, no./lOO ml
Benzldlne, mg/1
Biochemical oxygen demand 5-d
  (BOD5), mg/1
Bromide, mg/1
Chemical oxygen demand
  (COD), mg/1
Chloride, mg/1

Chlorinated organic compounds
  (except pesticides), mg/1
Chlorine—total residual, mg/1
Color, platinum cobalt units
  or dominant wavelength, hue
  luminance, purity
Electrometric end point (pH of 8.2)
or phenolphthlaneln end point
Electrometric titration (only to pH 4.5)
manual or automated, or equivalent
automated methods
Manual distillation (at pH 9.5)
followed by nesslerizatlon, titratlon
electrode, Automated phenol ate

MPN; membrane filter
MPN; membrane filter
MPN; membrane filter, plate count
0x1dation--colorimetrlc
Wlnkler (Azlde modification) or electrode
method
Titrimetric, lodlne-lodate
Bichromate reflux

Silver nitrate; mercuric nitrate; or
automated colorlmetrlc-ferrlcyanide
Gas chromatography

lodometric titration, amperometric  or
starch-Iodine end-point; DPD colorimetrlc
or Titrimetric methods (these last  2 are
Interim methods pending laboratory  testing)
Colorlmetrlc; spectrophotometric; or
ADMI procedure
1, 2, 3, 4

1. 2, 3, 4


1, 2, 3, 4
2, 4
2, 4
2, 4
5
2, 4

1, 3, 4
1, 2. 3, 4

1, 2, 3, 4

6

1, 2, 3
1, 2. 4

-------
                                              APPENDIX 9  (Continued)

                                           EPA OFFICIAL ANALYTICAL METHODOLOGY

                                              WATER QUALITY MEASUREMENTS
                                                                                                  PAGE 2 of 8
        PARAMETER
              METHOD
REFERENCE*
Cyanide, total, mg/1


Dissolved oxygen, mg/1

Fluoride, mg/1

Hardness—total, as CaC03, mg/1
Hydrogen ion (pll), pH units
Kjeldahl nitrogen (as N), mg/1
Metals
All dissolved metals

Aluminum—total, mg/1
Antimony--total,  mg/1
Arsenic—total, mg/1

Barium—total,  mg/1
Beryllium—total, mg/1

Boron—total, mg/1
 Distillation followed by silver nitrate
 titration or pyridine pyrazolone (or
 barbituric acid) colorimetric
 Kinkier  (Azide modification) or
 electrode method
 Distillation followed by ion electrode;
 SPADNS;  or automated complexone
 EDTA  titration; automated co1 orimetric;
 or atomic absorption (sum of Ca and Mg
 as their respective carbonates)
 Electrometric measurement
 Digestion and distillation followed
 by nesslerization, titration, or
 electrode; automated digestion
 automated phenol ate

 0.45 micron filtration7 followed by
 referenced method for total  metal
 Digestion8 followed by atomic absorption9
 or by colorimetric (Eriochrome
Cyanine R)
 Digestion8 followed by atomic absorption9
 Digestion followed by silver diethyl-
 dithiocarbamate; or atomic absorption9
 Digestion8 followed by atomic absorption9
 Digestion8 followed by atomic,
 absorption9 or by colorimetric (Aluminon)
Corimetric (Curcumin)
1, 2, 3. 4


1, 2, 3, 4

1, 2, 3, 4

1. 2, 3, 4
1, 2. 3, 4
1. 2, 4
1, 2, 4

1, 2, 4


1
1, 2, 4

1, 2, 4
1. 2, 4

1, 2

-------
                                              APPENDIX 9 (Continued)

                                          EPA OFFICIAL ANALYTICAL METHODOLOGY

                                              WATER QUALITY MEASUREMENTS
                                                                                                 PAGE 3 of 8
        PARAMETER
              METHOD
REFERENCE*
Cadmium—total, nig/1

Calc1um--total, mg/1

Chromium VI, mg/1

Chromium--total, mg/1

Cobalt—total, mg/1

Copper—total, mg/1


Gold—total, mg/1
Indium—total, mg/1
Iron—total, mg/1

Lead—total, mg/1

Magnesium—total, mg/1

Manganese—total, mg/1

Mercury—total, mg/1
Molybdenum—total, mg/1
Nickel—total, mg/1

Osmium—total, mg/1
Digestion** followed by atomic  absorption9          1, 2, 3, 4
or by colorimetrlc (Dithizone)
Digestion8 followed by atomic                      1, 2, 3, 4
absorption; or EDTA titratlon
Extraction and atomic absorption;                  1, 2, 4
colorimetrlc (Diphenylcarbazide)
Digestion8 followed by atomic  absorption9          1, 2, 3, 4
or by colorimetrlc (Diphenylcarbazide)
Digestion8 followed by atomic                      1, 2, 3, 4
absorption9
Digestion8 followed by atomic                      1, 2, 3, 4
absorption9 or by colorimetric
(Neocuproine)
Digestion8 followed at atomic  absorption9
Digestion8 followed by atomic  absorption9
Digestion8 followed by atomic  absorption9          1, 2, 3, 4
or by colorimetric (Phenanthrollne) ,
Digestion8 followed by atomic  absorption9          1, 2, 3, 4
or by colorimetric (Dithizone)
Digestion8 followed by atomic  absorption9          1, 2, 3, 4
or gravimetric
Digestion8 followed by atomic  absorption9          1, 2, 3, 4
or by colorimetrlc (Persulfate or perlodate)
Flameless atomic absorption                       1, 2, 3, 4
Digestion8 followed by atomic  absorption9          1, 3
Digestion8 followed by atomic  absorption9          1, 2, 3, 4
or by colorimetrlc (Heptoxime)
Digestion8 followed by atomic  absorption9

-------
                                              APPENDIX 9 (Continued)

                                          EPA OFFICIAL ANALYTICAL METHODOLOGY

                                              WATER QUALITY MEASUREMENTS
                                                                                                  PAGE  4  of 8
        PARAMETER
              METHOD
REFERENCE*
Palladium—total,  mg/1
Platinum—total,  mg/1
Potassium—total,  mg/1
Rhodium—total, mg/1
Ruthenium—total,  mg/1
Selenium—total, mg/1
Silica—dissolved, mg/1

Silver—total,  mg/1

Sodium—total,  mg/1

Thallium—total, mg/1
Tin—total, mg/1
Titanium—total, mg/1
Vanadium—total, mg/1

Zinc—total, mg/1

Nitrate (as N), mg/1

Nitrite (as N), mg/1

Oil and grease, mg/1
Digestion** followed by atomic absorption9
Digestion8 followed by atomic Absorption9
Digestion8 followed by atomic absorption
col or i metric (Cobalti nitrite),  or by flame
photometric
Digestion8 followed by atomic absorption9
Digestion8 followed by atomic absorption9
Digestion8 followed by atomic absorption9
0.45 micron filtration? followed by
colorimetric (Molybdosilicate)
Digestion8 followed by atomic absorption9
or by colorimetric (Dithizone)
Digestion8 followed by atomic absorption
or by flame photometric
Digestion8 followed by atomic absorption9
Digestion8 followed by atomic absorption9
Digestion8 followed by atomic absorption9
Digestion8 followed by atomic absorption9
or by colorimetric (Gallic acid)
Digestion8 followed by atomic absorption9
or by colorimetric (Dithizone)
Cadmium reduction; brucine sulfate;
automated cadmium or hydrazlne  reduction*0
Manual or automated colorimetric
(Diazotization)
Li quid-11 quid extraction with
trichloro-trlfluoroethane-gravimetric
1. 2, 3, 4
1. 2
1, 2, 3, 4

1. 2, 4

1. 2, 3. 4

1
1, 4
1
1, 2. 3, 4

1, 2, 3, 4

1. 2, 3, 4

1, 2, 4

1, 2

-------
                                              APPENDIX 9 (Continued)

                                          EPA OFFICIAL ANALYTICAL  METHODOLOGY

                                              WATER QUALITY MEASUREMENTS
                                                                                                 PAGE 5 of 8
        PARAMETER
              METHOD
REFERENCE*
Organic carbon—total  (TOC), mg/1
Organic nitrogen (as N),  mg/1

Orthophosphate (as P), mg/1

Pentachlorophenol, mg/1
Pesticides, mg/1
Phenols, mg/1

Phosphorus (elemental), mg/1
Phosphorus—total  (as  P), mg/1

Radiological
Alpha—total, pCI  per  liter
Alpha—counting error,
  pC1 per liter
Beta—total, pCi per liter
Beta—counting error,
  pC1 per liter
Radium—total, pCI per liter
Ra, pC1 per liter
Residue
Total, mg/1
Total dissolved (filterable), mg/1
Total suspended (nonfllterable),
  mg/1
Settleable, ml/1 or mg/1
Total volatile, mg/1
Specific conductance,  mlcromhos
  per centimeter at 25°C
Combust Ion--Infra red method**
Kjeldahl nitrogen minus ammonia
nitrogen
Manual or automated ascorbic acid
reduction
Gas chromatography6
6
Distillation followed by colorimetric
(4AAP)
Gas chromatography
Persulfate digestion followed by manual  or
automated ascorbic acid reduction

Proportional or scintillation counter
Proportional counter
Scintillation counter

Gravimetric, 103 to 105°C
Glass fiber filtration, 180t
Glass fiber filtration, 103 to 105°C

Volumetric or gravimetric
Gravimetric, 550°C
Wheatstone bridge conductimetry
1, 2, 3
1, 2, 4

1. 2, 3, 4

2, 3

1, 2, 3

12
1, 2, 3, 4
2, 3, 4
2, 3, 4

2, 3, 4
2, 3, 4

2, 3
1, 4

1, 2
1, 2
1,2

2
1, 2
1, 2, 3, 4

-------
                                             APPENDIX 9  (Continued)

                                          EPA OFFICIAL ANALYTICAL METHODOLOGY


                                             WATER QUALITY MEASUREMENTS
                                                                                                 PAGE 6 of 8
       PARAMETER
              METHOD
                                                                                              REFERENCE*
Sulfate (as S04), mg/1
Sulfide (as S), mg/1
Sulfite (as S03), mg/1
Surfactants, mg/1
Temperature, °C

Turbidity. NTU	
Gravimetric; turbidimetrlc; or
automated colorimetric (barium
chloranilate)
Titrimetr1c--1odine for levels
greater than 1 mg per liter;
Methylene blue photometric
Titrimetric, lodine-iodate
Colorimetric (Methylene blue)
Calibrated glass or electrometrlc
thermometer
Nephelometric	
2. 3


1. 3. 4
1. 2, 3
1, 2. 3, 4
1, 2, 4

1, 2, 3, 4
*References:

     Methods for Chemical  Analysis of Water and Wastes, 1979.  U.S. Environmental  Protection Agency.   Office
of Research and Development.   Environmental Monitoring and Support Laboratory, Cincinnati, Ohio.

     Standard Methods for  the Examination of Water and Wastewater, 14th edition,  1975.   American Public
Health Association,  American  Water Works Association and Water Pollution Control  Federation,  Washington,  D.C.

     3Annual Book of ASTM Standards, Part 31: Water, 1978.  American Society for  Testing and  Materials
Philadelphia, Pennsylvania.
          references  for USGC methods, unless otherwise noted, are to Brown,  E.,  Skougstad,  M.W.,  and  Fishman, M.J.
 Methods for Collection and  Analysis of Water Samples for Dissolved Minerals  and  Gases".   U.S.  Geological  Survey
Techniques of Water-Resources Inv., Book 5, Ch. Al (1970).

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                                                                                                  PAGE 7 of 8

                                                  APPENDIX 9  (CONTINUED)

                                            EPA OFFICIAL ANALYTICAL METHODOLOGY

                                                WATER QUALITY MEASUREMENT
      5 Adequately tested methods for benzldine  are  not  available.  Until approved methods are available, the
following Interim method can be used for the estimation of benzldine:  (1)  "Method for Benzidlne and Its Salts
1n Wastewaters," available from Environmental Monitoring and  Support Laboratory, U.S. Environmental Protection
Agency, Cincinnati, Ohio 45268.

      Procedures for pentachlorophenol , chlorinated  organic  compounds, and pesticides can be obtained from the
Environmental Monitoring and Support Laboratory,  U.S. Environmental Protection Agency, Cincinnati, Ohio 45268.

      ^Dissolved metals are defined as those constituents which  will pass  through a 0.45 urn membrane filter.  A
prefiltration is permissible to free the sample from  larger suspended  solids.  Filter the sample as soon as
practical after collection using the first  50 to 100  ml  to rinse the filter flask.  (Glass or plastic filtering
apparatus are recommended to avoid possible contamination).   Discard the portion used to rinse the flask and
collect the required volume of filtrate. Acidify the filtrate with 1:1 redistilled HN03 to a pll of 2.
Normally, 3 ml of (1:1) add per liter should be sufficient to preserve the samples.
           the determination of total  metals  the samples  Is  not  filtered before processing.  Because vigorous
digestion procedures may result in a loss of  certain metals  through  precipitation, a  less vigorous treatment
is recommended as given on page 83 (4.4.4) of "Methods  for Chemical  Analysis of Water and Wastes" (1974).
In those instances where a more vigorous digestion Is desired, the procedure on page  82  (4.1.3) should be
followed.  For the measurement of the noble metal  series  (gold,  Irldium, osmium,  palladium,  platinum,
rhodium, and ruthenium), an aqua regia digestion is to  be substituted  as follows: Transfer a representative
aliquot of the well-mixed sample to a Griffin beaker and  add 3 ml of concentrated redistilled HN03.  Place
the beaker on a steam bath and evaporate to dryness.  Cool the beaker  and cautiously  add a 5 ml portion of
aqua regia.  (Aqua regia 1s prepared immediately before use  by carefully adding 3 volumes of concentrated
IC1 to one volume of concentrated HN03).  Cover the beaker with  a watch glass  and return to  the steam bath.
Continue heating the covered beaker for 50 min.   Remove cover and evaporate
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                                                                                                  PAGE 8 of 8

                                                  APPENDIX  9  (CONTINUED)

                                            EPA OFFICIAL ANALYTICAL METHODOLOGY


                                                WATER QUALITY MEASUREMENTS
      9As the various furnace devices (flameless AA) are essentially atomic absorption techniques, they are
considered to be approved test methods.   Methods of standard addition are to be followed as noted in page 78
of "Methods for Chemical Analysis of Water  and  Wastes", 1974.

      10An automated hydrazine reduction method Is available from the Environmental Monitoring and Support
Laboratory, U.S. Environmental Protection Agency, Cincinnati, Ohio 45268.

      ^Goerlitz, D., Brown, E., "Methods for Analysis of Organic Substances 1n Water": U.S. Geological
Survey Techniques of Water-Resources Inv.8  Book 5, Ch. A3 (1972).

      12R.F. Addison and R.G. Ackman, "Direct Determination of Elemental Phosphorus by Gas-Liquid
Chromatography", "Journal of Chromatography", Vol. 47, No. 3, pp. 421-426, 1970.

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                                                       APPENDIX 10
                                           EPA OFFICIAL ANALYTICAL METHODOLOGY

                                                    RADIATION METHODS
PARAMETER AND UNITS
METHOD
SAMPLE MATRIX
  REFERENCE
Alpha - total pCI per liter


Beta - total pCi per liter
Radium-226 - pCi per liter
Strontium 89, 90 - pC1
  per liter
Tritium - pCI per liter
Cesium 134 - pCi per liter

Uranium - pCi per liter
Others (varium units
  depending on media)
Proportional or
scintillation counter
Proportional  counter
Scintillation counter
Fluorometric
    Water


    Mater
    Water
    Water

    Water
    Water

    Water

    Various
Interim Radiochemical  Methodology
for Drinking Water EPA-600/4-75-008
Standard Methods for the Examination
of Water and Wastewater, 14th  lid.
(same as above)
(same as above)
(same as above)

(same as above)
(same as above)
ASTM D-2459 Gamma Spectroscopy In
Water, 1975
ASTM D-2907 Micro Quantities of
Uranium in Water by Fluorimetry,  1975
HASL Procedure Manua,  HASL 300,
ERDA Health and Safety Laboratory,
New York, NY, 1973

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                                                    APPENDIX 11

                                        EPA OFFICIAL ANALYTICAL  METHODOLOGY


                                             AMBIENT AIR MEASUREMENTS
POLLUTANT
  MEASUREMENT METHOD
     OR PRINCIPLE
        REFERENCE
Suspended Participates
Sulfur Dioxide
Carbon Monoxide
Photochemical Oxidants
Nitrogen Dioxide
High Volume sampler
Tape sampler

Pararosaniline or equivalent
Nondispersive infrared
or equivalent

Gas phase chemlluminescence
or equivalent

Gas phase chemiluminescence
or equivalent
CFR 40, Part 50, Appendix B,
July 1, 1979

CFR 40, Part 50, Appendix A.
July 1, 1979

CFR 40, Part 50, Appendix C,
July 1, 1979

CFR 40, Part 50, Appendix D,
July 1, 1979

CFR 40, Part 50, Appendix F,
July 1, 1979

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                                                                                                  PAGE  1  of 2
                                                    APPENDIX 12
                                        EPA OFFICIAL ANALYTICAL METHODOLOGY
                                              SOURCE AIR MEASUREMENTS
DETERMINATION
DESCRIPTION OF METHOD
REFERENCE
Sample and Velocity Traverses


Stack Gas Velocity
Dry Molecular Weight of Gas
Stack Gas Moisture
Particulate Emissions
Sulfur Dioxide

Nitrogen Oxide
Sulfuric Acid Mist and
Sulfur Dioxide
Visible Emissions
Carbon Monoxide
Hydrogen Sulfide
     Pi tot
     Orsat
Volumetric & Gravimetric
     Gravimetric
Collection by impinger,
analysis by barium
perchlorate tltration
Collection by evacuated
flask, colorlmetric
analysis
Collection by Impinger,
analysis by barium
perchlorate tltration
Certified observer
Non-dispersive infrared
Collection by impinger,
iodimetric titration
EPA Method 1 Environmental
Protection Agency Performance
Test Methods, page 1-1,
EPA-340/1-78-011
EPA Method 2  1-13
EPA Method 3  1-45
EPA Method 4  1-61
EPA Method 5  1-79
EPA Method 6  1-119

EPA Method 7  1-135

EPA Method 8  1-157

EPA Method 9
EPA Method 10
EPA Method 11

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                                              APPENDIX 12 (CONTINUED)

                                        EPA OFFICIAL ANALYTICAL METHODOLOGY


                                              SOURCE AIR MEASUREMENTS
                                                                                                  PAGE 2 of 2
DETERMINATION
DESCRIPTION OF METHOD
REFERENCE
Fluoride
Sulfur Compounds
Sulfur Compounds
Particulate Matter
Collection by Implnger,
col orimetric, or specific
1on electrode

Gas chrontatographlc
determination of sulfur
gases emitted by a
Claus Sulfur Recovery Unit

Gas chromatographic
determiantion of reduced
sulfur compounds emitted
by paper mills

In-stack filter
determination of parti -
culate matter
EPA Method 13A (Colorimetric)
or 13B (Specific Ion Electrode)
EPA Method 15
EPA Method 16
EPA Method 17

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                                                  APPENDIX 13

                                      EPA OFFICIAL ANALYTICAL METHODOLOGY

                                          PUBLIC WATER SUPPLY METHODS
Parameter
Method
Reference
Organlcs
  (a) Chlorinated Hydrocarbons:
      Endrin
      Lindane
      Methoxychlor
      Toxaphene
  (b) Chlorophenoxys:
      2,4-Di chlorophenoxyacetlc
        acid
      2,4,5-Trichloro-
        phenoxyproplonic  acid

Radiation
Inorganic Chemicals
Physical Measurements
Microbiological Measurements
Gas chromatography with
electron capture detector
Methods for Organochlorine
Pesticides in Industrial
Effluents, MDQARL, EPA,
Cincinnati, Ohio, 1973
                                    Methods  for Chlorinated Phenoxy
                                    Add Herbicides  in  Industrial
                                    Effluents, MDQARL,  EPA,
                                    Cincinnati, Ohio, 1973
                                   Code of Federal  Regulations,
                                   40  (Parts  100  to 399):  169-197

                                   Code of Federal  Regulations,
                                   40  (Parts  100  to 399):  169-197

                                   Code of Federal  Regulations,
                                   40  (Parts  100  to 399):  169-197

                                   Code of Federal  Regulations,
                                   40  (Parts  100  to 399):  169-197

-------
                                        APPENDIX 14
                                                                      Page  1  of  3
                 SAMPLE COLLECTION CONTAINERS, PRESERVATIVES,  AND HOLDING
                TIMES FOR SAMPLES COLLECTED IN THE 1412 MONITORING PROGRAM

                                        CHEMISTRY!
PARAMETER
Arseni c
Ban urn
Cadmium
Chromium
Lead
Mercury

Nitrate
Selenium
Silver
Fl uori de
Chlorinated
PRESERVATIVE2
Cone. HN03 to pH<2
Cone. HN03 to pH<2
Cone. HNOs to pH<2
Cone. HNOs to pH<2
Cone. HNOs to pH<2
Cone. HNOs to pH<2

Cone. ^$04 to pH<2
Cone. HNOs to PH<2
Cone. HNOs to pH<2
None
Refrigerate at 4°C as
CONTAINER3
P or G
P or 6
P or 6
P or G
P or G
G
P
P or G
P or G
P or G
P or G
G with foil or
MAXIMUM
HOLDING
TIME4
6 months
6 months
6 months
6 months
6 months
38 days
14 days
14 days
6 months
6 months
1 month
14 days5
  hydrocarbon
Chlorophenoxys
soon as possible after
collection

Refrigerate at 4°C  as
soon as possible after
collection
Teflon lined cap


G with foil  or
Teflon lined cap
7 days5
1 - If a laboratory has no control  over these factors,  the  laboratory director must
    reject any samples not meeting  these criteria  and so  notify the authority
    requesting the analyses.
2 - If HNOs cannot be used because  of shipping restrictions, samples may be initially
    preserved by icing and immediately shipping it to the laboratory.  Upon receipt in
    the laboratory, the sample must be acidified with concHNOs to  pH<2.  At time of
    analysis, sample container should be thoroughly rinsed  with 1:1 HNOs; washings
    should be added to sample.
3 - P * Plastic, hard or solf;  G =  Glass, hard or  soft.
4 - In all cases, samples should be analyzed  as soon after  collection as possible.
5 - Well  stoppered and refrigerated extracts  can be held  up to 30  days.

-------
                                                                    Page 2 of 3
                               APPENDIX 14  (Continued)

                                   RADIX HEMISTRY1
PARAMETER
Gross alpha
Gross beta
Stronti um-89
Stronti urn- 90
Radi um-226
Radium- 228
Cesium- 134
Iodine- 131
Tri ti urn
Urani um
Photon emitters
PRESERVATIVE2
Cone.
Cone.
Cone.
Cone.
Cone.
Cone.
Cone.
None
None
Cone.
Cone.
fCl
mi
fCl
fCl
fCl
rci
rci


fCl
fCl
or
or
or
or
or
or
to


or
or
HN03
HN03
HN03
HN03
HN03
HN03
pH<2


HN03
HN03
to
to
to
to
to
to



to
to
-pH<24
PH<24
pH<2
pH<2
pH<2
pH<2



pH<2
pH<2
CONTAINER3
P
P
P
P
P
P
P
P
G
P
P
or
or
or
or
or
or
or
or

or
or
G
G
G
G
G
G
G
G

G
G
1 - "Federal  Register",  Volume 41,  No.  133, July 9,  1976.

2 - It is recommended that the preservative be  added to the sample at the time of
    collection unless suspended solids  activity is to be measured,   However, if the
    sample must be shipped to a laboratory or storage area, acidification of the
    sample (in its original  container)  may be delayed for  a period not to exceed
    5 days.   A minimum of 16 hours  must elapse  between acidification and analysis.

3 - P * Plastic, hard or soft; G =  Glass,  hard  or soft.

4 - If fCl is used to acidity samples which are to be analyzed for gross alpha or
    gross beta activities, the acid salts  must  be converted to nitrate salts
    before transfer of the samples  to planchets.

-------
                                                               Page 3  of  3
                          APPENDIX  14  (Continued)
                                MICROBIOLOGY
                           DRINKING WATER  SAMPLES

     Sample bottles must be of at least 120ml  capacity,  sterile plastic
or hard glass, wide"mouthed with stopper or plastic  screw cap  and  capable
of being sterilized repeatedly.   10mg/l sodium thiosulfate is  added to
the sample during preparation.   Sample volume  must be  at least 100ml.
Samples must be analyzed within  30  hours after collection.   If a State
principal laboratory is required by State  regulations  to examine samples
after 30 hours and up to 48 hours,  the laboratory must indicate that the
data may be invalid because of excessive delay before  sample analysis.
Samples arriving 48 hours shall  be  refused without exception and a new
sample requested.

-------
                APPENDIX  15
                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 DATt-   Mn
        MAR 0  1378
ic :CT:   Approved Alternative Analytical
        Methods - Nationwide Use
        Victor J.  Kizrm,  Deputy Assistant
        Administrator for Drinking Water (WH-550)

   T0:   All Regional Administrators

        Listed below are additional alternative analytical methods for,
        nationwide use which I have approved for the National Interim
        Primary Drinking Water Regulations.  As stated in my March 10,
        1977 memorandum on this subject, publication of new  alternate
        analytical methods will eventually follow in the Federal Register.

        Specific questions regarding the details of these procedures
        should be directed to the Director, Environmental Monitoring
        and Support Laboratory, Cincinnati.
             Measurement
        Organics (Pesticides)
        Fluoride
        Fluoride
                Method

"Standard Methods for the Examination of
Water and Kastswater," 14th ed.f 1975.
Organochlorine Pesticides, part 509A,
pp. 555-564, Chlorinated Phencxy Acid
Herbicides, part 509B, pp. 565-569.

Modified Automated Alizarin Blue, Ref:

"Fluoride in Water and Wastewater,"
Industrial Method =129-71W, Deceiuber 1972,
Technicon Industrial Systems
Tarrytown, NY  10591

Automated Electrode Method, Ref:'

"Fluoride in Water and Wastewater"
Industrial Method S380-75KS,
February 2, 1976, Technicon Industrial
Systems, Tarrytown, NY  10591
      cc:  Water/
          S  & A
          A  fit H M
 A Fo..» 1373 I. IR»...].;«)
                                                                    MAR 1 5 1978

                                                                   EPA REGION  5
                                                                   OFFICE OF REGIONAL

-------
                UNITED 5TYTPEESNi&lio.to-fl!?.^TECTiON AGENCY
 «E=SEP   1 tS77	   .
                                                .-.- :-••,.'< '/in, n >.  ;.'
 =cT:  ^Approved Alternative Analytical             .,. i.-..-.-.-«..c.  .  .
       Itliods -Nationwide Use ~                           .....
                     Orr Oil OF DiiH-'.oi'
                    <• •> i PS .irV.n "'.""•r, ".' -
                    O "v •••. .' • .-'On, •_. ,•••, r . -.
            J. Kimra, Deputy .Assistant  •
      Administrator for Water Supply (WH-550)

 TO:   All Regional Administrators
      This memorandum replaces my earlier memo of May 10 on this subject,
      since questions at the regional/State level concerning its implementation
      have been raised.  In addition, some points need further clarification
      and comment prior to official publication of the approved alternate
      analytical methods in the Federal Register.

      In order to expedite the publication of these needed alternate analytical
      methods and to correct and clarify  inaccuracies and other possible
      ambiguities which may have occurred as the result of collective actions
      the approved methods for nationwide use are summarized below; hence,
      iny May 10 memo should be disregarded.
     Measurement
                   Method
     Arsenic


     Arsenic
     Barium


     Cadmium


     Chromium

      •
     Fluoride
Flameless Atomic Absorption,  Graphite
Furnace Technique.

Silver Diethyldifhiocarbamate Method, Bef:
'^Methods  for Chemical Analysis of Water and
Wastes,"pp. 9-10, EPA Office of Technology
Transfer, (1974).

Flameless Atomic Absorption,  Graphite
Furnace Technique.

Flameless Atomic Absorption,  Graphite
Furnace Technique.

Flameless Atomic Absorption,  Graphite Furnace
Technique.

Automated Alizarin Fluoride Blue, Ref: "Stan-
dard Methods for the Examination of Water
and Wastewaler," 14,  pp. 614-616, (1975)
Tu
       fftvr. }•?*>

-------
                                      APPENDIX 15 (Continued)
Fluoride
Lead
Mercury
Nitrate
Nitrate
Qrganics
Selenium
Selenium-
Silver
 Zirconium-Eriochrome Cyanine R. Ref: "Methods
 for Collection and Analysis of Water Samples for -
 Dissolved Minerals and Gases, " USGS, Book 5,
 Chapter A1, pp. 90-93.

 Flameless Atomic Absorption,  Graphite
 Furnace Technique.
                                 *
 Automated Cold Vapor Technique, Ref: "Methods
 for Chemical Analysis of Water and Wastes,ff
 pp. 127-133, EPA Office of Technology Trans-
 fer, (1974).

 Automated Hydrazine Reduction, Ref:  "Methods
 for Chemical Analysis of Water and Wastes,"
 pp. 185-194, NERC Analytical Quality  Control
 Laboratory, (1971).

 Automated Cadmium Reduction, Ref: "Methods for
 Chemical Analysis of Water and Wastes, " pp. 207-
 212, EPA Office of Technology Transfer, (1974).

 Gas Chromatographic, Ref: "Methods  for Analysis -'.
 Organic Substances in Water,"  USGS,  Boc1- 5,"
 Chapter A 3, pp. 24-39.
\t
 Hydride generation - atomic absorption
 spectrophotometry, USGS.  Method, 1-1667-77,
 (1976).

 Flameless Atomic Absorption, Graphite Furnace
 Technique,  Ref: Atomic Absorption Newsletter,
 14, No. 5,  pp. 109-116, (1975).

 Flameless Atomic Absorption, Graphite Furnace
 Technique.
Once it is published, you will be provided with copies of the FR
notification by my office. In the interim, these methods may be
considered as  approved alternative analytical methods to meet the
monitoring requirements of the SDWA,  Additional information on

-------
                                                      APPENDIX 15 (Continued
the Homeless atomic absorption graphite furnace technique is
avcdlable from the Director of the Environmental Monitoring
and Support Laboratory in Cincinnati until the 1974 EPA
manual is updated.
1
  The various furnace devices are considered to be atomic absorption
techniques.  Methods of standard addition are to be followed as noted
on p. 78 of "Methods for Chemical Analysis of Water and Wastes, "
EPA Office of Technology Transfer,  (1974).

2
  Copies available from:  Water Quality Branch, National Center
U.S. Geological Survey,  112201 Sunrise Valley Drive, Reston,
Virginia 22092.

3
  Only the six pesticides named in the Interim Primary Drinking
Water Regulations are included: Endrin,  Lindane, Methoxychlor,
Toxaphene; 2,4-D; and 2,4;5-TP (Siivex).  Federal Register,
Vol. 40, No. 248, pp.  59570-59571, Dec. 24, 1975.

-------
                      APPENDIX 16
      PERFORMANCE TESTS FOR THE EVALUATION
                OF COMPUTERIZED
      GAS CHROMATOGRAPHY/MASS SPECTROMETRY
           EQUIPMENT AND LABORATORIES
                       by

                William L. Budde
              "'  "     and
             James W. Eichelberger
Environmental Monitoring and Support Laboratory
       Office of Research and Development
      U.S. Environmental Protection Agency
            Cincinnati, Ohio  45268

-------
 ... .  .  ._..    .  .                DISCLAIMER"  ""       ~~     "
 *

    This report has been reviewed by the Environmental Monitoring and
Support Laboratory, U.S. Environmental Protection Agency, and approved for
publication.  Mention of trade names or commercial products does not
constitute endorsement or recommendation for use.
                                       11

-------
                                   FOREWORD  '	  —	


    Environmental measurements are required to determine the quality of
ambient waters and the character of waste effluents.  The Environmental
Monitoring and Support Laboratory - Cincinnati, conducts research to:

    + Develop and evaluate methods to measure the presence and concentra-
      tion of physical, chemical, and radiological pollutants in water,
      wastewater, bottom sediments, and solid waste.

    + Investigate methods for the concentration, recovery, and identifica-
   — tion of viruses, bacteria and other microbiological organisms in
      water; and, to determine the responses of aquatic organisms to water
      quality.

    + Develop and operate an Agency-wide quality assurance program  to  assure
      standardization and quality control of systems for monitoring water
      and wastewater.

    + Develop and operate a computerized system for instrument automation
  •    leading to improved data collection, analysis, and quality control.

    This report was developed by the Advanced Instrumentation Section  of the
Environmental Monitoring and Support Laboratory.  It describes a series  of
general purpose tests to evaluate the performance of computerized gas
chromatography-raass spectrometry (GC/MS) systems.  Some of the tests go
beyond equipment performance and may be used to evaluate the performance of
laboratories using GC/MS for organics analysis.  The report will be useful
to the many Federal, State, local government, and private  laboratories that
are planning to employ this powerful analytical tool.
                                     Dwight 6. Ballinger
                                     Director
                                     Environmental Monitoring  and  Support
                                     Laboratory - Cincinnati

-------
                                   ABSTRACT


    A series of ten general purpose tests are described which are used to
evaluate the performance of computerized gas chromatography-mass
spectrometry systems.  Evaluation criteria are given with each performance
test.  Some of the tests go beyond equipment performance, and may be used to
evaluate the performance of laboratories using SS/MS for organics analysis.
                                      fv

-------
                                   CONTENTS


Foreword	Hi
Abstract	*	1v
Figures	vi
Tables	vi
Acknowledgment	 vii

    1.  Introduct i on	1

    2.  Summary of Tests	3

    3.  Experimental Procedures	5

         Test I    Spectrum Validation	5
         Test II   System Stability	8
         Test III  Instrument Detection Limit	8
         Test IV   Saturation Recovery	»..!!
         Test V    Precision	12
         Test VI   Library Search	16
         Test VII  Quantitative Analysis with Liquid-Liquid Extraction	17
         Test VIII Quantitative Analysis with Inert Gas Purge and Trap	19
         Test IX   Qualitative Analysis with Real Samples	27
         Test X    Solid Probe Inlet System	30

    4.   References	32

-------
                                   FIGURES .
Number                                                  •               Page
  1      Control chart for nitrobenzene 1n clean water ............. ....  21
  2      Control chart for pyrene in clean water .......................  22

                                    TABLES
Number                    _            __ .       .....    ____     Page
  1      Suggested GC Columns and Conditions ...........................   7
  2      Decaf luorotrlphenylphosphine Key Ions and  Ion Abundance .......   7
         Criteria
  3      Ions Over 3!! Relative Abundance Observed In  the 70 ev Mass
         Spectrum of OFTPP ............... . .......... .. .................  10
  4      Common Background  Ions  In GC/MS Systems
  5      Precision Statistics for Ten Priority Pollutants  Plus
         Octadecane ........................ • ...........................   13
  6      Precision Statistics Using  an  Internal  Standard ...............   15
  7      £-Sromofluoro benzene Key Ions  and Ion Abundance Criteria ......   16
  8      Precision and Accuracy Data for  Liquid-Liquid  Extraction
         with GC/MS and an External  Standard ...........................   20

  9      Method Efficiencies for Some Priority Pollutants  Plus
         p_-8romof1uorobenzene ................... . ................... ...   25
 10      Precision and Accuracy Data for  the  Purge  and  Trap Analysis
         with GC/MS and an External  Standard ...........................   26
 11      Precision and Accuracy Data for  the  Purge  and  Trap Analysis
         with GC/MS and the  Internal Standard p^-Sromofluorofaenzene .....   23
 12      Precision and Accuracy Data for  the  Purge  and  Trap Analysis
         with GC/MS and the  Internal Standard Dibromochloromethane .....   29
                                      vt

-------
                                ACKNOWLEDGMENT
    The authors wish to acknowledge the careful and competent technical
assistance of William Middleton, Jr., who has performed all of the SC/MS
tests described in this report at least once, and several of them hundreds
of times.

    A number of Environmental Protection Agency personnel reviewed the first
draft of this report, and many provided written comments which substantially
assisted the authors in the preparation of this document.  Our deep
appreciation is due to all of the following:
William Andrade
Region 1
Surveillance and Analysis Division
Lexington, MA  02173

Thomas A. Beliar
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

Robert L. Booth, Deputy Director
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

Aubry E. Oupuy, Jr.
Pesticides Monitoring Laboratory
Bay Saint Louis, MS  39520
Robert D. Kleopfer
Region 7
Surveillance and Analysis Division
Kansas City, KS  66115

John Logsdon
National Enforcement
Investigation Center
Denver, CO  80225
Dwight G. Ballinger, Director
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

Joseph N. Blazevich
Region 10
Surveillance and Analysis Division
Manchester, WA  98353

Herbert J. Brass
Division of Technical Support
Cincinnati, OH  45258
Denis Foerst
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45258

John Kopp
Environmental Monitoring and
Support Laboratory
Cincinnati, OH  45268

E. William Loy, Jr.
Region 4
Surveillance and Analysis  Division
Athens, GA 30601
                                      vii

-------
John M. McGuire
Environmental Research Laboratory
Athens, GA  30601

Aaron A. Rosen
Cincinnati Water Works
Cincinnati, OH  45228
0. C. Shew
R. S. Kerr Environmental
Research Laboratory
Ada, OK  74320
                   «

Alan Stevens
Municipal Environmental
Research Laboratory
Cincinnati, OH  45263
Curt Norwood
Environmental Research Laboratory
Narragansett, RI  02882

Dennis R. Seeger
Municipal Environmental
Research Laboratory
Cincinnati, OH  45263

Clois Slocum
Municipal Environmental Research
Laboratory
Cincinnati, OH  45263

Emilio Sturino
Region 5
Surveillance and Analysis Division
Chicago, IL  60606

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                                  SECTION 1

                                 INTRODUCTION


    This report gives a series of performance tests to evaluate  computerized
gas chromatography - mass spectrometry  (GC/MS) systems.  These tests were
designed for general use, and are applicable to  all types  of  GC/MS  systems.
All of the tests use the continuous,- repetitive  measurement of spectra
method of data•acquisition, and no selected ion  monitoring tests are
included.  Except for the spectrum validation test (Test I),  these
performance tests are not intended for  routine application in a  quality
assurance program.  Test I is a required daily quality control test for
GC/MS systems in routine use for measurements of organic compounds  in
environmental samples.  The other performance tests are intended for use  in
the evaluation of new GC/MS systems before purchase, or after the completion
of the manufacturer's installation. These tests  are also useful  to  evaluate
GC/MS performance after a long period of downtime for extensive  maintenance
or repair, after a long period of equipment neglect or non-use,  or  as
general training experiments for GC/MS  operators.  Several of the tests go
beyond equipment performance and may be used to  evaluate the  performance  of
laboratories using GC/MS for organics analysis.

    The performance tests described in  this report are more rigorous and
extensive than the typical manufacturer's installation tests. Indeed, this
was intended, and the emphasis of the tests is on an evaluation  of  the total
operating system in a rigorous way using experiments that  closely resemble
real, day-to-day operating situations.  The performance tests should be
conducted in the order given, but several are optional or  depend on the
availability of certain accessories, e.g., the solid probe inlet test.

    All the tests described in this report require an operator,  and some
depend heavily on the skills of laboratory personnel.  Therefore, the
results of some tests may be limited by the skills available  in  the
laboratory.  An experienced, two-person team consisting of a  professional
scientist and a technician will require approximately three weeks to
complete the equipment tests assuming there are  no major hardware or
software problems.  Inexperienced teams or individuals may require  anywhere
from six weeks to one year to complete  all the tests, especially if major
hardware or software problems develop.  In these tests, the operator  and
other laboratory personnel are a crucial part of the total operating  system.

    The examples given in this report reference  packed column gas chromatog-
raphy, but the tests described are equally applicable to opeg tubular GC/MS


                                      1

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systens.  With open tubular  (capillary)  systems  some minor  adjustments  in
operating conditions may be  necessary.

    For all the tests  it is  assumed  that the  manufacturer has  provided
acceptable documentation of  users  instructions for  the  operation  and
maintenance of the GC/MS system.   At the very minimum this  must  include
clearly written descriptions of  all  operating and test  functions,  clear
descriptions of all commands used  in the operation  of the data system,
examples of all commands,  and  intelligible  documentation of error messages.
Examples of all outputs must be  included as well as error recovery
procedures.  There must be a narrative  description  of all data system files,
and the narrative should describe  the exact nature  of the algorithm used for
all the significant mass spectrometric  processes.   The  maintenance manuals
must  include a complete set  of hardware engineering drawings,  and
maintenance must be described  1n terms  of block  diagrams,  logic  diagrams,
flow  charts, circuit descriptions, and  parts  lists.

    It  1s also assumed that  the  laboratory  has provided the GC/MS facility
with  an appropriate environment  including air conditioning  and other
utilities as required, trained management and operating personnel, needed
supplies, essential support  equipment,  and  a  reasonable amount of working
space which allows access  at the sides  and  rear  of  the  system for
maintenance.

    Finally, a  system  logbook  must be maintained throughout the  evaluation
period.  This must include an  entry for every working  day noting the status
of the  system.  This entry must  be made even  if  the system is not used on
that  day,  and  signed by the  responsible person.   The logbook must Include a
complete record of the number  of gas chromatographic -Injections  per day, the
number  of  solid probe  samples, all chromatographic  column changes, all
maintenance procedures,  all  requirements for service from the manufacturer,
 and each entry must be--iigned  -and dated.. This  information must be
 summarized in  the  performance  evaluation report, and the mean numbers  of gas
 chromatographic injections  and solid probe samples before ion source
maintenance (cleaning) must be reported.

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                                  SECTION 2

                         SUMMARY OF PERFORMANCE TESTS


I.    Spectrum Validation Test - Uses decafluorotriphenyl phosphine (DFTPP)
      to determine whether the system gives a 70 ev electron ionization
      fragmentation pattern similar to that found in the historical mass
      spectrometry data base, and the required mass resolution and natural
      abundance isotope patterns.  The spectrum of DFTPP must meet the
      criteria given in Table 2.

II.   System Stability Test - Uses DFTPP to test moderate term (20-28 hours)
      system stability.  The criteria given in Test I must be met.

III.  Instrument Detection Limit Test - Uses DFTPP to measure the full and.
      valid spectrum detection limit at a defined and tolerable noise
      level.  At a signal/noise « 5, the required instrument detection
      limits are 50 nanograms for systems used in the analysis of industrial
      or municipal wastes, and 30 nanograms for systems used in the analysis
      for ambient or drinking water.

IV.   Saturation Recovery Test - Uses DFTPP and £-bromobiphenyl to simulate
      a frequently encountered situation with real samples.  The spectrum  of
      DFTPP, measured-'within two minutes after the elution of a 250 fold
      excess of £-bromobiphenyl, must not contain significant contributions
      from the ions attributable to p_-bromobiphenyl.

V.    Precision Test - Uses a variety of typical environmental pollutants  to
      determine precision from filling a syringe to peak integration.  The
      mean relative standard deviation for the compounds used in the test
      which elute as narrow peaks must be 7S or less using either peak areas
      in arbitrary units or ratios of peak areas.  For broad peaks the mean
      relative standard deviation must be 132 or less.

VI.   Library Search Test - Uses data from Test V to evaluate the speed and
      completeness of the minicomputer library search algorithm.  The mean
      search time, including background subtraction, must be one minute or
      less, and all test compounds must be identified as most probable
      except isomers with very similar spectra should not be counted as
      incorrect.

VII.  Quantitative Analysis with Liquid-Liquid Extraction --Uses a variety
      of environmental pollutants to measure quantitative Si-curacy and

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      precision of the total analytical method.  The mean of the means of
      the percentages of the true values observed must be in the 6S-132S
      range with a mean relative standard deviation of 38S or less using
      either internal or external standards.  This test also evaluates
      laboratory performance.

VIII. Quantitative Analysis with Inert Gas Purge and Trap - Uses a variety
      of compounds to measure quantitative accuracy and precision of the
      total analytical method.  The mean of the mean method efficiencies
      'must be 70S or more.  Chloroform efficiency must exceed 90S and all
      compounds must exceed SOS efficiency.  The spectrum of £-bromofluoro-
      benzene must meet the criteria given 1n Table 7.  The mean of the
      means of the percentages of the true values observed must be in the
      range of 90-110S with a mean relative standard deviation of 19S or
      less using either Internal or external standards.

IX.   Qualitative Analysis with Real Samples - Uses a real sample to
      evaluate the ability of the system to deal with real sample matrix
      effects and interferences.  All compounds must be correctly identified
  • •   except isomers with nearly identical mass spectra should not be
      counted as incorrect.  This test also evaluates laboratory performance.

X.    Solid Probe Inlet System Test (Optional) - Uses cholesterol to
      evaluate the spectrum validity achievable with a solid probe  inlet
      system.  The spectrum of cholesterol must meet the criteria given  in
      step three of the test.

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                                  SECTION 3

                           EXPERIMENTAL PROCEDURES


I.  Spectrum Validation Test

      Correct identifications of organic pollutants from gas chromatography
mass spectrometry (GC/MS) data require valid mass spectra of the compounds
detected.  This is prerequisite to the interpretation of the spectra,  i.e.,
either an empirical search for a match within a collection of authentic
spectra or an analysis from the principles of organic ion fragmentation.  A
properly operating and well tuned GC/MS is required to obtain valid mass
spectra.

      The purpose of this test is to make a quick check - about  15 minutes -
of the performance of the total operating system of a computerized GC/MS.
Thus with a minimum expenditure of time, an operator can be reasonably sure
that the GC column, the enrichment device, the ion source, the ion separa-
ting device, the ion detection device, the signal amplifying circuits, the
analog to digital converter, the data reduction system, and the  data output
system are all functioning properly.

      An unsuccessful test requires, of course, the examination  of the
individual subsystems and correction of the faulty component.  Environmental
data acquired after" a successful systems check are, in a real sense, vali-
dated and of far more value than unvalidated data.  Environmental data
acquired after an unsuccessful test may be worthless and may cause erroneous
identifications.

      It is recommended that the test be applied at the beginning of a work
day on which the system will be used and also anytime there is a suspicion
of a malfunction.  A mass spectrometer which meets the criteria  of this  test
will, in general, generate mass spectra of organic compounds which are very
similar, if not identical, to spectra in collections and textbooks which
have been developed over the years with other types of spectrometers.   If
the performance criteria of this test cannot be met by the user, -the system
is unacceptable for general purpose environmental measurements.

Procedure:  '

      1.  Make up a stock solution of decafluorotriphenylphosphine  (DFTPP)
          at one milligram per mi Hi liter (1000 ppm) concentration  in
          acetone (or a hydrocarbon solvent).  The reference compound  used

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     in this test is available from PCR, Inc., P. 0. Box 1778,
     Gainesville, Florida, 32602 and may be named bis (perfluorophenyl)
     phenylphosphine.  This stock solution was shown to be 97+X stable
     after six months and indications are that it will remain usable
     for several years.  Dilute an aliquot of the stock solution to 10
     micrograms per. milliliter (10 ppm) concentration in acetone.  The
     very small quantity of material present in very dilute solutions
     is subject to depreciation due to adsorption on the walls of the
     glass container, reaction with trace impurities in acetone, etc.
     Therefore, this solution will be usable only in the short term,
     perhaps one week.

 2.   Select a SC column for the tests.  Any column that elutes DFTPP in
     a reasonable time may be used, and several suggested columns are
     listed in Table 1.  Parameters should be adjusted to permit at
     least four mass scans during elution of the DFTPP.  This will
     permit selection of a spectrum that is reasonably free of
     abundance distortions due to rapidly changing sample pressure.

 3.   Set the preamplifier to a suitable sensitivity, set the baseline
     threshold (zero instrument), and calibrate.
•
 4.   Prepare for data acquisition with the following variables:

           Mass Range:            40-450 amu
           Scan Time:             approximately five seconds
           Electron Energy:       70 ev
           Electron Multiplier:   Not to exceed that recommended by the
                                  supplier for the age of the device.

 5.   Inject with a syringe 50 nanograms (five micro!iters) of the
     dilute standard into the GC column.

 6.   After the acetone elutes from the column and is pumped or diverted
     from the system, turn on the ionizer and start scanning.

 7.   Terminate the run after the DFTPP elutes, turn the ionizer  and
     multiplier off, and plot the total ion current profile.

 8.   Select a spectrum number on the front side of the GC peak as  near
     the apex as possible, select a background spectrum number
     immediately preceding the peak, and display the background
     subtracted spectrum.  Some data systems permit spectrum  averaging
     to minimize variations in ion abundance due to rapidly changing
     sample pressure.  This option is acceptable, and may be  required
     for narrow peaks from open tubular columns.

 9.   The mass spectrum can be output in various ways  including  a plot
     of the full spectrum on the platter or cathode ray tube  or  a  print
     of the full spectrum on a printer or cathode ray tube.

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                TABLE 1.  SUGGESTED GC COLUMNS AND  CONDITIONS

Dimension (Type)   Packing                  Flow Rate     Temp.

                                                            180
2m x 2 mm ID
   (Glass)
2m x 2 mm ID
   (Glass)

2m x 2 mm ID
2m x 2 mm ID
   (Glass)

30m x .25mm ID
   (Glass)
1.95* QF-1 plus          30 ral/m1n
1.5% OV-17 on
80/100 mesh Gas-Chrom Q
                   3% OV-1 on 80/100        30 ml/m1n      220
                   mesh Chromosorb W

                   5* OV-17 on 80/100       30 ml/m1n      220
                   mesh Chromosorb W

                   1* SP2250 on 100/120     30 ml/rain      170
                   mesh Supelcoport

                   Wall coated SP 2100     2-5 ml/m1n    40,240
 R.  Time

 4 min



 5 min


 5 rain


 5 min


10 min
The spectrum obtained on the test system must contain  ion  abundances within
limits given for the key ions in Table 2 (1).

      If the relative abundances are not within the  limits specified,  the
appropriate adjustments must be made, i.e., resolution,  source  potentials,
calibration of the mass scale, source magnet position, etc.   The manufac-
turer may need to be consulted for assistance in this  adjustment.  Repeat
this test until satisfactory results are obtained.
 TABLE 2. OECAFLUQRQTRIPHENYLPHOSPHINE KEY  IONS  AND  ION  ABUNDANCE CRITERIA.
           Mass

            51
            68
            70
           127
           197
           198
           199 .
           275
           365
           441
           442
           443
                         Ion Abundance Criteria

                         30-80* of Mass 198
                         Less than 2* of Mass 59
                         Less than 2* of Mass 69
                         30-70% of Mass 198
                         Less than 1% of Mass 198
                         Base Peak, 100* Relative Abundance
                         5-9* of Mass 198
                         10-30* of Mass 198
                         At least IS of Mass 198
                         Present, but less than Mass 443
                         Greater than 40* of Mass 198
                         17-23* of Mass 442
^Criteria for masses 51 and 127 are modifications  of  previ-cus values (1)
based on new interlaboratory data.

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II.  System Stability Test

    The purpose of this test is to evaluate moderate term system stability.
Repeat the test described in Section I after 20-28 hours.  Do not make any
adjustments or recalibration of the system between tests except routine
overnight procedures.  The abundance criteria in Table 2 must be met.  If
these criteria are not met, the system is too unstable for routine use and
must be repaired.

III.  Instrument Detection Limit Test

    This test is to determine the smallest quantity of standard test
material that can be injected into the GC/MS system that gives an acceptable
spectrum meeting the criteria in Table 2, but has a sufficiently low  level
of background signals to allow correct Interpretation of that spectrum if
the sample was an unknown.  A spectrum of a test compound contaminated with
background signals to the extent of about 102 or more of its total ion
abundance is considered to be difficult or impossible to interpret
correctly.  This judgment is somewhat variable because 10* background dis-
tributed among a large number of small ions may be acceptable, but a
distribution among a few large ions will be unacceptable.  Therefore, a
signal to noise ratio based on a selection of six ions is used to evaluate
the detection limit.  This .also allows a relatively simple calculation of
the ratio.

    In a GC/MS system there are a number of potential sources of background
signals (chemical noise) including septum bleed, stationary phase bleed,
vacuum system background from various physical components, and  ion source
contamin- ation.  Furthermore, all signals are dependent on GC" column
efficiency, enrichment device efficiency, vacuum system efficiency,  ioniza-
tion efficiency, ion transmission efficiency, and detector gain.  Therefore,
this test is highly sensitive-to the specific system.configuration (specific
GC column, etc.) and the current condition of that system, e.g., condition
of the GC column, extent of contamination  in the ion source, extent  of
contamination of the quadrupole rods if a quadrupole instrument, and
condition of the electron multiplier.. The state of the system  should be
documented as part of the records of the instrument detection  limit  test.

Procedure:

    1. Make three dilutions of the  stock solution of DFTPP  described in Test
        I.  The dilutions should have the concentrations of  five micrograms
       per milliliter, one microgram per milliliter, and  one-tenth of a
       microgram per miniliter.

    2.  Follow the basic  procedures  given  in  Test  I  and  make the following
        series of  injections:

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           Amount Injected        Volumes and Standards

           20 nanograms          4 ul of 5 ug/ml standard
           10 nanograms          2 ul of 5 ug/ml standard
            5 nanograms          1 ul of 5 ug/ml standard
            1 nanograra           1 ul of 1 ug/ml standard
          100 picograms          1 ul of 0.1 ug/ml standard

3. List the masses, relative abundances, and/or absolute abundances
   (intensities) of the background subtracted spectra of OFTPP.  Sub-
   tract the background spectra as described in Test I.  If  necessary
   use an extracted ion current profile to locate the GC peak.  Discard
   all spectra that do not meet the criteria in Table 2.   From  the
   remaining spectra discard those that do not display at  least six
   non-OFTPP ions with relative abundances greater than 5S.   If
   additional dilutions or measurements are necessary, do  them.  Table 3
   contains all DFTPP ions over 3S relative abundance and  Table 4
   contains a group of common background ions.
4. For each of the qualified spectra compute the ratio R  as follows:

                          (DFTPP)
               R *        (SACKGD)

   where:
           (DFTPP) « the summation of the abundances  of  the  ions  at
           masses 127, 255, 275, 441, 442 and 443

           (BACKfiD) « the summation of the  abundances.of the six  most
           abundant (but each over 5* relative abundance)  non-OFTPP
           background ions

   Prepare a plot of R values as a function of amount injected.   The
   instrument detection limit defined in this test  is for the complete,
   valid spectrum with a defined level of acceptable  noise.   This
   detection limit is the amount injected that gives  an  R value of
   five.  If sufficient points are available, a  good  estimate of  the
   instrument detection limit may be obtained from  a  first or second
   order regression on this data.

   The rationale for the selection of an R  value of five is  consistent
   with the previous statement that background ions should be less than
   about 102 of the total ion abundance in  an interpretable  spectrum.
   The average relative abundance of the six DFTPP  ions  used to compute
   R is in the 25-35X range.  For an R value of  five  the average
   relative abundance of the six background ions will be in  the 5-7S
   range, and it is estimated that all background  ions under these
   conditions will be less than 10% of the  total ion  abundance.

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        TABLE 3.  IONS OVER 3* REUTIVE ABUNDANCE OBSERVED
              '   IN  THE 70 ev MASS  SPECTRUM OF  DFTPP


  AMU              .    INTENSITY        PERCENT OF  TOTAL INTENSITY

  50.0                     8.11                   l.n
  51.0                    34.60                   4.74
!;;69.o                    32-93                   4-si
  74.0                     3.10                   0.42
  75.0                     4.53                   0.62
  77.0                    34.84                   4.77
  78.0                     3.10                   0.42
  93.0                     3.10                   0.42
  99.0                     3.81                   0.52
 107.0                    10.97                   1.50
 110.0  .                  20.76                   2.84
 117.0                     6.44                   0.88
 127.0                    37.70                   5.16
 128.0  -  -  .      -  -    3.10  -    •            0.42
 129.0                    12.88                   1.76
 167.0                     4.05          •        0.55
 168.0                     4.77                   0.65
 186.0                    13.12                   1.79
 187.0                     3.81                   0.52
 198.0                   100.00                  13.69
 199.0                     7.15                   0.98
 205.0                     5.01                   0.68
 206.0             '       20.28                   2.77
 207.0                     4.53                   0.62
 217.0                     5.01                   0.68
 221.0                     4.29                   0.58
 224.0              -      11.21                   1.53
 227.0                     3.81                   0.52
 244.0                     8.11                   l.n
 255.0                    49.16  .                 6.73
 256.0                     7.39                   1.01
 274.0                  •  4.29                   0.58
 275.0                    23.15                   3.17
 276.0                     3.81                   0.52
 296.0                     5.01                   0.68
 423.0                     3.34                   0.45
 441.0                     9.30                   1.27
 442.0                    69.45                   9.51
 443.0                    12.88                   1.76
                              10

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               TABLE 4.  COMMON  BACKGROUND  IONS  IN  GC/MS  SYSTEMS


       Masses                    Sources

       41,43,55,57,              Saturated  hydrocarbons and
       69,71,81,83,              unsaturated  hydrocarbons -
       85,95,97,99               cyclic and open  chain-many  sources

       149                       Phthalate  esters used as plasticizers
                                 in  tubing, etc.

       73,101,135,197,207        Methyl and phenyl  silicone
       259,345,346,355           polymers used in stationary
                                 phases* diffusion  pump oil,  etc.

       169,251                   Polyphenyl ether diffusion
                                 pump oil

    The required instrument detection limits, at an R value  of five, are 50
nanograms for  systems used in the analyses of industrial or  municipal
wastes, and 30 nanograms for systems used  in analyses of ambient  or  drinking
waters.  These limits were obtained from considerations  of  EPA recommended
sample sizes and concentration  factors.  If  a system cannot  meet  these
criteria, maintenance or repair is  required.  Particular attention should be
given to those items mentioned  in the second paragraph of this test.

    Observed detection limits with  this test are as follows:

    1. A Finnigan 3200 equipped with a Varian 1400 GC, a packed IX SP  2250
       Column  (Table 1), a Systems  Industries RIB  interface, and  a PDP-3
       datasystem (disk) gave a detection  limit  of five  nanograms.

    2. A Finnigan 4000 with a Finnigan 9610  GC,  a  packed 1*  SP 2250  column
       (Table 1), an INCOS interface, and  an INCOS datasystem (Nova  3, disk)
       gave a detection limit of 25 nanograms.

IV.  Saturation Recovery Test

    The purpose of this test is  to  evaluate  the  ability  of  a system  to
measure the spectrum of a test  compound at a low level immediately after a
relatively large quantity of another compound entered the system.  This
situation occurs frequently in  real environmental  samples, especially  waste
samples where a very large concentration of  one  component may saturate the
detector, and within a few minutes or less a very  small  quantity  of  a
compound of interest may enter  the  detector.

Procedure:

    1. Prepare an acstone solution  containing five milligrams per millilitsr
       of £-brcmofaiphenyl and 20 micrograms  per  mi Hi liter jaf DFTPP.   A
       second solution containing approximately  50 micrograms per mil 11 liter

                                    11

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       of each is optional and may be useful to optimize chrcmatographic
       conditions.

    2. Establish GC conditions such that the DFTPP elutes within two minutes
       after the elution of the p_-bromcbiphenyl.  These conditions were
       achieved with a 6' x 2 mm ID glass column packed with It SP2250 on
       Supelcoport (100/120 mesh) using a flow of 30 ml of helium per minute
       with the initial column temperature at 120°C and programming to
       23QQC at 10° per minute.  The £-bromobiphenyl eluted at 110
       seconds and the DFTPP at 210 seconds.  This test is carried out using
       the same basic operating parameters given in Test I.

    3. Inject two microliters of the standard solution containing the 250:1
       ratio"of p-bromobiphenyl to DFTPP.  Plot the DFTPP spectrum as in
       Test I.  Each of the ions at masses 152, 232, and 234, which are the
       three most abundant in the spectrum of £-bromcbiphenyl, must be below
       5S relative abundance in the background subtracted spectrum of DFTPP.

V.  Precision Test

    The purpose of this test is to measure the precision of the GC/MS system
in quantitative analysis using continuous, repetitive measurement of spectra.
This test evaluates precision from filling a syringe to integration of the
peak area for a specific quantitation ion.  The entire test should be
carried out on the same day by the same technician.  The application of  an
automatic sample changer in this test 1s required if it will be used for
normal sample, processing.  This should be documented in the test results.
If acceptable precision cannot be obtained with this test, the precision of
a complete anaytical method may also be unacceptable.
         •
Procedure:

    1. Select a group of seven or more compounds, and prepare a standard
       solution in acetone that contains the entire group.  Some recommended
       compounds are in Table 5, and the concentration of each should be 20
       micrograms per mmiliter.  This group of compounds must include  a
       chlorinated hydrocarbon that may decompose on a hot metal surface  and
       a polycyclic aromatic hydrocarbon with a molecular weight greater
       than 200.  For compounds amenable to the inert gas purge and trap
       procedure, prepare the standard solution in methanol at the same
       concentration.  The purge and trap mixture must include chloroform,
       broraoform, sym-tetrachloroethane, and p-bromofluorobenzene.  Some
       recommended compounds are in Tables 9-12.  This test may be conducted
       with either or both groups of compounds.
                                     12

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  TABLE 5.  PRECISION STATISTICS FOR TEN PRIORITY POLLUTANTS PLUS OCTADECANE
COMPOUND


1,3-DICHLOROBENZENE

NAPHTHALENE

1,2,4-TRICHLOROBENZENE

n.-OCTAOECANE

DIMETHYL PHTHALATE

DI-£-BUTYL PHTHALATE

N-NITROSOD IPHENYLAMINE

HEXACHLOROBENZENE

PYRENE

CHRYSENE

BEMZO( A) PYRENE
:GRATIC
MASS
146
128
ISO
254
163
149
169
284
202
228
252
JN PEAK*
TYPE
N
N
N
N
N
N
N
N
N
B
B
MEAN
AREA
6771
18077
5412
345
13540
21770
6460
4027
18107
10345
9518
(S/MEAN
1 112!
278
375
195
15
501
364
228
139
607
636
631
4.1
2.1
3.6
4.2
3.7
1.7
3.5
3.4
3.4
6.2
7.2
   * narrow; B » broad (see text for definitions)
    2.  Select an appropriate GC column.  For compounds similar to those  in
        Table 5, the columns in Table 1 are satisfactory.  For compounds,
        amenable to purge and trap procedures, two acceptable columns  are  an
        8 ft. stainless steel or glass column packed with 1% SP-1000 coated
        on 60/80 mesh Carfaopack B or packed with 0.2% Carbowax 1500 coated
        on 60/80 mesh Carfaopack C.  Prepare for data acquisition with  the
        following variables:

        mass range:  35-350 amu (For purge and trap compounds use 20-260  amu)
        scan time:  approximately six seconds (two or three seconds with  open
                    tubular columns)
        electron energy:  70 ev
        electron multiplier:  not to exceed that recommended by the
                              supplier for the age of the device.

    3.  Inject with a syringe or automatic sample changer four raicroliters
        (80 nanograms of each compound) of the standard solaiion and acquire
       -data until all compounds have eluted from the column.  Save the data

                                      13

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       file on the  data  system  and repeat  the  Injection  a minimum of four
       times, saving  the data files  1n  each  case.   •

   4.  Plot the total  1on current profiles,  and  use a quantitatlon program
       to  Integrate peak areas  1n arbitrary  units  (usually
       analog-to-digltal  counts) over a specific quantltation  mass for each
       compound 1n  each  data file.   Precision  may  be evaluated using either
       the peak areas  In arbitrary units or  ratios of peak  areas.  The
       former gives a precision representative of  external  standardization,
       and the latter a  precision representative of Internal
       standardization.   There  will  be  no  significant difference in the
       results using  the two methods If the  system 1s operating properly
       and acceptable syringe filling and  injection techniques are used.
       It  1s recommended that calculations be  carried out using both
       methods for  comparison of results,  but  the  minimum requirement is
       that precision be evaluated using the method that corresponds to the
       standardization procedure used 1n the laboratory  for environmental
       samples.

    •  Table 5 Is an  example of data from  five replicate syringe injections
       of  80 nanograms of each  compound using  a  Finnigan 3ZQO  and a POP-3
       based data system.  The  mean  areas  are  1n analog-to-digital
       converter units and  the  standard deviations (S) were 'computed using
       the equation below.  The last column  in Table 5  is the  relative
       standard deviation which is  (S/mean area}* 100.   Table  6 contains
       the results  of computations with exactly  the  same raw data as in
       Table 5, but using ratios of  areas  as in  internal standard
       calibrations.   The response  factor  (RF) Is  defined "in test VII, and
       the mean response factors are shown in  Table  6.   The compound
       d1-n.-butylphthalate  was  selected as the internal  standard because 1t
       showed the smallest  variation in peak area (1.72, Table 5) and
       eluted near  the mid-point  in  the chromatograra.   The standard
       deviations and relative  standard deviations were  computed as in
       Table 5.
 I
 J

t
                   n      ~     u        ~
                 N£Area \ - (^  Area,)*.
                  1-1     1    i-1      1
                           N IN-lj

         where:

               S « the standard deviation

               N » the number of measurements
                   for each compound

               Area * the integrated ion abundance of the
                      quantitatlon mass

    The compounds designated as having narrow peak types in Tables 5  and  6
had widths at half height of 45 seconds or less.  The mean relative standard

                                      14

-------
          TABLE 6.  PRECISION STATISTICS USING AN INTERNAL STANDARD
COMPOUND

1,3-DICHLOROBENZENE
NAPHTHALENE
1,2,4-TRICHLOROBENZENE
nrOCTAOECANE
DIMETHYL PHTHALATE
DI-£-BUTYL PHTHALATE
N-NITROSOOIPHENYLAMINE
HEXACHLOROBENZENE
PYRENE
CHRYSENE
BENZO(A)PYRENE
INTEGRATION
MASS
•
146
128
180 •'
254
163
149
169
284
202
228
252
PEAK*
TYPE
N
N
N
N
N
N
N
N
N
B
B
MEAN
RF
0.3112
0.83048
0.2486
0.0158
0.62202
1.00000
0.2968
0.1850
0.83171
0.4751
0.4370
(S/MEAN 1
S *100
0.01512
0.017250
0.008571
0.000838
0.022980
0.00000
0.01008
0.005899
0.023110
0.02619
.0.0275
4.9
2.1
3.4
5.3
3.7
0
3.4
3.2
2.8
5.5
6.3
                                     15

-------
deviation for the data in Table 5  is 3.355,  and the corresponding mean from
Table 6 is 3.6 %.  Therefore there was no significant difference in  the
precision of external and internal standardization.  The requirement of  this
test is that the mean relative standard deviation of data from narrow peaks
be 11 or less.  This requirement is based on the general observation that
data from interlaboratory comparisons is usually about  a factor of two more
variable than single laboratory data, and this is a reasonable requirement
for an acceptable system.
                                                                         i"
    The last two compounds  in Tables 5 and  6 gave broader peaks with peak
widths at half height of more than 45 seconds.  Measurements of these are
more variable because of the changing baseline during temperature
programming and other factors.  The mean relative standard deviations from
Tables 5 and 6 are 6.7% and 5.95. respectively, and internal standardization
may have some slight advantage for these peaks but there are too few data
points to judge the significance of this.   The requirement of this test  is
that the mean relative standard deviation of data from  broad peaks be 13% or
less.  Again the rule of thumb on  interlaboratory data  was used to establish
this requirement.

    If this test is conducted with compounds amenable to the inert gas purge
and trap procedure* the compound £-brcmofluorobenzene must be included in
the mixture.  This compound is a secondary  spectrum validation compound
which is used with GC columns that do not elute DFTPP.  Therefore, after a
purge and trap column is Installed for this test p-bromofluorobenzene may be
used as a daily check on spectrum validity. The Ton abundance criteria  for
£-bromof1uorobenzene are in Table 7, and these are consistent with the DFTPP
criteria in Table 2.

      TABLE 7.  2-8ROMOFLUOR08ENZENE KEY IONS AND  ION ABUNDANCE CRITERIA

         Mass                       '  Ion  Abundance Criteria

          50                           20-405 of the base peak
          75                           50-70% of the base peak
          95                          • base peak, 100%  relative
                                       abundance
          96                           5-9% of the base peak
         173                           less than 1% of  the  base  peak
         174          .                 greater than 50% of  the base  peak
         175                           5-9% of mass 174
         176                           greater than 50% of  the base  peak
         177                           5-9% of mass 175

VI.  Library Search Test

    Minimum requirements for  the  library search  are the availability of the
EPA/NIH database which  is distributed through the  National  Bureau  of
Standards.  The  searchable  database may be  a  subset of  the  EPA/NIH database,
but the subset must contain at  least  10,000 spectra of  general  and
environmental  interest  and  the  Chemical" Abstracts  Service  (CAS)  registry
numbers for each compound.   Programs must be  available  to  allow  the operator

                                    16

-------
to submit background corrected spectra to the  library search, and receive  a
printed report of the search results.  The spectra from one of the
experiments in Test V should be submitted to the  library search system.
Each compound must be identified as the most probable by the library search,
except isomers that may have very similar 70 ev El mass spectra should not
be counted as incorrect.  The mean search time, including the time for
background subtraction, should be one minute or less.  Printed reports
should include CAS numbers.  During this test make several deliberate
typical operator errors, such as entry of an incorrect command and a
non-existent file name.  The data system should respond with an intelligible
error message, and return to a logical continuation point.

VII.  Quantitative Analysis with Liquid-Liquid Extraction

    This test uses a variety of environmental pollutants to measure quanti-
tative accuracy and precision of the total analytical method, but without
the complications of real sample matrix effects.  The test is designed for
laboratories that conduct quantitative analyses of water samples with GC/MS
using continuous repetitive measurement of spectra.  Therefore, laboratories
dealing in other media should design a similar test based on some standard
reference material.  The principal difference between this test and Test V,
the precision test, is the consideration of potential errors and variations
due to:  (a) extraction of the compounds from  a clean water matrix;  (b)
concentration of the extract to a small volume; and (c) standardization  of
the measured areas in terms of the concentration  of the original sample  in
micrograras per liter.  This is one of the tests that goes beyond equipment
performance, and may be used to evaluate the performance of  laboratories
using GC/MS for organics analysis.

    It is recommended that the same standard solution of seven or more
compounds that may have been prepared for the precision test (Test V) be
used in this test since retention information  is  already available,  and  the
concentrations are in an acceptable range.  However, new standards may be
used and the seven or more compounds should be at the 20 microgram per
rai Hi liter level in acetone.

Procedure:

    1.  Add 250 microl.iters (five micrograms of each compound) of the mixed
        standard solution in acetone to each of a minimum of five  liters of
        clean water.  This aqueous solution is called a  laboratory control
        standard.  Set aside one additional liter of clean water as  a
        reagent blank.

    2.  Carry out the extractions according to the established procedures
        (2,3,4).  The methylene chloride extract  must be concentrated  to 0.5
        milliliter.  The blank should be measured first by  itself,  and  if
        significant contamination is found, correct the problems before
        proceeding with this test.  See the references cited above  for
        information on the interpretation of blanks.
                                      17

-------
Area
Amount
Area
Amount
X)
X
si
5)
    Select  an  appropriate column (Test V),  and prepare for data
    acquisition  using  the SC/MS operating parameters given in Test V.
    Inject  four  microliters  of each of the  concentrated extracts,  and
    obtain  GC/MS data  from each injection.   Save all of the data files
    from the minimum of five extracts.  Quantitation may be accomplished
    with either  internal or  external standardization.  If an external
    standard will be used, this is already  prepared and is the solution
    used to prepare the laboratory control  standards.  Inject two
    microliters  (40 nanograms) of the external standard and acquire data
    using the  same acquisition parameters.

    If an internal standard  will be used, add five microliters of a one
    milligram  per milliliter solution of the internal standard to each
    of the  0.5 milliliters of concentrated  extract.  This corresponds to
    the addition of five raicrograms of the  internal standard in such a
    way as  to  not significantly change the  volume of the concentrated
    extract.   Inject four microliters of each extract as above and save
    all data files.  If an internal standard is used it will be
    necessary  to measure the response factors (RF) in a separate
    experiment with standards (no extraction).  The response factors are
    computed with the  following equation:
        RF
    where:   Area(X)     *  the peak area of the compound in
                           consistent units.

            Amount (X)  *  the quantity of the compound injected
                           in consistent units.

            Area (S)    *  the peak area of the internal standard  in
                           consistent units.

          Amount (S)    *  the quantity of  internal standard
                           injected in consistent units.

4.  Plot the total ion current profiles and use a quantitation  program
    to integrate peak areas in arbitrary units (usually
    analog-to-digital converter counts) over a specific quantitation
    mass for each compound in each data file.  If an internal standard
    was employed computations in terms of response factors  are
    acceptable.

5.  Precision and accuracy is expressed in  terms of the percentages of
    the true values (P) measured in the experiments and the statistical
    variations in the data.  The standard deviations (S) and  the
    relative standard deviations (S/mean P) *100, are  computed  as
    described in Test 5,  With an external  standard P  is computed  as
    follows:

                                 18

-------
            p m      area (concentrated extracts) *IOO
                          area (external standard)

        With an internal standard P is computed with the equation below
        which assumes the response factors are defined as above:


             p *      area (concentrated extract)   *100
                        area (internal standard)  *RF

    Table 8 shows precision and accuracy data obtained for eight compounds
extracted from clean water with methylene chloride and measured with GC/MS
using a single external standard.  The GC/MS was a Finnigan model 3200 with
a PDP-8 based datasystem.  One difference between the data in Table 8 and
the procedures described in this test is that the data in Table 8 represents
duplicate extractions and measurements at four different concentration
levels between 15-200 micrograms per liter for each compound.  Figures 1 and
2 show control charts which contain all eight P values for each of two of
the compounds.  This is a recommended method (5) of displaying precision and
accuracy data.  Charts should be labelled as in Figures 1 and 2.  General
experience shows that P values measured over a concentration range of one or
two orders of magnitude are often concentration independent within the
precision of the method.

    The mean of the P values in Table 8 is 84J£.  Therefore, the requirement
of this test is that the mean of the mean P values of the compounds used  in
this test must be in the range of 68-1322.  Again, as in Test V, the
expectation is that multi-laboratory data will usually be about a factor of
two.more variable than single laboratory data.  The mean relative standard
deviation from Table 8 is 19*, and the requirement of this test is that the
mean relative standard deviation be 385S or less.

VIII.  Quantitative Analysis with Inert Gas Purge and Trap

    This test uses a variety of environmental pollutants to measure
quantitative accuracy and precision of the total analytical method, but
without the complications of real sample matrix effects.  The test  is
designed for laboratories that conduct quantitative analyses of water
samples with GC/MS using continuous repetitive measurement of spectra.
Therefore, laboratories dealing in other media should design a similar test
based on some standard reference material.  The principal difference  between
this test and Test V, the precision test, 1s the consideration of potential
errors and variations due to:  (a) purging of the compounds from  a clean
water matrix; (fa) trapping and desorption of the compounds; and  (c)
standardization of the measured areas in terms of the concentration  of  the
original sample in micrograms per liter.  This test is required to evaluate
purge and trap equipment that is delivered as an  integral part of  a  GC/MS
system, or other purge and trap equipment that is interfaced to the  GC/MS
system.

    The series of experiments in this test is used to geneaate three  key
pieces of information about purge and trap performance:


                                     19

-------
      TABLE 8.  PRECISION AND ACCURACY DATA FOR LIQUID-LIQUID EXTRACTION
                     WITH GC/MS AND AN EXTERNAL STANDARD
                          INTEGRATION     MEAN              (S/MEAN P)
COMPOUND                     MASS          P          £        *1QQ
NITROBENZENE                 123           94       8.8          9.4
1,2,3-TRICHLOROBENZENE       180           85      13           15
NAPHTHALENE                  128           73      18           25
ACENAPHTHYLENE               152           83      15           18
N-NITROSODIPHENYLAMINE       169           89      19           21
FLUORANTHENE                 202           80      19           24
PYRENE                    •   202  '        -83      19           23
n-BUTYLB£NZYLPHTHALATE       206           86      17           20
                                     20

-------
        Compound: nitrobenzene
        Range: 50 • 200pg/l
        Method: extraction. CH2C12
        Relative standard deviation: 9%
Data acquisition : 35 - 400amu
Quantitation: mass 123. one
            external standard
                                                          MEAN + 3S




E
>
Recover




110-
100'

90-
80-
70-
60-
50-
40-


•
o
0
0 0
__°__ 	 ____°____0___
o

•
o /«M a /ti o /«s^ Q fti o/e Q/C o/e O/R
                     Experiment Date (1978)
                                                          MEAN * S

                                                          MEAN = 94 (5=3.8)

                                                          MEAN - S
                                                                          •

                                                          MEAN - 3S
Figure 1,  Control chart  for nitrobenzene in clean  water.
                                     21

-------
       Compound: pyrene
       Range: 15 • 130^9/1
Data acquisition: 35 • 400 amu
Quantitation: mass 202. one
1
1

130-
120-
no-
100-
g90'
i ""*
t 30'
!' | 70.
j 60-
50-
40-
30-
20
Method: extraction. CH2d2 «wm« ^anuare
Relative standard deviation: 23%
r
•'r



° , 0 ' ° °

O
0 0

0


II \ I t 1 \ 1
         8/31 8/31 3/31 8/31  9/5  9/5  9/5 9/5
                   Experiment Date (1973)
Figure 2.  Control chart for pyrene  1n clean  water.
                                     22

-------
    (a) Method efficiency for test coirpounds by  comparison of  the measured
        quantity from syringe injection into the EC with the quantity
        measured after purging, trapping,  and  desorption.  Because  of  the
        method of calibration used in the  purge  and trap procedure  high
        method efficiency as defined above is  not necessary for  acceptable
        precision and accuracy.  However,  high method efficiency is  required
        for acceptable sensitivity, and low method efficiency  will  result  in
        unacceptable detection  limits.  Also in  the case of real samples,  a
        low method efficiency combined with an unfavorable matrix effect
        could render the method totally useless.

    (b) Precision of the overall purge, trap,  desorption, and  GC/MS analysis.

    (c) Accuracy of the overall purge, trap, desorption, and GC/MS  analysis
        in terms of the percentage of the  true value found in  laboratory
        control standards.

    All the above information may be obtained  from the  same set  of  data.   It
is recommended that the same standard solution of seven or more  compounds
amenable to purge and trap that was recommended  for the precision test (Test
V) be used in this test since retention information may be already
available, and concentrations are in an acceptable range.  However, new
standards may be used, and the seven or more compounds should  be at the 20
micrograms per milliliter level in methanol.   The purge and trap mixture
must include chloroform, bromoform, sym-tetrachloroethane and
£-bromofluorobenzene.

Procedure:

    1.  Select an appropriate column (see  Test V) and prepare  for data
        acquisition using the GC/MS operating  parameters given in Test V.   ..

    2.  Add five microliters (100 nanograms of each compound)  of the. mixed
        standard in methanol to each of a  minimum of five aliquots  of low
        organic water.  Purge and trap samples may be 5 ml to  25 ml, but 5
        ml is recommended for optimum method efficiency.  This aqueous
        solution is called a laboratory control  standard.

    3.  Carry out the purge and trap according to the established procedures
        (2,3,4) at ambient temperature.  A low organic  water  blank  should be
        measured first and at occasional intervals to detect  instrument
        contamination.  If significant contamination  1s found, correct the
        problems before proceeding with this test.  See references  cited
        above for information on the interpretation of  blanks.

    4.  Purge, trap, desorb, and obtain GC/MS  data from a minimum of five
        laboratory control standards and save  all the data files.   At about
        the midpoint of the purge and trap analyses,  inject with a  syringe
        five microliters (100 nanograms of each  compound) of  the mixed
        standard in methanol into the purge and  trap GC column.   Acquire


                                     23

-------
    GC/MS data using the same acquisition parameters used for purge and
    trap analyses.

5.  Plot the total Ion current profiles, and use a quantitation program
    to Integrate peak areas in arbitrary units (usually analog-to-
    digital converter counts) over a specific quantitation mass for each
    compound In each data file.

6.  Method efficiency must be evaluated by comparing the measured areas
    from direct GC Injection with the corresponding areas from the
    purge, trap, and desorption experiments.  Internal standards cannot
    be used because method efficiencies for various compounds are not
    yet known, and comparable response factors cannot be computed for
    direct injection and purge/trap/desorption.

    Prepare a table similar to Table 9 which shows data obtained with  a
    Flnnigan model 3200, a POP-8'data system, and a Tekmar model, LSC-1
    purge and trap device with a 25 ml sample container.  The equation
    used to compute method efficiencies (£) is shown below.  The minimum
    requirement of this test is that the mean of the mean method
    efficiencies of the compounds used in this test be 70% or more.  The
    chloroform efficiency must exceed 902 and all compounds must be
    recovered with at least 30S efficiency.  Also the spectrum obtained
    from p-bromofluorobenzene must meet the ion abundance criteria given
    1n Table 7.  If these requirements cannot be met, the system is
    unacceptable for quantitative analyses and needs repair or
    redesign.  One critical method variable that may be optimized  is the
    purge gas flow rate.
     »

           e    »      area (after purge and trap)
           6           area (direct  injectionj

7.  Precision and accuracy data may be obtained by choosing one of the
    experiments in the purge and trap set as a standard,  and  computing
    the percentages of the true values (P) measured  in the other
    laboratory control standards.  This  is consistent with the  standard
    method of calibration used with .the purge and trap method.  The
    experiment chosen as the standard may either be  treated  as  an
    external standard, or may be used to compute response factors  for an
    Internal standard calibration.   Table 10 shows the  data  from  the
    method efficiency determination  recomputed by  ignoring the  direct
    injection result, and using one-of the purge and trap experiments as
    an external standard. -The equation  used to compute  the  percentages
    of the true values (P) is  as follows:
                                       e

              p m       area fafter  purge and trap)
                         area (external standard)

    The  standard  deviation of  P and  relative  standard  deviation were
    computed as described  in Test  V.  The mean  of  the  P  values  in Table
    10  is  95X and the mean relative  standard  deviation  1s 9.4S.   The

                                 2*

-------
COMPOUND
          TABLE 9.  METHOD EFFICIENCIES FOR SOME PRIORITY POLLUTANTS
                          PLUS £-BROMOFLUOROSENZENE
INTEGRATION    MEAN AREA    AREA DIRECT    MEAN METHOD
   MASS        PJURGE/TRAP   .INJECTION..   EFFICIENCY^)
CHLOROFORM
CARSON TETRACHLORIDE
BROMOOICHLOROMETHANE
TRICHLOROETHYLENE
DIBROMOCHLOROMETHANE
BRQMOFORM
TETRACHLOROETHYLENE
Sym-TETRACHLOROETHANE
2-BROMOFLUOROBENZENE
83
117
83
130
129
173
166
83
174
2883
2289
2925
1474
1572
1241
1737
1032
1542
3001
2314
3280
1553
2343
2788
2102
3071
2200
96
99
89
89
67
45
S3
34
70
                                     25

-------
        TABLE 10.  PRECISION AND" ACCURACY DATA FOR THE PURGE AND TRAP
                 ANALYSIS WITH GC/MS AND AN EXTERNAL STANDARD
COMPOUND

CHLOROFORM
CARBON TETRACHLORIDE
BROMODICHLOROMETHANE
TRICHLOROETHYLENE
DIBROMOCHLOROMETHANE
BROMOFORM
TETRACHLOROETHYLENE
Sym-TETRACHLOROETHANE
£-8ROMOFLUOROBENZENE
INTEGRATION
MASS
83
117
83
130
129
173
166
83
174
. MEAN
P
92
97
96
94
98
96
96
100
90
(S/MEAN P)
S *100
8.8
7.9
7.2
7.4
4.4
5.2
14
14
12
9.5
8.2
7.5
7.9
4.5
5.4
14
14
14

-------
        requirement of this test  is that the mean of the mean  P values  of
        the compounds used  in  this test must be  in  the range of 90-110%.
        This is based on the general rule, described in Test V, that  data
        from inter laboratory comparisons is usually about  a factor  of two
        more variable than  single  laboratory data.  The mean relative
        standard deviation  must be 19% or  less on the same basis.

        The percentages of  the true values (P) may  also be computed by
        selecting one compound in  the test mixture  as an internal standard,
        and using one of the purge and trap experiments to establish
        response factors as defined in Test VII.  The percentages of  the
        true values (P) in  the other laboratory control standards are
        computed as follows (the terms have the  same meaning defined  in Test
        VII):

              P ,       area (x) * 100
              r         area (s) *RF

    Table 11 shows the method  efficiency data recomputed with
p_-bromofluorobenzene as the internal standard.  Response factors were
established with the same purge and  trap experiment that  was  used  as an
external standard for the computations in Table 10. Table 12  shows the same
data recomputed with dibromochloromethane as an  internal standard.  Again,
response factors were established  with the same purge and  trap experiment
that was used as an external standard for the computations in  Table 10.

    The internal standard calculations reveal that  the percentages  of the
true values observed and the relative standard deviations  are  a function  of
the internal standard selected.  The compound £-bromofluorobenzene  eluted
late in the chromatogram after temperature programming, and measurements  of
it were more variable because  of this and other factors.   This is reflected
in the mean of the mean P values from Table 11 of 108X and the mean relative
standard deviation of 12%.  The compound dibromochloromethane  showed  the
least variation in the external standard data (Table 10) and is an  excellent
internal standard.  The mean of the mean P values from Table 12 is  97%  with
a mean relative standard deviation of 6.SS.  This illustrates  that  care must
be exercised in the selection  of an internal standard because  of the
potentially significant impact on  the observed precision and accuracy.  The
individual P values may also be charted as in Figures 1 and 2  to provide  a
graphic presentation of the data.

IX.  Qualitative Analysis with Real Samples

    The purpose of this test is to evaluate the  ability of the GC/MS  system,
laboratory, and sample preparation methods to deal  with natural background,
interferences, and sample matrices found in real environmental'samples.  The
test is limited to qualitative analyses because of  the unpredictable
quantitatvie effects of the sample matrix.  This is one of the tests  that
goes beyond equipment performance, and it may be used to evaluate the
performance of laboratories using  GC/MS for organics analysis. The test  is
designed for laboratories that conduct qualitative  analyses of water  samples
with GC/MS using continuous, repetitive measurement of spectra.

                                      27

-------
        TABLE 11.  PRECISION AND ACCURACY DATA FOR THE PURGE AND TRAP
      ANALYSIS WITH GC/MS AND THE INTERNAL STANDARD £-8ROMCFLUOROBENZENE

                        INTEGRATION      MEAN              -    (S/MEAN P)
COMPOUND                   MASS           P            IS         *100

CHLOROFORM                   83          103         13           13
CARSON TETRACHLORIDE        117          108         12           11
BROMOOICHLOROMETHANE         83 >        107         12           11
TRICHLOROETHYLENE           130          105         12           11
OIBROMOCHLOROMETHANE        129          110         11           10
BRQMOFORM                   173          108         12           11
TETRACHLOROETHYLENE         166          107         13           12
Sym-TETRACHLQROETHANE        83          112         19           17
£-BROMOFLUORC8ENZENE        174          100          0             0
                                      28-

-------
        TABLE 12.  PRECISION AND  ACCURACY  DATA  FOR THE  PURGE AND  TRAP
      ANALYSIS WITH GC/MS AND THE INTERNAL STANDARD DIBRCMOCKLOROMETHANE
COMPOUND
       •
CHLOROFORM
CARBON TETRACHLORIDE
BROMODICHLOROMETHANE
TRICHLOROETHYLENE
DIBROMOCHLOROMETHANE
BROMOFORM
TETRACHLOROETHYLENE
Sym-TETRACHLOROETHANE
£-BROMOFLUOROBENZENE
INTEGRATION
MASS
83
117
83
130
129
173
166
83
174
MEAN
P
94
98
98
95
100
98
98
101
92
.S
5.8
4.3
3.7
3.8
0
2.0
9.8
11
9.7
(S/MEAN P)
*100
6.2
4.4
3.7
4.0
0
2.0
10
11
11
                                     29

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Procedure:

    1.  Acquire appropriate quality control samples.  These should be in
        sealed glass ampoules containing one to fifty organic compounds
        dissolved in acetone, methanol, or some other miscible organic
        solvent.  The concentration levels should be suitable for the
        preparation of aqueous samples in the 10-500 micrograms per liter
        range by addition of 250 or fewer microliters of the organic
        solution to 5 to 1000 mi Hi liters of an environmental sample.
        Instructions for the dilutions must be supplied with the samples,
        but the identity of the compounds in the ampoules must be supplied
        separately in sealed envelopes to the laboratory management.
        Samples of this type are available from:

                        John A. Winter, Chief
                        Quality Assurance Branch
                        EMSL-Cincinnati
                        Environmental Protection Agency
                        Cincinnati, Ohio  45263

    2.  Obtain an environmental sample typical of the type normally analyzed
        in the laboratory.  Add the quality control samples to the
        environmental samples according to the instructions provided,  and
        proceed with the analyses using the appropriate method, e.g.,  as  in
        Tests VII and VIII.

    3.  Plot the total ion current profiles and  identify  all  the  compounds
        using the mass spectra.  All compounds must be correctly  identified
        except, as in the  library search, isomers with nearly identical
        70 ev electron ionization spectra should not be counted as  incorrect.

X.  Solid Probe Inlet System Test (optional)

    The purpose of this test  is to evaluate the  critical  thermal  character-
istics of the solid probe  inlet system, and to determine  whether  valid
spectra are produced with  this system.. The test uses cholesterol which  is
sensitive to thermal effects.  Data  acquisition  is  by continuous  repetitive
measurement of spectra.

Procedure:

     1.  Prepare a  standard solution  of cholesterol  in  acetone at  a concen-
        tration of 250 micrograms per  mill inter.   Evaporate one  micro! iter
        of  this solution  1n  the  solid  probe  sample  holder.

     2.  Use the data  acquisition parameters  given  in Test I,  and  gradually
        heat  the  sample  until  the  cholesterol  pressure  increases  and spectra
        may be measured.

     3.  Terminate  data  acquisition  and plot  a background subtracted spectrum
         of  cholesterol  as  described  in Test  I.   Measure the abundances of
         the ions  at  masses 386 and  368,  and  compute the 386/368 abundance

                                      30

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ratio.  This should be 3.0  or  greater  for  an  acceptable  solid probe
inlet system.  The ion abundance  at  mass 369  should be 26-34X of the
abundance at mass 386.  Finally large  ions  above  3CS relative
abundance should be at masses  41,  43,  55,  57,  67,  69,  71,  79, 81,
83, 91,  93, 95, 105, 107, 109, 119,  121, 133,  145,  147,  149,  159,
161, 213, 275, 301, and 386.
                             31

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                                  SECTION 4

                                  REFERENCES


1.  Eichelberger, J.W., I.E. Harris, and W.L. Budde, "Reference Compound to
    Calibrate Ion Abundance Measurements In Gas Chromatography - Mass
    Spectrometry Systems," Anal. Chem., 47, 995 (1975).

2.  Budde, W.L., and J.W. Eichelberger, "An EPA Manual for Organics Analysis
    Using Gas Chromatography - Mass Spectrometry," EPA Report No. EPA
    600/8-79-006, March, 1979.

3.  Budde, W,L., and J.W. Eichelberger, "Organics Analysis Using GC/MS," Ann
    Arbor Science Publishers, Ann Arbor, Michigan, July 1979.

4.  "Guidelines Establishing Test Procedures for the Analysis of
    Pollutants," Federal Register

5.  "Handbook for Analytical Quality Control in Water and Wastewater
    Laboratories,"  EPA Report No. EPA-600/4-79-019, March, 1979, Chapter 6.
                                      32

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                                APPENDIX 17

                 LIFE CYCLE  OF AN ON-SITE SYSTEM EVALUATION
                             Agency  Procedures
                             for  Evaluations of
                             Monitoring Programs
Approval  of
Region V's
Managi ng
Di rectors
Region V's QA^ Program
for Implementation of
Agency Procedures for
Evaluation of Monitoring
Programs	
                             Instructions  for
                             Evaluator

/
Direction of
Re-Evaluation,
if Required


Execution of On-Site [^
Eva! uati on N 	 ••• 	
1
Di recti ons for
•Special On-Site
Evaluations






	 ^Report of Comoliance | 	 5












\|f
On-Site Evaluation _
Report
\l/
Meeting for Discussion .Task Force
of Reoort and ' for Cormliance
Recommendati ons
J,
Corretive Action I/
for Compliance r*
' X
Check of Results
after Compliance
\^"
Reports to !/
Management (^
                                     JL
                             Monitoring Program
                             in Compliance with
                             Agency's Minimum
                             Quality Assurance
                             Requi rements

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                                 APPENDIX 18

         ELEMENTS FOR A SECTION 106,  208, 404(b)(l)  AND GREAT LAKES
           NATIONAL PROGRAM MONITORING QUALITY ASSURANCE PROGRAM

1.  The laboratory shall document and Implement a quality Assurance Policy
    to assure sufficient quality control  activities  are maintained to assure
    data credibility for each monitoring  project.  Management or supervisory
    quality control duties and responsibilities must be defined for its own
    monitoring and for contract projects.

2.  A Quality Assurance Coordinator shall be designated by each laboratory
    to coordinate quality control activities and to  assure that they are
    being performed.  If quality control  1s not practiced, then there can
    be no quality assurance.

3.  Documented, technique oriented collection procedures shall  be implemented
    by each agency to assure valid and representative samples for surface
    waters, ground waters, point source discharges,  fish, sediment, etc.
    Uniform record keeping will be established to provide data  credibility
    and sufficient "chain-of-custody".

4.  Field measurement methodologies shall be used that are appropriate for
    each monitoring project.  Reference or approved  methods must be used
    for monitoring.  Calibration and preventive maintenance protocols are
    to be established and used for all field instruments and methodologies.
    Records of the calibrations and maintenance are  to be maintained.

5.  Sample preservation protocols shall be established by EPA for consistency
    with the compositing time period used during monitoring, transport time
    between field and laboratory, and dictates of required laboratory
    methodologies, etc.

6.  A uniform source of sample containers shall be established.  Sufficient
    quality control will be established to assure the appropriateness of
    containers used for each monitoring project.

7.  Sufficient number of field and laboratory personnel trained in quality
    control practices shall be available  for each monitoring project.

8.  The laboratory will establish sufficient record  keeping and sample
    handling practices for sample receipt and analyses, consistent with
    field record keeping practices, in order to maintain data credibility
    and sufficient "chain-of-custody".

9.  Protocols will be established for and records will be kept  of instrument
    calibration and maintenance in an agency's laboratory.  Appropriate
    protocols will be established and used to assure the acceptance of
    designated laboratory prepared materials (eg.  -  distilled water)  and
    purchased materials (eg. - microbiology media).

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                           APPENDIX  18  (Continued)

10.  Each laboratory will  utilize and document  methodologies,  appropriate  in
     precision, sensitivity and accuracy,  for each  mom"ton'ng  project.
     Reference or approved methods must be used for monitoring and  are
     subject to review by  the QAO.

11.  Intra-laboratory audits of controls or "spiked" samples,  replicate
     analyses, and reagent blanks are to be utilized,  recorded,  and documented
     by each laboratory to assure the acceptance of data  for each monitoring
     project.  Summaries or quality  control  charts  for these intra-laboratory
     audits can be utilized to document analytical  performance.  The ability
     of these intra-laboratory aidit data  to represent actual  data  quality
     is dependent on the specific audits performed  and an understanding  of
     their utility by a data user.

12.  Inter-laboratory audits of independently prepared reference smples  or
     U.S. EPA quality control  samples,  when available, are to  be used at a
     minimum frequency of  quarterly  and their results  documented as part of
     an agency's quality assurance program.   Inter-laboratory  audits or
     reference samples assure analytical  accuracy and  maintenance of
     calibration accuracy  of a laboratory's day-to-day intra-laboratory
     quality control program.

13.  Each laboratory is requested to participate in U.S.  EPA's performance
     sample program, usually scheduled  once per year for  monitoring agencies.
     Results should be documented as part  of an agency's  quality assurance.
     program and can replace one of  the above inter-laboratory audits.

14.  A quality assurance program should assure  that only  data  meeting
     acceptance criteria for the above  elements are used  for each monitoring
     project.  Data in computerized  data management or storage systems must
     be audited or verified as being the same as the actual field and
     laboratory results.

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                               APPENDIX  19



SUMMARY OF GUIDELINES FOR  STATION SITING AND PROBE  PLACEMENT*

POLLUTANT
Sulfur
dioxide






Suspended
Particulates


Ozone






Nitrogen
dioxide



SITE TYPE
Peak




Nei ghborhood

Background
Peak

Neighborhood
Background
Peak



Nei ghborhood

Background
Peak

Neighborhood
Background
SITE SELECTION
SITE LOCATION
Maximum point determined from
atmosphere diffusion model,
hi stoical data, emission density,
and representative of population
exposure.
Determined on basis of population
patterns and air quality gradients
Nonurban area within Region
Same as for S02

Same as for S02
Same as for S02
Representative area downwind of the
CBDC area 15 to 25 km from downtown
and >100 m from major traffic
arteries or parking areas
Sites 1n center city, residential,
commercial areas
Nonurban area within Region
Same as for Ozone, except distance
of 10 to 15 km
Same as for Ozone
Same as for Ozone
PROBE
HEIGHT
ABOVE
GROUND
3 to 15




3 to 15

3 to 15
2 to 15

2 to 15
2 to 15
3 to 15



3 to 15

3 to 15
3 to 15

3 to 15
3 to 15
PL/CEMENT
(METERS)
VERTICAL HORIZONTAL
CLEARANCE3 CLEARANCE6
1 to 2




1 to 2

1 to 2
__

--
--
1 to 2



1 to 2

1 to 2
1 to 2

1 to 2
1 to 2
>2




>2

>2
>2

>2
>2
>2



>2

>2
>2

>2
>2

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                                                 APPENDIX 19 (Continued)
                                    SUMMARY OF GUIDELINES FOR STATION SITING AND PROBE PL/CEMENT*

POLLUTANT
Carbon
monoxide
Non-Methane
hydrocarbons
Nitric Oxide
Nitrogen
Dioxide


SITE TYPE
Street Canyon
Neighborhood
Corrider
Background
Research and
Planning
Research and
Planning
Research and
Planning
SITE SELECTION
SITE LOCATION
See Supplement A
See Supplement A
See Supplement A
See Supplement A
Generally limited to areas of peak
emission density of hydrocarbons,
i.e., CBDC
Generally coincident with NMHC sites
Generally coincident with NHMC sites
PROBE
HEIGHT
ABOVE
GROUND
3 1 1/2
3 +_ 1/2
3 +_ 1/2
3 to 10
3 to 15
3 to 15
PLACEMENT (METERS)
VERTICAL
CLEARANCE*
1
1
1
1
1 to 2
1 to 2
HORIZONTAL
CLEARANCE1*
>2
>2
>2
>2
>2
>2
*Guidance for Air Qulity Monitoring Network  Design  and  Instrument  Siting  (Revised).  U.S. Environmental Protection Agency
 Guideline Series OAQPS No.  1,2-012, September  1975.1
aVertical clearance above rooftop or other supporting structure.
bllorizontal  clearance from side of supporting structure or other restriction to air flow.
^Central Business District.

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                                 GLOSSARY
Analytical or reagent blank:  a blank used as a baseline for the analytical
     portion of a method.  For example, a blank consisting of a sample
     from a batch of absorbing solution used for normal samples, but
     processed through the analytical system only, and used to adjust
     or correct routine analytical results.

Audit;  A systematic check to determine the quality of operation of some
     function or activity.  Audits may be of two basic types: (1) performance
     audits in which quantitative data are independently obtained for
     comparison with routinely obtained data, or (2) system audits of a
     qualitative nature that consist of an on-site review of a laboratory's
     quality assurance program and physical facilities for sampling,
     calibration and measurement.

Bioassay;  Using living organisms to measure the effect of a substance,
     factor, or condition.

Biomonitoring:  The use of living organisms to test water quality at a
     discharge site or downstream.

Blank or sample blank:  a sample of a carrying agent (gas, liquid, or solid)
     that is normally used to selectively capture a material of interest
     and that is subjected to the usual analytical or measurement process
     to establish a zero baseline or background value, which is used to
     adjust or correct routine analytical results.

Calculation:  The arithmetic conversion of raw analytical data to some
     standardized dimension form suitable for formating in a data report
     or for its final intended use.  For example, "x" ml/500 ml  sample or
     reagent might be calculated to be 10 mg/liter of zinc chloride which
     exceeds the discharge limitations of a specific permit.

Calibration:  Establishment of a relationship between various calibration
     standards and the measurements of them by a measurement system (or
     portions thereof).  The levels of calibration standard should bracket
     th-e range of levels for which actual measurements are to be made.

Completeness:  The amount of valid data obtained from a measurement system
     compared to the amount that was expected to be obtained under correct
     normal  operations.

Confidence interval:  A value interval  that has a designated probability
     (the confidence coefficient) of including some defined parameter of
     the population.

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                                    2

Confidence limits:  The outer boundaries of a confidence interval.

Contract;  The legal instrument reflecting a relationship between the
     Federal Government and a State or local government or other recipient:
     (1) whenever the principal purpose of the instrument is  the acquisition,
     by purchase, lease, or barter, of property or services for the direct
     benefit or use of the Federal Government; or (2)  whenever an executive
     agency determines in a specific instance that the use of a type of
     procurement contract

Cooperative agreement:  The legal instrument reflecting the relationship
     between the Federal Government and a State or local government or
     other recipient whenever: (1) the principal  purpose of the relationship
     is the transfer of money, property, services, or anything of value
     to the State or local government or other recipient to accomplish
     a public purpose of support or stimulation authorized by Federal
     statute, rather than acquisition, by purchase, lease, or barter, of
     property or services for the direct benefit  or use of the Federal
     Government; and (2) substantial involvement  is anticipated between
     the executive agency acting for the Federal  Govenrment and the State
     or local government or other recipient during performance of the
     contemplated activity.

Data validation:  A systematic effort to review data to identify any
     outliers or errors and thereby cause deletion or flagging of suspect
     values to assure the validity of the data to the user.  This
     "screening" process may be done by manual and/or computer methods,
     and it may utilize any consistent technique  such as sample limits to
     screen out impossible values or complicated  acceptable relationships
     of the data with other data.

In-house project:  A project carried out by EPA staff in EPA  facilities.

Inter-laboratory;  Between two different laboratories.

Intra-laboratory:  Within a given laboratory.

Measures of dispersion or variability;  Measures  of the differences,
     scatter, or variability of values of a set of numbers.  Measures of
     the dispersion or variability are the range, the standard deviation,
     the variance, and the coefficient of variation.

Performance audit:  Planned independent (duplicate) sample checks of
     actual output made on a random basis to arrive at a quantitative

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     measure of the quality of the output.  These independent checks are
     made by an auditor subsequent to the routine checks by a field
     technician or laboratory analyst.

Performance test sample;  A sample or sample concentrate (to be diluted
     to a specified volume before analysis)  of known (to the EPA only)
     true value which has been statistically established by inter!aboratory
     tests.  These samples are commonly provided to laboratories to test
     analytical performance.  Analytical  results are reported to the EPA
     for evaluation.

Proficiency testing;  Special series of planned tests to determine  the
     ability of field technicians or laboratory analysts who normally
     perform routine analyses.  The results  may be used for comparison
     against established criteria, or for relative comparisons among the
     data from a group of technicians or analysts.

Program;  The technical  office or staff that has responsibility for a part
     of the Agency's operation.  For R&D  grants, the "programs" are the
     Office of Research  and Development,  the Office of Air Quality  Planning
     and Standards, the  Office of Solid Waste Management Programs,  and
     the Offi ce of Mobi1e Sources Ai r Pol1uti on C ontrol.

Project officer:  The EPA official designated in the grant or contract
     agreement as the Agency's principal  contact with the grantee on a
     particular grant.  This person is the individual  responsible for
     project monitoring  and for recommendations on or approval  of proposed
     project changes.

Quality:  The totality of feature and characteristics of a product  or
     service that bears  on its ability to satisfy a given purpose.   For
     pollution measurement systems, the product is pollution measurement
     data, and the characteristics of major  importance are accuracy.
     precision, and completeness.  For monitoring  systesm, "completeness",
     or the amount of valid measurements  obtained  relative to the amount
     expected to have been obtained, is usually a  very important measure
     of quality.  The relative importance of accuracy, precision, and
     completeness depends upon particular purpose  of the user.

Quality Assurance;  (1)  An organization's total  program for assuring  the
     reliability of the  data it produces.

                    (2)  A system for integrating the quality planning,
     quality Assessment, and quality improvement efforts of various groups
     in an organization  to enable operations to meet user requirements

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     at an economical  level.   In pollution measurement  systems,  quality
     assurance is concerned with all  of the activities  that  have an
     important effect on the quality of the pollution measurements,  as well
     as the establishment of methods and techniques to  measure the quality
     of the pollution measurements.   The more authoritative  usages
     differentiate between "quality assurance" and "quality  control",
     where quality control is "the system of activities to provide a
     quality product" and quality assurance is "the system of activities
     to provide assurance that the quality control  system is performing
     adequately".

Quality assurance manual:  An orderly assembly of management policies,
     objectives, principles, and general procedures by  which an  agency
     or laboratory outlines how it intends to produce quality data.

Quality assurance plan:  An orderly assembly of detailed and specific
     procedures by which an agency or laboratory delineates  how  is
     produces quality data for a specific project or measurement method.
     A given agency or laboratory would have only one quality assurance
     manual, but would have a quality assurance plan for each of its
     projects or programs (group of projects using the  same  measurement
     methods; for example, a laboratory service group might  develop  a
     plan by analytical instrument since the service is provided to  a
     number of projects).

Quality control:  The detailed and specific procedures  used  to insure the
     quality-of data produced by a particular measurement activity;  the
     system of activities designed and implemented to provide a  quality
     product.

Quality control (internal);  The routine activities and checks,  such as
     periodic calibrations, duplicate analyses, use of  spiked sample, etc.,
     included in normal internal procedures to control  the accuracy  and
     precision of a measurement process.

Quality control (external):  The activities which are performed  on an
     occasional basis, usually initiated and performed  by persons outside
     normal routine operations, such as on-site system  surveys,  independent
     performance audits, interlaboratory comparisons, etc.,  to assess
     the capability and performance of a measurement process.

Range:  The difference between the maximum and minimum  values of a set
     of values.  When the number of values is small (i.e., 12 or less), the
     range is a relatively sensitive (efficient) measure of  variability.

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Reagent:  A chemical  material, usually a compound of high  purity,  which  is
     used as a reactant in the process of a chemical  analysis.

Recovery:  That percentage of a parameter in a sample which  is  detected
     or "recovered" from that sample during chemical  analysis.

Reliability:  A numerical statement of accuracy and precision.

Representatiyeness:  A numerical  statement of how well  a sample or group
     of samples or the data derived therefrom represents the actual
     parameter variations at the sampling point, plus how well  that
     sampling point represents the actual parameter variations  which
     are under study.

Sample:  A subset or group of objects or things selected from a larger
     set called the "lot" or "population".  The objects or things  may
     be physical, such as specimens for testing, or they may be data
     values representing physical  samples.  Unless otherwise specified,
     all samples are assumed to be randomly selected.  Samples  can take
     numerous forms,  such as:

     Representative sample:  A sample taken to represent a lot  or  population
     as accurately and precisely as possible.  A representative sample may
     be either a completely random sample or a stratified  sample,  depending
     upon the objective of the sampling and the conceptual population  for
     a given situation.

     Spiked sample:  A normal sample of material (gas,  solid, or liquid)
     to which is added a known amount of some substance of interest.   The
     extent of the spiking is unknown to those analyzing the sample.   Spiked
     samples are used to check on the performance of a  routine  analysis  or
     the recovery efficiency of a method.

Standard deviation:  The square root of the variance of a  set of values:

                       n
                          /Y    Y \Z
                          (AJ - AJ

          S »          i * 1
                           n - 1
     if the values represent a sample from a larter population:

                       N
                           (X1 -  u)2

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     where u is the true arithmetic mean  of the  population.   The  property
     of the standard deviation that makes it most  particularly meaningful
     is that it is in the same units as the values of the  set, and
     universal  statistical  tables for the normal  (and other)  distributions
     are expressed as a function of the standard  deviation.   Mathematically,
     the tables could just as easily be expressed  as  a function of  the
     variance.

Standard reference material (SRM):   A material  produced in quantity,  of
     which certain properties have been certified  by  the National Bureau
     of Standards (NBS) or other agencies to the  extent possible  to satisfy
     its intended use.  The material should be  in  a matrix similar  to
     actual samples to be measured by a measurement system or be  used
     directly in preparing such a matrix.  Intended uses include:
     (1) standardization of solutions, (2) calibration of  equipment,  and
     (3) monitoring the accuracy and precision  of measurement systems.

Standard reference sample:   A carefully prepared  material  produced  from or
     compared aganist an SRM (or other equally  well characterized material)
     such that there is little loss of accuracy.   The sample  should have  a
     matrix similar to actual samples used in the measurement system.  These
     samples are intended for use primarily as  reference standards  to:
     (1) determine the precision and accuracy of measurement  systems,
     (2) evaluate calibration standards,  and (3)  evaluate  quality control
     reference samples.  They may be used "as is"  or  as a  component of  a
     calibration or quality control measurement  system. Examples:  an
     NMS-certified sulfur dioxide permeation device is an  SRM.  When  used
     in conjunction with an air dilution  device,  the  resulting gas  becomes
     an SRS.  An NBS-certified oxide gas  is an  SRM.  When  diluted with  air,
     the resulting gas is an SRS.

Standardization:  A physical or-mathematical adjustment or correction of  a
     measurement system to make the measurements  conform to predetermined
     values.  The adjustments or corrections are usually based on a
     single-point calibration level.

     Calibration standard:   A standard prepared  by the analyst for  the
     purpose of calibrating an instrument.  Laboratory control standards
     are prepared independently from calibration standards for most methods.

     Detection limit:  That number obtained by  adding two  standard  deviations
     to the average value obtained for a  series  of reagent blanks that  are
     analysed over a long time period (several  weeks  or months).

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     Duplication analyses:   The collection of two samples  from the same
     field-site which are analyzed at different times but  usually on the
     same day.

     Laboratory control  standard:   A standard of known concentration
     prepared by the analyst.

     Reference standard:   A solution obtained from an outside source
     having a known value and  analyzed as a blind sample.

     Relative percent error for duplicate analyses:   The difference between
     the measured concentration for the duplicate pair times  100  and
     divided by the average of the concentration.

     Relative percent error for laboratory control standards:   The difference
     between the measured value and the theoretically correct value times
     100 and divided by  the correct value.

     Relative percent error of a reference sample analysis:   The  difference
     between the correct  and measured values times 100 and divided by the
     correct concentration.

Standards based upon usuage:

     Calibration standard:   A  standard used to quantitate  the relationship
     between the output  of a sensor and a property to be measured.
     Calibration standards should  be traceable to standard reference
     materials or primary standard.

     Quality control reference sample (or working standard):   A material
     used to assess the  performance of a measurement  or portions  thereof.
     It is intended primarily  for  routine intralaboratory  use in  maintaining
     control of accuracy  and would be prepared from or traceable  to a
     calibration standard.

Standards depending upon  "purity"  or established physical  or  chemical constants:

     Primary standard:  A material  having a known property that is  stable,
     that can be accurately measured or derived from  established  physical
     or chemical constants, and that is readily reproducible.

     Secondary standard;   A material having a property that is calibrated
     against a primary standard.

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                                    8

Standards In naturally-occurring matrix:  Standards relating to the pollutant
'measurement portions of air pollution measurement systems may be
     categorized according to matrix, purity, or use.  Standards in a
     naturally-occurring matrix include Standard Reference Materials and
     Standard Reference Samples.

Statistical control chart (also Shewhart control chart):   A graphical chart
     with statistical control limits and plotted values (usually in
     chronological order) of some measured parameter for a series of
     samples.  Use of the charts provides a visual display of the pattern
     of the data, enabling the early detection of time trends and shifts
     in level.  For maximum usefulness in control, such charts should be
     plotted in a timely manner, i.e., as soon as the data are available.

System audit:  A systematic on-site qualitative review of facilities,
     equipment, training, procedures, record-keeping, validation, and
     reporting aspects of total (quality assurance) system to arrive at
     a measure of the capability and ability of the system.  Even though
     each element of the system audit is qualitative in nature, the
     evaluation of each element and the total may be quantified and
     scored on some subjective basis.

Systematic error;  The condition of a consistent deviation of the results
     of a measurement process from the reference or known level.

Test Variability:  Accuracy:  The degree of agreement of a measurement (or
     an average of measurements of the same thing), X, with an accepted
     reference or true value, T, usually expressed as the difference
     between the two values, X-T, or the difference as a percentage of the
     reference or true value, 100(X-T)/T, and sometimes expressed as a
     ratio, X/T.

     Bias:  A systematic (consistent) error in test results.  Bias can
     exist between test results and the true value (absolute bias, or lack
     of accuracy), or between results from different sources (relative
     bias).  For example, if different laboratories analyze a homogeneous
     and stable blind sample, the relative biases among the laboratories
     would be measured by the differences existing among the results from
     the different laboratories.  However, if the true value of the blind
     sample were known, the absolute bias or lack of accuracy from the
     true value would be known for each laboratory.

     Precision:  A measure of mutual agreement among individual measurements
     of the same property, usually under prescribed similar conditions.
     Precision is most desirably expressed in terms of the standard

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     deviation but can be expressed  in  terms  of the  variance,  range, or
     other statistics.   Various  measures  of precision  exist depending upon
     the "prescribed similar conditions".

     Replicates:   Repeated but  independent  determinations of the  same
     sample, by the same analyst,  at essentially the same time and same
     conditions.   Care should be exercised  in considering replicates of a
     portion of an analysis and  replicates  of a complete analysis.  For
     example, duplicate titrations of the same digestion are not  valid
     replicate analyses, although  they  may  be valid  replicate  titrations.
     Replicates may be performed to  any degree, e.g.,  duplicates, triplicates,
     etc.

     Reproducibility:   The precision, usually expressed as a standard
     deviation, measuring the variability among results of measurements
     of the same sample at different laboratories.

Validation:  A systematic effort to  review  data to identify outliers or
     errors and thereby cause deletion  or flagging of  suspect  values to  .
     assure the validity of the  user's  data.

Variance:  Mathematically, for  a sample,  the  sum of  squares of the
     differences between the individual values of a  set and the arithmetic
     mean of the set,  divided by one less than the number of values.

Verification:  Follows validation  and permits the certification of the data
     for an intended legal use,  presuming that the chain-of-custody require-
     ments are found to be intact.  Again the terminology used in this
     document is intended to be  general and should in  no way be construed
     to limit the use of special  area terminologies  in the preparation
     of the required QA Plan.

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                                     TECHNICAL REPORT DATA
                             (Please read Instructions an me reverse ue/ore comnlcang/
 1. HEPORT NO.
   EPA-905/4-80-001
                                                             3. RECIPIENT'S ACCESSIOr»NO.
 A. TITLS AND SUBTITt.2
  Quality Assurance Program,  Guidelines and
  Specifications, Criteria  and Procedures,
  Region V
                                                           5. REPORT DATE
                                                             January 15, 1980
                                                           6. PERFORMING ORGANIZATION CODE
 '. AUTHORtS)
                                                             8. PERFORMING ORGANIZATION REPORT NO.
   James H.  Adams, Jr.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Quality Assurance Office
  Surveillance and Analysis  Division
  U.S.  Environmental Protection  Agency
  Chicago, Illinois 60605
                                                             10. PROGRAM ELEMENT NO.
                                         Region V
                                                           11. CONTRACT/GRANT NO.
 liSPONSOR
   " —lity
        ORING AGENCY NAME AND ADDRESS
Quality Assurance Uftice
Surveillance  and  Analysis Division
U.S. Environmental  Protection Agency
Chicago, Illinois 60605
13. TYPE OP REPORT AND PERIOD COVERED
  Manual
                                            Region V
                                                             14. SPONSORING AGENCY COOE
 is.SUPPLEMENTARY NOTES Manual will  be reproduced in tne  current_format ipiastic  Dinciingj  ana
   maintained up-to-date by the  QAO, Region V.  Distribution  will  be to Agency  personnel
   and  its contractors, State  and  local  agency laboratory  Directors and QC offices  in
                                                                               -fter
 lO* ABSTRACT
  This  manual  documents the Quality Assurance Program  for  Region V, U.S. EPA,  that will
  produce a numerical estimate'of the reliability of all data values reported  or  used
  by  the Region.  Revisions will  be made per the requirements of the finalized Quality
  Assurance Plan of the:-Agency.   The elements of a quality assurance program are
  discussed, including Region V's QA Policy Statement, Objectives and Milestones,
 . Qua.Tlity Assurance^Management,  Personnel, .Facilities,. Equipment and Services, Review
  of  Program Plans, Project Plans "or Study Plans, Data" Collection, Data Processing,
  Corrective Actions, Data Quality Assessment, Data Quality Reports, Chain of  Custody
  and Specific Guidance.
 7.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.IDENTIFIERS/OPEN ENDED TERMS
                                                                        c.  COSATI Field/Group
  Quality  Assurance
  Quality  Control
                                              Intralaboratory QC
                                              Inter!aboratory QC
                                              Performance and 'System
                                               Audits
                                              Quality Control Program
                                              Accuracy Assessment
                                              Precision Assessment
                138
                14B
 8, DISTRIBUTION STATEMENT

   Release  Unlimited
                                             19. SECURITY CLASS {This Reponl
                                             Unclassified
             21. NO. OF PAGES
                  237
                                               20. SECURITY CLASS (Thispage)

                                                Unclassified
                                                                        22. PRICE
ETA Perm 2220-1 (9-73)

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   1.   REPORT NUMBER
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   2.   LEAVE BLANK

   3,   RECIPIENTS ACCESSION NUMBER
        Reserved for use by each report recipient.

   4.   TITLE AND SUBTITLE
        Title should indicate clearly and briefly the subject coverage of the report, and be displayed prominently. Sec subtitle, if used, in smaller
        type or otherwise subordinate it to mam  title. When a report is prepared in more than one volume, repeat the primary title, add volume
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        include ZIP code.

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        Indicate interim tuuL etc., and if applicable, dates covered.

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        Leave blank.

   -18.  SUPPLEMENTARY NOTES                   "            "                .   .   -     -  '
        Eater information not included elsewhere but useful, such as:  Prepared in cooperation with. Translation of, Presented at conference of,
        To be published in. Supersedes. Supplements, etc.

   18.  ABSTRACT
        Include a brief (ZOO words or lea) factual summary of the most significant information contained in the report. If the report contains a
        significant bibliography or literature survey, mention it here.

   17.  KEY WORDS ANO DOCUMENT ANALYSIS
        (a) DESCRIPTORS - Select from the Thesaurus of Engineering and Scientific Terms the proper authorized terms that identify the major
        concept of the research and are sufficiently specific and precise to be used as index entries for cataloging.

        (b) IDENTIFIERS AND OPEN-ENDED TERMS - Use identifiers for project names, code names, equipment liestcnators, etc. Use open-
        ended terms written m descriptor form for those  subjects for which no descriptor exists.

        (e) COSATI FIELD GROUP - Reid and group assignments are to be taken from the 1965 COSATI Subject Category List. Since the ma-
        jority of documents are muittdisciplinary in nature, the Primary Field/Group assignment! s) will be specific discipline, area ot' human
        endeavor, or type of physical object. The applications) will be cross-referenced with secondary Field. Group assignments that will follow
        the primary postingtsi.

   18.  DISTRIBUTION STATEMENT
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        the public, with address and price. ,

   19. & 20. SECURITY CLASSIFICATION
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   21.  NUMBER OP PAGES
        Insert the total number of pages, including this one and unnumbered pages, but exclude distribution list, if any:    ....

   22.  PRICE
        Insert the price  set by the National Technical Information Service or  the Government Printing Office, if known.
EPA'Form 2220.* (9-73) (R«v«rw>

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