United States       Office of Air Quality        EPA 450/4-90-015
            Environmental Protection   Planning and Standards
            Agency         Research Triangle Park NC 27711   AprB 1991

            _             .       _
svEPA
     Protocol For The Field Validation
     Of Emission Concentrations
     From Stationary Sources

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                                           EPA 450/4-90-015
                                           April 1991
           PROTOCOL FOR THE FIELD VALIDATION
               OF  EMISSION  CONCENTRATIONS
                FROM STATIONARY SOURCES
               Technical  Support Division
      Office  of Air  Quality  Planning  and Standards

                          and

               Quality Assurance Division
Atmospheric Research and Exposure Assessment Laboratory

          U.S.  Environmental Protection Agency
           Research Triangle Park, NC  27711

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                        TABLE OF CONTENTS

section

          List of Tables                                3

   1.0    Applicability                                 4

   2.0    Principle                                     4

   3.0    Reference Material                            5

   4.0    EPA Performance Audit Material                5

   5.0    Procedures for Determination of               6
          Bias and Precision in the Field

               5.1  Isotopic Spiking                    6
               5.2  Comparison Against a                7
                    Validated Method
               5.3  Analyte Spiking                     8

   6.0    Calculation of Bias and Precision             8

               6.1  Isotopic Sampling                   8
               6.2  Comparison Against                 10
                    Validated Method
               6.3  Analyte Spiking                    14
                                        »
   7.0    Field Validation                             16

   8.0    Followup Testing                             16

                            APPENDICES

Appendix A          Procedure for Obtaining A Waiver   17
                    From The Validation Protocol

Appendix B          Ruggedness Testing                 21
                    (Laboratory Evaluation)

Appendix C          Procedure for Including            24
                    Sample Stability In Bias and
                    Precision Evaluations

Appendix D          Procedure for Determination of     25
                    Practical Limit of Quantitation

Appendix E          Example Calculations               27

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                          LIST  OF  TABLES
Table A.I




Table B.I




Table B.2




Table B.3




Table E.I




Table E.2




Table E.3




Table E.4




Table E.5
EPA Regional Office



Ruggedness Test Matrix



Test Conditions



Analytical Results



Cr(VI) Recoveries



Analyte Recoveries



Paired Sample Recoveries



Quad Sample Recoveries



Method Mean Data
page




19




22




22




23




27




30




34




37




38

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                PROTOCOL FOR  THE FIELD VALIDATION
                   OF  EMISSION CONCENTRATIONS
                     FROM STATIONARY SOURCES
1.0  APPLICABILITY

1.1  This "Protocol for the Field Validation of Emission
Concentrations from Stationary Sources" (Protocol) includes
procedures for determining and documenting the quality, i.e.,
systematic error (bias) and random error (precision), of the
measured concentrations of the source emissions.  This protocol,
as specified in the underlying regulations, is to be used
whenever a source owner or operator (hereafter referred to as an
"analyst") proposes a test method to meet a U.S. Environmental
Protection Agency (EPA) requirement in the absence of a validated
method.  For example, the Protocol may be used to identify and
verify post-control emissions for early reduction credit [Section
112(5)(i) of the Clean Air Act Amendments of 1990].

1.2  If EPA currently recognizes an appropriate test method or
considers the analyst's test method to be satisfactory for a
particular source,  the Administrator may waive the use of this
protocol or may specify a less rigorous validation procedure.  A
list of validated methods can be obtained by contacting the
Emission Measurement Technical Information Center (EMTIC), Mail
Drop 19, U.S. Environmental Protection Agency, Research Triangle
Park, NC  27711, 919/541-2237.  Procedures for obtaining a waiver
from the protocol are in Appendix A.  State agencies may require
additional documentation regarding the quality of the emission
data.

1.3  This protocol includes optional procedures that may be used
to expand  the applicability of the proposed method.   Appendix B
is the "Ruggedness Testing (Laboratory Evaluation)," which
demonstrates the sensitivity of the method to various parameters.
Appendix C is "Procedure for Including Sample Stability in Bias
and Precision," for assessing sample recovery and analysis times;
Appendix D is "Procedure for the Determination of Practical Limit
of Quantitation" for determining the lower limit of the method.

2.0  PRINCIPLE

The purpose of the validation protocol is to determine bias and
precision of a test method at a permissible emission
concentration, e.g., emission standard, in the gas stream.  The
procedures involve (a)  introducing known concentrations of an
analyte or comparing the test method against a validated test
method to determine the method's bias and (b)  collecting multiple

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or collocated simultaneous samples to determine the method's
precision.

2.1  Bias is any systematic positive or negative difference
between the measured value and true value of a sample.  Three
common causes of bias are (a) interfering compounds in the
effluent gas, (b) calibration errors, and (c) inefficiencies in
the collection of the analyte.  Bias is established by comparing
the method's results against a reference value and may be
eliminated by dividing the measured concentration by an
appropriate factor (i.e., average measured
concentration/reference value).   An offset bias may be handled
accordingly.  Methods that have bias correction factors outside
0.7 to 1.3 are unacceptable.  Method to method comparisons,
Section 6.2, requires a more restrictive test of central tendency
and a lower correction factor allowance of 0.90 to 1.10.

2.2  Precision is the variability in the data obtained from the
entire measurement system (i.e., sampling and analysis) as
determined from collocated sampling trains.   At least two  (i.e.,
paired) sampling trains shall be used to establish precision.
The precision of the method at the level of the emission standard
shall not be greater than 50 percent relative standard deviation.
For method to method equivalency comparisons the analyst must
demonstrate that the precision of the proposed test method is as
good as that of the validated method for acceptance.

3.0  REFERENCE MATERIAL

The analyst shall obtain a known concentration of the reference
material  (i.e.,  analyte of concern) from an independent source
such as a specialty gas manufacturer, specialty chemical company,
or commercial laboratory.  A list of vendors may be obtained from
EMTIC (see Section 1.2). The analyst should obtain the
manufacturer's stability data of the analyte concentration and
recommendations for recertification.  If the reference material
is in the gaseous state, the concentration(s) [multiple levels
may be required to expand a method's concentration applicability]
shall be within 0.20 to 5 times the average concentration in the
sample gas stream.

3.1  Surrogate Reference Materials.   The analyst may use
surrogate compounds,  e.g., for highly toxic or reactive organic
compounds, provided the analyst can demonstrate to the
Administrator's satisfaction that the surrogate compound behaves
as the analyte.   A surrogate may be an isotope or one that
contains a unique element (e.g., chlorine)  that is not present in
the stack gas or a derivative of the toxic or reactive compound,
if the derivative formation is part of the method's procedure.
Laboratory experiments or literature data may be used to show
behavioral acceptability.

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3.2  Isotopically Labeled Materials.  Isotope mixtures may
contain the isotope and the natural analyte. For best results,
the isotope labeled analyte concentration should be more than
five times the natural concentration of the analyte.  Deuterated
compounds of interest may be in gaseous or liquid states.  The
gaseous form should be obtained in compressed-gas cylinders in
high-purity nitrogen.

4.0  EPA PERFORMANCE AUDIT MATERIAL

4.1  To assess the method bias independently, the analyst shall
use (in addition to the reference material) an EPA performance
audit material, if it is available.  The analyst may contact
EMTIC (see Section 1.2)  to receive a list of currently available
EPA audit materials.  If the analyte is listed, the analyst
should request the audit material at least 30 days before the
validation test.  If an EPA audit material is not available,
request documentation from the validation report reviewing
authority that the audit material is currently not available from
EPA.  Include this documentation with the field validation
report.

 4.2  The analyst shall sample and analyze the performance audit
sample three times according to the instructions provided with
the audit sample.  The analyst shall submit the three results
with the field validation report.  Although no acceptance
criteria are set for these performance audit results, the analyst
and reviewing authority may use them to assess the relative error
of sample recovery, sample preparation, and analytical procedures
and then consider the relative error in evaluating the measured
emissions.

5.0  PROCEDURE FOR DETERMINATION OF BIAS AND PRECISION IN THE
FIELD

The analyst shall select one of the sampling approaches below to
determine the bias and precision of the data.  After analyzing
the samples, the analyst shall calculate the bias and precision
according to the procedure described in Section 6.0.

5.1  Isotopic Spiking.  This approach shall be used only for
methods that require gas chromatography/mass spectrometry (GC/MS)
analysis.  Bias and precision are calculated by procedures
described in Section 6.1.

5.1.1  Number of Samples and Sampling Runs.  Collect a total of
12 samples using either paired (2) or quadruplet (4) collocated
sampling trains.  For paired trains, conduct six sampling runs.
For quadruplet trains, conduct three sampling runs.

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5.1.2  Spiking Procedure.  Spike all 12 sampling trains with the
reference material as follows.  The spike shall be introduced as
close to the tip of the probe as possible.

5.1.2.1  Gaseous Reference Material with Sorbent or Impinger
Trains. Sample the reference material (in the laboratory or in
the field) at a concentration equal to the level of the emission
standard for the time required by the method, and then sample the
gas stream for an equal amount of time.  The time for sampling
both the reference material and gas stream should be equal;
however, the time should be adjusted to avoid sorbent
breakthrough.

5.1.2.2  Gaseous Reference Material with Sample Container  (Bag or
Canister).  Spike the containers after completion of the test run
with an amount equal to the level of emission standards.  The
final concentration of the reference material shall approximate
the level of the emission standard. The volume amount of
reference material shall be less than 10 percent of the sample
volume.

5.1.2.3  Liquid and Solid Reference Material with Sorbent or
Impinger Trains.  Spike the trains with an amount equal to the
level of the emission standard before sampling the stack gas.
The spiking should be done in the field; however, it may be done
in the laboratory.

5.1.2.4  Liquid and Solid Reference Material with Sample
Container (Bag or Canister).  Spike the containers at the
completion of each test run with an amount equal to the level of
the emission standard.

5.2  Comparison Against a Validated Test Method.  Bias and
precision are calculated using the procedures described in
Section 6.2.  This approach shall be used when a validated method
is available and an alternative method is being proposed.

5.2.1  Number of Samples and Sampling Runs.  Collect a total of
18 samples using paired trains or 16 samples using quadruplet
sampling trains.  For paired trains, conduct nine sampling runs.
For quadruplet trains, conduct four sampling runs.  In each run,
the validated test method shall be used to collect and analyze
half of the samples.

5.2.2  Performance Audit Exception.  Conduct the performance
audit as required in Section 4.0 for the validated test method.
Conducting a performance audit on the test method being evaluated
is recommended.

5.2.3  Probe Placement and Arrangement.  The probes should be
placed in the same horizontal plane.  For paired sample probes
the arrangement should be that the probe tip is 2.5 cm from the

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outside edge of the other with the pitot tube on the outside of
each probe.  For quad probes, the tips shall be in a 6.0 cm x 6.0
cm square area measured from the inside edge of the probe tip
with the pitot tube in the center.

5.3  Analyte Spiking.  Bias and precision are calculated using
the procedures described in Section 6.3.

5.3.1  Number of Samples and Sampling Runs.  Collect a total of
24 samples using quadruplet sampling trains.  Conduct six
sampling runs.

5.3.2  In each run, spike half of the sampling trains (two out of
the four) according to the applicable procedure in Sections
5.1.2.1 through 5.1.2.4.

6.0  CALCULATION OF BIAS AND PRECISION

Data resulting from the procedures specified in Section 5.0 shall
be treated as follows to determine bias correction factors,
relative standard deviations, and data acceptance.  Example
calculations are provided in Appendix E.

6.1  Isotopic Spiking.  Analyze the data for isotopic spiking
tests as outlined in Sections 6.1.1 through 6.1.6.

6.1.1  Calculate the numerical value of the bias using the
results from the analysis of the isotopically spiked field
samples and the calculated value of the isotopically labeled
spike:


                            B =Sm - CS                      Eq. 6-1
where:
     B  = bias at the spike level;
     Sm = mean of the measured values of the isotopically spiked
          samples;
     CS = calculated value of the isotopically labeled spike.

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6.1.2  Calculate the standard deviation of the Si values as
follows:
                         SD =
                                 (n-1)
where :

     S± - The measured value of the isotopically labeled analyte
          in the ith field sample;

     n  = The number of isotopically spiked samples, 12.

6.1.3  Calculate the standard deviation of the mean  (SDM) as
follows:
                                                           Eq. 6-3
                                  1//T
6.1.4  Test the bias for statistical significance by calculating
the t- statistic,
                                                           Eq. 6-4
                                SDM
and compare it with the critical value of the two-sided
t-distribution at the 95-percent confidence level and n-1 degrees
of freedom.  This critical value is 2.201 for the eleven degrees
of freedom when the procedure specified in Section 5.1.2 is
followed.  If the calculated t-value is greater than the critical
value the bias is statistically significant and the analyst
should precede to evaluate the correction factor.

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6.1.5  Calculation of a correction factor.  If the t-test does
not show that the bias is statistically significant, precede to
the precision evaluation.  If the method's bias is statistically
significant, calculate the correction factor, CF using the
following equation:
                            CF =
                                  1
                       Eq. 6-5
                                    CS
Multiply all analytical results by CF to obtain the final values.

6.1.6  Calculation of the relative standard deviation
(precision).  Calculate the relative standard deviation as
follows:
                          RSD =
                                5D
x 100
Eq. 6-6
where Sm is the measured mean of the isotopically labeled spiked
samples.

6.2  Comparison with Validated Method.  Analyze the data for
comparison with a validated method as outlined in sections 6.2.1
through 6.2.2.5.  Conduct the following tests to determine if a
proposed method produces results as good as or better than the
validated method.  Make all necessary bias corrections for the
validated method, as  appropriate.  If the proposed method fails
either test, the method results are unacceptable, and conclude
that the proposed method is not as good as the validated method.
For some highly cyclic emission sources additional precision
checks may be necessary.  The paired sampling train procedure
requires the standard deviation of the validated method to be
known.If the standard deviation of the validated method is not
available, the paired sampling train procedure shall not be used.

6.2.1  Paired sampling trains.

6.2.1.1  Acceptable precision for equivalency.  Determine the
acceptance of the proposed method's variance with respect to the
variability of the validated method results.  If a significant
difference is determined, the proposed method and the results are
rejected.  Proposed methods demonstrating F-values equal to or
less than the critical value have acceptable precision.

                                10

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6.2.1.2  Calculate the variance of the proposed method, Sp2,  and
the validated method, S 2,  using the following equation:
                            s2 =
Where:    SDV  =    The standard deviation provided with the
                    validated method;

          SD_  =    The standard deviation of the proposed method
                    calculated using Equation 6-9a.

6.2.1.3  The F-test.  Determine if the variance of the proposed
method is significantly different from that of the validated
method by calculating the F-value using the following equation:


                                 5 2
                             F = -2—                       Eq.  6-8
                                 c 2
                                 -V
     Compare the experimental F-value with the critical value of
F.  The critical value is 1.0 when the procedure specified in
Section 5.2.1 for paired trains is followed.

     If the calculated F is greater than the critical value, the
difference in precision is significant and the data and proposed
method are unacceptable.

6.2.1.4  Bias analysis.  Test the bias for statistical
significance by calculating the t-statistic and determine if the
mean of the differences between the proposed method and the
validated method is significant at the 80-percent confidence
level.  This procedure requires the standard deviation of the
validated method, SDV, to be known.   Employ the value furnished
with the method.  If the standard deviation of the validated
method is not available, the paired sampling train procedure
shall not be used.  Determine the mean of the differences, dm,
and the standard deviation, SDd,  of the paired differences,  di's,
using Equation 6-2 .  Calculate the standard deviation of the
proposed method, SD ,  as follows:
                         SD = / SDd - SDV                    Eq- 6-9a
                                11

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(If SDV >  SDd, let SD = SDd/1.414.)   Calculate the value of the t-
statistic using the following equation:
                                                            Eq.6-9
where n is the total number of paired samples.  For the procedure
in Section 5.2.1, n equals nine.

     Compare the calculated t-statistic with the corresponding
value from the table of the t-statistic.  When nine runs are
conducted, as specified in Section 5.2.1, the critical value of
the t-statistic is 1.397 for eight degrees of freedom.  If the
calculated t-value is greater than the critical value the bias is
statistically significant and the analyst should precede to
evaluate the correction factor.

6.2.1.5  Calculation of a correction factor.  If the statistical
test cited above does not show a significant bias with respect to
the reference method, assume that the proposed method is unbiased
and use all analytical results without correction.  If the
method's bias is statistically significant, calculate the
correction factor, CF, as follows:
                            CF-
                                    d,,                     Eq. 6-10
where Vm is the mean of the validated method's values.   Multiply
all analytical results by CF to obtain the final values.

     The method results, and the method, are unacceptable if the
correction factor is outside the range of 0.9 to 1.10.

6.2.2  Quadruplet sampling trains.

6.2.2.1  Acceptable precision for equivalency.  Determine the
acceptance of the proposed method's variance with respect to the
variability of the validated method results.  If a significant
difference is determined the proposed method and the results are
rejected.
                                12

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6.2.2.2  Calculate the variance of the proposed method, Sp2, and
the validated method, S 2,  using the following equation:
                            52 =    di                     Eq. 6-11
                                  2/7
where the d^s are the differences between the validated method
values and the proposed method values.

6.2.2.3  The F-test.  Determine if the variance of the proposed
method is significantly different from that of the validated
method by calculating the F-value using Equation 6-8.  Compare
the experimental F-value with the critical value of F.  The
critical value is 1.0 when the procedure specified in Section
5.2.2 for quadruplet trains is followed.

     If the calculated F is greater than the critical value, the
difference in precision is significant the results and the
proposed method are unacceptable.

6.2.2.4  Bias Analysis.  Test the bias for statistical
significance at the 80 percent confidence level by calculating
the t-statistic.  Determine the bias  (mean of the differences
between the proposed method and the validated method, d^)  and the
standard deviation, SDd,  of the differences.   Calculate the
standard deviation of the mean of the differences, SDd,  using
Equation 6-2 where:
                                                           Eq.6-12
and:      V1;L  =  The first measured value of the validated
                 method in the ith test sample;

          P-^  =  The first measured value of the proposed method
                 in the ith test sample.

     Calculate the t-statistic using Equation 6-9 where n is the
total number of test sample differences (d±).  For the procedure
in Section 5.2.2, n equals four.

     Compare the calculated t-statistic with the corresponding
value from the table of the t-statistic and determine if the mean
is significant at the 80-percent confidence level.  When four
runs are conducted, as specified in Section 5.2.2, the critical
value of the t-statistic is 1.638 for three degrees of freedom.

                                13

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If the calculated t-value is greater than the critical value the
bias is statistically significant and the analyst should precede
to evaluate the correction factor.

6.2.2.4  Correction factor calculation.  If the method's bias is
statistically significant, calculate the correction factor, CF,
using Equation 6-10.  Multiply all analytical results by CF to
obtain the final values.  The method results, and the method, are
unacceptable if the correction factor is outside the range of 0.9
to l.io.

6.3  Analyte Spiking.  Conduct sampling as described in Section
5.3, and analyze the data for analyte spike testing as outlined
in Sections 6.3.1 through 6.3.6.

6.3.1  Calculate the numerical value of the bias using the
results from the analysis of the spiked field samples, the
unspiked field samples, and the calculated value of the spike:


                          B = Sm - Mm  - CS                   Eq. 6-13
where

     B  = absolute bias at the spike level
     Sm = mean of the spiked samples
     MJJ, = mean of the unspiked samples
     CS = calculated value of the spiked level.

6.3.2  Determine the precision of the spiked samples.  Calculate
the difference, di;  between the pairs of the spiked proposed
method measurements for each sampling run.  Determine the
standard deviation (SDS)  of the spiked values using the following
equation:
                          SDS =       /                      ^' 6'14
                            5       2/7
where:    n = the number of samples.

6.3.3  Calculate the standard deviation of the mean using
Equation 6-3.

6.3.4  Test the bias for statistical significance by calculating
the t- statistic using Equation 6-4 and comparing it with the
critical value of the two- sided t-distribution at the 95-percent

                                14

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confidence level and n-1 degrees of freedom.  This critical value
is 2.201 for the eleven degrees of freedom.

6.3.5  Calculation of a correction factor.  If the t-test does
not show that the bias is statistically significant use all
analytical results without correction.  If the method's bias is
statistically significant, calculate the correction factor using
Equation 6-5.  Multiply all analytical results by CF to obtain
the final values.

6.3.6  Determination of precision of the unspiked samples.
Calculate the standard deviation of the unspiked values using
Equation 6-14 and the relative standard deviation of the proposed
unspiked method using Equation 6-6.

7.0  FIELD VALIDATION REPORT FORMAT

The field validation report shall include a discussion of the
regulatory objectives for the testing which describe the reasons
for the test, applicable emission limits, and a description of
the source.  In addition, validation results shall include:

7.1  Summary of the results and calculations shown in
Section 6.0.

7.2  Reference material certification and value(s).

7.3  Performance audit results or letter from the reviewing
authority stating the audit material is currently not available.

7.4  Laboratory demonstration of the quality of the spiking
system.

7.5  Discussion of laboratory evaluations.

7.6  Discussion of field sampling.

7.7  Discussion of sample preparations and analysis.

7.8  Storage times of samples (and extracts, if applicable).

7.9  Reasons for eliminating any results.


8.0  FOLLOWUP TESTING

The correction factor calculated in Section 6.0 shall be used to
adjust the sample concentrations in all followup tests conducted
at the same source. These tests shall consist of at least three
sample collections, and the average shall be used to determine
the emission rate.  The number of samples per sample collection


                                15

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period (run) of the method shall be as follows, depending on the
validated method precision level:

8.1  Validated relative standard deviation (RSD) < ±15 Percent.
One sample per run or three total samples.

8.2  Validated RSD < ±30 Percent.  Two samples per run or six
total samples.

8.3  Validated RSD < ±50 Percent.  Three samples per run or nine
total samples.

8.4  Equivalent method.   One sample per run or three total
samples.
                               16

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                           APPENDIX A

  PROCEDURE FOR OBTAINING A WAIVER FROM THE VALIDATION PROTOCOL


A.I  INTRODUCTION

The validation protocol may be waived or a less rigorous protocol
may be granted for site-specific applications.  The following are
three example situations for which a waiver may be considered.

A.1.1  "Similar" sources.  If the test method has been validated
previously at a "similar" source, the validation protocol may be
waived provided the requester can demonstrate to the satisfaction
of the Administrator that the emission characteristics are
"similar."  The methods's applicability to the "similar" source
may be demonstrated by conducting a ruggedness test as described
in Appendix B.

A.1.2  "Documented " methods.  In some cases, bias and precision
may have been documented through laboratory tests or protocols
different from the protocol in this document.  If the analyst can
demonstrate to the satisfaction of the Administrator that the
bias and precision apply to a particular application, the
Administrator may waive the entire validation protocol or parts
of the validation protocol.

A.1.3  "Conditional" test methods.  When the method has been    ,
demonstrated to be valid at several sources, the analyst may seek
a "conditional" method designation from the Administrator.
"Conditional" method status provides an automatic waiver from the
protocol provided the method is used within the stated
applicability.

A.2  APPLICATION FOR WAIVER

In general, the reguester shall provide a thorough description of
the test method, the intended application, and results of any
validation or other supporting documents.  Because of the many
potential situations in which the Administrator may grant a
waiver, it is neither possible nor desirable to prescribe the
exact criteria for a waiver.   At a minimum, the reguester is
responsible for providing the following.

A.2.1  A clearly written test method,  preferably in the format of
40 CFR 60, Appendix A Reference Methods.  The method must include
an applicability statement, concentration range, precision, bias
(accuracy), and time in which samples must be analyzed.

A.2.2.2  Summaries (see Section 7.0)  of previous validation tests
or other supporting documents.  If a different protocol from that

                                17

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described in this document was used, the requester shall provide
appropriate documents substantiating (to the satisfaction of the
Administrator) the bias and precision values.

A.2.3  Discussion of the applicability statement and arguments
for approval of the waiver.  This discussion should address as
applicable the following:  Applicable regulation, emission
standards, effluent characteristics, and process operations.

A. 3  REQUESTS FOR WAIVER

Each request shall be in writing and signed by the analyst.

A.3.1  "Conditional" Method.  Submit requests to Director, OAQPS,
Technical Support Division, U.S. Environmental Protection Agency,
Research Triangle Park, NC 27711.

A.3.2  "Similar" Source or "Documented" Methods.  Submit requests
to the appropriate reviewing authority.  The appropriate
reviewing authority may be identified by contacting the EPA
Regional Offices listed in Table A.I.
                               18

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                   Table  A.I  EPA Regional Offices
Region
      Address
  States included
  II
  III
  IV
  V
  VI
Air Management Division
John F. Kennedy Bldg.
Rm 2203

Boston, MA  02203
(617) 565-3245

Air and Waste Management

Division
26 Federal Plaza
Room 900
New York, NY  10278
(212) 264-2517

Air Management Division
841 Chestnut Bldg.
Philadelphia, PA   19107
(215) 597-3989

Air Management Division
345 Courtland St., N.E.
Atlanta, GA  30365
(404) 347-2904
Air and Radiation Division

230 S. Dearborn St.
Chicago, IL  60604
(312)  353-2081

Air, Pesticides and
Toxics Division
1445 Ross Ave.
Dallas, TX  75202
(214)  655-7220
  Maine,  Vermont,
  New Hampshire,
  Connecticut,

  Rhode Island,
  Massachusetts

  New York,  New
  Jersey,
  Puerto Rico, Virgin
  Islands
  Pennsylvania,  West
  Virginia,  Virginia,
  Delaware,  Maryland
  Alabama,  Georgia,
  Kentucky,  Tennessee,
•  Mississippi,
  Florida,
  North Carolina,
  South Carolina

  Minnesota,
  Wisconsin,
  Michigan,  Illinois,
  Indiana,  Ohio
  Arkansas,  Louisiana,
  Oklahoma,  Texas,  New
  Mexico
                                 19

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             Table A.I   EFA Regional  Offices  (continued)
Region
      Address
States included
  VII
  VIII
  IX
Air and Toxics Division
726 Minnesota Ave.
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(913) 551-7020

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999 18th Street
Suite 500
One Denver Place
Denver, CO  80202-2405
(303) 293-1750

Air and Toxics Division
1235 Mission Street
San Francisco, CA  94103
(415) 556-5568

Air and Toxics Division
1200 6th Ave.
Mail Stop 50121
Seattle, WA  98101
(206)442-4166
Iowa, Kansas,
Missouri, Nebraska
Montana, Colorado,
Utah, Wyoming,
North Dakota, South
Dakota
California, Nevada,
Guam, Hawaii
                                                Alaska, Washington,
                                                Oregon, Idaho
                                 20

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                              APPENDIX B
              RUGGEDNESS TESTING (LABORATORY EVALUATION)


B.1  INTRODUCTION

B.I.I  Ruggedness testing is a useful and cost-effective laboratory
study to determine the sensitivity of a method to certain parameters
such as sample collection rate, interferant concentration, collecting
medium temperature, or sample recovery temperature.  This appendix
discusses generally the principle of the ruggedness test.

B.I.2  In a ruggedness test, several variables are changed
simultaneously rather than one variable at a time.  This reduces the
number of experiments required to evaluate the effect of a variable.
For example, the effect of seven variables can be determined in eight
experiments rather than 128 (W.J. Youden, Statistical Manual of the
Association of Official Analytical  Chemists, Association of Official
Analytical Chemists, Washington, DC, 1975, pp. 33-36).

B.I.3  Data from ruggedness tests are helpful in extending the
applicability of a test method to different source concentrations or
source categories.

B.2  RUGGEDNESS TEST DESIGN

B.2.1  If an evaluation of seven factors of a method is desired, then
eight experiments can be conducted in the combinations shown in Table
B.I. The uppercase letters A,  B, C, D, E, F, and G represent the
nominal values for the seven different factors, and the lowercase
letters a, b, c, d, e, f, and g represent alternative values for the
same factors.  The results from these combinations are denoted by the
letters s, t, u, v, w, x, y, and z.

B.2.2  To evaluate the effect of A-a, the average of the results from
combinations 1, 2, 3, and 4 (level A) are compared to combinations 5,
6, 7, and 8 (level a).  That is, the average (s+t+u+v)/4is
compared to (w+x+y+z)/4.  As can be seen from Table B.I, each of
the two groups contains the other seven factors, which occur twice at
the uppercase level and twice at the lowercase level.  The effects of
these other factors cancel out, which leaves only the effect of
changing A to a.  In the same way,  the effects of the other factors
can be evaluated.

B.3  EXAMPLE RUGGEDNESS TEST DESIGN

B.3.1  The example given below was taken from Appendix B of the
Statistical Manual of the Association of Official Analytical Chemists
(Youden, 1975).
                                  21

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B.3.2.  A ruggedness test was performed on a distillation method for
determining total water in phosphoric acid.  Table B.2 lists the seven
variables and the levels assigned to the uppercase letters and the
lowercase letters.
                  Table B.I.  Ruggedness Test Matrix

                          Combination Number
Factor
Value
A or a
B or b
C or c
D or d
E or e
F or f
G or g
Result
1
A
B
C
D
E
F
G
s
2
A
B
C
D
e
f
g
t
3
A
b
C
d
E
f
g
u
4
A
b
c
d
e
F
G
V
5
a
B
C
d
e
F
g
w
6
a
B
c
d
E
f
G
X
7
a
b
C
D
e
f
G
y
8
a
b
c
D
E
F
g
2
                      Table B.2.  Test Conditions
Condition
Amount of H2O
Reaction time .
Distillation rate
Distillation time
n-Heptane used
Aniline used
Reagent ....
NO.
1
2
3
4
5
6
7
Letter
A,
B,
c,
D,
E,
F,
G,
a
b
c
d
e
f
g
Value for Value for lower-
capital letter case letter
ca. 2 Ml
0 min
2 drops/s
90 min
210 Ml
8 Ml
New
ca. 5 Ml
15 min
6 drops/s
45 min
190 Ml
12 Ml
Used
                                  22

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B.3.3  The analytical results are shown in Table B.3
          	Table B.3.  Analytical Results

           Determination number   Water %
1
2
3
4
5
6
7
8
18.80
20.58
19.90
18.03
19.50
19.16
19.88
19.85
B.3.4  To determine the effect of using new reagent as opposed to used
reagent, compare the average water percentage determined from the four
determinations with new reagent (G) with the average determined from
the four determinations with used reagent (g).   Table B.I shows that G
(new reagent) was used in determinations 1,  4,  6, and 7, which gave
the results 18.80, 18.03, 19.16, and 19.88.   The average of these four
results is 18.97.  The average of the other four results with used
heptane (tests 2,3,5, and 8) is 19.96.  The difference in the averages
is -0.99,  which amounts to a 5.2-percent difference between
determinations made with new reagent and used reagent.  In the same
manner, the effect of changing the other analytical conditions can be
determined by comparing the averages of measurements performed with
two different values for conditions.
                                  23

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                              APPENDIX C

              PROCEDURE FOR  INCLUDING SAMPLE STABILITY
                   IN BIAS AND PRECISION EVALUATIONS


C.1  INTRODUCTION

C.I.I  The test method being evaluated must include procedures for
sample storage and the time within which the collected samples shall
be analyzed. For example,  Tedlar bag samples may be stored at room
temperature and kept in the dark to minimize photochemical
degradation.  Sorbent samples may be stored in the refrigerator or
freezer or on dry ice.   Impinger samples may be stored in
refrigerators.  If sorbent samples are extracted with solvent, then
the solvent along with the extracted material may be stored in a
refrigerator. In addition,  the method may specify that the collected
samples or extracted materials must be analyzed within 24 hours from
the time of collection or extraction.

C.I.2  This appendix discusses the procedures for including the effect
of storage time in bias and precision evaluations.  The evaluation may
be deleted if the test method specifies a time for sample storage.

C.2  STABILITY TEST DESIGN

The following procedures should be conducted to identify the effect of
storage times on analyte samples.  Store the samples according to the
procedure specified in the test method.

C.2.1  For sample container  (bag or canister)  and impinger sampling
systems set up in regards to Section 5.1 and 5.3, analyze six of the
samples at the minimum storage time.  Then analyze the same six
samples at the maximum storage time.

C.2.2  For sorbent sampling systems set up in regards to Section 5.1
and 5.3 that require liquid extraction,  extract six of the samples at
the minimum storage time and extract six other samples at the maximum
storage time.  Analyze an aliquot of the first six extracts at both
the minimum and maximum storage times.   This will provide some freedom
to analyze extract storage impacts.

C.2.3  For sorbent sampling systems set up in reference to Section 5.1
and 5.3 that require thermal desorption,  analyze six samples at the
minimum storage time.   Analyze another set of six samples at the
maximum storage time.

C.2.4  For systems set up in accordance with Section 5.2, the number
of samples analyzed at the minimum and maximum storage times shall be
half those collected (8 or 9).
                                  24

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                              APPENDIX D

    PROCEDURE FOR DETERMINATION OP PRACTICAL LIMIT OF QUANTITATION

D.1  INTRODUCTION

D.I.I  The practical limit of quantitation (PLQ) is the lowest level
above which quantitative results may be obtained with an acceptable
degree of confidence. For this protocol, the PLQ is defined as 10
times the standard deviation, s0,  at the blank level.   This PLQ
corresponds to an uncertainty of ±30 percent at the 99-percent
confidence level.

D.I.2  The PLQ will be used to establish the lower limit of the test
method.

D.2  PROCEDURE I FOR ESTIMATING SQ

This procedure is acceptable if the estimated PLQ is no more than
twice the calculated PLQ. If the PLQ is greater than twice the
calculated PLQ use Procedure II.

D.2.1  Estimate the PLQ and prepare a test standard at this level.
The test standard could consist of a dilution of the reference
material described in Section 3.0.

D.2.2  Using the normal sampling and analytical procedures for the
method, sample and analyze this standard at least seven times in the
laboratory.

D.2.3  Calculate the standard deviation, s0/  of the measured values.

D.2.4  Calculate the PLQ as 10 times s0.

D.3  PROCEDURE II FOR ESTIMATING SQ

This procedure is to be used if the estimated PLQ is more than twice
the calculated PLQ.

D.3.1  Prepare two additional standards at concentration levels lower
than the standard used in Procedure I.

D.3.2  Sample and analyze each of these standards at least seven
times.

D.3.3  Calculate the standard deviation for each concentration level.
                                  25

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D.3.4  Plot the standard deviations of the three test standards as a
function of the standard concentrations.

D.3.5  Draw a best-fit straight line through the data points and
extrapolate to zero concentration. The standard deviation at zero
concentration is s0.

D.3.6  Calculate the PLQ as 10 times s0.
                                  26

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                              APPENDIX E
                         EXAMPLE CALCULATIONS
E.I  INTRODUCTION
     The following section provides an illustration of the principles
outlined in Sections 5.0 and 6.0.

E.2  Bias and Precision Calculation for Isotopic and Analyte Spiking

E.2.1  Section 5.1 identifies an isotopic spiking approach for bias
and precision determinations.  Section 6.1 provides the calculation
procedures for isotopic spiking.  Section 5.3 identifies an analyte
spiking approach for bias and precision.  Sections 6.3 provides the
calculation procedures for analyte spiking.  Section 5.2 identifies an
approach for bias and precision comparing a proposed method to a
validated method.  Section 6.2 provides the calculation procedures for
the method comparison approach.

E.2. 2  The following example deals with an isotopic spiked
demonstration .

E.2. 2.1  A sampling train was spiked with 100 /^g of an isotope of
chromium while it was sampling combustion gas.  The isotope was
recovered from the trains and quantified.  Table E.I depicts the data
for the following example.


                      Table  E.I Cr(VI)  Recoveries
                                                                  2
                   Recovered      Difference                (Si-sm)
                   Cr(VI),        from 100 \iq
                     (si) / pg     standard                    /*g
                   110.2           10.2                      292.07
                   85.9           -14.1                       51.98
                   92.4           - 7.6                        0.50
                   93.9           - 6.1                        0.62
                   103.5            3.5                      107.95
                   117.3           17.3                      585.16
                   82.6           -17.4                      110.46
                   102.6            2.6                       90.06
                   79.5           -20.5                      185.28
                   89.7           -10.3                       11.63
                   73.1           -26.9                      400.40
                   86.7           -13.3                       41.09
                                  27

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E.2.2.2  Use Equation  6-1 to  calculate the numerical value of the
bias:
B =
                       (51+52+53+54+55+56 ..... 512)
                                   12
                         B = 93.11 - 100 = - 6.89
     CS should remain constant;  it  is the amount of spiked isotope
into each of the 12 samples.

E.2.2.3  Use Equation 6-2  to  calculate the standard deviation  (SD) of
the spiked sample values.
                     50 =
                                    n - 1
                         SD =
           1877.15
              n
= 13.06
E.2.2.4     Using the standard  deviation value calculate the standard
deviation of the mean (SDM)  using Equation 6-3.
                           SDM = 13-°6 =3.77
                                   28

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E.2.2.5  Test the bias for statistical significance using  Eqution  6-4,


                                    \B\
                                t =
                                    SDM
                             t-lJi.1.88
                                3.66
     The comparison with the critical value of the two-sided  t-
distribution at the 95-percent confidence level and n-1 degrees  of
freedom, indicates that 1.88 is less than the critical value  of  2.201,
The bias is not statistically significant.

E.2.2.6  To assess the acceptability of the precision, calculate the
relative standard deviation using Equation 6-6.


                             RSD = — x 100
                        RSD = 13'06 x 100 = 14.03 %
                             93.11
     The precision is 14.03 percent, which is less than the  50 percent
criteria specified in Section 2.2 of the protocol.

E.2.3  Bias and Precision Calculations for an Analyte Spiked
Demonstration

E.2.3.1    Half of the sampling trains required by Section 5.3 were
spiked with 100 /ig of the analyte of concern while it was sampling
combustion gas.  The analyte was recovered from the trains and
quantified.  Table E.2 depicts the data for the following example.
                                  29

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Table E.2 Analyte Recoveries
Sample
Run
1



2



3



4



5



6



Approximate
Stack
Value
Mg
22
22
22
22
30
30
30
30
27
27
27
27
12
12
12
12
28
28
28
28
6
6
6
6
Spike
Value
Mg
100
100


100
100


100
100


100
100


100
100


100
100


Measured
Value
Mg
119.7
112.9
24.9
30.5
137.1
136.4
32.0
21.3
118.0
123.0
35.0
32.0
109.3
104.0
5.4
18.0
119.8
124.6
36.0
33.7
109.8
109.2
11.6
14.7
Difference
Measured
Value
Mg/ di
6.8

-5.6

0.7

10.7

-5.0

-5.0

5.3

-12.6

-4.8

2.3

0.6

-3.1


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E.2.3.2  Use Equation  6-12 to  calculate the numerical value of the
bias:

     The mean of the spiked values  (Sm)      = 118.65 /KJ
     The mean of the unspiked  samples (MjJ   =  24.59 /Ltg
     The calculated value of the  spike (CS)  = 100 jug
                     B = 118.65 - 24.59 - 100  = - 5.94 fig


     CS should remain  constant;  it  is  the amount of spiked analyte
into each of the 12 sampling  trains.

E.2.3.3  Use Equation  6-13  to calculate the standard deviation  (SD) of
the spiked sample values.
                                     — = 3.204
                                   24
E.2.3.4     Using the standard  deviation calculated above calculate
the standard deviation of  the mean (SDM)  for the spiked samples using
Equation 6-3.


                            SDH = 3>2°4 = 0.926
                                   31

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E.2.3.5  Test the bias for statistical significance using
Equation 6-4 .
                                    SDM
                                     = 6.41
     The comparison with the critical value of the two-sided t-
distribution at the 95-percent confidence level and n-1 degrees of
freedom, indicates that 6.41 is greater than the critical value of
2.201.  The bias is statistically significant.

E.2.3.6  If the bias is statistically significant, a correction factor
is calculated using Equation 6-5.
                             CF -
                                      cs
                          CF = 	-	 = 1.06
                                  -5 94
                              1 +  J'^
                                   100
     The correction factor is between Section 2.1 criteria of  .70 and
1.3, and is therefore acceptable.  All of the analyte recovery results
should be multiplied by this factor for the final recovery results.
                                  32

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E.2.3.7  To assess the acceptability of the precision  calculate the
relative standard deviation using Equation 6-6.
RSD =

                                      x 100
                        RSD = 3'2°4  x 100 = 2.70 %
                             118.65
     The precision is 2.70 percent, which is less than  the  50  percent
criteria specified in Section 2.2 of the protocol.

E.2.3.8  From the differences between the pairs of the  unspiked method
measurements, determine the standard deviation using  Equation  6-13.
                         SDU =
                                    24
     Complete the evaluation by calculating the relative  standard
deviation of the mean of the unspiked samples using Equation  6-6.
                        RSD = -5^1 x 100 = 2.64 %
                              24.95
     The precision is 2.64 percent, which is less than the  50  percent
criteria specified in Section 2.2 of the protocol.
                                  33

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E.2.4  Bias and Precision Calculations for Method Comparisons

E.2.4.1  A source is proposing to reduce the cost of testing through
the use of a new method developed by the company.  Table E.3 provides
the results of a paired train sampling validation demonstration.

                  Table E.3 Paired Sample Recoveries
Test
1
2
3
4
5
6
7
8
9
vm =
Validated Proposed
Value Value
14.
14.
14.
14.
14.
14.
14.
15.
14.
14.6 /ig
7
5
7
6
5
8
3
0
4

14
15
14
14
15
15
14
14
14
Pm = 14
.0
.0
.6
.9
.0
.4
.9
.4
.5
.7 jltg
Difference d^2
-0.
0.
-0.
0.
0.
0;
0.
-0.
0.
<--
7
5
1
3
5
6
6
6
1
0.13
0.
0.
0.
0.
0.
0.
0.
0.
0.

49
25
01
09
25
36
36
36
01

E.2.4.1.1  Determine the acceptance of the proposed method's variance
with respect to the variability of the validated method results.   The
procedure provides a method for testing whether the scatter of two
sets of data is such as would be expected from two samples from the
same population.  The variance provided with the validated method is
0.046.
                                  34

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E.2.4.1.2  Calculate the variance of the proposed method, Sp2,
validated method, S 2,  using Equation 6-7.
                                                               and the
                              Sv =  0.046

                             Sp2 = 0.1717
E. 2. 4. 1.3  Test to compare if the experimental variance of the
proposed method is significantly different from that of the validated
method by calculating the F-value using Equation 6-8.
                                0.046
The calculated value of 3.73 is greater than the critical value of
1.0.  The proposed method is considered to be less precise than the
validated method.  The data is not as precise as would be obtained by
the validated method and therefore, the method and data should be
rejected.  A bias analysis should be made even though the precision  is
not.acceptable.

E.2.4.1.4  Test the bias for statistical significance.  This
illustration is provided to evaluate, in this example, whether the
bias is significant and the resulting correction factor would also
cause rejection of the data and the method.  The results do not
nullify the results of the F-test.  The d,,, equals 0.13 /xg.  The
standard deviation of the d^'s is, using Equation 6-2:
                                       = 0.502
                                  35

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The SD of the proposed method using Equation 6-9a is:
                            SDp =  SDd - SDV
                              SDp =0.1717
     Calculate the t-statistic using Equation 6-9.  The calculated
t-value is:
                           t-  °-'3   -Z.2S
                                0.1717
E.2.4.1.5  Compare the calculated t-statistic to the critical t-value
at the 80-percent confidence level and n-1 degrees of freedom.  The
critical value is 1.397 for eight degrees of freedom.  The calculated
value, 2.28, is greater than the criticle value.  A correction  factor
determination is necessary.  The data and method rejection in this
example is principly due to variability.  The cause of the
unacceptable variability should be ascertained by the analyst.

E.2.4.2  Table E.4, Quad Sample Recoveries, provides the results of  a
quadruplet test conducted in a proposed method demonstration test
following the procedures in Section 5.2.2.
                                  36

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                   Table  E.4   Quad  sample  Recoveries
Test   Method  Value    (V1+V2)/2   (P1+P2)/2
                 ppm
A



V
V
P
P
365
372
366
355
368 7.5 83.26

360.5

  B
V
V
P
P

V
V
P
P

V
V
P
P
381
377
370
380

349
380
330
320

362
365
338
346
379                 4.0        31.64

          375


364.5             -39.5     1434.51

          325


363.5               21.5      534.77

          342


                 d= - 1.625
E.2.4.2.1  Determine the acceptance of the proposed method's variance
with respect to the variability of the validated method results.  If a
significant difference is determined the proposed method and the
results are rejected.  Calculate the variance of the validated method,
Sv2,  and the proposed method,  S 2, using  Equation  6-7  and the results
in Table E.5.
                                  37

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                      Table E.5  Method Mean Data
Test
A
B
C
D
ei
365
372
381
377
349
380
362
365
(e^Jv2
49
16
169
81
361
144
36
9
ei
366
355
370
380
330
320
338
346
<•!-.> p2
225
16
841
361
441
961
169
25
S,,2  = 108.75
                                                   2 _
                                                     = 378.87
E.2.4.2.2  Determine if the variance of the proposed method  is
significantly different from that of the validated method  by
calculating the F-value using Equation 6-8.  Compare the calculated  F-
value with the critical value.  The critical value is  1.0  when  the
procedure specified in 5.2.2 for quadruplet trains is  followed.
                            F =
                379.87
                108.75
= 3.49
  The calculated F is not less than the critical value, this indicates
that the precision of the proposed method is not as good  as  the
validated method.
                                  38

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E.2.4.2.3  Test the bias for statistical significance by calculating
the t-statistic.  Determine the mean, d^, and the standard deviation,
SH,  of the dj/s.   Calculate the standard deviation of the mean of the
differences, SDd/  using Equation 6-7.
                                2084.18
                                        = 26.35
        Calculate the t-statistic using  Equation  6-9
                           t-  1'625  -0.123
                                26.35
  For the procedure in Section 5.2.2, n equals four.

  Compare the calculated t-statistic with the critical t-value from
the table of the t-statistic and determine if the mean is significant
at the 80-percent confidence level.  When four runs are conducted,  as
specified in Section 5.2.2, the critical value of the t-statistic  is
1.638 for three degrees of freedom.  The calculated t-value  is less
than the critical value and therefore the results should not be
corrected for bias.
                                  39

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                                   TECHNICAL REPORT DATA
                            (Plane read Instructions on the reverse before completing}
1. REPORT NO.
    450/4-90-015
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE

   Protocol  For The Field Validation of Emission

   Concentrations From Stationary Sources
   fc •         L_>      "
                                                            5. REPORT DATE

                                                               April  1991
                                                            6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
                                                            •S. PERFORMING ORGANIZATION REPORT NO.
-9. PERFORMING ORGANIZATION NAME AND ADDRESS
                                                             10. PROGRAM ELEMENT NO.
                                                            1 1. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
    U.S.  Environmental Protection  Agency
    Research  Triangle Park,  NC  27711
                                                             13.rf Xf.S. -O-
                                                                               PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
             The purpose  of the validation protocol  is to determine bias and precision
       of the test method  at the level  of concentration  in  the gas stream.  Procedures
       involve  (a)  introducing known  concentrations of an  analyte or  comparing  the
       method against a validated test method to determine  bias and (b) using multiple
       sampling trains to determine precision.

             The protocol  lists a number of  important requirements  for the validation
       of the test method.  They  include;  use of EPA audit material;  documenting  and
       reporting results;  procedures  for determining bias and precision  by  means of
       isotopic and analyte spiking of multiple train samples or comparison to validated
       methods; and,  procedures for calculating precision,  bias and correction factors
       The  protocol  also  defines the acceptance criteria in terms of  percent bias  and
       precision and  how  the  determined  precision  dictates   future testing  with  the
       validated method.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lOENTIFlEflS/OPEN ENDED TERMS
                                                                           c. COSATI Field/Group
       Emission Testing
       Early Reduction
      -Tftle III
                                                 Emission Testing
 18. DISTRIBUTION STATEMENT


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