EPA/600/R-94/134
                      METHOD 100.2
       DETERMINATION OF ASBESTOS STRUCTURES OVER
            10 im  IN  LENGTH  IN  DRINKING  WATER
           Kim A.  Brackett,  Ph.D.  (IT  Corp.)

Patrick 0. Clark (Risk Reduction Engineering Laboratory)
          U.S. Environmental  Protection Agency

          James R.  Millette,  Ph.D. (MVA, Inc.)
                       June  1994
      ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
           OFFICE OF RESEARCH AND DEVELOPMENT
          U.S.  ENVIRONMENTAL PROTECTION AGENCY
                 CINCINNATI, OHIO 45268

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                                METHOD  100.2

                  DETERMINATION OF ASBESTOS STRUCTURES OVER
                       10 im  IN  LENGTH IN DRINKING WATER
1.0   SCOPE AND APPLICATION

      1.1   This test method is recommended for the determination of the
            presence and quantitation of asbestos structures in drinking water
            samples.  The method allows for the quantitation of structures
            greater than 10 0m in length.
                                O
      1.2   This test method describes the equipment and procedures necessary
            for the sampling and analysis of drinking water by transmission
            electron microscopy (TEM).

      1.3   The identification of asbestos by TEM is based on (a) morphology,
            (b) selected area electron diffraction (SAED) and (c) energy
            dispersive x-ray analysis (EDXA).

      1.4   Applicable analytes and Chemical Abstract Service (CAS) Numbers:

                        Asbestos                            CAS Number
                     Chrysotile
                     Crocidolite
                     Amosite (Grunerite)
                     Anthophyllite
                     Tremolite
                     Actinolite

      1.5   Data Quality Objectives
      1.6
      1.7
                                                12001-29-5
                                                12001-28-4
                                                12001-73-5
                                                77536-67-5
                                                77536-68-6
                                                77536-66-4
Method
TEM
Accuracy3
95%
Precision3
95%
Completeness
100%
             a.
      Confidence coefficient of a confidence interval for a
      Poisson variable within which count ranges are expected to
      fall.

Analytical Sensitivity.  A sensitivity of 200,000 fibers per liter
(0.2 MFL) is required unless filter loading satisfies the stopping
rules in Sect. 11.31.  See TABLE 1.

Only asbestos structures meeting the definitions set forth in the
Chatfield protocol are counted (1).

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           TABLE 1.  Limitation of Analytical Sensitivity by Volume
                         of Water Sample Filtered (1)
Volume of Sample Filtered (mL)
25 mm Diam. Filterb
0.1
0.5
1.0
2.0
5.0
10
15
25
50
100
47 mm Diam. Filter0
0.6
2.8
5.7
11
28
57
85
142 •
285
570
Analytical
Sensitivity (f/L)a
3.0 x 107
6.0 x 106
3.0 x 106
1.6 x 106
6.0 x 10s
3.0 x 105
2.0 x 105 "
1.2 x 103
6.0 x 104
3.0 x 104
* Concentration corresponding to 1 structure detected in
  10 grid openings of approximately 0.008 mm2.

b Assuming active filter area of 1.99 cm2.

c Assuming active filter area of 11.34 cm2.

2.0   SUMMARY OF METHOD

      2.1   Water is collected in a polyethylene or glass container and
            shipped to the laboratory.  Known aliquots of the sample are
            filtered through a 0.1 to 0.22 urn pore mixed cellulose ester
            (MCE).  A carbon extraction replica is prepared from a portion of
            the filter and is examined in the TEM at a magnification of 10,000
            to 20,OOOX.  Asbestos structures are identified by morphology,
            selected area electron diffraction (SAED) and energy dispersive
            x-ray analysis (EDXA).  Structures are classified according to the
            counting rules specified in the Chatfield polycarbonate filter
            protocol (1).  Only asbestos structures greater than 10 /zm in
            length are counted.  Some states may require identification and
            measurement of all asbestos fibers, regardless of size.  In this
            case the use of a 0.1 [im pore-size polycarbonate or MCE filter
            membrane is necessary to prevent loss of small fibers during
            filtration.

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3.0   DEFINITIONS

      3.1   ANALYTICAL SENSITIVITY — The waterborne concentration represented
            by the finding of one asbestos structure in the total area of
            filter examined.  This value will depend on the fraction of the
            sample filtered and the dilution factor (if applicable).

      3.2   ASBESTIFORM — A specific type of fibrous habit which has greater.
            flexibility and higher tensile strength than other habits of the
            same mineral.

      3.3   ASBESTOS — Generic term for a group of hydrated mineral
            silicates.

      3.4   ASPECT RATIO -- The ratio of the length of a fibrous particulate
            to its apparent width (equivalent diameter).

      3.5   BUNDLE — A structure composed of three or more fibers in a
            parallel arrangement with each fiber lying less than one diameter
            apart.

      3.6   CLUSTER ~ A structure with fibers in a random arrangement such
            that all fibers are intermixed and no single fiber is isolated
            from the group.

      3.7   EDXA — Energy dispersive X-ray analysis.

      3.8   FIBER -- For the purposes of this method,  a structure having a
            minimum length of 10 pm and an aspect ratio (length to width)  of
            3:1 or greater with substantially parallel  sides.

      3.9   FIBRIL — The smallest crystalline fiber that can  be separated
            from a fiber bundle which cannot be subdivided without losing  its
            fibrous properties.

      3.10  GRID — A 3 mm diameter 200-mesh copper lattice used to hold the
            carbon extraction replica for observation  in the TEM.

      3.11  INTERSECTION -- Nonparallel touching or crossing of fibers,  with
            the projection having an aspect ratio >3:1.

      3.12  MATRIX — Fiber or fibers with one free end and the other end
            embedded in or hidden by a particulate.

      3.13  MFL -- Million fibers per liter.

      3.14  SAED or ED -- Selected area electron diffraction.

      3.15  STRUCTURE — A microscopic bundle,  cluster,  fiber  or matrix  which
            may contain asbestos.

      3.16  TEM — Transmission electron microscope.

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4.0   INTERFERENCES

      The minerals listed below can exhibit morphological, chemical or crystal
      structure similarities to the asbestos minerals.  The laboratory QA/QC
      manual should describe routine techniques to differentiate them from
      asbestos.  In general, these techniques should be the same as those
      required for accreditation by the National Institute of Standards and
      Technology/National Voluntary Laboratory Accreditation Program
      (NIST/NVLAP) for airborne asbestos.

      4.1   Antigorite

      4.2   Attapulgite  (Palygorskite)

      4.3   Halloysite

      4.4   Horneblende

      4.5   Pyroxenes

      4.6   Sepiolite

      4.7   Vermiculite  scrolls

5.0   SAFETY

      This  test method may  involve hazardous materials, operations and
      equipment, and does not  purport to  address all of the safety problems,
      if any,  associated with  its use.  It  is the responsibility of the user
      of this  method to  establish appropriate safety and  health practices and
      determine the applicability of regulatory limitations prior to use.
      Sample filtration  should take place in a clean HEPA filtered positive
      pressure hood to avoid possible contamination of the preparation.
      Collapsing of the  filter should be  performed in an  exhaust hood.

6.0   EQUIPMENT AND SUPPLIES

      6.1   Transmission Electron Microscope capable of performing electron
            diffraction, with  a fluorescent screen inscribed with a calibrated
            measuring scale.   The TEM must  have EDXA and  be able to produce a
            spot size, at crossover, less than 250 nm in  diameter.

      6.2   Energy dispersive  X-ray analyzer

      6.3   High vacuum  carbon evaporator with rotating stage

      6.4   Positive pressure  HEPA filtered hood

      6.5   Fume hood

      6.6   Table-top low power ultrasonic  bath

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      6.7   Ozone generator capable of generating at least 400g of ozone per
            day at a concentration of 1% by weight when supplied with dry
            oxygen.
      6.8   Quartz pipets
      6.9   Submersible UV lamp (254 fun wavelength)
      6.10  Waterproof marker
      6.11  Forceps (tweezers)
      6.12  Graduated pipettes (1, 5, 10 ml sizes), disposable glass
      6.13  25 or 47 mm diameter filter funnel assembly (either glass or
            disposable plastic)
      6.14  1000 ml side arm vacuum filtration flask
      6.15  25 or 47 mm diameter mixed cellulose ester (MCE) membrane filters
            (<0.22 fan and 5 /an pore size)
      6.16  Disposable petri dishes (or suitable equivalent) for storage of
            filtration membranes
      6.17  Glass microscope slides
      6.is  Curved scalpel blades
      6.19  Low temperature oven or cabinet-type desiccator
      6.20  Low temperature plasma asher
      6.21  Jaffe washer
      6.22  200 mesh copper TEM finder grids
      6.23  Carbon rods
      6.24  1000 mL glass or polyethylene sample bottles with screw-on caps
7.0   REAGENTS AND STANDARDS
      7.1   Reagent grade chemicals shall  be used in all  tests.   Unless
            otherwise indicated,  it is intended that all  reagents shall
            conform to the specifications of the Committee on Analytical
            Reagents of the American Chemical  Society (2).
      7.2   Deionized particle-free water
      7.3   Acetone
      7.4   Dimethylformamide (DMF)

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      7.5   Glacial acetic acid

      7.6   Chloroform

      7.7   1-methyl-2-pyrrolidone also called l-methyl-2-pyrolidinone or
            n-methyl-2-pyrrolidone
            (CAS 872-50-4)

      7.8   NIST traceable asbestos standards

      7.9   Laboratory standards for the interference minerals listed in Sect.
            4.0.

8.0   SAMPLE COLLECTION. PRESERVATION AND STORAGE

      8.1   The sample container will be an unused, pre-cleaned, screw-capped
            bottle of glass or low density (conventional) polyethylene of at
            least 1 liter capacity.  It is recommended that the use of
            polypropylene bottles be avoided since problems of particulate
            being released into water samples have been observed.  Before use,
            the bottles should be rinsed twice by filling approximately one-
            third full with fiber-free water and shaking vigorously for 30
            seconds.  After discarding the rinse water, the bottles should
            then be filled with fiber-free water and treated in an ultrasonic
            bath for 15 minutes, followed by several rinses with fiber-free
            water.

      8.2   Blank determinations should be made prior to sample collection.
            When using polyethylene bottles, one bottle from each batch, or a
            minimum of one from each 24, should be tested for background
            level.  When using glass bottles, four bottles from each 24 should
            be tested.  Additional blanks may be desirable when sampling
            waters suspected of containing very low levels of asbestos, or
            when additional confidence in the bottle blanks are desired.  An
            acceptable bottle blank level is defined as <0.01 MFL >10 jam.

      8.3   SAMPLE COLLECTION — It is beyond the scope of this procedure to
            furnish detailed instructions for field sampling; the general
            principles of obtaining water samples apply.  If tests are being
            made of drinking water in a bulk storage supply, there may be a
            vertical distribution of particle sizes.  If a representative
            sample of the water supply is required, a carefully designated set
            of samples should be taken representing the vertical as well as
            the horizontal distribution and then composited for analysis.
            Compositing must be done in the laboratory, and not in the field.

            When sampling from a distribution system a commonly used faucet
            should be chosen.  Remove all hoses or fittings from the faucet
            and allow the water to run to waste for a sufficiently long period
            to ensure that the sample collected is representative of the fresh
            water supply.  For most buildings this may be indicated by a
            change in temperature of the water at the faucet.  Faucets or
            valves should not be adjusted until all samples have been

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            collected.   Samples  should  not  be taken  from  hydrants  or  other
            faucets  at  the deadend of a distribution  system.

            As an  additional  precaution against contamination, each bottle may
            be rinsed several times  in  the  source water being tested  before
            the final sample  is  taken.  This procedure is not suitable when
            taking depth samples from a storage tank, however.

      8.4   QUANTITY OF SAMPLE — Two samples of approximately 800 ml should
            be collected from each site.  No preservatives should  be  added
            during sampling.  This sample volume will leave an air space to
            allow  efficient redispersal of  settled material, by shaking,
            before analysis.  Each bottle should be labeled with the  date,
            time,  place, field sample number and sampler's name using a
            waterproof  marker.

      8.5   SAMPLE SHIPMENT — Samples  must be transported to the analytical
            laboratory  as soon as possible  after collection.  The samples
            should be shipped in a sealed container,  separate from any bulk or
            air samples.  Samples should be shipped in a cooler with  ice to
            retard bacterial  or algal growth in the samples.  Do not  freeze
            the samples.  Samples should be received  and filtered in  the
            laboratory  within 48 hours  of collection.  Samples must be
            accompanied  by a  properly executed chain  of custody document.

      8.6   SAMPLE PRESERVATION — Samples should be  filtered immediately
            after  arrival at the laboratory or stored in a refrigerator until
            filtered,

      8.7   SAMPLE COMPOSITING — Up to five samples may be composited after
            receipt  in  the laboratory.  The composite sample must be  prepared
            from the individual  samples within 48 hours of collection, or, if
            the samples  have been stored for more than 48 hours,  they must be
            individually treated with Og-UV  in  the  original  containers.
            Samples  should be sonicated in the original  container and equal
            amounts extracted to make up the composite.   It may also be
            prudent to filter an aliquot of each sample for analysis  in case
            the composite sample exceeds l/5th the MCL (1.4 MFL >10 pi long).
            If, later,  the original  samples  are to be filtered separately,
            they must be treated again with  03-UV  in  the original  containers
            and resonicated..

9.0   QUALITY CONTROL

      9.1   The quality control  checks required for this  method generally
            follow those specified in the Federal  Register for AHERA analysis
            of air samples (3) and the NISTIR document relating to airborne
            asbestos analysis (4).   These requirements are summarized in TABLE
            2.  The criterion for acceptability of bottle  and  process blanks
            is <0.01 MFL >10 urn  in length.

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10.0  CALIBRATION AND STANDARDIZATION

      10.1  MAGNIFICATION CALIBRATION — Magnification calibration must be
            done at the fluorescent screen and must be performed at the
            magnification used for fiber counting, generally 10,000 and
            20,OOOX.  Calibration is performed using a grating replica (e.g.,
            one containing at least 2,160 lines/mm).  Define a field of view
            on the fluorescent screen either by markings or physical
            boundaries.  The field of view must be measurable or previously
            inscribed with a scale or concentric circles (all scales should be
            metric).  If the instrument contains a tilting stage (goniometer),
            the z-axis must be adjusted to ensure that the stage is in the
            eucentric position prior to performing any measurements.  A
            logbook must be maintained with the dates of the calibration
            recorded.  Frequency of calibration will depend on the service
            history of the instrument.  It is recommended that calibrations be
            performed monthly to establish the stability of the magnification.
            Also, the calibration should be checked following any maintenance
            of the microscope involving adjustment of the lens or high voltage
            power supplies or the disassembly of the electron optical  column
            apart from filament exchange.

      10.2  CAMERA CONSTANT ~ The camera length of the TEM in the electron
            diffraction (ED) mode must be calibrated before ED patterns of
            unknown samples are observed.  This can be achieved by using a
            carbon-coated grid on which a thin film of gold has been sputtered
            or evaporated.  A thin film of gold can also be evaporated on the
            specimen grids to obtain ED patterns superimposed on the ring
          •  pattern from the polycrystalline gold film*  In practice,  it is
            desirable to optimize the thickness of the gold film so that only
            one or two sharp rings are obtained on the superimposed ED
            pattern.  Thicker gold films will  tend to mask weaker diffraction
            spots from the fibrous particulates.  Since the unknown d-spacings
            of most interest in asbestos analysis are those which lie  closest
            to the transmitted beam,  multiple gold rings from thicker  films
            are unnecessary.  Alternatively,  a gold standard specimen  can be
            used to obtain an average camera constant on a regular basis for
            each TEM in the laboratory.   The stage must be at the eucentric
            position for this calibration.   The camera constant calculated for
            that particular instrument can  then be used for ED patterns of
            unknowns taken during the corresponding period.

      10.3  SPOT SIZE — The diameter of the smallest beam spot at crossover
            must be measured regularly.   Photograph the beam at crossover at
            20,000 to 25,OOOX at a short exposure setting (to avoid spreading
            of the exposed spot on the film).   Measure the diameter on the
            negative and divide by the magnification used.   The resulting
            figure must be less than  250 nm.
                                      8

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             TABLE 2.  SUMMARY OF LABORATORY DATA QUALITY OBJECTIVES
Unit Operation

Sample Receiving
Sample Prep





Sample Analysis




Performance
or 10%
QC Check
Review chain-of-
custody and
sampling data
Supplies and
reagents
Grid opening
size
Clean area
monitoring
Lab blank
Etcher blank
23 grids/sample
System check
Alignment check
Mag calibration
Camera constant
EDS Cu Ka line
Lab blank
Frequency
Expectation
Each sample
On receipt
20/20 grids/
lot of 1000
or I/sample
After service
I/series or
10%
1/20 samples
Each sample
Each day
Each day
Monthly or
after service
Weekly
Each day
1/prep series
Conformanee
95% complete
Meet specs.
100%
Meet specs.
Meet specs.
75%
>70% intact
openings
Each day
Each day
95%
95%
95%
Meet specs.
                  Replicate  count

                  Duplicate  count
                  Analysis of
                  standards
                  Analysis of SRM

                 Data entry
                 Record and verify
                 SAED patterns
>1/100 samples  l.SXPoisson
                  std. dev.
>1/100 samples  2XPoisson
                std. dev.
Training and
comparison with
  , unknowns
1 per analyst
   per year
Each sample
1/5 samples
  100%
Calculations
                 Hand calculation of  1/100 samples
                 automated data
                 reductions or 2nd
                 analyst check of
                 manual calcs.
l.SXPoisson
  std. dev.
   95%
   80%
accuracy
   85%

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      10.4  EDXA SYSTEM — The resolution and calibration of the EDXA must be
            checked at least monthly and after service.  Initially, the system
            is calibrated by using two reference elements to calibrate the
            energy scale of the instrument according to the manufacturer's
            instructions.  This can easily be done using a carbon-coated
            copper grid upon which a thin film of aluminum has been evap-
            orated.  The Al and Cu Ka peaks should be centered at 1.48 KeV and
            8.04 KeV respectively.  The deviation from these energies should
            be no more than ±10eV.  The ability of the system to resolve the
            sodium Ka line from the copper L line should be confirmed by
            obtaining a spectrum from a standard crocidolite sample on a
            copper grid.  Additional resolution checks are usually found in
            the manufacturer's instruction manual.  The k-factors relative to
            silicon should be calculated for Na, Mg, Al, Si, Ca and Fe using
            NIST SRM 2063.  The k-factor for Mg to Fe must be calculated;  a
            value of 1.5 or less is required.  EDXA spectra should be obtained
            from NIST traceable standards and kept on file in the laboratory
            for comparison with published, standard spectra and unknown
            spectra.
11.0  PROCEDURE
      11.1  If the water samples are suspected to contain high levels of
            organic contaminants, or have been stored for periods longer than
            48 hours, oxidation of the organics by the ozone-ultraviolet
            technique (1) may be necessary.  Details for this procedure appear
            in Appendix 1.

      11.2  Wet-wipe the exterior of the sample bottle before entering the
            clean area used for specimen preparation.  The sample prep area
            should be separate from the areas used for bulk sample or air
            sample preparation to avoid possible cross-contamination.  Sample
            filtration should take place in a positive pressure HEPA filtered
            hood.

      11.3  The use of vertical sided 25 or 47 mm diameter glass filtration
            systems with a sintered glass frit support is recommended to avoid
            loss of fibers by settling on tapered sides of the reservoir.
            Disposable plastic funnel assemblies may be substituted for glass
            apparatus.  A few precautions must be taken with reusable
            glassware to ensure optimum sample preparations.  All  glassware
            should be carefully washed in a detergent solution with a brush
            before each use and rinsed several times in fiber-free water.   Any
            glassware that has contained asbestos in solution should be placed
            in soapy water and scrubbed before it has had the opportunity to
            dry.  Sonication in a detergent solution is also recommended.
            Frequent blanks should be run with fiber-free water to check
            cleanliness of the apparatus.

      11.4  Unwrap an unused disposable plastic filter funnel  unit and remove
            the tape around the base of the funnel.   Remove the funnel  and
            discard the top filter membrane supplied with the unit.   Do not
            remove the coarse polypropylene support  pad.   Assemble the unit
            with the adapter and a properly sized neoprene one-hole stopper,
            and attach the assembly to the 1000 ml vacuum flask.


                                      10

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 11.5  Whether using a glass or plastic filtration unit, care must be
       taken to ensure that the filter support and the mating surface of
       the filtration base not be damp when the backing filter is placed
       on the support.  If this should occur, the vacuum across the
       nitration surface will be uneven, resulting in uneven distribu-
       tion of the filtered particulates.  Either the filtration base
       must be thoroughly dried before use, or completely wetted so that
       the backing filter and filtration membrane are uniformly wet
       before filtration is started.

 11.6  DISPOSABLE FILTER UNIT - Wet the support pad with distilled
       water, if desired,  and place a 5 urn pore-size MCE backing filter
       on the pad   Place a <0.22 urn pore-size MCE filter membrane on the
       backing filter.   Ensure that both filter membranes are completely
       wet,  or dry depending upon the technique preferred.   Apply a
       vacuum to the flask and ensure that the filters are centered and
       pulled flat with no entrapped air bubbles between the membranes.
       If any irregularities are seen on the filter surface, discard  the
       filters and try  again.   Replace the funnel  and  seal  the assembly
       with  tape.

 11.7  REUSABLE GLASS FILTER UNIT

       11.7.1   (Dry Filter) Apply vacuum to the flask and  leave the
                vacuum on until the filtration process is completed.
                Place a <5 /«n pore-size MCE filter on the glass frit to
                serve as a backing filter.  Be sure that the filter is
                not creased during installation.  If the filter appears
                to absorb water, it should be discarded and the frit
                rinsed with methanol to speed drying.   Place a <0.22 urn
                pore-size MCE filter membrane on the backing filter
                Make sure that the mating surface of the filter
                reservoir is dry, then place it on the filters and clamp
                in place.                                               r

        11.7.2   (Wet Filter) Wet the glass frit and place a 5 jum pore-
                size MCE filter on the frit to serve as a backing
                filter.  Place a <0.22 /on pore-size MCE filter membrane
                on the  backing filter.  Make sure  that both membranes
                are thoroughly soaked with water.   Install  the filter
                reservoir  and clamp in place.

11.8   A process  blank sample consisting of fiber-free water should be
       run before the first field sample.  The quantity of  water should
       be >10 mL  for a 25 mm diameter filter and >50 mL for a 47 mm
       diameter filter.

11.9   Shake the capped sample bottle vigorously by hand and place in a
       low power ultrasonic bath for 15 minutes.  Shake the sample by
       hand again before removal of any aliquots.

11.10  Remove the desired aliquot from the original sample.  Large
       volumes may be measured with a graduated cylinder, smaller
       volumes should be taken with disposable glass pipettes.  Samples
       taken by pipette should be taken from the vertical center of the
       original sample.  No aliquot less than 1 mL should be taken from

                                11

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        the original  sample.   The minimum volume that should be filtered
        is 10 ml for a 25 mm  diameter filter,  or 50 ml for a 47 mm
        diameter filter.   If  it is necessary to filter aliquots less
        than these volumes, the aliquots should be brought up to these
        levels with fiber-free water and shaken vigorously before
        filtration.  Obtaining a filter with the proper loading is a
        matter of trial  and error.  It -is best to filter several  volumes
        of the sample.   Samples with high particulate or asbestos
        content may require volumes less than  1 ml to be filtered.  In
        this case,  preparation of serial  dilutions must be performed.

11.11   Agitate the aliquot and pour into the  filter reservoir.   Apply
        vacuum to the flask.   When volumes larger than the capacity of
        the reservoir have to be filtered,  the additional  solution
        should be carefully added while the reservoir is over half full
        to avoid disturbing the particulates already deposited on the
        filter.   Do not rinse the sides of the reservoir.

11.12   If a reusable glass reservoir is  used,  immediately remove the
        reservoir and place in soapy water.

11.13   Disassemble the filtration apparatus and  remove the filters  with
        clean forceps.  Carefully separate  the working filter from the
        backing  filter and discard the  backing filter.   Place the
        working  filter in  a pre-cleaned disposable  petri dish and cover.

11.14   Allow filter  to dry.   Drying may  take  place  in a HEPA filtered
        hood,  an  asbestos-free oven,  or a cabinet type desiccator.   The
        cover of the  petri dish  should  be opened  slightly  to  allow water
        vapor to  escape.

11.15   Using  a  clean scalpel   remove a  portion  of the  dry  filters  for
        preparation of TEM grids  by  the direct  transfer  technique.   Be
        sure  to  avoid the  outer  ring of the  filter that  was covered  by
        the mating  surface of  the  reservoir.  Transfer the  removed
        portion to  an unused petri dish.

11.16  A portion of  an unused filter should also be prepared  as  a lot
        blank.

11.17  MCE filters must be collapsed prior to  low temperature etching.
       Use of either the  DMF-Acetic acid method or the  acetone method
        is acceptable.  Samples should be transferred to an exhaust hood
       for this step.

       11.17.1   DMF-ACETIC ACID METHOD -- Place a drop of the clearing
                 solution  (35% dimethylformamide [DMF],  15% glacial
                 acetic  acid  and 50% water [V/V]  on a clean microscope
                 slide.   Use  just enough  solution to saturate the
                 filter.   DMF is a relatively  toxic solvent and  should
                 be used  in a fume hood.   Carefully lay the filter
                 segment,  sample surface  upward,  on  top of the solution,
                 bringing  the filter and  solution  together at an  angle
                 of about  20°  to  help exclude  air bubbles.  Remove any
                 solution  not absorbed  by the  filter with  lens paper.
                 Label the slide with a glass  scribing tool  or a

                                12

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                  permanent  marker.   Place  the  slide  into an  oven,  or on
                  the  surface  of a  hot  plate, at  65-70°C  for  10 to 30
                  minutes.

        11.17.2   ACETONE METHOD — Place the filter  section  on a clean
                  microscope slide.   Affix  the  filter section to the
                  slide with tape around the edges.   Label the slide with
                  a glass scribing tool or  permanent  marker.   Place the
                  slide in a petri dish containing several paper filters
                  soaked with  acetone.  Cover the dish and wait for the
                  sample to  fuse  and  clear  (approximately 5 minutes).

        11.17.3   Plasma etching  of the collapsed filter  is required if
                  0.22 fm pore-size membrane filters  are used.  Plasma
                  etching is optional  (but recommended) with  0.1 urn pore-
                  size filters.   The microscope slide to which the
                  collapsed  filter pieces are attached is placed in a low
                  temperature plasma asher.   Because plasma ashers vary
                 greatly in their performance,  both from unit to unit
                  and between different positions in the asher barrel, it
                  is difficult to specify the conditions that should be
                 used.  Insufficient  etching will result in a failure to
                 expose embedded fibrils,  and too much etching may
                 result in loss of particulate  from the surface.   It is
                 recommended that conditions be used  which will  remove
                 about 10% of the filter mass.   Additional  information
                 about calibration  of the plasma asher can be found in
                 the AHERA (3) and  NISTIR (4) documents.

11.18  CARBON-COATING FILTER SEGMENTS

       11.18.1   Coating must  be performed  with a high-vacuum evap-
                 oration unit  equipped  with a rotating tilting stage.
                 Units based on evaporation of  carbon filaments  in  a
                 vacuum generated only  by an oil  rotary pump  have not
                 been  evaluated for this application  and  must not be
                 used.  The  carbon rods should  be sharpened by a carbon
                 rod sharpener to necks of  about  4 mm long and 1 mm in
                 diameter.   The rods  are installed in the evaporator  in
                 such  a manner that the points  are approximately 10 cm
                 from  the surface of  the microscope slide.

       11.18.2   Affix the glass  slide to the rotating tilting table and
                 evacuate the  chamber to a  pressure of <0.013  Pa.  The
                 evaporation must be  performed  in very short  bursts
                 separated by  some seconds  to allow the electrodes to
                 cool to avoid  overheating the  surface of the  filter
                An experienced analyst can judge the thickness of the
                 carbon film to be applied,  and some tests should be
                made first on  unused filters.  If the film is too thin,
                there will be  few complete, undamaged grid openings on
                the specimen and large particles may be lost.  If the
                coating is too thick, the TEM  image will  lack contrast
                and the ability to obtain selected area electron
                diffraction (SAED)  patterns will  be compromised.   A


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                 carbon film that appears similar to a 15% gray scale is
                 usually adequate.

11.19   Prepare  the  Jaffe washer.  The  precise design of  the  Jaffe
        washer is not  important, so  any one  of the published  designs may
        be  used  (3,5).   Place the washer in  a fume hood and fill with
        DMF,  acetone or  l-methyl-2-pyrrolidone to the level of the
        screen on which  the  samples  will  be  placed.

11.20   Place calibrated TEM grids in the Jaffe washer.   Indexed
        ("Finder") grids or  grids with  a unique center mark should be
        used.  The area  of the grid  square openings must  be determined
        either by using  the  TEM at a calibrated magnification low enough
        to  measure the sides of the  opening, or with phase contrast
        microscopy at a  calibrated magnification (usually 400X).  If the
        measurements are made by TEM, one grid opening per grid is
        measured.  For measurement by phase  contrast, 20  grid openings
        are measured on  each of 20 grids  and the average  size calcu-
        lated.   The  TEM  grids are first  placed on a piece of lens tissue
        or  filter paper  so that individual grids can be picked up with
        forceps.  Grids  should be placed  on  pieces of filter paper or on
        individual screens and placed in  the Jaffe washer.  Three or
        more  grids should be prepared from each sample,

11.21   Using a  clean curved scalpel blade,  cut 3 mm square pieces of
        the carbon coated filter from the glass slide.  The point of the
        scalpel  should be placed on  the  filter and a rocking motion used
        to  cut the 3 mm  square segments.  Squares should  be selected
        from the center  of the filter and at two points between the
        outer periphery  of the active surface and the center.  The
        excised  filter segments are  placed carbon-side up on the grids.
        A map of the Jaffe washer should  be  drawn to keep track of the
        samples.  Place  the  lid on the Jaffe washer and allow to stand
        until the filter is  adequately dissolved (several  hours).

11.22   Remove the grids from the Jaffe washer and allow to dry
        thoroughly before placing them in marked grid storage boxes (or
        other suitable containers).

11.23  Analyze the samples  by TEM at an accelerating voltage of 80 to
        120 kV and a screen magnification of 10,000 to 20.000X.

        11.23.1   Use at  least three  grids from each  filter to obtain the
                 necessary number  of grid openings or structures to
                 reach the required  analytical sensitivity.

        11.23.2   Carefully load the  grid into the sample  holder.  Orient
                 the grid so that  the grid bars are  parallel  and
                 perpendicular to  the long axis of the holder.  This
                 orientation will  align the  grid bars with the X and Y
                 axes  of the specimen translation controls.

       11.23.3   Scan  the grid at  a  magnification of 250  to 1000X to
                 determine its suitability for analysis.  Reject the
                 grid  if:
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              •    1.   Less than 70% of the grid openings covered by the
                      replica are intact.

                  2.   The replica is folded or doubled.

                  3.   The replica is too dark or has obviously visible
                      filter structure because of incomplete
                      dissolution.

                  4.   The grid is too heavily loaded to obtain an
                      accurate count.

                  5.   The distribution of structures on the grid is
                      obviously not uniform.

        11.23.4   Reject individual grid openings with greater than 5% of
                 their areas occupied by holes or tears in the carbon
                 film.  Reject openings with  >25% covered by
                 particulates.

11.24   Examine the grid openings at 10-20,OOOX magnification.

11.25   Record the length and width of any grouping of particles in
       which an asbestos fiber with an aspect ratio >3:1 and a lenqth
       greater than 10 /tm is detected.

11.26  Asbestos structures will be classified as fibers according to
       the following rules.

       11.26.1   FIBER — A structure  having  a minimum  length greater
                 than  10 fjan and  an  aspect  ratio  (length  to  width) of 3:1
                 or greater and  substantially parallel  sides without
                 rounded ends.

       11.26.2   Count an asbestos bundle  >10 pm long as  a  single fiber.
                Assign a length equal to  the maximum length of any
                 fiber within  the bundle.  If the bundle  has stepped
                 sides assign  a width equal to an estimate  of the mean
                width of the  bundle.

       11.26.3  Count a matrix as a single fiber if it contains a fiber
                or fibers, meeting the length and aspect ratio require-
                ments, with one free end and the other end embedded in
                or hidden by a particulate.   If two ends are visible
                which appear to be the ends of a single fiber,  the
                distance between, the two ends is measured.  If only one
                end of the fiber is visible,  the fiber will be assigned
                a length equal to twice its  visible length, except
                where this would place the concealed end outside of the
                particle.   In this case,  the  length will be recorded as
                the visible length plus the  diameter of the portion of
                the particle at the point of the fiber intersection.
                If the structure is too complex to be dealt with in
                this  manner, record the overall  dimensions of the
                structure  but do not include  it in the fiber count.


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        11.26.4  Count and record as single fibers the individual fibers
                 visible with a cluster as long as they meet the fiber
                 definition.  If the aggregate is too complex, record
                 the overall dimensions but do not include it in the
                 fiber count.

        11.26.5  Fibers which intersect the top and left sides of the
                 grid opening are counted and recorded as twice their
                 visible length.  Fibers intersecting the bottom and
                 right sides of the grid opening are not recorded.

        11.26.6  Count only one end of the fiber to avoid the possi-
                 bility of counting a single fiber more than once.

11.27   Structures  classified  as chrysotile must first be examined by
        SAED.   If the characteristic chrysotile ED pattern is observed,
        the  fiber will be counted.  If no pattern is observed, or the
        pattern is  not distinctive, the fiber must be examined by
        quantitative EDXA.   If EDXA is characteristic of chrysotile, the
        fiber will  be counted.  Chrysotile fibers identified by
        morphology  alone can be recorded but not counted towards the
        regulatory  limit.  The analyst's count sheet must indicate the
        method  used to verify  identity.  A modified version of .the AHERA
        count sheet may be used, which has columns to check off the
        method  of identification.

11.28   Structures  which are suspected to be an amphibole must first be
        examined  by SAED.  If  a random orientation ED pattern with a
        0.53 nm layer spacing  is obtained, the fiber should be analyzed
        by EDXA.  If the elements and peak ratios of the spectra
        correspond  to those of a known amphibole, the fiber will be
        counted.  If the random orientation ED pattern cannot be
        obtained, is incomplete or is not recognizable as a non-
        amphibole pattern, but an EDXA spectrum corresponding to a known
        amphibole is obtained, the fiber will be counted.  Only fibers
        classified  in this manner or by single or double zone axis SAED
        can be  included in the regulated fiber count.  The count sheet
        should  indicate method used for identification.

11.29   Record  both a typical SAED pattern and x-ray spectrum for each
        type of asbestos observed for each set of samples from the same
        source, or  a minimum of every fifth sample analyzed.   Record the
        micrograph  number on the count sheet and attach the x-ray
        spectrum  to the back of the count sheet.  If the x-ray spectrum
        is stored on disk, record the file and disk number on the count
        sheet.

11.30   Record  NSD when no structures are detected in the grid opening.

11.31   STOPPING  RULES — Counting can be stopped at the completion of
        the grid  opening in which an analytical  sensitivity of 0.2 MFL
        is reached, or at the completion of the grid opening which
        contains  the 100th structure, whichever occurs first.  A minimum
        of 4 grid openings must be analyzed even if this results in the
        counting  of more than 100 asbestos fibers over 10 fan in length.


                                16

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      11.32  The grid openings examined must be drawn approximately equally
             from the three grids used in the analysis.
      11.33  After completion of analysis, remove the grid from the
             microscope and replace in the labelled specimen storage box.
             Sample grids must be stored for a minimum of three years from
             the date of analysis.  Sample filters may also be archived if
             desired.
12.0  DATA ANALYSIS AND CALCULATIONS
      12.1   Calculation of results.  The concentration of asbestos in a
             given sample is calculated using the following formula:
                              no str  x efa x RD
                            GO x GOA x  Vx  1000

             where:
             no str = number of asbestos  fibers  counted
             efa =  effective filter  area  of the  sampling filter  in  mm2
             RO  = dilution ratio of original sample (if applicable)
             60 = number of  grid openings counted
             GOA = area of grid openings  in /im2
             V  = original volume of sample filtered in ml

     12.2    The following information must be reported for each sample
             analyzed:
             12.2.1    Mean  concentration  of asbestos  in million  fibers  per
                      liter.                                        .
             12.2.2    Upper  and lower  95% confidence  limits on the  mean
                      concentration.
            12.2.3    Aliquot  used for analysis  and dilution factor (if  any).
            12.2.4    Effective filter area.
            12.2.5    Total  area of filter examined.
            12.2.6    Number of asbestos structures counted.
            12.2.7   Analytical sensitivity.
            12.2.8    Copies of the TEM count sheet, if requested.
                                    17

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             12.2.9    Number of structures which were too complex to
                       classify, and number of suspected chrysotile and
                       amphibole fibers which could not be positively
                       identified.

13.0  METHOD PERFORMANCE

      13.1   Limitations of accuracy can result from errors in identification
             of asbestos structures.  Complete identification of every fiber
             is not possible due to both instrumental limitations and the
             nature of some of the fibers.

             13.1.1    The  requirement  for a calibrated SAED pattern
                       eliminates the possibility of an incorrect
                       identification of chrysotile fibers.   However,  it  is
                       not  always possible to obtain a satisfactory
                       diffraction pattern from every fiber.   The  only
                       significant possibilities  of misidentification  occur
                       with halloysite,  vermiculite scrolls  or palygorskite,
                       all  of which can  be discriminated from  chrysotile  by
                       the  use  of EDXA  and by observation of the 0.73  nm  (002)
                       reflection of chrysotile in  the  SAED  pattern  (1).

             13.1.2    Complete identification of all  amphibole fibers is  not
                       practical  due to  instrumental  factors,  the  nature  of
                       some of  the fibers,  and limitations of  time  and cost.
                       Particles  of a number of other minerals having
                       compositions similar to those  of  some amphiboles could
                       be mistakenly classified as  amphibole when zone axis
                       SAED is  not  used.   However,  quantitative EDXA
                       measurements on all  fibers as  support for the random
                       orientation  SAED  patterns makes misidentification
                       unlikely.  The possibility of  misidentification is
                       further  reduced with  increasing aspect ratio, since
                       many of  the  minerals  with which amphibole may be
                       confused do  not display its  prominent cleavage  parallel
                       to the c-axis (1).

      13.2    Limitations  of accuracy can also result from the  overlapping of
             structures by  other (nonasbestos) particulates.

      13.3    Inadequate dispersion of fibers can  occur  if enough organic
             contaminants were  present  in the original  sample  to cause
             adhesion  of  the fibers to  the container walls or  each  other.

      13.4    Contamination  of the aliquots  by asbestos during  preparation  in
             the laboratory can lead to  inaccuracy  of results.  This is a
             particular problem with chrysotile,  and  should  be carefully
             monitored by preparation of blank samples.

      13.5    This method  has  not  yet been subjected to an  inter!aboratory
             test round.  Precision measurements  for  EPA intralaboratory
             comparisons of results from multiple operators using three TEMs
             produced  a relative  standard deviation (RSD) of 26.5% for MCE
             filters and 25.5%  for  PC filters  for fibers over  10/im  in  length
             in standard samples.   For similar methods,  precision

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              measurements  for  intralaboratory  comparisons  have  been  found  to
              have  an  RSD of  13  to  22%rfor  standard  and  environmental  water
              samples, with an  RSD  of 8.4 to  29%  for interlaboratory  com-
              parisons (1).   Statistical formulae for the establishment  of
              confidence limits  on  the laboratory results can be found in
              Chatfield and Dillon  (1).  An earlier  study found an  inter-
              laboratory reproducibility of 25  to 50% in standard samples (6).
              Accuracy measurements from inter  and intralaboratory  studies
              have demonstrated  an  RSD of 17% for standard  chrysotile
              suspensions and an RSD of 16% for standard crocidolite
              suspensions (1).

       13.6   The detection limit will depend upon the concentration of
              asbestos in the original sample and the constraints of time and
              cost of analysis.   The detection limit can be improved by
              increasing the amount of water filtered, increasing the number
              of grid openings counted or decreasing the size of the filter
              used (when practical).  Samples containing a high level  of
              particulates will  necessarily have a higher detection limit.

 14.0  POLLUTION PREVENTION            .

       14.1    Pollution prevention encompasses any technique that reduces or
              eliminates  the quantity or  toxicity of waste  at the point of
              generation.  Numerous  opportunities for pollution  prevention
              exist  in  laboratory operation.   The EPA has established  a
              preferred hierarchy of environmental management techniques  that
              places pollution prevention as  the management  option  of  first
              choice.   Whenever  feasible, laboratory  personnel should  use
              pollution prevention techniques  to address  their waste
              generation.  When  wastes cannot  be feasibly reduced at the
              source, the Agency recommends  recycling as  the next best  option.

       14.2    The  quantity of  chemicals purchased  should  be  based on expected
              usage  during its shelf life and  disposal cost  of unused
              material.  Actual  reagent preparation volumes  should reflect
              anticipated usage  and  reagent stability.

       14.3    For  information  about  pollution  prevention that may be
              applicable to laboratories and research  institutions,  consult
              Less  is Better:  Laboratory Chemical Management for Waste
              Reduction," available  from the American Chemical Society's
              Department of Government Regulations and Science Policy,   1155
              16th Street N.W., Washington D.C. 20036, (202)872-4477.

15.0  WASTE MANAGEMENT

      15.1   The U.S. Environmental  Protection Agency requires that
             laboratory waste management  practices be conducted consistent
             with all applicable rules and  regulations.   Excess reagents
             samples and method  process wastes should be characterized and
             disposed of in  an acceptable manner.  The Agency urges
             laboratories to protect the  air,  water and  land by minimizing
             and controlling all releases from hoods  and bench operations
             complying  with  the  letter and  spirit of any waste discharge
             permit  and regulations, and  by  complying with  all  solid and

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             hazardous waste regulations, particularly the hazardous waste
             identification rules and land disposal restrictions.  For
             further information on waste management consult the  "Waste
             Management Manual for Laboratory Personnel," available from the
             American Chemical Society at the address listed in Sect. 14.3.

16.0  REFERENCES

      1.    E.J. Chatfield and M.J.  Dillon,  "Analytical  Method for the
            Determination of Asbestos in Water."  EPA 600/4-83-043.

      2.    "Reagent Chemicals, American Chemical Society Specifications,"
            American Chemical  Society,  Washington, D.C.

      3.    USEPA, Asbestos-Containing  Materials in Schools:  Final Rule  and
            Notice.  Federal  Register,  40 CFR Part 763,  Appendix A to Subpart
            E., October 30,  1987.

      4.    NIST/NVLAP Program Handbook for  Airborne Asbestos Analysis.
            NISTIR 89-4137,  August,  1989.

      5.    G.J. Burdett and A.P.  Rood,  "Membrane-Filter DirectrTransfer
            Technique for the  Analysis  of Asbestos Fibers or  Other Inorganic
            Particles by Transmission Electron Microscopy," Environ. -Sci.
            Techno!.  17:643-648,  1983.

      6.    K.S. Chopra,  HInter!aboratory Measurements of Amphibole and
            Chrysotile  Fiber Concentrations  in Water," in National  Bureau of
            Standards Special  Publication 506, Proceedings of the  Workshop  on
            Asbestos:  'Definitions and Measurement Methods, 1977.
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