822F93009
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460 .
                                                     OFFICE OF
                                                      WATER
NOTE;


SUBJECT:  Additional  Material  for  the Water  Quality  Standards
          Handbook
FROM:     DavidTK. Sabock,  Chief
          Water Quality  Standards Branch


TO:       Recipients  of the  Water Quality  Standards Handbook
          Second Edition
     On October 1, 1993,  the Acting Assistant  Administrator for
Water issued the Office  of Water PolicyandTechnical Guidance on
Interpretation and Implementation of Acniatic Life Metals Criteria.

     Since the policy document was signed too late for inclusion in
the Water Quality Standards Handbook - Second Edition, the complete
policy document is attached  and should  i>e kept with the Handbook.
Later this fiscal year, you will receive an update to the Handbook/
to be inserted  in this section,  reflecting the policy document.

     If you have  any further  questions  on the Handbook  or the
attached guidance,  contact me at 202-260-1315  or  the appropriate
technical contacts listed  on page 7 of the cover memorandum of the
guidance.

Attachment
                                                PriHUdoHKtcycUdPaptr

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               WASHINGTON, D.C. 20460
                                 . OCT I 5 1993


 Dear Environmental Advocate:
OFFICE OF
 WATER
       On October 1,  1993,1 signed a memorandum regarding the Office of Water's Policy

 and Technical Guidance on Interpretation and Implementation of-Aquatic Life Metals

 Criteria.  This memorandum  covers a number of areas including the expression of aquatic

 life criteria,  total maximum daily loads, National Pollution Discharge Elimination System

 permits and  enforcement, effluent monitoring, and ambient monitoring.  The policy and

 guidance in this document considers comments received from the U.S. Environmental

 Protection Agency (EPA) Regional Offices, recommendations made to EPA by the

 participants in a meeting held in January 1993 in Annapolis, Maryland, and public comments

 in the June 8, 1993, Federal Register notice requesting general public comments on the

 Annapolis meeting recommendations. As stated in the enclosed memorandum, we will

 continue to issue f uidance as  more information becomes available.
                                      Sincerely you
                                      Martha G. Prothro,
                                      Acting Assistant Adminisbator
Enclosure

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                   UNrTEO STATES ENVIRONMENTAL PROTECTION AGENCY
                                 WASHINGTON. D.C. 20460   -
                                      OCT   1 893

                                                                       OFFCCOF
                                                                        WATER
MEMORANDUM

SUBJECT:    Office of Water Policy and Technical Guidance on Interpretation and
             'Implementation of Aquatic Life Metals Criteria

FROM:       Martha G.Prothro:^
              Acting Assistant Administrator for Water

TO:          Water Management Division Directors
              Environmental Services Division Directors
              Regions I-X

Introduction

       The implementation of metals criteria is complex due to the site-specific nature of
metals toxicity. We have undertaken a number of activities to develop guidance in this area,
notably the Interim Metals Guidance, published May 1992, and a public meeting of experts
held in Annapolis,  MD, in January  1993. This memorandum transmits Office of Water
(OW) policy and guidance on the interpretation and implementation of aquatic life criteria for
the management of metals and supplements my April 1, 1993, memorandum on the same
subject. The issue coven a number of areas including the expression of aquatic life criteria;
total maximum daily- loads (TMDLs), permits, effluent.monitoring, and compliance; and
ambient monitoring.  The memorandum coven each in turn.-  Attached to this policy
memorandum are three guidance documents with additional technical details.  They are:
Guidance Document on Expression of Aquatic Life Criteria as Dissolved Criteria
(Attachment 42), Guidance Document on  Dynamic Modeling and Translators (Attachment
f3), and Guidance  Document on Monitoring (Attachment *4). These will be supplemented
as additional data become available.  (See the schedule in Attachment f 1.)

       Since metals toxicity is significantly affected by site-specific factors, it presents a
number of programmatic challenges. Factors that must be considered in the management of
metals in the aquatic environment include: toxicity specific to effluent chemistry;  toxicity
specific to ambient water  chemistry; different patterns of toxicity for different metals;
evolution of the state of the science of metals toxicity, fate, and transport; resource
limitations for monitoring, analysis, implementation, and research functions; concerns
regarding  some of  the analytical data currently on record due to possible sampling and
analytical contamination; and lack of standardized protocols for clean and ultradean metals
analysis.  The States have the key role in the risk management process of balancing these
factors in  the management of water programs.  The site-specific nature of this issue could •*
perceived as requiring a permit-by-permit approach to implementation. However, we believe

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 that this guidance can be effectively implemented on a broader level, across any waters with
 roughly the same physical and chemical characteristics, and recommend that we work with
 the States with that perspective in mind.

 Expression of Aquatic Life Criteria

 o      Dissolved vs. Total Recoverable Metal

        A major issue is whether, and how, to use dissolved metal concentrations ("dissolved
 metal") or total recoverable metal concentrations ("total recoverable metal") in setting State
 water quality standards.  In the past, States have used both approaches when applying the
 same Environmental Protection Agency (EPA) criteria numbers. .Some older criteria
 documents may have facilitated these different approaches to interpretation of the criteria
• because the documents were somewhat equivocal with regards to analytical methods.  The
 May 1992 interim guidance continued the policy that either approach was  acceptable.

        It is now the policy of the Office of Water that the use of dissolved metal to set and
 measure compliance with water quality standards is the recommended approach, because
 dissolved meal more closely approximates the bioavailable fraction of metal in the water
 column than does total recoverable metal.  This  conclusion regarding metals bioavailability is
 supported by a majority of the scientific community within and outside the Agency. One
reason is that a primary mechanism for water column toxicity is adsorption at the gill surface
which requires metals to be in the dissolved form.

       The position mat the dissolved metals approach is more accurate has been questioned
because it  neglects the possible toxicity of paniculate metal  It is true that some studies  have
indicated mat paniculate metals appear to contribute to the toxicity of metals, perhaps
because of factors such as desoiption of metals at the gill surface, but these same studies
indicate the toxicity of paniculate metal is substantially less man that of dissolved metal.

       Furthermore, any error incurred from excluding the contribution of paniculate metal
will generally be compensated by other factors which make criteria conservative.  For
example, metals in toxicity tests are  added  as simple salts to relatively clean water.  Due to
the likely presence of a significant concentration of metals binding agents in  many discharges
and ambient waters, metals in toxicity tests would generally be expected to be more
bioavailabile than metals in discharges or in ambient waters.

       If total recoverable metal is used for the purpose of water quality standards,
compounding of factors due to the lower bioavailability of paniculate meal and lower
bioavailability  of metals as they are discharged  may result in a conservative water quality
standard. The use of dissolved metal in water quality standards gives a more accurate result.
However, the majority of the participants at the  Annapolis meeting felt that total recoverable
measurements in ambient water had  some value, and that exceedences of criteria on a total
recoverable basis were an indication that metal loadings could be a stress to the ecosystem,
particularly in locations other than the water column.

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        The reasons for the potential consideration of total recoverable measurements include
 risk management considerations not covered by evaluation of water column toxicity. The
 ambient water quality criteria are neither designed nor intended 10 protect sediments, or to
 prevent effects due to food webs containing sediment dwelling organisms.  A risk manager,
 however, may consider sediments and food chain effects and may decide to take a        •'-  .
 conservative approach for metals, considering that metals are very persistent chemicals. This
 conservative approach could include the use of total recoverable metal in water quality
 standards. However, since consideration of sediment impacts is not incorporated into the
 criteria methodology, the degree of conservatism inherent in .the total recoverable approach is
 unknown. The uncertainty of metal impacts in sediments stem from the lack of sediment
 criteria and an imprecise understanding of the fate and transport of metals.  EPA will
 continue to pursue research- and othe^activitie* to close these knowledge gaps.

       Until the scientific uncertainties are  better resolved, a range  of different risk
 management decisions can be justified. EPA  recommends that State water quality standards
 be based on dissolved metal. (See the paragraph below and the attached guidance for
 technical details on developing dissolved criteria.)  EPA will also approve a State risk
 management decision to adopt standards based on total recoverable metal, if those standards
 are otherwise approvable as  a matter of law.

 o      Dissolved Criteria

       In the toxicity tests used to develop EPA metals criteria for aquatic life, some fraction
 of the metal is dissolved white some fraction is bound to paniculate matter.  The present
 criteria  were developed using total recoverable metal measurements  or measures expected to
 give equivalent results in toxicity tests, and are articulated as total recoverable.  Therefore,
 in order to express the EPA  criteria as dissolved, a total recoverable to dissolved correction
 factor must be used. Attachment 12 provides guidance for calculating EPA dissolved criteria
 from the published total recoverable criteria.  The data expressed, as percentage metal,.
dissolved are presented as recommended values and ranges.  However, the choice within
ranges is a State risk management decision. We have recently supplemented the data for
copper and are proceeding to further supplement the data for copper and other metals.  As
testing is completed, we will make this information available and this is expected to reduce
 the magnitude of the ranges for some of the conversion factors provided. We also strongly
encourage the application of dissolved criteria across a watershedVor waterbody, as
technically sound and the best use of resources.

o      Site-Specific Criteria  Modifications

       While the above methods will correct some site-specific factors affecting metals
 toxicity, further refinements  are possible. EPA has issued guidance (Water Quality
 Standards Handbook, 1983; Guidelines for Deriving Numerical Aquatic Site-Specific Water
 Quality Criteria by Modifying National Criteria, EPA-600/3-H4-099, October 1984) for three
 site-specific criteria development methodologies:  recalculation procedure, indicator species
 procedure (also known as the water-effect ratio (WER)) and resident species procedure.
 Only the first two of these have been widely used.

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       In the National Toxics Rule (57 FR 60848, December 22,  1992), EPA identified the
 WER as an optional method for site-specific criteria development  for certain metals. EPA
 committed in the NTR preamble to provide guidance on determining the WER.  A draft of
 this guidance has been circulated to the States and Regions for review and comment As
justified by water characteristics and as recommended by the WER guidance, we strongly
 encourage the application of the WER across a watershed or waterbody as opposed to
 application on a discharger by discharger basis, as technically sound and an efficient use of
 resources.

       In order to meet current needs, but allow for changes suggested by protocol users,
 EPA  will issue the guidance as  "interim."  EPA will accept WERs developed using this
 guidance, as well as by using other scientifically defensible protocols.  OW expects the
 interim WER guidance will be issued in the next two months.

Total Maximum Daily Loads fTMPLsl and National Pollutant Discharge Elimination System
 ffJPDES> Permits

 o      Dynamic Water Quality  Modeling

       Although not specifically part of the reassessment of water  quality criteria for metals,
dynamic or probabilistic models are another useful tool for implementing water quality
criteria, especially for those criteria protecting aquatic life. These models provide another
way to incorporate site-specific  data.  The 1991 Technical Support Document for Water
Quality-based Toxics Control (TSD) (EPA/505/2-90-001) describes dynamic, as well as static
(steady-state) models. Dynamic models make  the best use of the specified
duration, and frequency of water quality criteria and, therefore, provide a more accurate
representation of the probability that a water quality standard exceedence will occur.  In
contrast, steady-state models make a number of simplifying, worst case assumptions which
makes them less complex and less accurate than- dynamic models.

      Dynamic models have received increased attention over the last few yean as a result
of the widespread belief that steady-state modeling is over-conservative due to
environmentally conservative dilution assumptions. This belkf has led to the misconception
that dynamic models will always lead to less stringent regulatory controls (e.g., NPDES
effluent limits) than steady-state models, which is not true in every application of dynamic
models.  EPA considers dynamic models to be a more accurate approach to implementing
water quality criteria and continues to recommend their use.  Dynamic modeling does require
commitment of resources to develop appropriate data. (See Attachment 13 and the TSD for
details on the use of dynamic models.)

o      Dissolved-Total Metal Translators

       Expressing water quality criteria as the dissolved form of a metal poses a need to  be
able to translate from  dissolved metal to total recoverable metal for TMDLs and NPDES
permits. TMDLs for  metals must be able to calculate:  (1) dissolved metal in order to
ascertain attainment of water quality standards, and (2) total recoverable metal in order to
achieve mass balance  necessary for permitting purposes.

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       EPA's NPDES regulations require that limits of metals in permits be stated as total
 recoverable in most cases (see 40 CFR §122.45(c)) except when an effluent guideline
 specifies the limitation in another form of the metal, the approved analytical methods
 measure only dissolved metal, or the permit writer expresses a metals limit in another form
 (e.g., dissolved, valent, or total)  when required to carry out provisions  of the dean Water
 Act.  This is because the chemical conditions in ambient waters frequently differ substantially
 from those in the effluent, and there is no assurance mat effluent paniculate metal would not
 dissolve after discharge.  The NPDES rule does not require that State water quality standards
 be expressed as total recoverable; rather, the rule requires permit writers to translate between
 different metal forms in the calculation of the permit limit so that a total recoverable limit
 can be established.  Both the TMDL and NPDES uses of water quality criteria require the
 ability to translate between dissolved metal and total recoverable metal.   Attachment 13
 provides methods for this translation.

 Guidance on Monitoring

 o      Use of Clean Sampling and Analytical Techniques

       In assessing  waterbodies to determine the potential for toxicity problems due to
 metals, the quality of the data used is an important issue. Metals data are used to determine
attainment status for water quality standards, discern trends in water quality, estimate
background loads for TMDLs, calibrate fete and transport models, estimate effluent
concentrations (including effluent variability), assess permit compliance, and conduct
 research.  The quality of trace level metal data, especially below 1 ppb, may be
compromised due to contamination of samples during collection, preparation, storage, and
analysis. Depending on the level of metal present, the use of "clean" and "ultraclean"
techniques for sampling and analysis may be critical to accurate data for implementation of
aquatic life criteria for metals. ...

       The magnitude of the contamination problem increases as the ambient and effluent
metal concentration  decreases and, therefore, problems are more likely in ambient
measurements.  "Clean" techniques refer to those requirements (or practices for sample
collection and handling) necessary to produce reliable analytical data in the part per  billion
 (ppb) rangeV "Ultraclean* techniques refer to those requirements or practices necessary to
produce reliable analytical data in the part per trillion (ppt) range.  Because typical
concentrations of metals in surface waters and effluents vary from one metal to another, the
effect of contamination on the quality of metals monitoring data varies appreciably.

       We plan to develop protocols on the use of dean and ultra-clean techniques and are
 coordinating with the United States Geological Survey (USGS) on this project, because USGS
 has been doing work on these techniques for some time, erpetiaUy the sampling procedures.
 We anticipate that our draft protocols for clean techniques will be available in late calendar
 year 1993.  The development of comparable protocols for ultra-dean techniques is underway
 and will be available in 1995. In developing these protocols, we will consider the costs of
 these techniques and will give guidance as to the situations where their use is necessary.
 Appendix B to the WER guidance document provides some general guidance on the use of

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 clean analytical techniques. (See Attachment #4.)  We recommend that this guidance be used
 by States and Regions as an interim step, while the clean and ultra-clean protocols are being
 developed.  _                                       -

 o .     Use of Historical Data      -    -

        The concerns about metals sampling and analysis discussed above raise corresponding
 concerns about the validity of historical data. Data on effluent and ambient metal
       itrations are collected by a variety of organizations including Federal agencies (e.g.,
wvuwcni
 EPA, ITSGS), State pollution control agencies and health departments, local government
 agencies, municipalities, industrial dischargers, researchers, and others.  The data are
 collected fora variety of purposes as discussed above.

      _ Concern  about the reliability of the sample collection and analysis procedures is
 greatest where they have been used to monitor very low level metal concentrations.
 Specifically, studies have shown data sets with contamination problems during sample
 collection and laboratory analysis, that have resulted in inaccurate measurements.  For
 example, in developing a TMDL for New York Harbor, some historical ambient data showed
 extensive metals problems in the harbor, white other historical ambient data showed only
 limited metals problems. Careful resampling and analysis in 1992/1993  showed the latter
 view was correct.  The key to producing accurate data is appropriate quality assurance (QA)
and quality control (QC) procedures.  We believe that most historical data for metals,
collected and analyzed with appropriate QA and QC at levels of 1 ppb or higher, are
reliable.  The data used in development of EPA criteria are also considered reliable, both
because they meet the above test and because the toxitity test solutions are created by adding
known amounts of metals.

       With respect to effluent monitoring reported by an NPDES permittee, the permittee is
responsible for collecting and reporting quality data on a Discharge Monitoring Report
(DMR).  Permitting authorities should continue to consider the information reported to be
true, accurate, and complete as certified by the permittee.  Where the permittee becomes
aware of new information specific to the effluent discharge that questions the quality of
previously submitted DMR data, the permittee must promptly submit that information to the
permitting authority. The permitting authority will consider all information submitted by the
permittee in determining appropriate enforcement responses to monitoring/reporting and
effluent violations.  (See Attachment *4 for additional details.)

Summary

       The management of metals in the aquatic environment is complex. The science
supporting our technical and regulatory programs is continuing to evolve, here as in all
4,-eas.  The policy and guidance outlined above represent the position of OW and should be
incorporated into ongoing program operations.  We do not expect that ongoing operations
would be delayed or deferred because of this guidance.

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       If you have questions concerning this guidance, please contact Jim Hanlon, Acting
Director, Office of Science and Technology, at 202-260-5400.  If you have questions on
specific details of the guidance, please contact the appropriate OW Branch Chief.  The
Branch Chiefs responsible for the various areas of the water quality program are:  Bob April
(202-260-6322, water quality criteria), Elizabeth Fellows (202-260-7046, monitoring and data
issues),  Russ Kinerson (202-260-1330, modeling and translators), Don Brady (202-260-7074,
Total Maximum Daily Loads), Sheila Frace (202-260-9537, permits), Dave Sabock
(202-260-1315, water quality standards), Bill Telliard (202-260-7134, analytical methods)
and Dave Lyons (202-260-8310, enforcement).
Attachments

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                                                              ATTACHMENT *\

                     TECHNICAL GUIDANCE FOR METALS

                          Schedule of Upcoming Guidance   -
Water-effect Ratio Guidance - September 1993


Draft "Clean" Analytical Methods - Spring 1994
Dissolved Criteria - currently being done; as testing is completed, we will release the
updated percent  dissolved data
Draft Sediment Criteria for Metals - 1994


Final Sediment Criteria for Metals -1995

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                          ATTACHMENT Wl
   GUIDANCE DOCUMENT
  ON DISSOLVED CRITERIA
Expression of Aquatic Life Criteria
         October 1993

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                                                           10-1-93


       Percent Dissolved in Aquatic Toxicity Tests on Metals


The  attached table contains all the data that were found
concerning the percent of the total recoverable metal that was
dissolved in aquatic toxicity tests.  This table is intended to
contain-the available data that are relevant to the conversion of
EPA's  aquatic life criteria for metals from a total recoverable
basis  to a dissolved basis.  (A factor of 1.0 is used to convert
aquatic life criteria for metals that are expressed on the basis
of the acid-soluble measurement to criteria expressed on the
basis  of the total recoverable measurement.)   Reports by Grunvald
(1992)  and Brungs et al.  (1992) provided.references to many of
the  documents in which pertinent, data were.found.   Each document
was  obtained and examined to determine whether it contained
useful data.

"Dissolved11 is defined as metal that passes through a 0.45-pm
membrane filter.   If otherwise acceptable,  data that were
obtained using 0.3-^m glass fiber  filters and  0.1-pm membrane
filters were used,  and are identified in the table;  these data
did  not seem to be outliers.

Data were used only if the metal was in a dissolved inorganic
form when it  was  added to the dilution water.   In  addition,  data
were used only if they were generated in water that would have
been acceptable for use as a dilution water in tests used in the
derivation of water quality criteria for aquatic life;  in
particular, the pH had to be between 6.5 and 9.0,  and the
concentrations of total organic carbon (TOC) and total  suspended
solids  (TSS)  had  to be below 5 mg/L.   Thus  most data generated
using river water would not be used.

Some data were not used for other  reasons.  Data presented by
Carroll et al.  (1979)  for cadmium  were not  used because 9 of the
36 values were above 150%.   Data presented  by  Davies et al.
(1976)  for lead and Holcombe and Andrew (1978)  for zinc were not
used because "dissolved11  was defined on the basis  of
polarography,  rather than filtration.

Beyond this,  the data were not reviewed for quality.  Horowitz et
al.  (1992)  reported that  a number  of aspects  of the filtration
procedure might affect the results.   In addition,  there might  be
concern about use of "clean techniques" and adequate QA/QC.

Each line in the table is intended to represent a  separate piece
of information.   All of the data in the table  were determined  in
fresh  water,  because no saltwater  data were found.   Data are
becoming available for copper in salt water from the Mew York

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 Harbor study; based on the first set of tests, Hansen  (1993)
 suggested that the average percent of the copper that  is
 -dissolved in sensitive saltwater tests.is in the range of 76 to
' 82 percent. .               .

 -A thorough investigation of the percent of total recoverable
 metal that is dissolved in toxicity tests might'attempt to
 determine if the percentage is .affected by test technique
 (static, renewal, flow-through), feeding (were the test animals
 •fed and, if so, what food and how much), water quality
 characteristics (hardness, alkalinity, pR, salinity),  test
 organisms (species, loading), etc.

 The attached table also gives the freshwater criteria
 concentrations (CMC and CCC)  because percentages for total
 recoverable concentrations much (e.g., more than a factor of 3)
 above or below the CMC and CCC are-likely to be less relevant.
 When a criterion is expressed as a hardness equation, the range
 given extends from a hardness of.50 mg/L to a hardness of 200
 mg/L.

 The following is a summary of the available information for each
 metal:
 Arsenicfill)

 The data available indicate that the percent dissolved is about
 100,  but all  the available data are for concentrations that are
 much higher than the CMC and CCC.


 Cadmium

 Schuytema et  al. (1984)  reported that "there were  no real
 differences'*  between measurements of total and dissolved cadmium
 at  concentrations of 10  to 80 ug/L (pH • 6.7 to 7.8, hardness --
 25  mg/L,  and  alkalinity  * 33 mg/L); total and dissolved
 concentrations were said to be "virtually equivalent".

 The CMC and CCC are close together and only range  from 0.66 to
 8.6 ug/t>  The only available data that are known  to be in the
 range of the  CMC and CCC were determined with a glass fiber
 filter.  The  percentages 'that are probably most relevant are 75,
 92, 89, 78, and 80.


 ChromiumfTIT1

 The percent dissolved decreased as the total recoverable
 concentration increased, even though the highest concentrations
 reduced the pH substantially.  The percentages that are probably

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 most relevant to the CMC are 50-75, whereas the percentages that
 are probably most relevant to the CCC are 86 and 61.


 ChromiumfVTi               .-.---.        -

 The data available indicate that the percent dissolved is about
 100,  but all the available data are for concentrations*that are
 much ftigher than the CMC and CCC.


 Copper

 Howarth and Sprague (1978)  reported that the total and dissolved
 concentrations of copper were."little,different"  except  when the
 total copper  concentration was  above 500 ug/L at  hardness » 360
 zng/L and pH * 8 or 9.   Chakoumakos et al.  (1979)  found that the
 percent dissolved depended more on alkalinity than on  hardness,
 pH,  or the  total recoverable concentration of copper.

 Chapman (1993)  and Lazorchak (1987)  both found that the  addition
 of  daphnid  food affected the percent dissolved very little,  even
 though Chapman used yeast-trout chow-alfalfa whereas Lazorchak
 used  algae  in most tests,  but yeast-trout  chow-alfalfa in some
 tests.   Chapman (1993)  found a  low percent dissolved with and
 without food,  whereas Lazorchak (1987)  found a  high percent
 dissolved with and without  food.   All of Lazorchak's values were
 in  high hardness water;  Chapman's one value in  high hardness
 water was much higher than  his  other values.

 Chapman (1993)  and Lazorchak (1987)  both compared  the  effect of
 food  on the total recoverable LC50 with the effect of  food  on the
 dissolved LC50.   Both authors found  that food raised both the
 dissolved LC50 and the  total recoverable LC50 in about the  same
 proportion, indicating  thatr food did not raise  the total
recoverable LC50 by sofbing metal onto  food particles; possibly
the food raised both LCSOs  by (a)  decreasing the toxicity of
dissolved metal,  (b) forming nontoxic dissolved complexes with
the metal, or  (c)  reducing  uptake.

The CMC and CCC are close together and  only range  from 6.5  to 34
 ug/L.   The percentages  that are probably most, relevant are  74,
 95, 95, 73, 57,  53,  52,  64,  and 91.


 Lead

The data presented in Spehar et al.  (1978)  were from Holcombe et
 al.  (1976).   Both Chapman  (1993)  and Holcombe et al. (1976)  found
 that  the percent dissolved  increased as the total  recoverable
 concentration  increased.   It would seem reasonable to  expect more
 precipitate at higher total recoverable concentrations and

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therefore  a  lower percent dissolved at higher  concentrations.
The  incr«a«a in  parcant dissolved with incraasing concentration
night ba dua to  a lowering of  the pH as more natal  is addad  if
the  stock  solution was  acidic.

Tha  percentages  that are probably nost relevant to  the CMC ara 9,
18,  25, 10,  62,  68, 71,  75,  81, and-95, whereas the percentages
that ara probably nost  relevant to  the CCC ara 9 and 10.


Mercury

Tha  only percentage that is  available is 73, but it is for a
concentration that is nuch higher than the CMC.


Nickel

The  percentages  that ara probably nost relevant to  the CMC are
88,  93, 92,  and  100, whereas the only percentage that is probably
relevant to  the  CCC is  76.


Selenium

No data ara  available.
Silver

There is a CMC, but not a CCC.  Tha percentage dissolved seen* to
be greatly reduced by the food used to feed daphnida, but not by
tha food used to faad fathead ainnows.  Tha percentages that are
probably nost relevant to tha CMC ara 41, 79, 79, 73, 91, 90, and
93.


zinc

Tha CMC and CCC ara close together and only range fron 59 to 210
ug/L.  Tha percentages that are probably nost relevant ara 31,
77, 77, *9, 94, 100, 103, and 96.

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 Recommended Values  (%)A and Ranges of Measured Percent Dissolved
              Considered Most Relevant in Fresh Water


  Metal                    £M£   "                CCC

                  Recommended      "    Recommended
                   Value (*\  fBanaa *1   Value (*1  rRange
Arsenic (III)
Cadmium
Chromium (III)
Chromium (VI)
•Copper
Lead
Mercury
Nickel
Selenium
Silver
Zinc
95
85
85
95
85
50
85
85
NAB
85
85
100-104*
75-92
50-75
100*
52-95
9-95
73*
88-100
NAC
41-93
31-103
95
85
85
95
85
25
NAB
85
NAB
YY°
85
100-104*
75-92
61-86
100*
52-95
9-10
NAB
76
NAC
YY°
31-103
A The recommended values are based on current knowledge and are
  subject to change as more data becomes available.

* All available data are for concentrations that are much higher
  than the CMC.

c NA - Mo data are available.
      .•-".">'•'..
0 YY - A CCC is not available, and therefore cannot be adjusted.

E NA - Bioaccumulative chemical and not appropriate to adjust to
  percent dissolved.

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Conch.*   Percent
fuq/L>    Dia«.»   n£  Spades"  fi££!  Eflfid  UflJaL.  AUu  fiU    Raf.
ARSENIC f nil   (Freshwater: CCC • 190 ug/L; CMC » 360 ug/L)

600-15000  104     5      ?       ?     ?      48    41   7.6   Lima  et  al.  1984*

12600      100     3      FM      F     No     44    43   7.4   Spehar and Fiandt 1986




CADMIUM   (Freshwater:  CCC - 0.66 to 2.0 ug/L; CMC - 1.8  to  8.6 ug/L)11

o.i6       41      ?      DM      R     Yes    53    46   7.6   Chapman  1993
0'.28       75      ?      DM      R     Yes   103    83   7.9   Chapman  1993
 0.4-4.0     92°      ?      CS      F     No     21     19  .  7.1   Finlayson and Verrue 1982

 13          89      3      FM      F     No     44     43    7.4   Spehar and Fiandt 1986

 15-21      96      8      FM      S     No     42     31    7.5   Spehar and Carlson 1984
 42          84      4      FM      8     No     45     41    7.4   Spehar and Carlson 1984

 10          78      ?      DM      S     No     51     38    7.5   Chapman 1993
 35          77      ?      DM      S     No    105     88    8.0   Chapman 1993
 51          59      ?      DM      S     No    209    167    8.4   Chapman 1993

 6.80       80      8      ?       S     No     47     44    7.5   Call et al. 1982

 3-232      90"     5      ?       F     ?      46     42    7.4   Spehar et al. 1978

 450-6400   70      5      FM      F     No    202    157    7.7   Pickering and Cast 1972

-------
CHROMIUM rim  (Freshwater: CCC « 120 to 370 ug/L; CMC = 980 to 3100 ug/L)*
5-13
19-495
>1100
42
114
16840
26267
27416
58665
94 ? :;>.
86 ? -"
50-75 ?
54 ?
61 ?
26 ?
32 ?
27 ?
23 ?
CHROMIUM (VI) (Freshwater
>2b,000
43,300
COPPER
10-30
40-200
30-100

100-200
20-200
40-300
10-80
100 1
99.5 4
(Freshwater: CCC
74 ?
78 ?
79 ?

82 ?
86 ?
87 ?
89 ?
SG
SG
SG
DM
DM
DM
DM
DM
DM
: ccc
FM,GF
FM
- 6.5
CT
CT
CT

CT
CT
CT
CT
F
F
F
R
R
S
S
S
S
» 11
F
F
to 21
F
F
F

F
F
F
F
?
?
No
Yes
Yes
No
No
No
No
ug/L; CMC
Yes
No
25
25
25
206
52
<51
110
96
190
- 16
220
44
ug/L; CMC » 9
No
No
No

No
No
No
No
27
154
74

192
31
83
25
24
24
24
166
45
9
9
10
25
Ug/L)
214
43
.2 to
20
20
23

72
78
70
169
7.3
7.2
7.0
8.2
7.4
6.31
6.7
6.01
6.21

7.6
7.4
34 ug/L)
7.0
6.8
7.6

7.0
8.3
7.4
8.5
Stevens and Chapman 198
Stevens and Chapman 198
Stevens and Chapman 198
Chapman 1993
Chapman 1993
Chapman 1993
Chapman 1993
Chapman 1993
Chapman 1993

Adelman and Smith
Spehar and Flandt
p
Chakoumakos et al.
Chakoumakos et al.
Chakoumakos et al.
i .1
Chakoumakos et al.
Chakoumakos et al.
Chakoumakos et al.
Chakoumakoa et «i.







1976
1986

1979
1979
1979

1979
1979
1979
1470

-------
300-1300
100-400
3-41
12-911
18-19
201
50
17 51
5-52
6-80
6.7
35
13
16
51
32
33
39
25-84
17
120
15-90
12-162
28-58
26-59
56,101
92
94
125-167
79-84
95
95
96
91
••'82*
83°
57
43
73
57
39
S3
52
64
96
91
88
74
80"
85
79
86
?
?
2
i
2
1
2
2
?
?
?
?
?
?
?
?
?
?
14
6
14
19
?
6
7
2
CT
CT
CD
CD
DA
DA
FM
FM •
FM
CS
DM
DM
DM
DM
DM
DM
DM
DM
FM,GM
DM
SG
?
BG
DM
DM
DM
F
F
R
R
S
R
S
R
F
F
S
S
R
R
R
S
S
8
S
S
8
S
F
R
R
R
No
No
Yes
Yes
No
No
No
No
YesL
No
No
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
YesL
No
Yes"
Yes11
195
70
31
31
52
31
52
31
47
21
49
48
211
51
104
52
105
106
50
52
48
48
45
168
168
168
160
174
38
38
55
38
55
38
43
19
37
39
169
44
83
45
79
82
40
43
47
47
43
117
117
117
7.0
8.5
7.2
7.2
7.7
7.2
7.7
7.2
8.0
7.1
7.7
7.4
8.1
7.6
7.8
7.8
7.9
8.1
7.0
7.3
7.3
7.7
7-8
8.0
8.0
8.0
                   Chakoumakos et al. 1979
                   Chakotmakos et al. 1979

                   Carlson et al.' 1966a,b
                   Carlson et al. 1986a,b,
                   Carlson et al. I986b
                   Carlson et.al. I986b
                   Carlson et al. 1986b
                   Carlson et al. I986b

                   Llnd et al. 1978
                   Finlayson and Verrue 1982

                   Chapman 1993
                   chapman 1993

                   Chapman 1993
                   Chapman 1993    '
                   Chapman 1993

                   Chapman 1993
                   Chapman 1993'   '
                   Chapman 1993

                   Hammermeister et al. 1983
                   Hammermelster et al. 1983
                   Hammermeister et al. 1983

                   call et al. 1982

                   Benolt 1975

                   Lazorchak 1987
                   Lazorchak 1987
                   Lazorchak 1987
8

-------
96
86
FM
F
                                        NO
44
43   7.4   Spehar and Fiandt 1986
160
230-3000
94
>69->79
LEAD (Freshwater:
17
181
193
612
952
1907
7-29
34
58
119
235
474
4100
2100
220-2700
580
9
18
25
29
33
-38
10
62"
68M
71"
75M
81"
82"
79
96
95
1 FM
? CR
CCC * 1.3 to
? DM
? DM
? DM
? DM
? DM
? DM
? EZ
? BT
? BT
? BT
? BT
? BT
? BT
7 FM
14 FM,GM,DM
14 SG
S
F
7.7
R
R
R
S
S
S
R
F
F
F
F
F
F
F
S
S
No
No
ug/L; CMC
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
No
No
No
No
203
17
•= 34
52
102
151
50
100
150
22
44
44
44
44
44
44
44
49
51
171
13
to 200
47
86
126
--
—
••••
—
43
43
43
43
43
43
43
44
48
8.2
7.6
ug/L)F
7.6
7.8
8.1
_- _
	
— — —
	
7.2
7.2
7.2
7.2
7.2
7.2
7.4
7.2
7.2
                                                                Geckler et al. 1976
                                                                Rice and Harrison 1983
                                                                Chapman 1993
                                                                Chapnan 1993
                                                                Chapnan 1993

                                                                Chapnan 1993
                                                                Chapaan 1993
                                                                Chapnan 1993

                                                                JRB Associates  1983

                                                                Hoicombe et al.  1976
                                                                Holconbe et al.  1976
                                                                Holconbe et al.  1976
                                                                Holconbe et al.  1976
                                                                Holconbe et al.  1976
                                                                Holconbe et al.  1976

                                                                Spehar and Fiandt  1986

                                                                Hannemeister et al.  1983
                                                                Hannerneister et al.  1983
MERCURYfin   (Freshwater: CMC -  2.4 ug/L)

172        73       1      FM      F     No
                                    44    43   7.4   Spehar and  Fiandt 1986

-------
NICKEL  (Freshwater: CCC - 88 to 280 ug/L; CMC - 790 to 2500 ug/L)*
  21
 ISO
 578

 645
1809
1940
2344

4000
81
76
87
88
93
92
100
? DM
? DM
? •*? DM
? DM
? DM
? DM
? DM
R
R
R
S
S
S
S
Yes
Yes
Yes
No
No
No
No
51
107
205
54
51
104
100
49
87
161
43
44
84
84
7.4
7.8
8.1
7.7
7.7
8.2
7.9
90
PK
NO
21
Chapman 1993
Chapaan 1993
Chapaan 1993 '

Chapnan 1993
Chapaan 1993
Chapman 1993
Chapaan 1993
(            i
JRB Associates 1983"
SELENIUM   (FRESHWATER: CCC - 5 ug/L; CMC - 20 ug/L)

No data are available.



SILVER   (Freshwater: CMC - 1.2 to 13 ug/L; a CCC is not available)
0.19
9.98
4.0
4.0
3
2-54
2-32
4-32
5-89
6-401
74 "t
13 1
41 't
11 1
79 \
79 1
73 1
91 1
90 1
93 1
• DM
P DM
r DM
r DM
r FM
r FM
? FM
P FM
? FM
? FM
S
S
8
8
S
8
S
8
S
S
No
Yes
No
Yes
No
Yes0
No
No
No
No
47
47
36
36
51
49
50
48
120
249
37
37
25
25
49
49
49
49
49
49
7.6
7.5
7 .0
7.0
8.1
7.9
8.1
8.1
8.2
8.1
Chapman 1993
Chapaan 1993
Nebeker et
Nebeker et
UWS 1993
UWS 1993
UWS 1993
UWS 1993
UWS 1993
UWS 1993
al. 1983
al. 1983




i

                                             10

-------
ZINC   (Freshwater: CCC -  59  to 190 ug/L;  CMC 65 to 210 ug/I,)F
52
62
191
356
551
741
71
18-2731
167'
180
188-3931
551
40-500

1940
5520
<4000
>4000
160-400
240
31
77
77
74
78
76
71-129
81-107
99
94
100
100
95°

100
83
90
70
103
96
?
?
»'$
?
?
?
2
2
2
1
2
1
?

?
?
?
?
13
13
DM
DM
DM
DM
DM
DM
CD
CD
CD
CD
FM
FM
CS

AS
AS
FM
FM
FM,GM,DM
SG
R
R
R
S
S
S
R
R
R
S
R
S
F

F
F
F
F
S
S
Yes
Yes
Yes
No
No
No
Yes
Yes
No
No
No
No
No

No
No
No
No
No
NO
211
104
52
54
105
196
31
31
31
52
31
52
21

20
20
204
204
52
49
169
83
47
47
85
153
38
38
38
55
38
55
19

12
12
162
162
43
46
8.2
7.8
7.5
7.6
8.1
8.2
7.2
7.2
7.2
7.7
7.2
7.7
7.1

7.1
7.9
7.7
7.7
7.5
7.2
Chapman 1993
Chapman 1993
Chapman 1993
Chapman 1993
Chapman 1993
Chapman 1993
Carlson et al.
Carlson et al.
Carlson et al.
Carlson et al.
Carlson et al.
Carlson et al.
: Finlayson and
,
Sprague 1964
Sprague 1964
Mount 1966
Mount 1966
Hammermeister
Hammermeister


I986b
1986b
1986b
1986b
1986b
1986b
Verrue 1982
t \



et al. 1983
et al. 1983
A Total recoverable concentration.



• Except as noted, a 0.45-jim membrane  filter  was used.
                                             11

-------
c Number of paired comparisons.

0 The abbreviations used are:
         AS
         BT
         CD
         CR
         cs
         CT
         DA
Atlantic salmon
Brook trout
Ceriodjiphnia dubia
Crayfish
Chinook salmon
Cutthroat trout
Daphnids
DM
EZ
FM
GF
GH
PK
SG
Daphnia maqna
Elassoma gon.atum
Fathead minnow
Goldfish
Gammarid
Palaemonetes kadiakenaiS
Salmq aairdneri
B Tha abbreviations  used are:
         8 - static
         R » renewal
         F • flow- through
                                                       i
                                                       \
' The two numbers are  for  hardnesses of  50 and 200 mg/L, respectively.

u A 0.3-^m glass fiber filter was used.

M A 0.10-pm membrane filter was used.                               __.  '

1 The pH was below 6.5.

1 The dilution water was a clean river water with TSS and TOC below 5 ag/L.

K Only  limited information is available  concerning this value.

L  It  is  assumed that the solution  that was  filtered was from the test chambers that
   contained  fish and food.

M  The food was  algae.                                                    :r

N  The food was  yeast-trout  chow-alfalfa.

0  The food was  frozen adult brine  shrimp.
                                             12

-------
 References


 Adelman,.  I.R.,  and L.L.  Smith,  Jr.   1976.   standard Test Fish
 Development:.  Part I.  Fathead Minnows fPim«phal«a pronalasi  and
 Goldfish  rcaraaaiua auratuai  as Standard Fish in Bioassays  and
 Their Reaction  to Potential Reference Toxicants.  EPA-600/3-76-
 06la.  National Technical Information Service,  Springfield,  VA.
 Page 24.

 Benoit, D.A.  1975.   Chronic Effects of Copper on Survival,
 Growth, and Reproduction of the Bluegill (Lepoais aacrochlrus).
 Trans. An. Fish.  Soc.  104:353-358.

 Brungs, H.A., T.S.  Holderman, and M.T.  Southerland.   1992.
 Synopsis  of Hater-Effect Ratics -for-Heavy Metals as  Derived  for
 Site-Specific Water Quality Criteria.

 Call, D.J., L.T.  Brooke,  and D.D. Vaishnav.   1982.   Aquatic
 Pollutant Hazard  Assessments and Development  of a Hazard
 Prediction Technology by Quantitative Structure-Activity
 Relationships.  Fourth Quarterly Report.  University of
 Wisconsin-Superior, Superior, WZ.  .

 Carlson,  A.R.,  H. Nelson,  and D. Hammermeister.   1986a.
 Development and Validation of Sxte-Specific Water Quality
 Criteria  for Copper.   Environ.  Toxicol.  Chem.  5:997-1012.

 Carlson,  A.R.,  H. Nelson,  and D. Hammermeister.   1986b.
 Evaluation of Site-Specific Criteria for Copper and  Zinc: An
 Integration of  Metal Addition Toxicity,  Effluent and Receiving
 Water Toxicity, and Ecological  Survey Data.   EPA/600/S3-86-026.
 National  Technical  Information  Service,  Springfield,  VA.

 Carroll,  J.J.,  S.J. Ellis,  and W.S.  Oliver.   1979.   Influences  of
 Hardness  Constituents  on the Acute Toxicity of  Cadmium to Brook
Trout (Salvelinus tontlnalis).

Chakoumakos, C.,  R.C.  Russo,  and R.v.  Thurston.   1979.   Toxicity
 of Copper to Cutthroat Trout (Saloo  clariki) under Different
 Conditions of Alkalinity,  pH, and Hardness.   Environ. Sci.
 Techno!V  13:213-219.

 Chapman,  G.A.   1993.   Memorandum to  C.  Stephen.   June 4.

 Davies, P.H., J.P.  Goettl,  Jr.,  J.R. Sinley,  and N.F. Smith.
 1976.  Acute  and  Chronic Toxicity of Lead to  Rainbow Trout Salao
 grairdneri, in Hard  and Soft Water.   Water Res.  10:199-206.

 Finlayson, B.J.,  and  K.M Verrue.  1982.  Toxicities  of Copper,
 Zinc, and Cadmium Mixtures to Juvenile Chinook Salmon.   Trans.
 Am. Fish. Soc.  111:645-650.

                                13

-------
 Geckler, J.R.,  W.B. Horning, T.M. Neiheisel,  Q.H. Pickering, E.L.
 Robinson, and C.E.  Stephan.   1976.  Validity  of Laboratory Tests
 for Predicting Copper Toxicity in Streams.   EPA-600/3-76-lie.
 National Technical Information Service,  Springfield,  VA.  Page
 118.

 Grunwald, D.   1992.  Metal Toxicity Evaluation: Review,  Results,
 and Data Base Documentation.

 Hammermeister,  D.,  c. Northcott,  L. Brooke, and D. Call.  1983.
 Comparison of Copper', Lead and Zinc Toxicity  to Four Animal
 Species in Laboratory and ST.  Louis River Water.   University of
 Wisconsin-Superior, Superior,  WI.

 Hansen,  D.J.  1993.  Memorandum to C.E.  Stephan.   April  15.

 Holcombe,  G.W.,  D.A.  Benoit, E.N. Leonard, and  J.M. McKim.   1976.
 Long-Term Effects of  Lead Exposure on Three Generations  of  Brook
 Trout  (5alvelijius iontin&lis).  J.  Fish.  Res. .Bd.  Canada 33:1731-
 1741.

 Holcombe,  G.W.,  and R.W.  Andrew.   1978.   The Acute Toxicity of
 Zinc to  Rainbow  and Brook Trout.   EPA-600/3-78-094.  National
 Technical  Information Service,  Springfield, VA.

 Horowitz,  A.J.,  K.A.  Elrick, and  M.R. Colberg.  1992.  The  Effect
 of Membrane Filtration Artifacts  on Dissolved Trace Element
 Concentrations.  Water Res.  26:753-763.

 Howarth, R.S., and  J.B. Sprague.   1978.   Copper Lethality to
 Rainbow  Trout in Waters on Various  Hardness and pH.  Water  Res.
 12:455-462.

JRB Associates.  1983.  Demonstration of  the Site-specific
Criteria Modification Process:  Selser's Creek.  Ponchatoula,
Louisiana.

Lazorchak, J.M.  1987.  The  Significance  of Weight Loss  of
Daohnia  maema Straus  During Acute Toxicity Tests with Copper.
Ph.D. Thesis.

 Lima, A.R., C. Curtis, D.E.  Hammermeister, T.P. Markee,  C.E.
Northcott, L.T.  Brooke.   1984.  Acute and Chronic  Toxicities of
Arsenic(III) to  Fathead Minnows,  Flagfish, Daphnids, and an
Amphipod.  Arch. Environ.  Contam. Toxicol. 13:595-601.

 Lind, D.,  K. Alto,  and S.  Chatterton.  1978.  Regional Copper-
 Nickel Study.  Draft.

Mount, D.I,  1966.  The Effect  of Total Hardneas  and pH  on  Acut«
Toxicity of Zinc to Fish.  Air  water Pollut. Int.  J.  10:49-56.


                                14

-------
 Nebeker, A.V., c.K. McAuliffe, R. Mshar, and D.G. Stevens.  1983.
 Toxicity of Silver to Steelhead and Rainbow Trout, Fathead
 Minnows, and Daphnia magna.  Environ, toxicol. Chem. 2:95-104.

 Pickering,  Q.P.,  and M.H. Cast.  1972.  Acute and Chronic
 Toxicity of Cadmium to the Fathead Minnow (Pimephales promela*).
 J.  Fish. Res.  Bd.  Canada 29:1099-1106.

 Rice,  D.W.,  Jr.,  and F.L. Harrison.  1983.   The Sensitivity of
 Adult,  Embryonic,  and Larval Crayfish Procaobams clarJcii to
 Copper.   NUREG/CR-3133 or UCRL-53048.  National Technical
 Information Service,  Springfield,  VA.

 Schuytema,  G.S.,  P.O.  Nelson, K.W.  Malueg,  A.V.  Nebeker,  O.F.
 Krawczyk, A.K.  Ratcliff,  and J.H.  Gakstatter.   1984.  Toxicity of
 Cadmium in  Water  and: Sediment Slurrie* to .Daphnia magna.
 Environ. Toxicol.  Chem.  3:293-308.

 Spehar,  R.L.,  R.L.  Anderson,  and.J.T. Fiandt.   1978.  Toxicity
 and Bioaccumulation of Cadmium and Lead in  Aquatic Invertebrates.
 Environ.  Pollut.  15:195-208.

 Spehar,  R.L.,  and A.R.  Carlson.   1984.   Derivation of Site-
 Specific Hater  Quality Criteria for Cadmium and  the St. Louis
 River Basin, Duluth, Minnesota.  Environ. Toxicol.  Chem.  3:651-
 665.

 Spehar,  R.L., and J.T. Fiandt.   1986.  Acute and Chronic  Effects
 of Water Quality Criteria-Based Metal Mixtures on Three Aquatic
 Species.  Environ. Toxicol. Chem. 5:917-931.

 Sprague, J.B.   1964.  Lethal  Concentration of Copper and  Zinc  for
 Young Atlantic  Salmon.  J.  Fish. Res. Bd. Canada 21:17-9926.

 Stevens, D.G.,  and G.A., Chapman.  1984.  Toxicity of Trivalent
 Chromium to Early Life Stages of Steelhead Trout.   Environ.
Toxicol. Chem.  3:125-133.

University of Wisconsin-Superior.   1993.  Preliminary data from
work assignment 1-10 for  Contract No.  68-C1-0034.
                                15

-------
                                                             ATTACHMENT #3
                              GUIDANCE DOCUMENT
                  ON DYNAMIC MODELING AND TRANSLATORS
                                      August 1993
 TtHfll Maximum Daily Loads fTMDLs) and Permits

 o     Dynamic Water Quality Modeling

       Although not specifically part of the reassessment of water quality criteria for metals,
 dynamic or probabilistic models are another useful tool for implementing water quality
 criteria, especially those for protecting aquatic life.  Dynamic models make best use of the
 specified magnitude, duration, and frequency of water quality criteria and thereby provide a
 more accurate calculation of discharge impacts on ambient water quality. In contrast, steady-
 state modeling is based on various simplifying assumptions which makes it less complex and
 less accurate than dynamic modeling.  Building on accepted practices in water resource
 engineering, ten yean ago OW devised methods allowing the use of probability distributions
 in place of worst-case conditions.  The description of these models and their advantages and
 disadvantages is found in the  1991 Technical Support Document for Water Quality-based
Toxic Control (TSD).

       Dynamic models have received increased attention in the last few yean as a result of
 the perception that static modeling is over-conservative due to environmentally conservative
 dilution assumptions.  This has led to the misconception that dynamic models will always
justify less stringent regulatory controls (e.g. NPDES effluent limits) than static models. In
 effluent dominated waters where the upstream concentrations are relatively constant,
 however, a dynamic model will calculate a more-stringent wasteload allocation than will a
 steady state model.  The reason is that die critical low flow required by many State water
 quality standards in effluent dominated streams occurs more frequently than once every three
 years.  When other environmental factors (e.g. upstream pollutant concentrations) do not
 vary appreciably, then the overall  return  frequency of the steady stale model may be greater
 than once jo three yean.  A dynamic modeling approach, on the other hand, would be more
 stringent, allowing only a once in  three year return  frequency. As a result, EPA considers
 dynamic models to be a more accurate rather than a less stringent approach to implementing
 water quality criteria.

       The 1991 TSD provides recommendations on the use of steady state and dynamic
 water quality models. The reliability of  any modeling technique greatly depends on the
 accuracy of the data used in the analysis. Therefore, the selection of a model also depends
 upon The data.  EPA recommends that steady state wasteload allocation analyses generally be
 used where few or no whole effluent toxiciry or specific chemical measurements are
 available, or where daily receiving water flow records are not available.  Also, if staff
 resources are insufficient to use and defend the use  of dynamic models, then steady state

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 models may be necessary. If adequate receiving water flow and effluent concentration data
 are available to estimate frequency distributions, EPA recommends that one of the dynamic
 -wasteload allocation modeling techniques.be used to derive wasteload allocations which will
 more exactly maintain water quality .standards. The minimum data required for input into
 dynamic models include at least 30 years of-river flow data and one year of effluent and
 ambient pollutant concentrations.
 o     Dissolved-Total Metal Translators

       When water quality criteria are expressed as the dissolved form of a metal, there is a
 need to translate TMDLs and NPDES permits to and from the dissolved form of a metal to
 the total recoverable form. TMDLs for toxic metals must be able to calculate 1) the
 dissolved metal concentration in order to ascertain attainment of water quality standards and
 2) the total recoverable metal concentration in order to achieve mass balance. In meeting
 these requirements, TMDLs consider metals to be conservative pollutants and quantified as
 total recoverable to preserve conservation of mass. The TMDL calculates the dissolved or  -
 ionic species of the metals based on factors such as total suspended solids (TSS) and ambient
 pH.  (These assumptions ignore the complicating factors of metals interactions with other
 metals.)  In addition, this approach assumes that ambient factors influencing metal
 partitioning remain constant with distance down the river.  This assumption probably is valid
 under the low flow conditions typically used as design flows for permitting of metals (e.g.,
 7Q10, 4B3, etc) because erosion, resuspension, and wet weather loadings are unlikely to be
 significant and river chemistry is generally stable.  In steady-state dilution modeling, metals
 releases may be assumed to remain fairly constant (concentrations exhibit low Variability)
 with time.

       EPA's NPDES regulations require that metals limits in permits be stated as total
 recoverable in most cases (see 40 CFR *122.45(c)). .Exceptions occur when an effluent
guideline specifies the limitation in .another form of the metal or the approved analytical
 methods measure only the  dissolved form.  Also, the permit writer may express a metals
 limit in another form (e.g., dissolved, valent, or total) when required, in highly unusual
cases, to cany out die provisions of the CWA.

       The preamble to the September 1984 National Pollutant Discharge Elimination System
 Permit Regulations states that the total recoverable method measures dissolved metals plus
 that portion of solid metals that can easily dissolve under ambient conditions (see 49 Federal
 Register 38028, September 26,1984). This method is intended to measure metals in the
effluent that are or may easily become environmentally active, white not measuring metals
 that are expected to settle out and remain inert.

       The preamble cites, as an example, effluent from an electroplating facility that adds
 lime and uses clarifiers. This effluent will be a combination of solids not removed by the
 clarifiers and residual dissolved metals.   When  the effluent from the clarifiers, usually with a

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 high pH level, mixes with receiving water having significantly lower pH level, these solids
 instantly dissolve.  Measuring dissolved metals in the effluent, in this case, would
 underestimate the impact on the receiving water.  .Measuring with the total metals method, on
 the other hand, would measure metals that would be expected to disperse or settle out and
 remain inert or be covered over. Thus, measuring total recoverable metals in the effluent
 best approximates the amount of metal likely to produce water quality impacts.

       However, the NPDES rule does not require in any way that State water quality
 standards be in the total recoverable form; rather, the rule requires permit writers to consider
 the translation between differing metal forms in the calculation of the permit limit so that a
 total recoverable limit can be established.  Therefore, both the TMDL and NPDES uses of
 water quality criteria require the ability to translate from the dissolved form and the total
 recoverable form.

       Many toxic substances, including metals, have a tendency to leave the dissolved phase
 and attach to suspended solids.  The partitioning of toxics between solid and dissolved phases
 can be determined as a  function of a pollutant-specific partition coefficient and the
 concentration of solids.  This function is expressed by a linear partitioning equation:
                        1+JT/7SS-10"'
                                                           where,
                          dissolved phase metal concentration,
                          total metal concentration,
                    TSS * total suspended solids concentration, and
                    K* » partition coefficient.
       A key assumption of the linear partitioning equation is that the sorption reaction
reaches dynamic equilibrium at the point of application of the criteria; mat is, after allowing
for initial mixing the partitioning of the pollutant between the adsorbed and dissolved forms
can be uaeid at any location to predict the fraction of pollutant in each respective phase.

       Successful application of the linear partitioning equation relies on tile selection of the
partition coefficient  The use of a partition coefficient to represent the degree to which
toxics adsorb to solids is most readily  applied to organic pollutants;  partition coefficients for
metals are more difficult to define.  Metals  typically exhibit more complex speciation and
complexation reactions than organics and  the degree of partitioning can vary greatly
depending upon site-specific water chemistry. Estimated partition coefficients can be
determined for a number of metals,  but waterbody or site-specific observations of dissolved
and adsorbed concentrations are preferred.

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       EPA suggests three approaches for instances where a water quality criterion for a
metal is expressed in the dissolved form in a State/s water quality standards:

       1.  Using clean analytical techniques and field sampling procedures with appropriate
       QA/QC, collect receiving water samples and determine site specific values of K^ for
       each metal.  Use these K< values to 'translate' between total recoverable and
       dissolved metals in receiving water. This approach is.more difficult to apply because
       it relies upon the availability of good quality measurements of ambient metal
       concentrations.  This approach provides an accurate assessment of the dissolved metal
       fraction providing sufficient samples are collected.  EPA's initial recommendation is
       that at least four pain of total recoverable and dissolved ambient metal measurements
       be made during low flow conditions or 20 pain over aU flow conditions.  EPA
       suggests that the average of data collected during low flow or the 95th percentile  -
       highest dissolved fraction for all flows be used.  The low flow average provides a
       representative picture of conditions during the rare low flow events. The 95th
       percentile highest dissolved fraction for all flows provides a critical condition
       approach analogous to the approach used to identify low flows and other critical
       environmental conditions.

       2.  Calculate the total recoverable concentration for the purpose of setting the permit
       limit.  Use a value of 1 unless the permittee has collected data (see i 1 above) to show
       that a different ratio should be used. The value of 1 is conservative and will not err
       on  the side of violating standards.  This approach is very simple to apply because it
       places the entire burden of data collection and analysis solely upon permitted
       facilities. In terms of technical merit, it has the same characteristics of the previous
       approach. However, permitting authorities may be faced with difficulties in
       negotiating with facilities on the amount of data necessary to determine the ratio and
       the necessary  quality control methods to assure that the ambient data are reliable.

       3.  Use the historical data on total tiiipmdcd solids (TSS)  in receiving waterbodies at
       appropriate design flows and K* values presented in the Technical Guidance Manual
       for Performing Waste Load Allocations.  BookIL Streams and Riven.  EPA-440/4-
       84-020 (1984) to "translate" between (total recoverable) permits limits and dissolved
       metals in receiving water.  This approach is fairly simple to apply. However, these
       K< values are suspect due to possible quality assurance problems with the data used to
       develop the values.  EPA's initial analysis of this approach and these values in one
       site indicates that these K* values generally over-estimate the dissolved fraction of
       metals in ambient waters (see Figures following). Therefore, although this  approach
       may not provide an smiratf estimate of the dissolved fraction, the bias in die estimate
       is likely to be a conservative one.

       EPA suggests that regulatory authorities use approaches f 1 and 12 where States
express their water quality standards in the dissolved form.  In mote States where the
standards are in the total recoverable or acid  soluble form, EPA recommends mat no

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translation be used until the time that the State changes the standards to the dissolved form.
Approach #3 may be used as an interim measure until the data are collected to implement
approach Ml.

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Di««olv*d Copp«r Concentration*
                                       -H
                                        45
                                               iv-  Measured

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M«asur«4 *•• Mod«l«4 Dissolved Cadaiua Concentrations
         10
IS
 20      25
Sampling Station
30
35
40
                                                                            Modeled
                                                                            Measured

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                            *».  Mo4«l«4 Diasolvad L«ad Concentration*
1    -^
                                                                                        "  M000MO



                                                                                      "   Measured

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            M«Mur«d  vs. Nod«l«d Dissolved lUroury  concentration*
0.12
 0.1
008
006
094
002
                                                       • -, Modeled
                                                          i
                                                       "   Measured
                    10
15
20
25
30
35
40
45

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Miek«l Concentrttiona
                                          Modeled
                                          Measured

-------
              M«Mur«4 *•.  M*c«l«d DUaolvad  lino Concentrations
  30
  25
  20
i»
  10
W.
                                                 ,^
                                           25
                                  SampUng Station
   b-°n

30      35
40
                                       •   Modeled
                                       «>  Measured
                               45

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                 Mtmmur«6 *••  Mo4«l«4 Dl««olv«d Ars«nio Concentrations
      2.5
»    T
      IS
      O.S
                                                                        40
 i:
-H

 45
                                                                                       it
            Measured

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                                                      ATTACHMENT #4
                             GUIDANCE DOCUMENT
           ON CLEAN ANALYTICAL TECHNIQUES AND MONITORING
                                    October 1993
Guidance on Monitoring

o    Use of Clean Sampling and Analytical Techniques

     Appendix B to the WER guidance document (attached) provides some general guidance
on the use of clean techniques.  The Office of Water recommends that this guidance be used
by States and Regions as an interim step while the Office of Water prepares more detailed
guidance.


o     Use of Historical DMR Data

      With respect to effluent or ambient monitoring data reported by ah NPDES permittee
on a Discharge Monitoring Report (DMR), the certification requirements place the burden on
the permittee for collecting and reporting quality data.  The certification regulation at 40
CFR 122.22(d) requires permittees, when submitting information, to state:  "I certify under
penalty of law that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly
gather and evaluate the information submitted. Based on my inquiry of the person or persons
who manage the system, or those persons directly responsible for gathering the information.
the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information.
            possibility of fine and imprisonment for knowing violations."
       Pei'mitting authorities should continue to consider the information reported in DMRs
to be true, accurate, and complete as certified by the permittee.  Under 40 CFR 122.410K8).
however, as soon as the permittee becomes aware of new information specific to the effluent
discharge that calls into question the accuracy of the DMR data, the permittee must submit
such information to the permitting authority. Examples of such information include a new
finding that the reagents used in the laboratory analysis are contaminated with trace levels of
metals, or a new study that the sampling equipment imparts trace metal contamination.  This
information must be specific to the discharge and based on actual measurements rather than
extrapolations from reports from other facilities.  Where a permittee submits information

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supporting the contention that the previous data are questionable and the permitting authority
agrees with the findings of the information, EPA expects that permitting authorities will
consider such information in determining appropriate enforcement responses.

       In addition to submitting the information described above, the permittee also must
develop procedures to assure the collection and analysis of quality data that are true,
accurate, and complete. For example, the permittee may submit a revised quality assurance
plan that describes the specific procedures to be undertaken to reduce or eliminate trace
metal contamination.

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                                                        10-1-93
 Appendix B. Guidance Concerning the Use of "Clean Techniques" and
             QA/QC in the Measurement of Traea Metals


 Recent information (ShiHer and Boyle 1987; windom et al.  1991)
 has raised questions concerning the quality of reported
 concentrations of trace metals in both fresh and salt (estuarine-
 and marine)  surface waters.  A lack of awareness of true ambient
 concentrations of metals in saltwater and freshwater systems can
 be both a cause and a result of the problem.  The ranges of
 dissolved metals that are typical in surface waters of the United
 States away from the immediate influence of discharges (Bruland
 1983;. Shillar and Boyle 1985,1987; Trefry et al.  1986; Windom et
 al.  1991)  are:

            Metal        Salt water          Fresh water
           	         fucr/Ll               fua/Ll
          Cadmium      0.01   to   0.2        0.002 to 0.08
          Copper       0.1    to   3.         0.4   to 4.
          Lead         0.01   to   1.         0.01  to 0.19
          Nickel       0.3    to   5.         1.    to 2.
          Silver       0.005  to   0.2
          Zinc         o.l    to 15.         0.03  to 5.

The U.S. EPA  (1983,1991) has published analytical methods for
monitoring metals in waters  and  wastewatars, but these methods
are inadequate for determination of ambient concentrations of
some metals in some surface  waters.  Accurate and precise
measurement of these low concentrations requires appropriate
attention to seven areas:
l. Use of "clean techniques" during collecting, handling,
   storing, preparing, and analyzing samples to avoid
   contamination.. •	
2. Use of analytical methods that have sufficiently low detection
   limits.
3. Avoidance of interference in  the quantification (instrumental
   analysis) step.
4. Use of blanks to assess contamination.
5. Use^jOf matrix spikes (sample  spikes) and certified reference
   materials  (CRMs) to assess interference and contamination.
6. Use of replicates to assess precision.
7. Use of certified standards.
In a strict sense, the term  "clean techniques" refers to
techniques that reduce contamination and enable the accurate and
precise measurement of trace metals in fresh and salt surface
waters.  In a broader  sense, the term also refers to related
issues concerning detection  limits, quality control, and quality
assurance.  Documenting data quality demonstrates the amount of
confidence that can be placed in the data, whereas increasing the
sensitivity of methods reduce the problem of deciding how to

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 interpret results that are reported to  be  below detection limits.

 This  appendix ia  written for thoaa  analytical  laboratories that
 want  guidance concerning wava to  lowar  detection  limits,  ineraaaa
 precision, and/or ineraaaa accuracy.  The  ways to achieve these
 goals are to  increase  the .sensitivity of the analytical methods,
 decrease  contamination,  and decrease interference.   Ideally,
 validation of a procedure for measuring concentrations of metals
 in i surface water  requires demonstration that agreement can be
 obtained  using completely different procedures beginning  with the
 sampling  step and continuing through the quantification step
 (Bruland  et al. 1979),  but few laboratories have  the resources to
 compare two different  procedures.   Laboratories can, however, (a)
 use techniques that others have found useful for  improving
 detection limits,  accuracy,  and precision, and (b) document data
 quality through use of  blanks,  spikes,  CRMs, replicates,  and
 standards.

 In general, in order to achieve accurate and precise measurement
 of a  particular concentration,  both the detection limit and the
 blanks should be  less than one-tenth of that concentration.
 Therefore, the term "metal-free" can be interpreted to mean that
 the total amount  of contamination that  occurs during sample
 collection and processing (e.g., from gloves, sample containers,
 labware,  sampling apparatus,  cleaning solutions,  air, reagents,
etc.) is  sufficiently low that  blanks are  less than one-tenth of
the lowest concentration that needs to  be measured.

Atmospheric particulates can  be a major source of contamination
 (Moody 1982;  Adeloju and Bond 1985).  The term "class-100"  refers
to a  specification concerning the amount of particulates in air
 (Moody 1982);  although the  specification says nothing about the
composition of the particulates, generic control  of particulates
can greatly reduce trace-metal  blanks.  Except during collection
of samples and initial  cleaning of  equipment, all handling  of
samples,  sample containers,  labware, and sampling apparatus
should be performed in  a class-100  bench,  room, or glove box.

Nothing contained or not contained  in tftia appendix adda to or
 subtracts from anv regulatory raquira-aen'ta set forth in other RPA
document:* concerning aetal analyses.  The word "must" is used in
 this  appendix merely to indicate items  that are considered very
 important by  analytical chemists who have  worked  to  increase
 accuracy  and  precision and lower detection limits in trace-metal
 analysis.  Some items  are considered important because they have
 been  found to have received inadequate  attention  in  some
 laboratories  performing trace-metal analyses.

 Two topics that are not addressed in this  appendix are:
 1. The "ultraclean techniques"  that are likely to be necessary
   when trace analyses of mercury are performed.
 2. Safety in  analytical laboratories.

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Other  documents  should be consulted if  these topics  are of
concern.

Avoiding  contamination bv use  of "clean techniques*

Measurement of trace  metals in receiving waters vast take into
account the potential for contamination.during each  step in the
process.  Regardless  of the specific procedures used for
collection, handling,  storage,  preparation (digestion,
filtration, and/or extraction),  and quantification (instrumental
analysis), the general principles of contamination control must
be applied.  Some specific recommendations are:
a. Noir-talc latex or  class-100  polyethylene gloves must be worn
   during all steps from sample collection to analysis.   (Talc
   seems to be a particular problem with zinc; gloves made with
   talc cannot be decontaminated sufficiently.)  Gloves should
   only contact surfaces that' are metal-free;  gloves should be
   changed if even suspected of  contamination.
b. The acid used to acidify samples for preservation and
   digestion and to acidify water for final cleaning of labware,
   sampling apparatus,  and sample containers must  be metal-free.
   The quality of the  acid used  should  be better than reagent-
   grade.  Each lot of acid must be analyzed for the metal(s) of
   interest before use.
c. The water used to prepare acidic cleaning solutions  and  to
   rinse labware, sample containers,  and sampling  apparatus may
   be prepared by distillation,  deionization, or reverse osmosis,
   and must be demonstrated to be metal-free.
d. The work area, including bench tops  and hoods,  should be
   cleaned (e.g., washed and wiped  dry  with lint-free,  class-100
   wipes) frequently to  remove contamination.
e. All handling of samples  in the laboratory, including filtering
   and analysis, must  be performed  in a class-100  clean  bench or
   a glove box fed by  particle-free air or nitrogen; ideally the
   clean bench or glove  box should  be located within a  class-100
   clean room.: «
f. Labware,  reagents,  sampling apparatus,  and sample containers
   must never be left  open  to the atmosphere; they should be
   stored in a class-100  bench,  covered with plastic wrap,  stored
   in a plastic box, or  turned upside down on a clean surface.
   Minimizing the time between cleaning and using  will  help
   minimize contamination.
g. Separate sets of sample  containers,  labware, and  sampling
   apparatus should be dedicated for different kinds of samples,
   e.g., receiving water samples, effluent samples,  etc.
h. To avoid contamination of clean  rooms,  samples  that  contain
   very high concentrations of metals and do not require use of
   "clean techniques"  should not be brought into clean  rooms.
i. Acid-cleaned plastic,  such as high-density polyethylene
   (HOPE), low-density polyethylene (LDPE),  or .a fluoroplastic,
   must be the only material that ever  contacts a  sample, except
   possibly during digestion for the total recoverable

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 measurement.   (Total recoverable samples can be digested in
 some plastic  containers.)   Even HOPE and LOPE night not be
 acceptable for mercury,  however.
 All  labware,  sample containers,  and  sampling apparatus mist be
 acid-cleaned  before use  or  reuse.
 1. sample  containers,  sampling  apparatus,  tubing,  membrane
   filters, filter assemblies,  and other labware Bust be
   soaked  in  acid  until  metal-free.   The amount of cleaning
   necessary  might depend on the amount  of contamination and
   the  length of time  the item will  be in contact  with
   samples.   For example, if an  acidified sample will be
   stored  in  a sample  container  for  three weeks, ideally the
   container  should have been soaked in  an- acidified metal-
   free solution for at  least three  weeks.
 2. It might be desirable to perform  initial cleaning,  for
   which reagent-grade acid may be used, before the  items are
   allowed into a  clean  room.  For most metals, items should
   be either  (a) soaked  in 10 percent concentrated nitric acid
   at 50*C for at  least  one hour, or (b) soaked in 50  percent
   concentrated nitric acid at'room  temperature for  at least
   two days;  for arsenic and mercury, soaking for up to two
   weeks at 50 •€ in 10 percent concentrated nitric acid might
   be required.  For plastics that might be damaged  by strong
   nitric acid, such as polycarbonate and possibly HOPE and
   LOPE, soaking in 10 percent concentrated hydrochloric  acid,
   either in place of or before soaking in a nitric  acid
   solution, might be desirable.
3. Chromic acid must not be used to clean items that will  be
   used in analysis of metals.
4. Final soaking and cleaning of sample containers],  labware,
   and sampling apparatus must be performed in a class-100
   clean room using metal-free acid and water.  The solution
   in an acid bath must be analyzed periodically to
   demonstrate that it is metal-free.
5. After labware and sampling apparatus are cleaned, they may
   be stored in a clean room in a weak acid bath prepared
   using metal-free acid and water.   Before use, the items
   should be rinsed at least three times with metal-free
   water.   After the final rinse, the items should be moved
   immediately, with the open end pointed down, to a class-100
   clean bench.  Items may be dried on a class-100 clean
   bench; items must not be dried in an oven or with
   laboratory towels.  The sampling apparatus should be
   assembled in a class-100 clean room or bench and  double-
   bagged in metal-free polyethylene xip-type bags for
   transport to the field; new bags are usually mmtal-free.
6. After sample containers are cleaned, they should  be filled
   with metal-free water that has been acidified to  a  pH  of  2
   with metal-free nitric acid (about 0.5 mL per liter) for
   storage until use.  At the time of sample collection,  the
   sample containers should be emptied and rinsed at least
   twice with the solution being sampled before the  actual

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       sample is placed in the sample container.
    Field samples must be collected in a manner that eliminates
   -the potential for contamination from the sampling platform,
    probes,  etc.  Exhaust from boats and the direction of wind and
    water currents should be taken into account.   The people who
    collect  the samples must be specifically trained on how to
    collect  field samples.  After collection,  all handling of
    samples  in the field that will expose the sample to air must
    be performed in a portable class-100 clean bench or glove box.
    Samples  must be acidified (after/filtration if dissolved metal
    is to be measured)  to a pH of less than 2, except that the pH
   must be  less than 1 for mercury.   Acidification should be done
    in a clean room or bench,  and so it might be  desirable to wait
    and acidify samples in a laboratory rather than in the field.
    If samples are acidified in the field,  metal-free acid can be
    transported in plastic bottles.andipoured:into a plastic
    container from which acid can be removed and  added to samples
   using plastic pipettes.   Alternatively,  plastic automatic
   dispensers can be used.
   Such things as probes and thermometers  must mot be put in
   samples  that are to be analyzed for metals.   In particular, pH
   electrodes and mercury-in-glass thermometers  must not be used
    if mercury is to be measured.   If pH is measured,  it  must be
   done on  a separate  aliquot.
   Sample handling should be minimized.  For  example,  instead of
   pouring  a sample into a graduated cylinder to measure the
   volume,  the  sample  can be weighed after being poured  into a
   tared  container;  alternatively, the  container from which the
   sample is  poured can be weighed.   (For  saltwater samples,  the
   salinity or  density should be taken  into account when weight
   is converted to  volume.)
   Each reagent used must be verified to be metal-free.  If
   metal-free reagents  are not commercially available, removal of
   metals will  probably be necessary.
   For the  total recoverable measurement,* samples should be
   digested in  a class-100 bench, not in a  metallic-hood.   If  .
   feasible,  digestion  should be done in the sample container by
   acidification and heating.
   The longer the time  between collection and analysis of
   samples,   the greater the chance of contamination,  loss, etc.
   Samples  must be  stored  in the dark,  preferably between 0  and
   4»C with no  air  space  in the sample  container.
Achieving low detection limits

a. Extraction of the metal from the sample can be extremely
   useful if it simultaneously concentrates the metal and
   eliminates potential matrix interferences.  For example,
   ammonium 1-pyrrolidinedithiocarbamate and/or diethylammoniua
   diethyldithiocarbamate can extract cadmium, copper, lead,

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   nickel,  and zinc (Bruland et al.  1979; Mriagu  et al.  1993).
 b. The detection limit should be less than  ten percent of  the
   lowest concentration that is to be measured.

 Avoiding  interferences

 a. Potential  interferences must be assessed for the specific
   instrumental analysis -technique used and each  metal to  be
   -measured.                                        '•     "
 b. If  direct  analysis  is used,  the salt present in high-salinity
   saltwater  samples is likely to cause interference in most
   instrumental techniques.
 c. As  stated  above, extraction of the metal  from  the sample  is
   particularly.useful because it simultaneously  concentrates the
   metal  and  eliminates potential matrix interferences.
Uaina blanks to assess contamination

a. A laboratory (procedural, method) blank consists of filling a
   sample container with analyzed metal-free water and processing
   (filtering, acidifying, etc.) the water through the laboratory
   procedure in exactly the same way as a sample.  A laboratory
   blank must be included in each set of ten or fewer samples to
   check for contamination in the laboratory, and most contain
   less than ten percent of the lowest concentration that is to
   be measured.  Separate laboratory blanks must be processed for
   the total recoverable and dissolved measurements, if both
   measurements are performed.
b. A field (trip) blank consists of filling a sample container
   with analyzed metal-free water in the laboratory, taking the
   container to the site, processing the water through tubing,
   filter, etc., collecting the water in a sample container, and
   acidifying the water the -same as a field sample.  A field
   blank must be processed for each sampling trip.  Separate
   field blanks must be processed for the total recoverable
   measurement and for the dissolved measurement, if filtrations
   are performed at the site.  Field blanks must be processed in
   the laboratory the same as laboratory blanks.
Assessing accuracy

a. A calibration curve must be determined for each analytical run
   and the calibration should be checked about every tenth
   sample,  calibration solutions mast be traceable back to a
   certified standard from the U.S. EPA or the National Institute
   of Science and Technology (HIST).
b. A blind standard or a blind calibration solution must be
   included in each group of about  twenty samples.

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c. At  least  one of  the following must be included in each group
   of  about  twenty  samples:            '•
   1.  A matrix  spike  (spiked saaple;  the method of known
       additions).
   -2.  A CRN,  if one is available in a matrix that closely
     -  approximates  that of the samples.  .Values obtained for the
       CRN must  be within the published values.
The concentrations  in blind  standards and solutions,  spikes,  and
CRMs vast met be more than 5 times  the median concentration
expected to  be  present in the samples.
Assessing precision

a. A sampling replicate must be  included with each set of samples
   collected at each sampling  location.
b. If the volume of the sample is  large enough, replicate
   analysis of at least one sample must be performed along with
   each group of about ten samples.
Special eonsi.derafei.ons eoncemi.no the dissolved Measurement

Whereas the total recoverable measurement is especially subject
to contamination during the digestion step, the dissolved
measurement is subject to both loss and contamination during the
filtration step.
a. Filtrations must be performed using acid-cleaned plastic
   filter holders and acid-cleaned membrane filters.  Samples
   must not be filtered through glass fiber filters, even if the
   filters have been cleaned with acid.  If positive-pressure
   filtration is used, the air. or gas must be passed through a
   0.2-um in-line filter; if vacuum filtration is used, it must
   be performed on a class-100 bench.
b. Plastic filter holders must be rinsed and/or dipped between
   filtrations, but they do not have to be soaked between
   filtrations if all the samples contain about the same
   concentrations of metal.  It is best to filter samples from
   lowr^fc high concentrations.  A membrane filter must met be
   used for more than one filtration.  After each filtration, the
   membrane filter must be removed and discarded, and the filter
   holder must be either rinsed with metal-free water or dilute
   acid and dipped in a metal-free acid bath or rinsed at least
   twice with metal-free dilute acid; finally, the filter holder
   must be rinsed at least twice with metal-free water.
c. For each sample to be filtered, the filter holder and membrane
   filter must be conditioned with the sample, i.e., an initial
   portion of the sample must be filtered and discarded.

The accuracy and precision of the dissolved measurement should be

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 assessed periodically.   A large volume of a buffered solution
 (such as aerated 0.05 N sodium bicarbonate)  should be spiked so
 that th« concentration of the metal of'interest is in the range
 of the lov concentrations that are to be measured.  The total
 recoverable concentration and the dissolved concentration of the
 aetal in the spiked buffered solution should be measured
 alternately until each measurement has been performed at least
 ten times.   The means and standard deviations for the two
 measurements should be the same.   All values deleted as outliers
 must be acknowledged.
Raporti.no reaulta

To indicate the quality of. the data, reportsof results  of
measurements of the concentrations of metals mast include a
description of the blanks, spikes, CRMs, replicates, and
standards that were run, the number run, and the results
obtained.  All values deleted as outliers must be acknowledged.
Additional  information

The items presented above are some of the important aspects of
"clean techniques"; some aspects of quality assurance and quality
control are also presented.  This is not a definitive treatment
of these topics; additional information that might be useful is
available in such publications as Patterson and Settle (1976),
Zief and Mitchell (1976), Bruland et al. (1979), Moody and Beary
(1982), Moody (1982), Bruland (1983), Adeloju and Bond (1985),
Herman and Yeats (1985), Byrd and Andreae (1986), Taylor (1987),
Sakamoto-Arnold (1987), Tramontane et al. (1987), Puls and
Barcelona (1989), Windom et al. (1991), U.S. EPA (1992), Horowitz
et al. (1992), and Mriagu et al. (1993).
References

Adelo}«; S.B., and A.M. Bond.  1985.  Influence of Laboratory
Environment on the Precision and Accuracy of Trace Element  *
Analysis.  Anal. Chem. 57:1728-1733.

Barman, S.S.t and P.A. Yeats.  1985.  Sampling of Seawater  for
Trace Metals.  CRC Reviews in Analytical Chemistry 16:1-14.

Bruland, K.w., R.P. Franks, G.A. Knauer, and J.H. Martin.   1979.
Sampling and Analytical Methods for the Determination of Copper,
Cadmium, Zinc, and Nickel at the Nanogram per Liter Level in Sea
Water.  Anal. Chin. Acta 105:233-245.

                                8

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 Bruland, K.W.  1983.  Trace Elements in Sea-water.  In: Chemical
 Oceanography, Vol. 8.  J.P. Riley and R. Chester, •dm.  Academic
 Press, New York, NY.  pp. 157-220.

 Byrd, J.T.,  and M.o. Andreae.  1986. - Dissolved and Particulate
 Tin in North Atlantic Seawater.  Marine Chemistry 19:193-200.

 Horowitz,  A.J.,  K.A. Elrick, and M.R. Colberg.  1992.  The Effect
 of Membrane  Filtration Artifacts on Dissolved Trace Element
 Concentrations.   Water Res. 26:753-763.

 Moody, J.R.   1982.  NBS Clean Laboratories for Trace Element
 Analysis.  Anal. Chen. 54:1358A-1376A.

 Moody, J.R.,  and E.S. Beary.  1982.   Purified Reagents for Trace
 Metal Analysis.   Talanta 29:ro03-101O.

 Nriagu,  J.O.,  G.  Lawson,  H.K.T. Hong, and J.M. Azcue.  1993.  A
 Protocol for  Minimizing Contamination in the Analysis of Trace
 Metals in  Great  Lakes Waters.   J.  Great Lakes Res.  19:175-182.

 Patterson, C.C.,  and D.M.  Settle.   1976.   The Reduction in orders
 of Magnitude  Errors in Lead Analysis of Biological  Materials and
 Natural  Waters by Evaluating and Controlling the Extent and
 Sources  of Industrial Lead Contamination Introduced during Sample
 Collection and Processing.   In:  Accuracy in  Trace Analysis:
 Sampling, Sample  Handling,  Analysis.  P.O. LaFleur,  ed.   National
 Bureau of Standards Spec.  Publ.  422,  U.S.  Government Printing
 Office,  Washington,  DC.

 Puls,  R.W., and M.J.  Barcelona.  1989.  Ground Water Sampling for
 Metals Analyses.   EPA/540/4-89/001.   National  Technical
 Information Service,  Springfield, VA.

 Sakamoto-Arnold,  C.M., A.K.  Hanson, Jr., D.L.  Huizenga,  and  D.R.
 Kester.  1987.  Spatial and Temporal  Variability of Cadmium  in
 Gulf Stream Warm-core Rings and  Associated Waters.   J. Mar.  Res.
 45:201-230.

 Shiller, A.M., and E.  Boyle.   1985.   Dissolved Zinc in Rivers.
 Nature,317:49-52.
Shiller, A.M., and E.A. Boyle.  1987.  Variability of Dissolved
Trace Metals in the Mississippi River.  Geochim. Cosmochim. Acta
51:3273-3277.

Taylor, J.K.  1987.  Quality Assurance of Chemical Measurements.
Lewis Publishers, Chelsea, MI.

Tramontane, J.M., J.R. Scudlark, and T.M. Church.  1987.  A
Method for the Collection, Handling, and Analysis of Trace Metals
in Precipitation.  Environ. Sci. Techno1. 21:749-753.

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"Trefry,  J.H.,  T.A.  Nelsen,  R.P.  Trocine,  s.  Mate.,  and T.W.
Vetter.   1986.  Rapp.  P.-v.  Reun.  Cons.  int.  Explor.  Mer.
186:277-288.

U.S.  Environmental  Protaction Agancy.   1983.  Methods for
Chemical Analysis of Watar  and Wastas.   EPA-600/4-79-020.
National Tachnical  Information Service,  Springfield,  VA.
Sactions 4.1.1,  4.1.3,  and 4.1.4

U.S.  Environmental  Protaction Agancy.   1991.  Methods for  the
Determination  of Metals in  Environmental Samples.   EPA-600/4-91-
010.  National Technical Information Service, Springfield, VA.

U.S.  Environmental  Protaction Agency.   1992.  Evaluation of
Trace-Metal Levels  in Ambient Waters and Tributaries  to New
York/New Jersey  Harbor -for Waste Load-Allocation.   Prepared  by
Battalia Ocean Sciences under Contract  No. 68-C8-0105.

Windom,  H.L.,  J.T.  Byrd,  R.6.  Smith, and F. Huan.   1991.
Inadequacy of  NASQAN Data for Assessing Metals Trends in the
Nation's Rivers.  Environ. Sci.  Technol.  25:1137-1142.  (Also see
Comment  and Response, Vol. 25, p.  1940.)

Zief, M., and  J.W.  Mitchell.   1976.  Contamination  Control in
Trace Element  Analysis.   Chemical  Analysis Series,  Vol. 47.
Wiley, New York,  NY.
                                10

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