&EPA
         United States
         Environmental Protection
         Agency
             Office of Research and
             Development
             Washington, DC 20460
EPA/600/R-01/084
September 2001
Innovative Technology
Verification Report
         Field Measurement
         Technologies for Total
         Petroleum Hydrocarbons in Soil

         Strategic Diagnostics  Inc.
         EnSys Petro Test System

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                                   EPA/600/R-01/084
                                   September 2001
Innovative Technology
   Verification Report
   Strategic Diagnostics Inc.
   EnSys Petro Test System
                Prepared by

              Tetra Tech EM Inc.
         200 East Randolph Drive, Suite 4700
             Chicago, Illinois 60601

            Contract No. 68-C5-0037
              Dr. Stephen Billets
         Characterization and Monitoring Branch
          Environmental Sciences Division
          Las Vegas, Nevada 89193-3478
         National Exposure Research Laboratory
         Office of Research and Development
         U.S. Environmental Protection Agency

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                                       Notice
This document was prepared for the U.S. E nvironmental Protection Agency (EPA) Superfund
Innovative Technology Evaluation Program under Contract No. 68-C5-0037. The document has
been subjected to the EPA's peer and administrative reviews and has been approved for publication.
Mention of corporation names, trade names, or commercial products does not constitute endorsement
or recommendation for use.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
               Office of Research and Development
                    Washington, DC 20460
                                                                                                 ^ft
                                                                                            \^W
                                                                                     ETv
             ENVIRONMENTAL TECHNOLOGY VERIFICATION PROGRAM
                               VERIFICATION STATEMENT
 TECHNOLOGY TYPE:    FIELD MEASUREMENT DEVICE

 APPLICATION:           MEASUREMENT OF TOTAL PETROLEUM HYDROCARBONS

 TECHNOLOGY NAME:   EnSys PETRO TEST SYSTEM

 COMPANY:              STRATEGIC DIAGNOSTICS INC.
 ADDRESS:               111 PENCADER DRIVE
                           NEWARK, DE 19702

 WEB SITE:               http://www.sdix.com

 TELEPHONE:            (800) 544-8881
VERIFICATION PROGRAM DESCRIPTION

The U.S. Environmental Protection Agency (EPA) created the Superfund Innovative Tec hnology Evaluation (SITE) and
Environmental Technology Verification (ETV) Programs to  facilitate deployment of innovative technologies through
performance verification and information dissemination. The goa 1 of these programs is to further environmental protection
by substantially accelerating the acceptance and use of improved and cost-effective technologies. These programs assist and
inform those involved in design, distribution, permitting,  and purchase of environmental technologies.  This document
summarizes results of a demonstration of the EnSys Petro Test System developed by Strategic Diagnostics Inc. (SDI).

PROGRAM OPERATION

Under the  SITE and ETV Programs, with the full participa tion of the technology developers, the EPA evaluates and
documents the performance of innovative technologies by developi ng demonstration plans, conducting field tests, collecting
and analyzing demonstration data, and preparing reports.  The technologies are evaluated under rigorous quality assurance
(Q A) protocols to produce well-documented data of known quality . The EPA National Exposure Research Laboratory, which
demonstrates field sampling, monitoring, and measurement tec hnologies, selected Terra Tech EM Inc. as the verification
organization to assist in field testing seven field measuremen t devices for total petroleum hydrocarbons (TPH) in soil. This
demonstration was funded by the SITE Program.

DEMONSTRATION DESCRIPTION

In June 2000, the EPA  conducted a field demonstration of the EnSys Petro Test System and six other field measurement
devices for TPH in soil.  This verification statement focuses on the EnSys Petro Test System; a similar statement has been
prepared for each of the other six devices. The performance and co  st of the EnSys Petro Test System were compared to those
of an off-site laboratory reference method, "Test Methods for Evaluating Solid Waste" (SW-846) Method 8015B (modified).
To verify a wide range of performance attributes, the demons tration had both primary and secondary objectives. The primary
objectives  included (1) determining  the method detection  limit, (2) evaluating the accuracy and precision  of TPH
measurement, (3) evaluating the effect of interferents, and (4 ) evaluating the effect of moisture content on TPH measurement
for each device. Additional primary objectives were to m  easure sample throughput and estimate TPH measurement costs.
Secondary objectives  included  (1)  documenting  the skills and training  required to  properly operate the device,
(2) documenting the portability of the device, (3) evaluating the device's durability, and (4) documenting the availability of
the device and associated spare parts.

The EnSys Petro Test System was demonstrated by using it to analyze 66 soil environmental samples, 89 soil performance
evaluation (PE) samples, and 36 liquid PE samples. In add ition to these 191 samples, 12 extract duplicates prepared using
the environmental samples were analyzed. The environmenta 1 samples were collected in four areas contaminated with
gasoline, diesel, or other petroleum products, and the PE sa mples were obtained from a commercial provider. SDI chose not
to analyze soil samples collected in a fifth area because accord ing to SDI, the EnSys Petro Test System was not designed to
measure the heavy lubricating oil present in the area.
                          The accompanying notice is an integral part of this verification statement.                 September 2001

                                                 iii

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Collectively, the environmental and PE samples provided the di  fferent matrix types and the different levels and types of
petroleum hydrocarbon contamination needed to perform a comp rehensive evaluation of the EnSys Petro Test System. A
complete description of the demonstration and a summary  of its results are available in the "Innovative Technology
Verification Report: Field Measurement Devices for Total Pe troleum Hydrocarbons in Soil—Strategic Diagnostics Inc.,
EnSys Petro Test System" (EPA/600/R-01/084).

TECHNOLOGY DESCRIPTION

The EnSys Petro Test System manufactured by SDI is based  on a combination of immunoassay (specifically, enzyme-linked
immunosorbent assay) and colorimetry.  The EnSys Petro Test System includes the SDI Sample Extraction Kit, the EnSys
Petro 12T Soil Test Kit, and the EnSys/EnviroGard * Common Accessory Kit.  With this device, methanol is used for
extraction of petroleum hydrocarbons from soil samples. Each sa mple extract is mixed with an enzyme conjugate solution.
The reaction mixture is then transferred to an antibody-coated  test tube. The hydrocarbons in the sample extract and those
in the enzyme conjugate competitively bind to specific antibody sites on the test tube. The test tube is rinsed with a dilute
detergent solution to remove any enzyme conjugate and hydro  carbons not bound to the antibodies. A color developer solution
and hydrogen peroxide are added to the test tube in order to give yellow color to the enzymes that remain attached to the test
tube.  The color intensity is inversely proportional to the c oncentration of hydrocarbons in the extract. To accomplish color
measurement, the absorbance of the antibody-coated tube c ontaining the sample extract and an antibody-coated tube
containing a reference standard (m-xylene) is compared using a differential photometer. A positive reading on the photometer
indicates that the total concentration of petroleum hydrocarbons  in the sample extract is less than that in the reference
standard. Similarly, a negative reading on the photometer i ndicates that the total concentration of petroleum hydrocarbons
in the sample extract is greater th an that in the reference standard.

During the demonstration, extraction of petroleum hydrocarbons in a given soil sample was completed by adding 20 milliliters
of methanol to  10 grams of the sample. SDI performed each an alysis at three detection levels by diluting the sample extract
twice during sample and standard preparation.  The refere  nee  standard concentrations for gasoline (10 milligrams per
kilogram [mg/kg]) and diesel (15 mg/kg) were multiplied by th e dilution factors used. Thus, the concentration ranges used
to estimate sample  TPH concentrations were (1) less than  (<)10; greater  than (>)10 to  <100; >100 to <1,000; and
> 1,000 mg/kg for samples containing gasoline range organics a nd (2) < 15; > 15 to < 100; > 100 to <1,000; and > 1,000 mg/kg
for samples containing extended diesel range organics.

VERIFICATION OF PERFORMANCE

To ensure data usability, data quality indicators for accuracy, precision, representativeness, completeness, and comparability
were assessed  for the reference method based on project-s pecific QA objectives.  Although the reference method results
generally exhibited a negative bias, based  on the results for  the data quality indicators, the reference method results were
considered to  be of adequate quality.  The  bias was considered  to be significant primarily  for low- and  medium-
concentration-range soil samples containing diesel, which made up only 13 percent of the total number of samples analyzed
during the demonstration. The reference method recoveries obs erved during the demonstration were typical of the recoveries
obtained by most organic analytical methods for environmental samples. In general, the user should exercise caution when
evaluating the accuracy of a field measurement device by comp aring it to reference methods because the reference methods
themselves may  have limitations. Key demonstration fi ndings are summarized below for the primary objectives.

Method Detection Limit: Based on the TPH results for seven low-concentr ation-range diesel soil PE samples, the method
detection limit for the reference method was determined to  be  6.32 mg/kg.  Because the EnSys Petro Test System is a
semiquantitative device, a method detection limit could not be  determined  for the device; however, the device's TPH
concentration ranges for six of seven samp les overlapped the reference method results.

Accuracy and Precision: The EnSys Petro Test System results for 16 of 66 soil environmental samples were inconclusive.
Of the remaining 50 results, the device's TPH concentrati on ranges overlapped the reference method results for only
8 samples (16 percent); 3 6 EnSys Petro Test System results were biased high, and 6 results were biased low. The EnSys Petro
Test System results for 12 of 28 soil PE samples were inconclusive.  Of the remaining 16  results, the device's TPH
concentration ranges overlapped the reference method results  for only 5 samples (31 percent); 9 EnSys Petro Test System
results were biased high, and 2 results were biased low. The EnSys Petro Test System results for all 6 liquid PE samples were
inconclusive.

The EnSys Petro Test System results for 3 of 66 soil environmen tal samples used to draw conclusions regarding whether the
TPH concentrations in a given sampling area or sample type exceeded a specified action level were inconclusive.  Of the
remaining 63 results, the device's conclusions agreed with  those of the reference method for 41 samples (65 percent);
21  EnSys Petro  Test System conclusions were false positives, and 1 was  a false negative. The EnSys Petro Test System
results for 14 of 34 soil PE samples were inconclusive.  Of the remaining 20 results, the device's conclusions agreed with
those of the reference method for 15 samples (75 percent); 3 En Sys Petro Test  System conclusions were false positives, and
2 were false negatives.
                             The accompanying notice is an integral part of this verification statement.                   September 2001

                                                       iv

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Both the EnSys Petro Test System and reference method exhibited good precision. Specifically, for 17 of 19 soil sample
replicate sets and 2 of 2 liquid sample replicate sets, the En  Sys Petro Test System TPH concentration ranges were the same
for each replicate set. For 12 of 12 extract duplicate sets,  the device's TPH concentration ranges were the same for each
extract duplicate set.  For the reference method, the median relative standard deviation ranged from 5.5 to 16 percent for
18 soil and 2 liquid sample replicate sets, and the median re lative percent difference was 3 for 12 extract duplicate sets.

Effect oflnterferents: The EnSys Petro Test System showed a mean response of at least 24 percent for neat tetrachloroethene
(PCE); Stoddard solvent; turpentine; and 1,2,4-trichlorobenzen  e. The device showed no response for neat methyl-tert-butyl
ether (MTBE) or soil spiked with humic acid. The reference  method showed varying mean responses for MTBE (39 percent);
PCE (17.5 percent); Stoddard solvent (85 percent); turpentine (52 percent); 1,2,4-trichlorobenzene (50 percent); and humic
acid (0 percent). For the demonstration, MTBE and St oddard solvent were included in the definition of TPH.

Effect of Moisture Content: The EnSys Petro Test System TPH results were in conclusive with regard to the effect of soil
moisture content. The reference method TPH results were unaffected when the soil moisture content was increased from
(1) 9 to 16 percent for weathered gasoline soil PE samples and (2) less than 1 to 9 percent for diesel soil PE samples.

Measurement Time: From the time of sample receipt, SDI required 39 hours, 35 minutes, to prepare a draft data package
containing TPH results for 191 samples and 12 extract duplicates compared to 30 days for the reference method, which was
used to analyze 199 samples and 13 extract duplicates.

Measurement Costs: For the EnSys Petro Test System, the TPH measurement cost for 191 samples and 12 extract duplicates
was estimated to be $10,210 (including the daily rental cost of the EnSys/EnviroGard * Common Accessory Kit, whose
purchase price is $1,999) compared to $41,290 for the reference method.

Key demonstration findings are summarized below for the secondary objectives.

Skill and Training Requirements: The  EnSys Petro Test System can be opera ted by one person with basic wet chemistry
skills.  The sample analysis procedure for the device can be learned in the field with a few practice attempts.

Portability: The EnSys Petro Test System is battery-operated and  requires no alternating current power source. The device
can be easily moved between sampling areas in the field, if necessary.

Durability and Availability of the Device : All items in the EnSys Petro Test System are available from SDI. During a 1 -year
warranty period, SDI will supply  replacement parts for the de vice by overnight courier service at no cost.  During the
demonstration, none of the device's reus able items malfunctioned or was damaged.

In summary, during the demonstration, the EnSys  Petro Test  System exhibited the following desirable characteristics of a
field TPH measurement device: (1) good precision and (2) high sa mple throughput. In addition, the EnSys Petro Test System
exhibited moderate measurement costs.  However, a signifi cant number of the EnSys Petro Test System TPH results  were
determined to be inconclusive because the detection levels  used by SDI were not appropriate to address the demonstration
objectives. Overall, the  device's results did not compare well  with those of the  reference method; in general, the device
exhibited a high positive bias. Collectively, the demonstration  findings indicated that the user should exercise caution when
considering the device for a site-specific field TPH measurement application.

Original
signed by

Gary J. Foley, Ph.D.
Director
National Exposure Research Laboratory
Office of Research and Development
  NOTICE: EPA verifications are based on an evaluation oft echnology performance under specific, predetermined criteria
  and appropriate quality assurance procedures. The EPA make s no expressed or implied warranties as to the performance
  of the technology and does not certify that a technology will always  operate as verified. The end user is solely responsible
  for complying with any and all applicable federal, state, and local requirements.
                             The accompanying notice is an integral part of this verification statement.                   September 2001

                                                       V

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                                      Foreword
The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
nation's natural resources. Under the mandate of national environmental laws, the agency strives
to formulate and implement actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life. To meet this mandate, the EPA's Office
of Research and Development provides data and  scientific support that can be used  to solve
environmental problems, build the scientific knowle dge base needed to manage ecological resources
wisely, understand how pollutants affect public health, and prevent or reduce environmental risks.

The National Exposure Research Laboratory (NERL) is the agency's center  for investigation of
technical and  management approaches for identifyi ng and quantifying risks to human health and the
environment.  Goals of the laboratory's research program are to (1) develop and evaluate methods
and technologies for characterizing and monitoring air, soil, and water; (2) support regulatory and
policy decisions; and (3) provide the scientific support needed to ensure effective implementation
of environmental regulations and strategies.

The EPA's Superfund Innovative Technology Evaluation (SITE) Program evaluates technologies
designed  for  characterization and remediation of contaminated  Superfund  and Resource
Conservation and Recovery Act sites. The SITE Program was created to provide reliable cost and
performance data in order to speed acceptance and use of innovative remediation, characterization,
and monitoring technologies by the regulatory and user community.

Effective  measurement and  monitoring  technologies  are  needed to assess  the  degree of
contamination at a site, provide data that can be used to determine the risk to  public health or the
environment,  supply the  necessary cost  and performance data to select the most appropriate
technology, and monitor the success or failure of a remediation process. One component of the EPA
SITE Program, the Monitoring and Measurement Technology (MMT) Program, demonstrates and
evaluates innovative technologies to meet these needs.

Candidate technologies can originate within the fe deral government or the private sector. Through
the SITE Program, developers are given the opportun ity to conduct a rigorous demonstration of their
technologies under actual field conditions. By comp leting the demonstration and distributing the
results, the agency establishes a baseline for acceptance and use of these technologies.  The MMT
Program is administered by the Environmental Sc iences Division of NERL in  Las Vegas, Nevada.
                                            Gary J. Foley, Ph.D.
                                            Director
                                            National Exposure Research Laboratory
                                            Office of Research and Development
                                           VI

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                                       Abstract
The EnSys Petro Test System developed by Strate gic Diagnostics Inc. (SDI) was demonstrated under
the U.S. Environmental Protection Agency Superfund Innovative Technology Evaluation Program
in June 2000 at the Navy Base Ventura County site in Port Hueneme, California. The purpose of
the demonstration was to collect reliable performan ce and cost data for the EnSys Petro Test System
and six other field measurement devices for total pe troleum hydrocarbons (TPH) in soil. In addition
to assessing ease of device operation, the key objectives of the demonstration included determining
the (1) method detection limit, (2) accuracy and precision, (3) effects of interferents and soil moisture
content on  TPH measurement, (4) sample thr oughput, and (5) TPH measurement costs for each
device.   The  demonstration  involved  analysis  of both performance evaluation samples and
environmental samples collected in four areas contam inated with gasoline, diesel, or other petroleum
products. The performance and cost results for a given field measurement device were compared to
those for an off-site laboratory  reference  method, "Test Methods  for Evaluating Solid Waste"
(SW-846) Method 8015B (modified). During the de monstration, SDI required 39 hours, 3 5 minutes,
for TPH measurement of 191 samples and 12 extract duplicates. The TPH measurement costs for
these samples were estimated to be $10,210 for the EnSys Petro Test System compared to $41,290
for the reference method. The method detection limit for the reference method was determined to
be 6.32 milligrams per kilogram; a method detection limit could not be determined for the EnSys
Petro Test System because it is a semiquantitative device.  During the demonstration, the device
exhibited good precision and lack of sensitivity to soil spiked with humic acid.  The device showed
a mean response of at least 24 percent for interferents that are not petroleum hydrocarbons (neat
materials, including tetrachloroethene; turpentine; andl,2,4-trichlorobenzene). A significant number
of the EnSys Petro  Test System TPH results  we re determined to  be inconclusive because the
detection levels used by SDI were not appropriate to address the demonstration objectives.  Overall,
the device's results did not compare well with those of the reference method; in general,  the device
exhibited a high positive bias. Collectively, the dem onstration findings indicated that the user should
exercise caution when considering the device for a site-specific field TPH measurement application.
                                           vn

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                                      Contents


Chapter                                                                         Page

Notice	ii

Verification Statement	 iii

Foreword  	 vi

Abstract 	vii

Figures	 xi

Tables	xii

Abbreviations, Acronyms, and Symbols	  xiv

Acknowledgments  	  xvi

1       Introduction	1
        1.1     Description of SITE Program  	1
        1.2     Scope of Demonstration	4
        1.3     Components and Definition of TPH  	4
               1.3.1   Composition of Petroleum and Its Products 	4
                      1.3.1.1  Gasoline	6
                       .3.1.2  Naphthas 	6
                       .3.1.3  Kerosene 	6
                       .3.1.4  JetFuels	6
                       .3.1.5  Fuel Oils	6
                       .3.1.6  Diesel	7
                      1.3.1.7  Lubricating Oils	7
               1.3.2   Measurement of TPH  	7
                      1.3.2.1  Historical Perspective  	7
                      1.3.2.2  Current Options for TPH Measurement in Soil 	8
                      1.3.2.3  Definition of TPH  	9

2       Description of Immunoassay and Colorimetry and the EnSys Petro Test System  	11
        2.1     Description of Immunoassay and Colorimetry  	11
               2.1.1   Immunoassay  	12
               2.1.2   Colorimetry	15
        2.2     Description of EnSys Petro Test System  	16
                                          vin

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                              Contents (Continued)
Chapter                                                                         Page

              2.2.1   Device Description 	16
              2.2.2   Operating Procedure	18
       2.3    Developer Contact Information	18

3      Demonstration Site Descriptions  	19
       3.1    Navy Base Ventura County Site  	20
              3.1.1   Fuel Farm Area	20
              3.1.2   Naval Exchange Service Station Area 	21
              3.1.3   Phytoremediation Area	21
       3.2    Kelly Air Force Base Site  	22
       3.3    Petroleum Company Site	22

4      Demonstration Approach 	24
       4.1    Demonstration Objectives 	24
       4.2    Demonstration Design	24
              4.2.1   Approach for Addressing Primary Objectives  	25
              4.2.2   Approach for Addressing Secondary Objectives   	29
       4.3    Sample Preparation and Management	33
              4.3.1   Sample Preparation	33
              4.3.2   Sample Management	35

5      Confirmatory Process  	39
       5.1    Reference Method Selection 	39
       5.2    Reference Laboratory Selection	41
       5.3    Summary of Reference Method	41

6      Assessment of Reference Method Data Quality 	50
       6.1    Quality Control Check Results  	50
              6.1.1   GRO Analysis	50
              6.1.2   EDRO Analysis	53
       6.2    Selected Performance Evaluation Sample Results	59
       6.3    Data Quality	62

7      Performance of the EnSys Petro Test System	63
       7.1    Primary Objectives	63
              7.1.1   Primary Objective PI: Method Detection Limit	65
              7.1.2   Primary Objective P2: Accuracy and Precision 	66
                      7.1.2.1 Accuracy 	66
                      7.1.2.2 Precision	71
              7.1.3   Primary Objective P3: Effect of Interferents  	76
                     7.1.3.1 Interferent Sample Results	76
                      7.1.3.2 Effects of Interferents on TPH Results for Soil Samples	76
              7.1.4   Primary Objective P4: Effect of Soil Moisture Content	83
              7.1.5   Primary Objective P5: Time Required for TPH Measurement  	83
       7.2    Secondary Objectives	86
                                          IX

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                              Contents (Continued)
Chapter
Page
              7.2.1   Skill and Training Requirements for Proper Device Operation  	86
              7.2.2   Health and Safety Concerns Associated with Device Operation  	87
              7.2.3   Portability of the Device	87
              7.2.4   Durability of the Device 	88
              7.2.5   Availability of the Device and Spare Parts 	88

8      Economic Analysis	89
       8.1     Issues and Assumptions	89
              8. .1   Capital Equipment Cost 	89
              8. .2   Cost of Supplies 	90
              8. .3   Support Equipment Cost	90
              8. .4   Labor Cost	90
              8. .5   Investigation-Derived Waste Disposal Cost	90
              8. .6   Costs Not Included	90
       8.2     EnSys Petro Test System Costs	91
              8.2.1   Capital Equipment Cost 	91
              8.2.2   Cost of Supplies 	91
              8.2.3   Support Equipment Cost	92
              8.2.4   Labor Cost	92
              8.2.5   Investigation-Derived Waste Disposal Cost	92
              8.2.6   Summary of EnSys Petro Test System Costs	92
       8.3     Reference Method Costs  	93
       8.4     Comparison of Economic Analysis Results	93

9      Summary of Demonstration Results	94

10     References	99
Appendix     Supplemental Information Provided by the Developer 	101

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                                       Figures

Figure                                                                             Page
1 -1.    Distribution of various petroleum hy drocarbon types throughout boiling point range
       of crude oil  	5
2-1.    Immunoglobulin G antibody structure and locations of antigen-binding sites  	12
2-2.    Enzyme-linked immunosorbent assay	14
5-1.    Reference method selection process  	40
7-1.    Summary of statistical analysis of TPH results	64
                                           XI

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                                      Tables
Table                                                                           Page

1-1.    Summary of Calibration Information for Infrared Analytical Method	8
1-2.    Current Technologies for TPH Measurement	9
2-1.    EnSys Petro Test System Method Detection Limits	17
2-2.    EnSys Petro Test System Components	17
3-1.    Summary of Site Characteristics	20
4-1.    Action Levels Used to Evaluate Analytical Accuracy  	26
4-2.    Demonstration Approach 	30
4-3.    Environmental Samples 	34
4-4.    Performance Evaluation Samples	36
4-5.    Sample Container, Preservation, and Holding Time Requirements  	38
5-1.    Laboratory Sample Preparation and Analytical Methods 	42
5-2.    Summary of Project-Specific Procedures for GRO Analysis	43
5-3.    Summary of Project-Specific Procedures for EDRO Analysis	47
6-1.    Summary of Quality Control Check Results for GRO Analysis	54
6-2.    Summary of Quality Control Check Results for EDRO Analysis  	58
6-3.    Comparison of Soil and Liquid Performance Evaluation Sample Results	60
6-4.    Comparison of Environmental Resource Associates Historical Results to
       Reference Method Results  	62
7-1.    TPH Results for Low-Concentration-Range Diesel Soil Performance Evaluation
       Samples	65
7-2.    Comparison of EnSys Petro Test Syst em and Reference Method TPH Results for
       Environmental Samples 	67
7-3.    Comparison of EnSys Petro Test Syst em and Reference Method TPH Results for
       Performance Evaluation Samples	69
7-4.    Action Level Conclusions	71
7-5.    Summary of EnSys Petro Test System and Reference Method Precision for Field
       Triplicates of Environmental Samples 	73
                                         Xll

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                               Tables (Continued)
Table                                                                           Page
7-6.    Summary of EnSys Petro Test System and Reference Method Precision for
       Extract Duplicates	74
7-7.    Comparison of EnSys Petro Test System and Reference Method Precision for
       Replicate Performance Evaluation Samples	75
7-8.    Comparison of EnSys Petro Test System and Reference Method Results for
       Interferent Samples	77
7-9.    Comparison of EnSys Petro Test System and Reference Method Results for Soil
       Performance Evaluation Samples Containing Interferents	79
7-10.   Comparison of Results for Soil Performance Evaluation Samples at Different
       Moisture Levels  	84
7-11.   Time Required to Complete TPH Measurement Activities Using the EnSys Petro
       Test System	85
8-1.    EnSys Petro Test System Cost Summary	92
8-2.    Reference Method Cost Summary  	93
9-1.    Summary of EnSys Petro Test System Results for the Primary Objectives	95
9-2.    Summary of EnSys Petro Test System Results for the Secondary Objectives  	98
                                         Xlll

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                   Abbreviations, Acronyms, and Symbols
"g
um
12T Soil Test Kit
AEHS
AFB
API
ASTM
bgs
BTEX
BVC
CCV
CFC
CFR
Common Accessory Kit
DER
DRO
EDRO
ELISA
EPA
EPH
ERA
FFA
FID
GC
GRO
ICV
row
Ig
ITVR
kg
L
LCS
LCSD
MCAWW
MDL
Means
Less than
Greater than
Less than or equal to
Plus or minus
Microgram
Micrometer
EnSys Petro 12T Soil Test Kit
Association for Environmental Health and Sciences
Air Force Base
American Petroleum Institute
American Society for Testing and Materials
Below ground surface
Benzene, toluene, ethylbenzene, and xylene
Base Ventura County
Continuing calibration verification
Chlorofluorocarbon
Code of Federal Regulations
EnSys/EnviroGard® Common Accessory Kit
Data evaluation report
Diesel range organics
Extended diesel range organics
Enzyme-linked immunosorbent assay
U.S. Environmental Protection Agency
Extractable petroleum hydrocarbon
Environmental Resource Associates
Fuel Farm Area
Flame ionization detector
Gas chromatograph
Gasoline range organics
Initial calibration verification
Investigation-derived waste
Immunoglobulin
Innovative technology verification report
Kilogram
Liter
Laboratory control sample
Laboratory control sample duplicate
"Methods for Chemical Analysis of Water and Wastes"
Method detection limit
R.S. Means Company
                                        xiv

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           Abbreviations, Acronyms, and Symbols (Continued)
mg
min
mL
MMT
MS
MSD
MTBE
n-Cx'
NERL
NEX
ng
ORD
ORO
OSWER
PC
PCB
PCE
PE
PHC
PPE
PRA
PRO
QA
QC
RPD
RSD
Sample Extraction Kit
SDI
SFT
SITE
STL Tampa East
SW-846
TPH
UST
VPH
Milligram
Minute
Milliliter
Monitoring and Measurement Technology
Matrix spike
Matrix spike duplicate
Methyl-tert-butyl ether
Alkane with "x" carbon atoms
National Exposure Research Laboratory
Naval Exchange
Nanogram
Office of Research and Development
Oil range organics
Office of Solid Waste and Emergency Response
Petroleum company
Polychlorinated biphenyl
Tetrachloroethene
Performance evaluation
Petroleum hydrocarbons
Personal protective equipment
Phytoremediation Area
Petroleum range organics
Quality assurance
Quality control
Relative percent difference
Relative standard deviation
SDI Sample Extraction Kit
Strategic Diagnostics Inc.
Slop Fill Tank
Superfund Innovative Technology Evaluation
Severn Trent Laboratories in Tampa, Florida
"Test Methods for Evaluating Solid Waste"
Total petroleum hydrocarbons
Underground storage tank
Volatile petroleum hydrocarbons
                                        xv

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                                Acknowledgments
This report was prepared for the U. S. Environm ental Protection Agency (EPA) Superfund Innovative
Technology Evaluation Program under the direction and coordination of Dr. Stephen Billets of the
EPA National Exposure Research Laboratory (NERL)—Environmental Sciences Division in Las
Vegas, Nevada. The EPA NERL thanks Mr. Ernest Lory of Navy Base Ventura County, Ms. Amy
Whitley of Kelly Air Force Base, and Mr. Jay Simonds of Handex of Indiana for their support in
conducting field activities for the project. Mr. Eric Koglin of the EPA NERL served as the technical
reviewer of this report. Mr. Roger Claff of the American Petroleum Institute, Mr.  Dominick
De Angelis of ExxonMobil Corporation, Dr. Ileana Rhodes of Equilon Enterprises, and Dr. Al
Verstuy ft of Chevron Research and Technology Comp any served as the peer reviewers of this report.

This report was prepared for the EPA by Dr. Kirankumar Topudurti and Mr. Eric Monschein of
Terra Tech EM Inc.  Special acknowledgment is gi ven to Mr. Jerry  Parr of Catalyst Information
Resources,  L.L.C.,  for  serving  as the  technical  consultant for the project.   Additional
acknowledgment  and thanks are  given to Ms.  Jeanne Kowalski, Mr. Jon Mann, Mr. Stanley
Labunski, and Mr. Joe Abboreno of Terra Tech EM Inc. for their assistance during the preparation
of this report.
                                         xvi

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                                              Chapter 1
                                             Introduction
The U.S. Environmental Protection Agency (EPA) Office
of Research and Development (ORD) National Exposure
Research Laboratory (NERL) conducted a demonstration
of seven innovative field measurement devices for total
petroleum hydrocarbons (TPH) in soil. The demonstration
was conducted as part of the EPA Superfund Innovative
Technology  Evaluation   (SITE)  Monitoring  and
Measurement Technology (MMT) Program using TPH-
contaminated soil from five areas located in three regions
of the United States. The demonstration was conducted at
Port Hueneme, California, during the week of June  12,
2000.  The purpose of the demonstration was to obtain
reliable performance and cost data on field measurement
devices in order to provide (1) potential users with a better
understanding of the devices' performance and operating
costs under well-defined field conditions and  (2)  the
developers with documented results that will assist them in
promoting acceptance and use of their devices. The TPH
results obtained using the seven field measurement devices
were compared  to the  TPH results obtained  from a
reference laboratory chosen for the demonstration, which
used a reference method modified for the demonstration.

This innovative  technology verification  report  (ITVR)
presents demonstration performance results and associated
costs for the EnSys  Petro  Test  System developed by
Strategic Diagnostics Inc. (SDI).  Specifically, this report
describes  the  SITE  Program,  the   scope   of  the
demonstration, and the components and definition of TPH
(Chapter 1); the innovative field measurement device and
the  technology upon  which it is based (Chapter 2);  the
three demonstration sites (Chapter 3); the demonstration
approach (Chapter 4); the  selection of  the reference
method and laboratory (Chapter 5); the assessment of
reference  method   data  quality  (Chapter  6);  the
performance of the field measurement device (Chapter 7);
the  economic analysis for the field measurement device
and reference method (Chapter  8); the demonstration
results in summary form (Chapter 9); and the references
used to prepare the ITVR (Chapter 10).  Supplemental
information provided by SDI is presented in the appendix.

1.1    Description of SITE Program

Performance verification  of innovative  environmental
technologies is an integral  part of the regulatory and
research mission of the EPA. The SITE Program was
established by  the EPA Office of Solid Waste and
Emergency Response (OSWER) and  ORD under the
Superfund Amendments and Reauthorization Act of 1986.
The  overall goal of  the SITE Program is to conduct
performance verification  studies and  to promote  the
acceptance of innovative technologies that may be used to
achieve  long-term  protection of human  health and the
environment.  The program  is designed to meet three
primary objectives: (1) identify and remove obstacles to
the development and  commercial use  of innovative
technologies,  (2)  demonstrate  promising  innovative
technologies and gather reliable performance and cost
information to support site characterization and cleanup
activities,  and  (3) develop procedures and policies that
encourage the use of innovative technologies at Superfund
sites as well as at other waste sites or commercial facilities.

The  intent  of  a  SITE  demonstration is  to  obtain
representative, high-quality performance and cost data on
one or more innovative technologies so that potential users
can assess the  suitability of a given technology for a
specific application.  The SITE Program includes the
following elements:

•  MMT Program—Evaluates innovative technologies
   that sample, detect, monitor, or measure  hazardous
   and toxic substances. These technologies are expected
   to provide better,  faster,  or more cost-effective

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    methods for producing  real-time data during site
    characterization and  remediation studies than  do
    conventional technologies.

•   Remediation  Technology   Program—Conducts
    demonstrations of innovative treatment technologies to
    provide reliable performance, cost, and applicability
    data for site cleanups.

•   Technology  Transfer  Program—Provides  and
    disseminates technical information in the form of
    updates,  brochures,  and  other  publications  that
    promote  the  SITE   Program   and  participating
    technologies. The Technology Transfer Program also
    offers technical assistance, training, and workshops to
    support the technologies.  A significant number of
    these activities are performed by EPA's Technology
    Innovation Office.

The TPH field  measurement device demonstration was
conducted as part of the MMT Program, which provides
developers  of  innovative hazardous waste  sampling,
detection, monitoring, and measurement devices with an
opportunity  to  demonstrate  the performance of their
devices under actual field conditions.  These devices may
be used to sample, detect, monitor, or measure hazardous
and toxic substances in water, soil gas, soil, and sediment.
The technologies include chemical sensors for in situ (in
place) measurements, soil and sediment samplers, soil gas
samplers, groundwater samplers, field-portable analytical
equipment, and other systems that support field sampling
or data acquisition and analysis.

The MMT Program promotes acceptance of technologies
that can be used to (1) accurately assess the  degree of
contamination at a site,  (2) provide data to evaluate
potential effects on human health and the environment, (3)
apply data to assist in selecting the most appropriate
cleanup action, and (4) monitor the  effectiveness of a
remediation process. The program places a high priority
on innovative  technologies  that provide  more  cost-
effective, faster, and safer methods forproducing real-time
or near-real-time data than do conventional, laboratory-
based technologies. These innovative technologies  are
demonstrated under field conditions,  and the results  are
compiled, evaluated, published, and disseminated by the
ORD. The primary objectives of the MMT Program are as
follows:

•   Test and verify the performance of innovative field
    sampling and  analytical technologies that enhance
    sampling,  monitoring,  and  site  characterization
    capabilities

    Identify  performance  attributes  of   innovative
    technologies to address field sampling, monitoring,
    and characterization problems in a more cost-effective
    and efficient manner

•   Prepare protocols, guidelines, methods,  and other
    technical publications that enhance acceptance of these
    technologies for routine use

The MMT Program is administered by the Environmental
Sciences  Division of the NERL in Las Vegas, Nevada.
The NERL is the EPA center for investigation of technical
and  management  approaches   for   identifying   and
quantifying risks to human health and the environment.
The NERL mission components include (1) developing
and evaluating methods  and technologies for sampling,
monitoring,  and characterizing  water,  air,   soil,  and
sediment; (2) supporting  regulatory and policy decisions;
and (3) providing the technical support needed to ensure
effective  implementation of environmental regulations
and  strategies.   By demonstrating  innovative  field
measurement devices for TPH  in soil, the MMT Program
is supporting the development  and evaluation of methods
and  technologies  for  field  measurement  of TPH
concentrations in a variety of soil types.  Information
regarding the selection of field measurement devices for
TPH is available in American Petroleum Institute (API)
publications (API 1996,1998).

The MMT Program's technology verification process  is
designed to conduct  demonstrations  that will generate
high-quality data so  that potential users  have reliable
information regarding device performance and cost. Four
steps are  inherent in the process: (1) needs identification
and technology  selection, (2) demonstration planning
and  implementation,   (3)  report  preparation,   and
(4) information distribution.

The first step  of the verification process begins with
identifying technology needs of the EPA and the regulated
community.   The EPA  regional  offices,   the  U.S.
Department of Energy, the U.S. Department of Defense,
industry, and state environmental regulatory agencies are
asked  to  identify  technology  needs  for   sampling,
monitoring, and measurement of environmental media.
Once a need is identified, a search is conducted to identify
suitable technologies that will address the need.   The
technology search and identification process  consists  of

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examining  industry  and trade publications,  attending
related conferences,  exploring leads  from technology
developers and industry experts, and reviewing responses
to Commerce Business Daily announcements. Selection of
technologies for field testing includes evaluation of the
candidate technologies  based on  several criteria.  A
suitable technology for field testing

    Is designed for use in the field

    Is  applicable  to  a  variety  of  environmentally
    contaminated sites

•   Has  potential  for solving problems that  current
    methods cannot satisfactorily address

•   Has  estimated costs that  are lower  than those of
    conventional methods

•   Is likely to achieve better results than current methods
    in areas such as data quality and turnaround time

•   Uses techniques that are easier or safer than current
    methods

    Is commercially available

Once  candidate  technologies  are  identified,  their
developers  are  asked  to  participate  in a  developer
conference.   This  conference gives  the  developers an
opportunity to describe their technologies' performance
and to leam about the MMT Program.

The second step of the verification process is to plan and
implement a demonstration that will generate high-quality
data to assist potential users in selecting a technology.
Demonstration   planning  activities  include   a
predemonstration sampling and analysis investigation that
assesses existing conditions at the proposed demonstration
site or sites.  The objectives of the predemonstration
investigation are to (1) confirm available information on
applicable   physical,   chemical,   and  biological
characteristics of contaminated media at the sites to justify
selection of site areas for the demonstration; (2) provide
the technology developers with an opportunity to evaluate
the areas, analyze representative samples, and identify
logistical requirements;  (3) assess the overall logistical
requirements for  conducting the demonstration; and
(4) provide the reference laboratory with an opportunity
to  identify  any  matrix-specific  analytical  problems
associated with the contaminated media and to propose
appropriate solutions. Information generated through the
predemonstration investigation is used to develop the final
demonstration  design   and  sampling  and  analysis
procedures.

Demonstration planning activities also include preparing
a detailed demonstration plan that describes the procedures
to  be used to verify the performance  and cost of each
innovative  technology.     The  demonstration  plan
incorporates  information  generated  during   the
predemonstration investigation  as  well as input from
technology developers, demonstration site representatives,
and technical peer reviewers. The demonstration plan also
incorporates  the quality assurance (QA)  and quality
control (QC) elements needed to produce data of sufficient
quality to document the performance  and cost of each
technology.

During the demonstration,  each innovative technology
is  evaluated independently  and,  when possible  and
appropriate, is compared to  a reference technology. The
performance and cost of one innovative technology are not
compared to those of another technology evaluated in the
demonstration.  Rather, demonstration data are used to
evaluate  the  individual performance,  cost, advantages,
limitations, and field applicability of each technology.

As part of the third step of the verification process,  the
EPA  publishes  a verification statement and a detailed
evaluation of each technology in an ITVR. To ensure its
quality, the ITVR is published only after comments from
the technology developer and external peer reviewers are
satisfactorily addressed.  In addition,  all demonstration
data used to evaluate  each innovative technology  are
summarized  in  a  data evaluation  report  (DER)  that
constitutes a complete record of the demonstration.  The
DER is  not  published as  an EPA document, but  an
unpublished copy may be obtained from the EPA project
manager.

The fourth step of the verification process is to distribute
information regarding demonstration results. To benefit
technology developers and potential technology users, the
EPA  distributes demonstration bulletins  and  ITVRs
through  direct  mailings, at  conferences,  and on  the
Internet.   The ITVRs and additional information on the
SITE Program are  available on  the EPA ORD web site
(http://www.epa.gov/ORD/SITE).

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1.2    Scope of Demonstration

The purpose of the demonstration was to evaluate field
measurement devices for TPH in soil in order to provide
(1) potential users with a better understanding of the
devices' performance and costs under well-defined field
conditions and (2) the developers with documented results
that will assist them in promoting acceptance and use of
their devices.

Chapter 2 of this ITVR describes both the technology upon
which the EnSys Petro Test System is based and the field
measurement device itself. Because TPH is  a "method-
defined parameter," the performance results for the device
are compared to the results  obtained using an off-site
laboratory measurement method—that  is, a reference
method. Details on the selection of the reference method
and laboratory are provided in Chapter 5.

The  demonstration  had both primary  and secondary
objectives.   Primary  objectives were  critical  to  the
technology verification and required the use of quantitative
results  to  draw  conclusions  regarding  each field
measurement device's performance as well as to estimate
the cost of operating the device.  Secondary objectives
pertained to information that was useful but did  not
necessarily require the use of quantitative results to draw
conclusions regarding the performance of each device.
Both the primary and secondary objectives are discussed
in Chapter 4.

To meet the demonstration  objectives,  samples were
collected from five individual areas at three sites. The first
site is referred to as the Navy Base Ventura County (BVC)
site; is located in Port Hueneme, California; and contained
three sampling  areas.  The Navy BVC site lies in EPA
Region 9.  The second site is referred to as the Kelly Air
Force Base (AFB) site; is located in San Antonio, Texas;
and contained one sampling area. The Kelly AFB site lies
in EPA Region 6.   The third site is referred to as  the
petroleum company (PC) site, is located in north-central
Indiana, and contained one sampling area. The PC site lies
in EPA Region 5.

In preparation for the demonstration, a predemonstration
sampling and analysis investigation was completed at the
three  sites in  January  2000.   The purpose of  this
investigation was to assess whether the sites and sampling
areas  were appropriate  for evaluating the  seven field
measurement  devices   based on  the  demonstration
objectives. Demonstration field activities were conducted
between June 5 and 18, 2000.  The procedures used to
verify the performance and costs of the field measurement
devices are documented in a demonstration plan completed
in June 2000 (EPA 2000).  The plan also incorporates the
QA/QC elements that were needed to generate data of
sufficient quality to document field measurement device
and reference laboratory performance and costs. The plan
is  available  through  the  EPA   ORD   web   site
(http://www.epa.gov/ORD/SITE) or from the EPA project
manager.

1.3    Components and Definition of TPH

To  understand the term  "TPH," it  is  necessary  to
understand the composition of petroleum and its products.
This section briefly describes the composition of petroleum
and its products and defines TPH from a measurement
standpoint.   The  organic  compounds containing  only
hydrogen and carbon that are present in petroleum and its
derivatives  are collectively  referred to as  petroleum
hydrocarbons (PHC). Therefore, in this ITVR, the term
"PHC"  is used to identify sample constituents, and the
term "TPH" is used to identify analyses performed and the
associated results (for example, TPH concentrations).

1.3.1  Composition of Petroleum and Its Products

Petroleum is essentially a mixture of gaseous, liquid, and
solid  hydrocarbons  that  occur  in sedimentary  rock
deposits. On the molecular level, petroleum is a complex
mixture of hydrocarbons; organic  compounds of sulfur,
nitrogen, and oxygen; and compounds containing metallic
constituents,  particularly  vanadium,  nickel,  iron,  and
copper. Based on the limited data available, the elemental
composition of petroleum appears to vary over a relatively
narrow range: 83 to 87 percent carbon, 10 to  14 percent
hydrogen, 0.05 to 6 percent sulfur,  0.1  to  2 percent
nitrogen, and 0.05 to 1.5 percent oxygen.  Metals are
present in petroleum at concentrations of up to 0.1 percent
(Speight 1991).

Petroleum in the crude state (crude  oil) is  a mineral
resource but when  refined it provides liquid  fuels,
solvents, lubricants, and many other marketable products.
The hydrocarbon  components of crude  oil include
paraffmic, naphthenic, and aromatic groups.  Paraffins
(alkanes) are  saturated,  aliphatic hydrocarbons  with
straight or branched chains but without any ring structure.

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Naphthenes  are  saturated,  aliphatic  hydrocarbons
containing one or more rings, each of which may have one
or more paraffinic side chains (alicyclic hydrocarbons).
Aromatic hydrocarbons contain one or more aromatic
nuclei, such as benzene, naphthalene, and phenanthrene
ring systems, that may be linked  with (substituted)
naphthenic rings or paraffinic side chains. In crude oil, the
relationship  among  the   three  primary  groups  of
hydrocarbon components is a result of hydrogen gain or
loss between  any two groups.    Another class  of
compounds that is present in petroleum products such as
automobile gasoline but rarely in  crude oil is known as
olefins.  Olefins  (alkenes) are  unsaturated, aliphatic
hydrocarbons.

The distribution of paraffins, naphthenes, and aromatic
hydrocarbons depends  on the source of crude oil.  For
example, Pennsylvania crude oil contains high levels of
paraffins (about 50 percent), whereas Borneo crude oil
contains less than (<) 1 percent paraffins. As shown in
Figure 1 -1, the proportion of straight or branched paraffins
decreases with increasing molecular weight or boiling
point fraction for a given crude oil; however, this is not
true for  naphthenes or aromatic hydrocarbons.   The
                        proportion  of  monocyclonaphthenes  decreases  with
                        increasing molecular weight or boiling point fraction,
                        whereas the opposite is true for polycyclonaphthenes (for
                        example,  tetralin and decalin) and polynuclear aromatic
                        hydrocarbons; the proportion of mononuclear aromatic
                        hydrocarbons appears to be independent of molecular
                        weight or boiling point fraction.

                        Various petroleum products consisting  of carbon and
                        hydrogen are formed when crude oil  is subjected to
                        distillation and other processes in a refinery. Processing of
                        crude oil results in petroleum products with trace quantities
                        of metals and organic compounds that contain nitrogen,
                        sulfur, and  oxygen.  These  products include liquefied
                        petroleum gas,  gasoline, naphthas, kerosene, fuel oils,
                        lubricating  oils, coke,  waxes,  and asphalt.  Of  these
                        products, gasoline, naphthas, kerosene, fuel oils, and
                        lubricating  oils  are  liquids and  may  be  present at
                        petroleum-contaminated sites.  Except for gasoline and
                        some naphthas, these products  are made primarily by
                        collecting particular boiling point fractions of crude oil
                        from a distillation column.  Because this classification of
                        petroleum products is based on boiling point and not on
                        chemical composition, the composition of these products,
            Lighter oils
   100
                                           >  Heavier oils and residues
Increasing nitrogen, oxygen, sulfur, and metal content   	*•
 o>
                                                                    Polynuclear aromatic hydrocarbons
                           Mononuclear aromatic hydrocarbons
             Monocyclonaphthenes   •
                                                                              Polycyclonaphthenes
               Straight and branched paraffins
     0
         i         •          i          •         i          •
        0                  100                200                300
                                                    Boiling point, °C
Source: Speight 1991
Figure 1-1. Distribution of various petroleum hydrocarbon types throughout boiling point range of crude oil.
                                                    400
500

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including the ratio of aliphatic to aromatic hydrocarbons,
varies depending on the source of crude oil.  In addition,
specific information (such as boiling points and carbon
ranges) for different petroleum  products, varies slightly
depending on the source of the information. Commonly
encountered forms and blends of petroleum products are
briefly described below.  The descriptions are primarily
based on information in books written by Speight (1991)
and Gary and Handwerk (1993). Additional information
is provided by Dryoff(1993).
1.3.1.1
Gasoline
Gasoline is a  major exception  to  the  boiling  point
classification  described  above  because  "straight-run
gasoline" (gasoline directly recovered from a distillation
column) is only a small fraction of the blended gasoline
that  is commercially available as fuel.  Commercially
available gasolines are complex mixtures of hydrocarbons
that boil below 180 °C or at most 225 °C and that contain
hydrocarbons with 4 to 12 carbon atoms per molecule. Of
the commercially available gasolines, aviation gasoline has
a narrower boiling range (38 to 170 °C) than automobile
gasoline (-1 to 200 °C). In addition, aviation gasoline may
contain high levels  of paraffins (50  to  60  percent),
moderate levels of naphthenes (20 to 30 percent), a low
level of aromatic  hydrocarbons  (10 percent), and no
olefins, whereas automobile gasoline may contain  up to
30  percent  olefins  and  up to  40 percent  aromatic
hydrocarbons.

Gasoline composition can vary widely depending on the
source of crude oil.  In addition, gasoline composition
varies from region to region because of consumer needs for
gasoline with a high octane rating  to prevent engine
"knocking."  Moreover, EPA regulations regarding the
vapor pressure of gasoline, the chemicals used to produce
a high octane  rating, and  cleaner-burning  fuels have
affected gasoline composition. For example, when use of
tetraethyl lead to produce  gasoline  with  a  high octane
rating was banned by the EPA, oxygenated fuels came into
existence. Production of these fuels included addition of
methyl-tert-butyl  ether  (MTBE),  ethanol,  and  other
oxygenates.  Use  of oxygenated fuels  also  results in
reduction of air pollutant emissions (for example, carbon
monoxide and nitrogen oxides).

1.3.1.2     Naphthas

"Naphtha" is a generic term applied to petroleum solvents.
Under standardized  distillation  conditions,  at  least
10 percent of naphthas should distill below 175 °C, and at
least 95 percent of naphthas should distill below 240 °C.
Naphthas can be both aliphatic and aromatic and contain
hydrocarbons with 6 to  14 carbon atoms per molecule.
Depending on the intended use of a naphtha, it may be free
of aromatic hydrocarbons (to make it odor-free) and sulfur
(to make it less toxic and less corrosive).  Many forms of
naphthas are commercially available, including Varnish
Makers' and Painters' naphthas (Types I and II), mineral
spirits  (Types I through  IV),  and aromatic  naphthas
(Types I and II).  Stoddard solvent is an example of an
aliphatic naphtha.
                                            1.3.1.3
           Kerosene
                                            Kerosene is a straight-run petroleum fraction that has a
                                            boiling point range of 205 to 260 °C. Kerosene typically
                                            contains hydrocarbons with 12 or more carbon atoms per
                                            molecule.  Because of its use as  an indoor fuel, kerosene
                                            must be free of aromatic and unsaturated hydrocarbons as
                                            well as sulfur compounds.
                                            1.3.1.4
           Jet Fuels
                                            Jet fuels, which are also known as aircraft turbine fuels,
                                            are manufactured by blending gasoline, naphtha, and
                                            kerosene in varying proportions. Therefore, jet fuels may
                                            contain a carbon range that  covers  gasoline through
                                            kerosene.  Jet fuels are used in  both military and
                                            commercial aircraft.  Some examples of jet fuels include
                                            Type A, Type A-l, Type B, JP-4, JP-5, and JP-8. The
                                            aromatic hydrocarbon content of these fuels  ranges from
                                            20 to 25 percent.  The military jet fuel JP-4 has a wide
                                            boiling point range (65 to 290 °C), whereas commercial jet
                                            fuels,  including JP-5 and Types A and A-l, have a
                                            narrower boiling point range (175 to 290 °C) because of
                                            safety considerations. Increasing concerns over combat
                                            hazards associated with JP-4 jet fuel led to development of
                                            JP-8 jet fuel, which  has a flash point of 38  °C and a
                                            boiling point range  of  165  to 275 °C.  JP-8 jet fuel
                                            contains hydrocarbons with 9 to 15 carbon atoms per
                                            molecule. Type B jet fuel has a boiling point range  of
                                            55 to 230 °C and a carbon range of 5 to 13 atoms per
                                            molecule.   A new  specification is currently  being
                                            developed  by the American  Society for Testing and
                                            Materials (ASTM) for Type B jet fuel.
                                            1.3.1.5
           Fuel Oils
                                            Fuel oils  are divided into two classes: distillates and
                                            residuals.  No. 1 and 2 fuel oils are distillates and include

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kerosene, diesel, and home heating oil. No. 4, 5, and 6
fuel oils are residuals or black oils, and they all contain
crude distillation tower bottoms (tar) to which cutter stocks
(semirefined or refined distillates) have been added. No. 4
fuel oil contains the most cutter stock, and No. 6 fuel oil
contains the least.

Commonly available fuel oils include No. 1,2,4,5, and 6.
The boiling points, viscosities, and densities of these fuel
oils increase  with  increasing  number designation.  The
boiling point ranges for No. 1,2, and 4 fuel oils are about
180 to 320, 175 to 340, and 150 to 480 °C, respectively.
No. 1 and 2 fuel oils contain hydrocarbons with 10 to 22
carbon atoms per molecule; the carbon range for No. 4 fuel
oil is 22 to  40 atoms per molecule.  No. 5 and 6 fuel oils
have a boiling point range of  150 to 540 °C but differ in
the amounts of residue they contain: No. 5 fuel oil contains
a small amount of residue, whereas No. 6 fuel oil contains
a large amount. No. 5 and 6 fuel oils contain hydrocarbons
with 28 to 90  carbon  atoms per molecule.   Fuel  oils
typically contain about 60 percent aliphatic hydrocarbons
and 40 percent aromatic hydrocarbons.
1.3.1.6
Diesel
Diesel is primarily used to operate motor vehicle and
railroad diesel engines. Automobile diesel is available in
two grades: No. 1 and 2. No.  1 diesel, which is sold in
regions with cold climates, has a boiling point range of 180
to 320 °C and  a cetane number above 50. The cetane
number is similar  to  the octane number of gasoline; a
higher number corresponds to less knocking. No. 2 diesel
is very similar to No. 2 fuel oil.  No. 2 diesel has a boiling
point range  of 175 to 340 °C and a minimum cetane
number of 52. No. 1 diesel is used in high-speed engines
such as truck and bus engines, whereas No. 2 diesel is used
in other diesel engines. Railroad diesel is similar to No. 2
diesel but has a higher boiling point (up to 370 °C) and
lower cetane number (40 to 45). The ratio of aliphatic to
aromatic hydrocarbons in diesel  is about 5. The carbon
range for hydrocarbons present in diesel is 10 to 28 atoms
per molecule.

1.3.1.7     Lubricating Oils

Lubricating oils can be distinguished from other crude oil
fractions by their high  boiling points (greater than [>]
400 °C) and viscosities.  Materials suitable for production
of  lubricating  oils  are  composed   principally   of
hydrocarbons containing 25 to 35 or even 40 carbon atoms
per  molecule,  whereas residual  stocks  may  contain
hydrocarbons with 50 to 60 or more (up  to 80  or so)
carbon atoms per molecule.  Because it is difficult to
isolate hydrocarbons from the lubricant fraction of
petroleum, aliphatic to aromatic hydrocarbon ratios are not
well documented for lubricating oils.  However, these
ratios are expected to be comparable to those of the source
crude oil.

1.3.2  Measurement of TPH

As  described  in Section  1.3.1, the  composition of
petroleum and its products is complex and variable, which
complicates TPH measurement. The measurement of TPH
in soil is further complicated by weathering effects. When
a petroleum product is  released to soil, the  product's
composition  immediately  begins  to change.    The
components with lower boiling points are volatilized, the
more water-soluble components migrate to  groundwater,
and biodegradation  can  affect many other components.
Within a short period, the contamination remaining in soil
may have only some characteristics in common with the
parent product.

This  section provides a historical perspective on TPH
measurement,   reviews  current  options  for  TPH
measurement in soil, and discusses the definition of TPH
that was used for the demonstration.

1.3.2.1     Historical Perspective

Most  environmental  measurements  are  focused  on
identifying and quantifying a particular trace  element (such
as  lead)  or  organic compound  (such   as  benzene).
However, for  some "method-defined" parameters, the
particular substance being measured may yield different
results depending  on the  measurement method used.
Examples of such parameters include oil and grease and
surfactants. Perhaps the most problematic of the method-
defined parameters is TPH. TPH arose as a parameter for
wastewater analyses in the 1960s because  of petroleum
industry  concerns  that  the original  "oil  and  grease"
analytical method, which is gravimetric in  nature, might
inaccurately characterize petroleum industry wastewaters
that  contained  naturally occurring  vegetable  oils and
greases along  with PHCs.  These  naturally  occurring
materials are typically long-chain fatty acids (for example,
oleic acid, the major component of olive oil).

Originally, TPH was defined as any material extracted
with a particular solvent that is not adsorbed by the silica
gel used to remove fatty acids and that is not lost when the

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solvent is evaporated.  Although this definition covers
most of the components of petroleum products, it includes
many other  organic  compounds  as  well, including
chlorinated  solvents,  pesticides,  and  other  synthetic
organic   chemicals.    Furthermore,  because  of  the
evaporation step in the gravimetric analytical method, the
definition excludes  most  of  the petroleum-derived
compounds in gasoline that are volatile in nature. For
these reasons, an infrared analytical method was developed
to measure TPH.  In this method, a calibration standard
consisting of three components is analyzed at a wavelength
of 3.41   micrometers  (um),  which corresponds  to an
aliphatic CH2 hydrocarbon stretch. As shown in Table 1 -1,
the calibration standard is designed to mimic a petroleum
product having a relative  distribution of aliphatic and
aromatic  compounds as well as a certain percentage of
aliphatic  CH2 hydrocarbons.  The infrared analytical
method indicates that any compound that is extracted by
the solvent, is not adsorbed by silica gel, and contains a
CH2 bond is a PHC.  Both the gravimetric and infrared
analytical methods  include  an  optional,  silica  gel
fractionation step to remove polar, biogenic compounds
such as fatty acids, but this cleanup step can also remove
some petroleum degradation products  that are  polar in
nature.

In the 1980s, because  of the  change in  focus from
wastewater  analyses to characterization  of hazardous
waste sites that contained contaminated soil, many parties
began to adapt the existing wastewater analytical methods
for application to soil. Unfortunately, the term "TPH" was
in common  use, as  many states had adopted this term
(and the  wastewater  analytical methods) for  cleanup
activities  at  underground  storage tank  (UST)  sites.
Despite efforts by the API and others to establish new
analyte  names (for example, gasoline range  organics
[GRO] and diesel range organics [DRO]), "TPH" is still
present in many state regulations as a somewhat ill-defined
term, and most state programs still have cleanup criteria
for TPH.

1.3.2.2     Current Options for TPH Measurement
           in Soil

Three widely used technologies measure some form of
TPH in soil to some degree. These technologies were used
as starting points in deciding how to define TPH for the
demonstration.  The three technologies and the analytes
measured are summarized in Table 1-2.

Of the three  technologies, gravimetry and infrared are
discussed in Section 1.3.2.1. The third technology, the gas
chromatograph/flame ionization detector (GC/FID), came
into use because of the documented shortcomings of the
other two technologies. The GC/FID had long been used
in the petroleum refining industry as a product QC tool to
determine the boiling point distribution of pure petroleum
products. In the 1980s, environmental laboratories began
to apply this technology along with sample preparation
methods developed for soil samples to measure PHCs at
environmental levels (Zilis, McDevitt, and Parr  1988).
GC/FID methods measure all organic compounds that are
extracted by the solvent and that can be chromatographed.
However, because of method limitations, the very volatile
portion  of gasoline compounds containing four or five
carbon atoms per molecule is not addressed by GC/FID
methods; therefore, 100  percent recovery cannot  be
achieved for  pure  gasoline.   This omission is not
considered  significant because  these low-boiling-point
aliphatic compounds (1) are not expected to be present in
environmental samples (because of volatilization) and
(2) pose less  environmental  risk  than  the   aromatic
hydrocarbons in gasoline.
Table 1-1.  Summary of Calibration Information for Infrared Analytical Method
Standard
Constituent
Hexadecane
Isooctane
Chlorobenzene
Constituent Type
Straight-chain aliphatic
Branched-chain aliphatic
Aromatic
Portion of Constituent
in Standard
(percent by volume)
37.5
37.5
25
Number of Carbon Atoms
Aliphatic
CH3
2
5
0
CH2
14
1
0
CH
0
1
0
Aromatic
CH
0
0
5
Average
Portion of Aliphatic CH2 in
Standard Constituent
(percent by weight)
91
14
0
35

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Table 1-2. Current Technologies for TPH Measurement
Technology
Gravimetry
Infrared
Gas chromatograph/flame ionization detector
What Is Measured
All analytes removed from the sample by the
extraction solvent that are not volatilized
All analytes removed from the sample by the
extraction solvent that contain an aliphatic CH2
stretch
All analytes removed from the sample by the
extraction solvent that can be chromatographed
and that respond to the detector
What Is Not Measured
Volatiles; very polar organics
Benzene, naphthalene, and other aromatic
hydrocarbons with no aliphatic group attached;
very polar organics
Very polar organics; compounds with high
molecular weights or high boiling points
The primary limitation of GC/FID methods relates to the
extraction solvent used. The solvent should not interfere
with the analysis, but to achieve environmental levels of
detection (in the low milligram per kilogram [mg/kg]
range) for soil, some concentration of the extract is needed
because the sensitivity of the FID is in the nanogram (ng)
range.   This  limitation  has resulted in three  basic
approaches for GC/FID  analyses for GRO, DRO, and
PHCs.

For GRO analysis,  a GC/FID method was developed as
part of research sponsored by API and was the subject of
an interlaboratory validation study (API 1994); the method
was  first published in 1990.  In  this method, GRO is
defined as the sum of the organic compounds in the boiling
point range of 60  to 170 °C, and the method uses a
synthetic calibration standard as both a window-defining
mix and a quantitation standard. The GRO method was
specifically  incorporated  into EPA "Test Methods  for
Evaluating Solid Waste" (SW-846) Method 8015B in 1996
(EPA 1996).  The GRO method uses the purge-and-trap
technique for sample preparation, effectively limiting the
TPH components to the volatile compounds only.

For DRO analysis, a GC/FID method was developed under
the sponsorship of API as a companion to the GRO method
and was  interlaboratory-validated in 1994. In the DRO
method,  DRO is defined as the sum of the organic
compounds in the boiling point range of 170 to 430 °C.  As
in the GRO method,  a synthetic calibration standard is
used  for quantitation.   The DRO  method  was also
incorporated into SW-846 Method 8015B in 1996. The
technology  used in  the  DRO  method can  measure
hydrocarbons with boiling points up to 540 °C. However,
the hydrocarbons with boiling points in the range of 430 to
540   °C  are specifically  excluded  from   SW-846
Method 8015B so  as not to include the higher-boiling-
point petroleum  products.  The  DRO method uses a
solvent  extraction  and concentration step,  effectively
limiting the method to nonvolatile hydrocarbons.

For PHC analysis, a GC/FID method was developed by
Shell  Oil Company (now  Equilon  Enterprises).  This
method was interlaboratory-validated along with the GRO
and DRO methods  in an API study in 1994.  The PHC
method  originally  defined PHC as  the sum of the
compounds in the  boiling  point range of about 70 to
400 °C, but  it now defines PHC as the sum of the
compounds in the boiling point range of  70  to 490 °C.
The method provides options for instrument calibration,
including use of synthetic standards, but it recommends
use of products similar to the contaminants present at the
site of concern. The PHC method has not been specifically
incorporated into SW-846; however, the method has been
used as the basis for the TPH methods in several states,
including Massachusetts, Washington, and Texas.  The
PHC method uses solvent microextraction and thus has a
higher detection limit than  the GRO and DRO methods.
The PHC method also begins peak integration after elution
of the solvent peak for n-pentane.  Thus, this  method
probably cannot measure some volatile compounds (for
example, 2-methyl pentane and MTBE) that are measured
using the GRO method.
1.3.23
Definition of TPH
It is not possible to establish a definition of TPH that
would  include crude oil and its refined products and
exclude other  organic compounds.  Ideally, the TPH
definition selected for the demonstration would have

    Included compounds that are PHCs, such as paraffins,
    naphthenes, and aromatic hydrocarbons

•   Included, to the  extent possible, the  major liquid
    petroleum products (gasoline, naphthas, kerosene, jet
    fuels, fuel oils, diesel, and lubricating oils)

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•   Had little inherent bias based on the composition of an
    individual manufacturer's product

•   Had  little  inherent  bias  based  on  the  relative
    concentrations of aliphatic and aromatic hydrocarbons
    present

•   Included much of the volatile  portion of gasoline,
    including all weathered gasoline

•   Included MTBE

    Excluded crude oil residuals beyond the extended
    diesel range organic (EDRO) range

•   Excluded  nonpetroleum organic  compounds (for
    example,   chlorinated   solvents,  pesticides,
    polychlorinated  biphenyls  [PCB],  and  naturally
    occurring oils and greases)

•   Allowed TPH measurement using a widely accepted
    method

•   Reflected  accepted TPH  measurement practice  in
    many states

Several  states,  including  Massachusetts,  Alaska,
Louisiana, and North Carolina, have implemented or are
planning to implement a  TPH contamination cleanup
approach based on the aliphatic and aromatic hydrocarbon
fractions of TPH.  The action levels  for the aromatic
hydrocarbon fraction are more stringent than those for the
aliphatic hydrocarbon fraction.  The approach used in the
above-mentioned  states involves performing a sample
fractionation procedure and two analyses to determine the
aliphatic and aromatic hydrocarbon concentrations in a
sample. However, in most applications of this approach,
only a few samples are subjected to the dual aliphatic and
aromatic hydrocarbon  analyses  because of the costs
associated with performing sample fractionation and two
analyses.

For the demonstration, TPH was not defined based on the
aliphatic and aromatic hydrocarbon fractions because

•   Such a definition is used in only a few states.
    Variations exist among the sample fractionation and
    analysis procedures used in different states.

•   The  repeatability  and   versatility  of   sample
    fractionation and analysis procedures are not well
    documented.

•   In some states, TPH-based action levels are still used.

•   The associated analytical costs are high.

As stated in Section 1.3.2.2, analytical methods currently
available for  measurement of TPH each exclude some
portion of TPH and are unable  to measure TPH alone
while excluding all other organic compounds, thus making
TPH a method-defined parameter. After consideration of
all the information presented above, the GRO and DRO
analytical methods were selected for TPH measurement for
the  demonstration.  However, because of the general
interest in higher-boiling-point petroleum products, the
integration  range of the  DRO method was extended to
include  compounds  with boiling points  up to  540 °C.
Thus, for the  demonstration, the TPH concentration was
the sum of all  organic compounds that have boiling points
between 60 and 540 °C and that can be chromatographed,
or the sum of the results obtained using the GRO and DRO
methods.   This approach accounts  for most gasoline,
including MTBE,  and  virtually  all other  petroleum
products and excludes a portion (25 to 50 percent) of the
heavy lubricating oils. Thus, TPH measurement for the
demonstration included PHCs as well as some organic
compounds that are not PHCs.  More specifically,  TPH
measurement  did not  exclude nonpetroleum  organic
compounds such as chlorinated solvents,  other synthetic
organic  chemicals  such as pesticides and PCBs, and
naturally occurring  oils and  greases.    A  silica gel
fractionation  step  used to  remove polar,  biogenic
compounds such as fatty acids in some GC/FID methods
was not included in the sample preparation step because,
according to  the State of California,  this step can also
remove some petroleum degradation products that are also
polar in nature  (California  Environmental  Protection
Agency 1999). The step-by-step approach used to select
the  reference method for the  demonstration  and the
project-specific procedures implemented for soil sample
preparation and analysis using the reference method are
detailed in Chapter 5.
                                                    10

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                                              Chapter 2
     Description of Immunoassay and Colorimetry and the EnSys Petro Test System
Measurement of TPH in soil by field measurement devices
generally involves extraction of PHCs from soil using an
appropriate solvent followed by measurement of the TPH
concentration in the extract using an optical method. An
extraction solvent is selected that will not interfere with the
optical measurement of TPH in the  extract.  Some field
measurement devices use light in the visible wavelength
range, and others use light outside the visible wavelength
range (for example, ultraviolet light).

The  optical measurements  made by field measurement
devices  may   involve  absorbance,   reflectance,  or
fluorescence.  In general, the optical measurement for a
soil extract is compared to a calibration curve in order to
determine the TPH concentration. Calibration curves may
be developed by (1) using a series of calibration standards
selected based on the type of PHCs  being measured at a
site  or (2) establishing a  correlation between off-site
laboratory  measurements  and field measurements  for
selected, site-specific soil samples.

Field measurement  devices  may  be  categorized as
quantitative, semiquantitative, and  qualitative.  These
categories are explained below.

•   A quantitative measurement device measures TPH
    concentrations ranging from its reporting limit through
    its linear range. The measurement result is reported as
    a single, numerical value that has an established
    precision and accuracy.

•   A semiquantitative measurement device  measures
    TPH concentrations above its reporting limit.  The
    measurement result may be reported as a concentration
    range with lower and upper limits.

•   A  qualitative measurement device indicates  the
    presence or absence of PHCs above or below a
    specified value (for example, the reporting limit or an
    action level).

The EnSys Petro  Test System is a field measurement
device capable  of providing  semiquantitative  TPH
measurement results. Measurements made by the EnSys
Petro  Test System are  based  on immunoassay  and
colorimetry using  light in the visible wavelength range.
Immunoassay and colorimetry are described in Section 2.1.
The EnSys Petro Test System does not require generation
of a calibration curve because it provides semiquantitative
results. A concentration range is reported by evaluating
whether the TPH concentration in a given sample is greater
or less than the concentration  in one or more reference
standards; SDI does  not report  an  absolute  sample
concentration through interpolation of reference standard
concentrations.

Section 2.1 describes  the  technology  upon which the
EnSys Petro Test System is based, Section 2.2 describes
the EnSys Petro  Test System itself, and Section 2.3
provides  SDI contact information.  The technology and
device descriptions presented below are not intended  to
provide complete operating procedures for measuring TPH
concentrations in soil using the EnSys Petro Test System.
Detailed operating procedures for the device, including soil
extraction, TPH measurement, and TPH concentration
range calculation  procedures,  are  available  from SDI.
Supplemental information provided by SDI is presented in
the appendix.

2.1    Description of Immunoassay and
       Colorimetry

Measurement of TPH in soil using the EnSys Petro Test
System is based on a combination of immunoassay and
colorimetry.  According  to SDI,  this combination of
technologies is suitable for measuring a large portion  of
                                                   11

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the  aromatic  hydrocarbons   and  a  few   aliphatic
hydrocarbons  in the  C6 through C22 carbon  range.
Immunoassay and colorimetry are described below.

2.1.1      Immunoassay

Immunoassay  is  a technique  for measuring  a target
compound's concentration using biologically engineered
antibodies. Antibodies are a class  of proteins known as
immunoglobulins that are produced by the immune system
of animals in response to a foreign substance (an antigen).
The antibodies produced can bind  with the antigen that
stimulated their production.  Specifically, antibodies are
produced in response to localized, reactive sites called
antigenic  determinants  on the  surface  of the antigen.
Antigenic determinants consist of amino acid sequences
(Rittenburg 1990).  Because an antigen may possess more
than one type of antigenic determinant, more than one type
of antibody may be produced by the immune system. In
general, the antibodies produced are structured  in such a
way  that  they  selectively  bind  to  the   antigenic
determinants   on  the   antigen  that  stimulated  their
production, resulting in formation of an antibody-antigen
complex.

Five major classes of antibodies (immunoglobulin [Ig] A,
IgD, IgE, IgG, and IgM)  are produced by the immune
system. IgG is the most common type of antibody used in
immunoassay  (Rittenburg 1990).   IgG  is  a  Y-shaped
molecule consisting of two identical heavy polypeptide
chains and two identical light polypeptide chains bound
together by disulfide bonds.  Both the heavy  and light
chains have variable and constant regions. The variable
regions at the ends  of the two arms of the Y-shaped
antibody form areas called antigen-binding sites; therefore,
two antigen-binding  sites  are present on each antibody.
The general structure of the IgG antibody is shown in
Figure 2-1.

The dimensions and contours of antigen-binding sites are
determined by the sequence of amino acids in the variable
regions of the antibody. On a single antibody molecule,
the two binding sites have identical variable regions. As
a result, the two binding sites have identical specificity for
a  particular antigenic determinant (Rittenburg  1990).
However, the binding sites of antibodies produced in
response to different antigenic determinants are not the
same.

The binding affinity between an antibody and antigen is
determined by (1) the sequence of amino  acids in the
variable regions of the antibody, (2) the structure and
location of the antigenic determinant on the antigen, and
(3) the attractive forces that stabilize the antibody-antigen
complex. The attractive forces include a combination of
hydrogen  bonds,  hydrophobic  bonds,   coulombic
interaction, and van der Waals forces (Rittenburg 1990).
The closer the antigenic  determinant is to the antigen-
binding site  on the antibody, the higher the binding
affinity.

Immunoassays employ either polyclonal or monoclonal
antibodies. Because an antigen generally contains more
than one type of antigenic determinant, more than one type
of antibody may be produced in the immune response.
Therefore, the antibodies  produced are not identical and
are called polyclonal antibodies.  Because polyclonal
antibodies are not identical, they will, as a group, exhibit
varied specificities and binding affinities for antigenic
determinants.  Monoclonal antibodies are produced  by
isolating those antibodies produced in response to one type
of antigenic determinant.   As a result,  monoclonal
antibodies are structurally identical and exhibit the same
specificities and  binding affinities for the antigenic
determinant that stimulated their production.

Although an antibody has a particular specificity and
binding  affinity  for  the antigenic determinant  that
produced the  antibody, cross-reactivity  with  other
compounds may occur. For example, cross-reactivity may
occur when the antigenic  determinant that stimulated the
antibody's production is present in other compounds (SDI
2000).   Cross-reactivity may also occur  with  other
compounds  that possess structurally  similar antigenic
determinants (Rittenburg  1990).

Immunoassay effectiveness  is  primarily a  function  of
(1) the specificities and binding affinities of the polyclonal
or monoclonal antibodies used and  (2) whether one
compound or a group of  compounds is being measured.
For example, cross-reactivity will result in false positives
when only one compound is  being measured. However,
cross-reactivity is desirable when a group of compounds,
such as PHCs, is being measured. Whether polyclonal or
monoclonal antibodies are better  suited for measuring
PHCs  depends on the individual  antibodies used;  for
example, highly cross-reactive, monoclonal antibodies can
be  as  effective  as   less  cross-reactive,  polyclonal
antibodies.
                                                     12

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                                              Antigen-binding
                                                   sites
                                                   Heavy
                                                   chains
~


CH


-s-s-
-s-s-
•S J
-S J
-S J
•S J
k
%
5-
3-
^





                                                                                              Light
                                                                                              chain
Notes:

-S-S- = Disulfide bond
C    = Constant region
H    = Heavy polypeptide chain
L    = Light polypeptide chain
V    = Variable region

Figure 2-1. Immunoglobulin G antibody structure and locations of antigen-binding sites.
The EnSys  Petro  Test  System is based on  a type of
immunoassay called enzyme-linked immunosorbent assay
(ELISA).  ELISA uses either polyclonal or monoclonal
antibodies adsorbed to the inside wall of a test tube in
order to facilitate separation of target compounds from
nontarget compounds during a washing step. In ELISA, an
enzyme conjugate solution is used to produce color whose
intensity  is  inversely  proportional   to   the  total
concentration  of PHCs in a  sample extract.   ELISA
involves the following three steps: (1) enzyme conjugate
and sample extract addition, (2) washing, and (3) color
development.  These steps are described below and are
illustrated in Figure 2-2.  The intensity  of the color
produced during color development is measured using
standard  colorimetric   principles   as   described  in
Section 2.1.2.

Enzyme Conjugate and Sample Extract Addition .  As
a first step, an enzyme conjugate solution is added to the
soil sample extract.  An enzyme conjugate is an enzyme
                                                     13

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Step
Schematic
Description
Enzyme conjugate and sample extract addition
                                              00...
                       A reaction mixture containing the sample
                       extract and enzyme conjugate solution is
                       added to an antibody-coated test tube. The
                       sample extract target compound and enzyme
                       conjugate compete for antigen-binding sites.
Washing
                       The unbound sample extract target
                       compound and enzyme conjugate are
                       removed from the test tube.
Color development
                                                          J-
                                                                          A substrate and chromogen are added to the
                                                                          test tube.
                                                                          The substrate and chromogen react with the
                                                                          enzyme in the enzyme conjugate to produce
                                                                          color. The lower the color intensity, the
                                                                          higher the sample extract target compound
                                                                          concentration.
Notes:

 Y  = Antibody
 •  = Sample extract target compound
 O  = Enzyme conjugate
 s*  = Substrate
 _i_  = Chromogen

Figure 2-2. Enzyme-linked immunosorbent assay.
bound to a target compound. The antigen used to initiate
antibody production is also used as the target compound
portion of the enzyme conjugate. The enzyme portion of
the enzyme conjugate plays its role in ELISA during the
color development step;  the  enzyme  typically used in
ELISA is horseradish peroxidase.  The reaction mixture
containing  the  sample extract and enzyme  conjugate
solution is added to an antibody-coated test tube. Because
both the sample extract target compound and the enzyme
conjugate can bind with the antibodies, the sample extract
target compound and the enzyme conjugate compete for
the antigen-binding sites on the antibodies. The sample
extract target compound and the enzyme conjugate bind to
the  antibodies  in direct  proportion  to  their relative
concentrations in the reaction mixture. For example, the
greater the  ratio of the sample extract target compound
concentration to the enzyme conjugate concentration, the
      greater the proportion of antigen-binding sites that are
      occupied by the sample extract target compound.

      Washing.  The sample extract target compound and the
      enzyme conjugate that are bound to the antibodies are
      separated  from  the  unbound  sample  extract target
      compound and enzyme conjugate by emptying the reaction
      mixture from the test tube and washing the test tube with
      potable water or a dilute detergent solution.

      Color Development.   A substrate, such  as hydrogen
      peroxide, and a chromogen, such as tetramethylbenzidine
      or orthophenylenediamine, are then added to the test tube
      in order to produce color when they react with the enzyme
      in the enzyme conjugate.   For  example,  the  enzyme
      horseradish peroxidase reacts with the hydrogen peroxide
      to release a proton, which in turn reduces the chromogen
                                                      14

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to form the colored product. After a specified period of
time, color development in the test tube is terminated using
a stopping solution such as hydrochloric acid. The amount
of color formed is directly proportional to the amount of
enzyme conjugate bound to the antibodies.  Because the
sample extract target compound competes with the enzyme
conjugate for antigen-binding sites, ELISA  results in
formation of color in the test tube whose intensity is
inversely proportional to the concentration of the sample
extract target compound; for example, less color indicates
a higher concentration  of the  sample  extract target
compound.

2.1.2  Colorimetry

After completion of color development, the concentration
of PHCs  in the  sample extract is  determined using
colorimetry.  Colorimetry is a technique by which the
intensity  of  color  is  assessed   using  visual or
spectrophotometric means. Use of a spectrophotometer is
preferred over visual assessment of color charts because
the  spectrophotometer provides a more accurate  and
precise measurement and does not rely  on a person's
skill  in  interpreting  color  charts.    A reflectance
spectrophotometer measures the intensity of light reflected
from  solid  particles in  a  reaction mixture, and an
absorbance spectrophotometer measures  the intensity of
light that passes through the liquid portion of a reaction
mixture. The EnSys Petro T est System uses an absorbance
spectrophotometer because the colored reaction product is
present in the liquid phase.

When  a  spectrophotometer  is  used  in  the  visible
wavelength range, the reaction mixture is placed in a glass
or  quartz   cuvette  that is  then  inserted  into  the
spectrophotometer. A beam of visible light is then passed
through the reaction mixture. The wavelength of the light
entering  the reaction mixture is initially  selected by
performing a series of absorbance measurements over a
range of wavelengths; the selected wavelength generally
provides  maximum  absorbance  and   allows  target
compound measurement over a wide concentration range.

Some of the light is absorbed by the chemicals in the
reaction mixture, and the rest of the light passes through.
Absorbance, which is defined as the logarithm of the ratio
of the radiant power of the light source to that of the light
that passes through the reaction mixture, is measured by a
photoelectric detector in the spectrophotometer (Fritz and
Schenk 1987).  Absorbance  can  be calculated  using
Equation 2-1.
where
    A
    I   =
            A = 109(10/1)                (2-1)

    Absorbance

    Intensity of light source

    Intensity of  light that  passes through the
    reaction mixture
Therefore, the intensity of the light that passes through
the reaction  mixture  is  inversely proportional  to  the
concentration  of the  colored product in the reaction
mixture,  or the  intensity of the light absorbed by  the
reaction  mixture   is  directly  proportional  to   the
concentration  of the  colored product in the reaction
mixture.

According to Beer-Lambert's law, Equation 2-1  may be
expressed as shown in Equation 2-2.
                      A=ebc
                                        (2-2)
where
    A
= Absorbance
    e  = Molar absorptivity (centimeter per mole per
          liter [L])

    b  = Light path length (centimeter)

    C  = Concentration of  absorbing species (mole
          perL)

Thus, according to Beer-Lambert's law, the absorbance of
a  chemical  species  is  directly proportional to  the
concentration of the absorbing chemical species (colored
reaction product) and the path length of the light that is not
absorbed by the reaction mixture and passes through the
mixture.   In Equation 2-2, the molar absorptivity is a
proportionality constant, which is a characteristic of the
absorbing species and changes as the wavelength of the
light irradiating the reaction mixture changes. Therefore,
Beer-Lambert's law applies only to monochromatic light
(light energy of one wavelength).

For the EnSys Petro Test System, the absorbance of the
colored reaction mixture is assessed using a differential
photometer. The differential photometer is a double-beam
instrument in  which two equivalent  beams of light are
produced within the visible range of the electromagnetic
spectrum. One beam passes through the colored reaction
mixture developed  using the sample extract, while the
other beam passes  through a colored reaction mixture
developed using a reference standard.  The  photometer
                                                     15

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measures the difference in absorbance between the two
colored reaction mixtures.   Because color intensity  is
inversely proportional to the concentration of the sample
extract  target compound, a positive reading  on the
photometer indicates that the total concentration of PHCs
in the sample extract is less  than that in the reference
standard. Similarly, a negative reading on the photometer
indicates that the total concentration of PHCs in the sample
extract is greater than that in the reference standard.

2.2     Description of EnSys Petro Test System

The EnSys Petro Test System is manufactured by SDI and
has been commercially available since  1992. The device
conforms to SW-846 Method 4030 for screening PHCs
using immunoassay detection (EPA 1996). This section
describes  the device  and  summarizes  its  operating
procedure.

2.2.1   Device Description

The EnSys Petro Test System consists of three kits: the
(1) SDI Sample Extraction Kit (Sample Extraction Kit),
(2) EnSys Petro 12T Soil Test Kit (12T Soil Test Kit), and
(3) EnSys/EnviroGard® Common Accessory Kit (Common
Accessory Kit). The EnSys Petro Test System includes
antibody-coated   test  tubes  containing   monoclonal
antibodies, which are produced using m-xylene  as the
antigen. The enzyme conjugate used to produce color is
composed  of m-xylene  as  the  target compound and
horseradish peroxidase as the enzyme.  The washing step
is performed with  a dilute  detergent solution.   Color
development is achieved using hydrogen peroxide as the
substrate and tetramethy Ibenzidine as the chromogen. The
stop solution added to terminate color development  is
0.5 percent sulfuric  acid. A differential photometer that
emits light in the visible range of the electromagnetic
spectrum  at  a 450-nanometer wavelength is used  to
measure the absorbance of the sample extract and of a
reference standard containing  3 mg/L m-xylene  during
color measurement.  The total concentration of PHCs  in
the sample extract is then determined by comparing the
absorbance readings associated with the sample extract and
reference standard.

According to SDI, the EnSys Petro Test System can be
used to measure the  following petroleum products in soil:
gasoline, diesel, Jet A fuel, JP-4, kerosene, No. 2 fuel oil,
No.  6  fuel  oil, and mineral spirits.   The  monoclonal
antibodies used in the device are specific to a subset of
petroleum product components, including a large portion
of the  aromatic  hydrocarbons  and  a  few aliphatic
hydrocarbons in the C6 through C22 carbon range.

The method detection limits (MDL) of the EnSys Petro
Test System claimed by SDI for a variety of aromatic and
aliphatic hydrocarbons are presented hi Table 2-1. Except
for benzene, which has  an  MDL of 400 mg/kg, the
aromatic hydrocarbons listed in Table 2-1 have MDLs that
are less than or equal to (<.) 40 mg/kg, indicating a high
degree of selectivity.  A few aliphatic hydrocarbons, such
as 2-methylpentane and isooctane, also have low MDLs.
Table 2-1  also presents the MDLs for various petroleum
products.  These MDLs generally range from 10 mg/kg
(gasoline) to 40 mg/kg (mineral spirits).  The MDLs for
machine oil, brake fluid,  unused motor oil, grease, and
mineral oil are all > 1,000 mg/kg, indicating that the EnSys
Petro Test System is not as sensitive to these formulated
petroleum products.

According to SDI, the operating temperature range for the
12T Soil Test Kit is 16 to 38 °C and the test kit should be
stored at <.21 °C when not in use.  SDI does not have an
operating humidity restriction for the test kit.   The shelf
life of the test kit is  typically  1 year after its  date of
manufacture; lot-specific  expiration  date  information is
provided on the test kit packaging.  The chromogen and
substrate solutions should not be exposed to direct sunlight
during test kit operation or storage.

The components of the EnSys Petro Test System are listed
in Table 2-2. The Sample Extraction Kit contains enough
supplies to perform 12 soil sample extractions. The 12T
Soil Test Kit contains enough supplies to process up to
12 samples (for example, 10 soil sample extracts and
duplicate calibration standards). The Common Accessory
Kit contains multi-use items that do not require frequent
replacement. All Common Accessory Kit items are housed
in a hard-plastic carrying case to prevent  damage to the
items during kit transport.  The Sample Extraction Kit and
12T Soil Test Kit items are shipped in cardboard boxes.

The  differential photometer (Artel DP™ Differential
Photometer) included in the Common Accessory Kit is
designed to provide an immediate, direct comparison of the
absorbance of two liquid samples (for example, a soil
sample extract and a reference standard) by means of a
digital display; the  display indicates  the difference in
                                                    16

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Table 2-1.  EnSys Petro Test System Method Detection Limits
                                Table 2-2. EnSys Petro Test System Components
Compound or Substance
Method Detection Limit
(milligram per kilogram)8
Petroleum fuel product
Gasoline
Diesel
Jet A fuel
JP-4
Kerosene
No. 2 fuel oil
No. 6 fuel oil
Formulated petroleum product
Mineral spirits
Machine oil
Brake fluid
Unused motor oil
Grease
Mineral oil
Aromatic hydrocarbon
Benzene
Toluene
Ethylbenzene
o-Xylene
m-Xylene
p-Xylene
Styrene
1 ,2-Dichlorobenzene
Hexachlorobenzene
Naphthalene
Acenaphthalene
Biphenyl
Creosote
Aliphatic hydrocarbon
2-Methylpentane
Hexanes (mixed)
Heptane
Isooctane
Undecane
Trichloroethylene
Methyl-tert-butyl ether
Notes:
> = Greater than

10
15
15
15
15
15
25

40>
>1,000b
>1,000.
>1,000b
>1,000b
>1,000

400
40
7
8.5
8
4.5
7
2.5
10
0.8
0.5
10
1.5

35
65
130
8-5b
>1,000
>1,000b
>1,000


•    Minimum soil concentration necessary to obtain a positive result
     more than 95 percent of the time
b    Highest concentration tested; positive  result not obtained at this
     concentration

Source: SD11999
SDI Sample Extraction Kit
•  12 extraction jars with screw caps (each jar contains 3 stainless-
   steel mixing balls)
*  12 filter units (tops and bottoms)
•  12 ampule crackers
•  12 dilution ampules for each dilution level
•  12 wooden spatulas
•  12 plastic weigh canoes
•  12 disposable transfer pipettes
•  12 ampules containing 100 percent methanol solvent
•  User guide

EnSys Petro 12T Soil Test Kit
•  48 monoclonal antibody-coated tubes
•  48 conjugate tubes
•  1 80-milliliter bottle of phosphate buffer solution
•  1 15-milliliter bottle of chromogen (tetramethylbenzidine)
•  1 15-milliliter bottle of substrate (hydrogen peroxide)
•  1 15-milliliter bottle of stop solution (0.5 percent sulfuric acid)
•  3 1-milliliter vials of Petro standard (3 milligrams per liter m-xylene)
•  24 Microman® positive displacement pipettor tips
•  3 5-milliliter Combitips® for the repeater pipettor
•  1 12.5-milliliterCombitip® for the repeater pipettor
•  12 plastic ampule crackers
•  3 amber vials (for storage of remnant solution from cracked
   ampules)
•  3 disposable transfer pipettes
•  2 480-milliliter bottles of dilute detergent solution (Tween-20)
•  User guide

EnSys/EnviroGard® Common Accessory Kit
•  1 battery-powered Artel DP™ Differential Photometer, including
   4 rechargeable  nickel-cadmium batteries and 1 battery recharger
•  1 battery-powered ACCULAB® digital balance, including 1 100-gram
   calibration weight and 1 9-volt battery
•  1 battery-powered digital timer, including 1 G-13 cell button battery
•  1 Gilson M-25 Microman® positive displacement pipettor
•  1 Eppendorf™ repeater pipettor
•  3 5-milliliter Combitips* for the repeater pipettor
•  5 12.5-milliliter Combitips® for the repeater pipettor
•  1 50-milliliter Combitip* for the repeater pipettor
•  1 wash bottle
•  1 foam workstation
•  2 foam 30-position test tube racks
•  User guides for differential photometer, balance, timer, and
   pipettors
•  Carrying case
absorbance between the two samples. The photometer is
3.4 inches long, 5.3 inches wide, and 2.6 inches high and
weighs 0.8 pound. The power supply for the photometer
consists of four rechargeable nickel-cadmium batteries; the
photometer cannot be operated using an alternating current
power source.  The batteries require 8 to 10 hours to
achieve a full recharge after discharge and last for about
500 readings between recharges.   According  to  SDI,
the  operating temperature  range  for the photometer is
                                 10 to 40 °C  and the photometer should be  stored at a
                                 temperature between -20 and 66 °C when not in use.  SDI
                                 does not have an operating humidity  restriction for the
                                 photometer.

                                 According  to SDI,  12 samples (including  soil  sample
                                 extracts  and reference standards) can be analyzed as one
                                 batch by one person using the EnSys Petro Test System in
                                 approximately 45 minutes.  The device is easy to operate
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and is designed to be used by those  with  basic wet
chemistry skills. In addition to the user guide or guides
that accompany each kit of the device, SDI provides
technical support over the telephone at no additional cost.
SDI also offers a 1-day, on-site training program.

According  to  SDI, the  EnSys Petro  Test System  is
innovative because the device uses biologically engineered
antibodies to measure PHCs in soil. SDI also claims that
the device  measures most  aromatic hydrocarbons and
some aliphatic hydrocarbons in the C6 through  C22 carbon
range.

2.2.2   Operating Procedure

During the demonstration, measuring TPH in soil using the
EnSys Petro Test System involved the following five steps:
(1) extraction,  (2) sample and standard  preparation,
(3) washing,  (4)  color  development,  and  (5)  color
measurement and estimation  of TPH concentration.
Extraction of a given soil sample was completed by adding
20 milliliters (mL) of methanol to 10 grams of the sample.
During  sample and  standard  preparation, the sample
extract  and a reference  standard were transferred  to
conjugate tubes containing phosphate buffer solution. The
mixtures were then transferred from the conjugate tubes to
antibody-coated tubes. Washing was accomplished by first
discarding the contents of the antibody-coated tubes and
then washing each tube with  dilute  detergent solution.
Color development included addition of chromogen and
substrate to each antibody-coated tube; the addition  of
substrate turned the reaction mixture blue. Stop solution
was then added to stop color development; the addition of
stop solution turned the reaction mixture  yellow.  To
accomplish color measurement, the absorbance of the
antibody-coated tubes containing the sample extract and of
the antibody-coated tube containing the reference standard
was compared using the differential photometer. Because
color   intensity  is  inversely  proportional  to  the
concentration of the sample extract target compound, a
positive reading on the photometer indicated that the total
concentration of PHCs in the sample extract was less than
that  in the reference standard.   Similarly,  a negative
reading  on  the  photometer  indicated that the  total
concentration of PHCs in the sample extract was greater
than that in the reference standard.

During the demonstration, SDI performed each analysis at
three detection levels by diluting the sample extract twice
during the sample and  standard preparation step.  The
reference standard concentrations for gasoline (10 mg/kg)
and  diesel (15 mg/kg) were multiplied by the  dilution
factors used.   Thus,  the concentration ranges  used to
estimate sample TPH concentrations were (1) <10; >10 to
<100; >100 to < 1,000; and > 1,000 mg/kg  for GRO-
containing samples and (2) <15; >15 to <100;  >100 to
< 1,000; and > 1,000 mg/kg for EDRO-containing samples.

During the demonstration, a QC check was performed for
the EnSys Petro Test  System during the fifth step (color
measurement and estimation of TPH concentration) of the
operating  procedure.   Two reference standard tubes
(duplicates) were switched in the photometer until the
photometer reading  was  negative  or zero.   Device
performance was considered to  be  acceptable if the
difference in the absorbance values between the standards
was <-0.30.

2.3    Developer Contact Information

Additional information about the EnSys Petro Test System
can be obtained from the following source:

    Strategic Diagnostics Inc.
    Mr. Joseph Dautlick
    111 Pencader Drive
    Newark, DEI 9702
    Telephone: (800)  544-8881, extension 222
    Fax: (302) 456-6770
    E-mail: jdautlick@sdix.com
    Internet: www.sdix.com
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                                               Chapter 3
                                 Demonstration Site Descriptions
This  chapter  describes  the  three sites  selected for
conducting the demonstration. The first site is referred to
as the Navy BVC site;  it is located in Port Hueneme,
California, and contains three sampling areas. The second
site is referred to as the Kelly AFB site; it is located in San
Antonio, Texas, and contains one sampling area. The third
site is referred to as the PC site; it is  located in north-
central Indiana and contains one sampling area.  After
review of the information available on these and other
candidate sites, the Navy BVC, Kelly AFB, and PC sites
were selected based on the following criteria:

    Site Diversity—Collectively, the three sites contained
    sampling areas with the different soil types and the
    different levels and types of PHC contamination
    needed to  evaluate  the seven field measurement
    devices selected for the demonstration.

•   Access and Cooperation—The site representatives
    were interested in supporting the  demonstration by
    providing site access for collection of soil samples
    required for the demonstration.  In addition, the field
    measurement devices were to be demonstrated at the
    Navy BVC site using soil samples from all three sites,
    and the Navy BVC site representatives were willing to
    provide the site support facilities required for the
    demonstration and to support a visitors' day during
    the  demonstration.   As a testing location for the
    Department  of Defense  National  Environmental
    Technology Test Site program, the Navy BVC site is
    used to demonstrate technologies and systems for
    characterizing  or  remediating soil,  sediment,  and
    groundwater contaminated with fuel hydrocarbons or
    waste oil.

To ensure  that the sampling areas were selected based
on current site   characteristics,  a  predemonstration
investigation was conducted.  During this investigation,
samples were collected from the five candidate areas and
were  analyzed for GRO  and EDRO using SW-846
Method 8015B (modified) by the reference laboratory,
Severn Trent Laboratories in Tampa, Florida (STL Tampa
East).  The site descriptions in Sections 3.1 through 3.3
are based on  data collected during predemonstration
investigation sampling activities, data collected during
demonstration   sampling  activities,  and  information
provided by the site representatives.  Physical character-
ization of samples was performed in the field by  a
geologist during both predemonstration investigation and
demonstration activities.

Some of the predemonstration investigation samples were
also analyzed by the EnSys Petro Test System developer,
SDI, at its facility.  SDI used reference laboratory  and
EnSys Petro Test System results to gain a preliminary
understanding of the demonstration samples and to prepare
for the demonstration.

Table 3-1 summarizes key site characteristics, including
the contamination type, sampling depth intervals, TPH
concentration ranges, and soil type in each sampling area.
The TPH concentration ranges and soil types presented in
Table  3-1  and  throughout  this report  are  based  on
reference  laboratory  TPH results  for  demonstration
samples and soil characterization completed  during the
demonstration, respectively. TPH concentration range and
soil type information obtained during the demonstration
was generally  consistent with the information obtained
during the predemonstration investigation except for the
B-38  Area at  Kelly AFB.  Additional information on
differences between demonstration and predemonstration
investigation   activities  and  results  is  presented in
Section 3.2.
                                                    19

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Table 3-1. Summary of Site Characteristics
Site
Navy Base
Ventura
County
Kelly Air
Force
Base
Petroleum
company
Sampling Area
Fuel Farm Area
Naval Exchange
Service Station
Area
Phytoremediation
Area
B-38 Area
Slop Fill Tank
Area
Contamination Type8
EDRO (weathered diesel
with carbon range from
n-C,0 through n-C40)
GRO and EDRO (fairly
weathered gasoline with
carbon range from n-C6
through n-C14)
EDRO (heavy lubricating
oil with carbon range from
n-C14 through n-C40>)
GRO and EDRO (fresh
gasoline and diesel or
weathered gasoline and
trace amounts of
lubricating oil with carbon
range from n-C6 through
n-C40)
GRO and EDRO
(combination of slightly
weathered gasoline,
kerosene, JP-5, and diesel
with carbon range from
n-Cs through n-C32)
Approximate
Sampling Depth
Interval
(foot bgs)
Upper layer*
Lower layer6
7 to 8
8 to 9
9 to 10
10 to 11
1.5 to 2.5
23 to 25
25 to 27
2 to 4
4 to 6
6 to 8
8 to 10
TPH Concentration
Range (mg/kg)
44.1 to 93.7
8,0901015,000
28.1 to 280
144 to 2,570
617 to 3,030
9.56 to 293
1,130 to 2,140
43.8 to 193
41 .5 to 69.4
6.16 to 3,300
37.1 to 3,960
43.9 to 1,210
52.4 to 554
Type of Soil
Medium-grained sand
Medium-grained sand
Silty sand
Sandy clay or silty sand and gravel in
upper depth interval and clayey sand
and gravel in deeper depth interval
Silty clay with traces of sand and gravel
in deeper depth intervals
Notes:

bgs   = Below ground surface
mg/kg = Milligram per kilogram

*   The beginning or end point of the carbon range identified as "n-Cx" represents an alkane marker consisting of "x" carbon atoms on a gas
    chromatogram.
*   Because of soil conditions encountered in the Fuel Farm Area, the sampling depth intervals could not be accurately determined. Sample collection
    was initiated approximately 10 feet bgs, and attempts were made to collect 4-foot-long soil cores. This approach resulted in varying degrees of
    core tube  penetration up to 17 feet bgs. At each location in the area, the sample cores were divided into two samples based on visual
    observations.  The upper layer of the soil core, which consisted of yellowish-brown, medium-grained sand, made up one sample, and the lower
    layer of the soil core, which consisted of grayish-black, medium-grained sand and smelled of hydrocarbons, made up the second sample.
3.1     Navy Base Ventura County Site

The Navy BVC site in Port Hueneme, California, covers
about 1,600 acres along the south California coast.  Three
areas at the Navy BVC site were selected as sampling areas
for the demonstration:  (1) the Fuel Farm Area (FFA),
(2) the Naval Exchange (NEX) Service Station Area, and
(3) the Phytoremediation Area (PRA).  These areas are
briefly described below.
3.1.1   Fuel Farm Area

The FFA is a tank  farm in the southwest comer of the
Navy BVC site.  The area contains five tanks and was
constructed to refuel ships and to supply heating fuel for
the Navy BVC site.  Tank No. 5114 along the south edge
of the FFA was used to store marine diesel.  After Tank
No. 5114  was deactivated in 1991,  corroded pipelines
leading into and out of the tank leaked and contaminated
the surrounding soil with diesel.
                                                        20

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The horizontal area of contamination in the FFA was
estimated to be about 20 feet wide and 90 feet long.
Demonstration samples  were collected within several
inches of  the three  predemonstration  investigation
sampling locations  in  the  FFA using a  Geoprobe®.
Samples were collected at the three locations from east to
west and about 5 feet apart. During the demonstration, soil
in the area was found to generally  consist of medium-
grained sand, and the soil cores contained two distinct
layers. The upper layer consisted of yellowish-brown,
medium-grained sand with no hydrocarbon odor and TPH
concentrations ranging from44.1 to 93.7 mg/kg; the upper
layer's  TPH  concentration  range  during  the
predemonstration investigation was 38 to 470 mg/kg. The
lower layer consisted of grayish-black, medium-grained
sand  with  a  strong  hydrocarbon  odor  and  TPH
concentrations ranging from 8,090 to 15,000 mg/kg; the
lower  layer's TPH  concentration range  during the
predemonstration   investigation   was   7,700  to
11,000 mg/kg.

Gas   chromatograms   from  the   predemonstration
investigation and the demonstration showed that FFA soil
samples contained (1) weathered diesel, (2) hydrocarbons
in the n-C10  through  n-C28  carbon  range with the
hydrocarbon  hump  maximizing  at  n-C17,  and
(3) hydrocarbons in the n-C 12 through n-C40 carbon range
with the hydrocarbon hump maximizing at n-C 20-

3.1.2  Naval Exchange Service Station Area

The NEX Service Station Area lies in the northeast portion
of the Navy BVC site.  About 11,000 gallons of regular
and unleaded gasoline was released from UST lines in this
area between September 1984 and March 1985. Although
the primary soil contaminant  in this area is gasoline,
EDRO is also of concern because (1) another spill north of
the area may have resulted  in a commingled plume of
gasoline  and diesel  and (2) a  significant  portion of
weathered gasoline is associated with EDRO.

The horizontal area of contamination in the NEX Service
Station Area was estimated to be about 450 feet wide and
750 feet long. During the demonstration, samples were
collected at  the  three  predemonstration  investigation
sampling locations in the NEX Service Station Area from
south to north and about 60 feet apart using a Geoprobe ®.
Soil in the area was  found  to generally  consist of
(1)  brownish-black,  medium-grained  sand  in the
uppermost depth interval and (2) grayish-black, medium-
grained sand in the three deeper depth intervals. Traces of
coarse sand were also present in the deepest depth interval.
Soil  samples collected  from the area had a  strong
hydrocarbon odor.  The water  table in the area  was
encountered at about 9 feet below ground surface (bgs).
During the demonstration, TPH concentrations ranged
from 28.1 to 280 mg/kg in the  7- to 8-foot bgs depth
interval;  144 to 3,030 mg/kg in the  8- to 9- and 9- to
10-foot bgs depth intervals; and 9.56 to 293 mg/kg in the
10- to 11-foot bgs depth interval. During the predemon-
stration  investigation, the TPH concentrations  in the
(1) top two depth intervals (7 to 8 and 8 to 9 feet  bgs)
ranged from 25 to 65 mg/kg and (2) bottom depth interval
(10 to 11 feet bgs) ranged from 24 to 300 mg/kg.

Gas   chromatograms  from  the   predemonstration
investigation and the demonstration  showed that NEX
Service  Station Area soil samples contained (1) fairly
weathered gasoline with a high aromatic hydrocarbon
content and (2) hydrocarbons in  the n-C6 through n-C14
carbon range. Benzene, toluene, ethylbenzene, and xylene
(BTEX)   analytical  results  for  predemonstration
investigation samples from the 9- to 10-foot bgs depth
interval  at the middle  sampling  location  revealed a
concentration of 347 mg/kg; BTEX made up 39 percent of
the total GRO and 27 percent of the TPH at this location.
During the predemonstration investigation, BTEX analyses
were conducted  at the request of a  few developers to
estimate the aromatic hydrocarbon content of the GRO;
such analyses were  not  conducted  for demonstration
samples.

3.1.3  Phytoremediation Area

The PRA lies north of the FFA and west of the NEX
Service  Station Area at the Navy BVC  site.  The PRA
consists of soil from a fuel tank removal project conducted
at the Naval Weapons Station in  Seal Beach, California.
The  area  is contained within concrete railings  and is
60 feet wide, 100 feet long, and about  3 feet deep. It
consists of 12 cells of equal size (20 by 25 feet) that have
three different types of cover: (1) un vegetated cover, (2) a
grass and legume mix, and (3) a native grass mix.  There
are four replicate cells of each cover type.

In the PRA, demonstration samples were collected from
the 1.5- to 2.5-foot bgs depth interval within several inches
of the  six  predemonstration  investigation  sampling
locations  using  a  split-core sampler.    During  the
demonstration, soil at four adjacent sampling locations
was found to generally consist of dark yellowish-brown,
silty sand with some clay and no hydrocarbon odor.  Soil
                                                   21

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at the two remaining adjacent sampling locations primarily
consisted of dark yellowish-brown, clayey sand with no
hydrocarbon odor, indicating the absence of volatile PHCs.
The TPH  concentrations  in the demonstration  samples
ranged from 1,130 to 2,140 mg/kg; the TPH concentrations
in the predemonstration investigation samples ranged from
1,500 to 2,700 mg/kg.

Gas   chromatograms  from  the  predemonstration
investigation and the demonstration showed that PRA soil
samples  contained  (1)  heavy  lubricating  oil  and
(2) hydrocarbons in the n-C H through n-C4(H carbon range
with the hydrocarbon hump maximizing at n-C 32.

SDI chose not to demonstrate the EnSys Petro Test System
using soil samples collected in the PRA because according
to SDI,  its device was not designed to measure heavy
lubricating oil, the primary contaminant in the area.

3.2    Kelly Air Force Base Site

The Kelly AFB site covers approximately 4,660 acres and
is about 7 miles from the center of San Antonio, Texas.
One area at Kelly AFB, the B-38 Area, was  selected as a
sampling area for the demonstration.  The B-38 Area lies
along the east boundary of Kelly AFB and is part of an
active UST farm that serves the government vehicle
refueling  station  at the base.   In December  1992,
subsurface soil contamination resulting from leaking diesel
and gasoline USTs and associated piping was discovered
in this area during UST removal and upgrading activities.

The B-38 Area was estimated to be about  150 square feet
in size.  Based on discussions with site representatives,
predemonstration investigation samples were collected in
the 13- to 17- and 29- to 30-foot bgs depth intervals at four
locations in the area using  a Geoprobe®.  Based  on
historical  information, the  water  table  in  the  area
fluctuates  between  16 and 24  feet bgs.   During the
predemonstration investigation, soil in the area was found
to generally consist of (1) clayey silt in the upper depth
interval  above the water table with a TPH concentration
of 9 mg/kg and (2) sandy clay with significant gravel in
the deeper depth interval below  the water table  with
TPH concentrations ranging  from 9  to 18  mg/kg.  Gas
chromatograms from the predemonstration  investigation
showed  that B-38 Area soil samples contained (1) heavy
lubricating oil and (2)  hydrocarbons in the n-C24 through
n-C30 carbon range.
Based on the low TPH concentrations and the type of
contamination  detected  during  the  predemonstration
investigation  as  well  as   discussions  with   site
representatives  who  indicated   that  most  of  the
contamination in the B-38 Area can be found at or near the
water table, demonstration samples were collected near the
water table. During the demonstration, the water table was
24 feet bgs.  Therefore, the demonstration samples were
collected in the 23- to 25- and 25- to 27-foot bgs depth
intervals at three locations in the B-38 Area using a
Geoprobe®.  Air Force activities in the area during the
demonstration prevented the sampling team from accessing
the fourth location sampled during the predemonstration
investigation.

During the demonstration, soil in the  area  was found to
generally consist of (1) sandy clay or silty sand and gravel
in the upper depth interval with a TPH concentration
between 43.8 and 193 mg/kg and (2) clayey sand  and
gravel   in  the  deeper  depth   interval  with  TPH
concentrations between 41.5 and 69.4 mg/kg. Soil samples
collected in the area had little or no hydrocarbon odor.
Gas chromatograms from the demonstration showed that
B-38 Area soil samples contained either (1) fresh gasoline,
diesel, and hydrocarbons in the n-C 6 through n-C25 carbon
range with the hydrocarbon hump maximizing at n-C 17;
(2) weathered gasoline with trace amounts of lubricating
oil and  hydrocarbons in  the n-C6  through n-C30 carbon
range  with  a  hydrocarbon  hump  representing  the
lubricating oil between n-C20 and n-C30; or (3) weathered
gasoline  with   trace  amounts  of lubricating   oil
and hydrocarbons in the n-C6 through n-C40 carbon range
with a hydrocarbon hump representing the lubricating oil
maximizing at n-C31.

3.3     Petroleum Company Site

One area at the PC site in north-central Indiana, the Slop
Fill Tank (SFT) Area, was selected as a sampling area for
the demonstration. The SFT Area lies  in the west-central
portion  of the PC site and is  part of an active fuel tank
farm. Although the primary soil contaminant in this area
is gasoline, EDRO is also of concern because of a heating
oil release that occurred north of the area.

The SFT Area was estimated to be 20 feet long and 20 feet
wide. In this area, demonstration samples were collected
from 2  to 10 feet bgs at 2-foot depth intervals within
several inches of the five predemonstration investigation
sampling locations using  a  Geoprobe®.  Four of the
                                                    22

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sampling locations were spaced about 15 feet apart to form
the comers of a square, and the fifth sampling location was
at the center of the square. During the demonstration, soil
in the area was found to generally consist of brown to
brownish-gray, silty clay with traces of sand and gravel in
the deeper depth intervals.  Demonstration soil samples
collected in the area had little or no hydrocarbon odor.
During the demonstration, soil in the three upper depth
intervals had TPH concentrations ranging from 6.16 to
3,960 mg/kg, and soil in the  deepest depth interval had
TPH concentrations ranging  from 52.4  to 554 mg/kg.
During the predemonstration investigation, soils  in the
three upper depth intervals and the deepest depth interval
had TPH concentrations ranging from 27 to 1,300 mg/kg
and from 49 to 260 mg/kg, respectively.
Gas   chromatograms  from   the   predemonstration
investigation and the demonstration showed that SFT Area
soil samples contained (1) slightly weathered gasoline,
kerosene, JP-5, and diesel and  (2) hydrocarbons in the
n-C5 through n-C20 carbon range. There was also evidence
of  an  unidentified  petroleum  product  containing
hydrocarbons in the n-C24 through n-C32 carbon range.
BTEX  analytical  results   for   predemonstration
investigation  samples from the deepest  depth  interval
revealed concentrations of 26, 197, and 67 mg/kg at the
northwest, center,  and  southwest sampling  locations,
respectively.  At the northwest location, BTEX made up
13 percent of the total GRO and 5 percent of the TPH.  At
the center location, BTEX made  up 16 percent of the total
GRO and 7 percent of the TPH. At the southwest location,
BTEX made up 23 percent  of the total  GRO  and
18 percent of the TPH.   BTEX analyses  were not
conducted for demonstration samples.
                                                   23

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                                               Chapter 4
                                     Demonstration Approach
This chapter presents the objectives (Section 4.1), design
(Section 4.2), and sample  preparation and management
procedures (Section 4.3) for the demonstration.

4.1    Demonstration Objectives

The primary goal of the SITE MMT Program is to develop
reliable performance and cost data on innovative, field-
ready technologies.  A SITE demonstration must provide
detailed and reliable performance and cost data so that
potential technology users  have adequate information to
make  sound   judgments  regarding  an  innovative
technology's applicability to a specific site and to compare
the technology to conventional technologies.

The  demonstration  had both primary and secondary
objectives.  Primary objectives  were critical  to  the
technology evaluation and required the use of quantitative
results to  draw conclusions  regarding a  technology's
performance.    Secondary   objectives   pertained   to
information that was useful  but did not necessarily require
the  use of quantitative results  to draw conclusions
regarding a technology's performance.

The  primary objectives for the  demonstration  of  the
individual field measurement devices were as follows:

PI. Determine the MDL

P2. Evaluate  the  accuracy  and  precision  of TPH
    measurement for a variety  of contaminated soil
    samples

P3. Evaluate  the   effect   of  interferents  on  TPH
    measurement

P4. Evaluate the effect of soil moisture content on TPH
    measurement
P5. Measure the time required for TPH measurement

P6. Estimate costs associated with TPH measurement

The secondary objectives for the demonstration of the
individual field measurement devices were as follows:

S1. Document the skills and training required to properly
    operate the device

S2. Document health and safety concerns associated with
    operating the device

S3. Document the portability of the device

S4. Evaluate  the durability of the device based on  its
    materials of construction and engineering design

S5. Document the availability of the device and associated
    spare parts

The objectives for the demonstration were developed based
on input from MMT Program stakeholders, general user
expectations of field measurement devices, characteristics
of the demonstration areas, the time available to complete
the demonstration, and  device capabilities  that the
developers intended to highlight.

4.2    Demonstration Design

A  predemonstration sampling and analysis investigation
was conducted to assess existing conditions and confirm
available   information  on  physical   and   chemical
characteristics of soil in each demonstration area. Based
on information from the predemonstration investigation as
well as available historical data, a demonstration design
was developed to address the demonstration objectives.
Input  regarding the demonstration design was obtained
                                                    24

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from   the  developers  and  demonstration  site
representatives. The demonstration design is summarized
below.

The demonstration involved analysis of soil environmental
samples, soil performance evaluation (PE) samples, and
liquid PE samples.   The environmental samples were
collected  from three  contaminated sites, and  the  PE
samples were  obtained from  a  commercial provider,
Environmental Resource Associates (ERA)  in Arvada,
Colorado. Collectively, the environmental and PE samples
provided the different matrix types and the different levels
and types of PHC contamination needed to perform a
comprehensive demonstration.

The  environmental  samples  were soil core samples
collected from  the demonstration areas at the Navy BVC,
Kelly AFB, and PC sites described in Chapter 3. The soil
core samples collected at the Kelly AFB and PC sites were
shipped to the Navy BVC site 5 days prior to the start of
the field  analysis activities.   Each soil core sample
collected from a specific depth interval at a particular
sampling location in a given area was homogenized and
placed in individual sample containers. Soil samples were
then provided to the developers and reference laboratory.
In addition, the PE samples were obtained from ERA for
distribution to  the developers and reference  laboratory.
Field analysis of all environmental and PE samples was
conducted near the PRA at the Navy BVC site.

The  field measurement devices  were  evaluated based
primarily  on how they compared with the reference
method selected for the demonstration. PE samples were
used to verify that reference method performance was
acceptable. However, for the comparison with the device
results, the reference method results were not adjusted
based on the recoveries observed during analysis of the PE
samples.

The sample collection and homogenization  procedures
may have resulted in GRO losses of up to one order of
magnitude in environmental samples.  Despite any such
losses, the homogenized samples were expected to contain
sufficient levels of GRO to allow demonstration objectives
to be achieved.  Moreover,  the  environmental sample
collection and  homogenization procedures implemented
during the demonstration ensured  that the developers and
reference laboratory received the same sample material
for analysis, which was required to allow meaningful
comparisons of field measurement device and reference
method results.

To facilitate effective use of available information on both
the  environmental  and  PE  samples  during  the
demonstration, the developers and reference laboratory
were  informed  of (1)  whether each  sample was  an
environmental or  PE sample, (2) the area where each
environmental sample  was  collected,  and  (3) the
contamination type and concentration range of each
sample. This information was included in each sample
identification number.  Each sample was identified as
having a low (< 100 mg/kg), medium (100 to 1,000 mg/kg),
or high (> 1,000 mg/kg) TPH concentration range.  The
concentration  ranges   were   based  primarily  on
predemonstration investigation results or the amount of
weathered gasoline or diesel added  during PE sample
preparation.  The concentration ranges were meant to be
used only as a guide by the developers and reference
laboratory. The gasoline used for PE sample preparation
was 50 percent weathered; the weathering was achieved by
bubbling nitrogen gas into a known volume of gasoline
until the volume was reduced by 50 percent.  Some PE
samples also contained interferents specifically added to
evaluate the  effect of interferents on TPH measurement.
The   type   of contamination   and  expected  TPH
concentration ranges were identified; however, the specific
compounds used as interferents were not identified. All
PE samples were prepared in  triplicate as separate, blind
samples.

During the demonstration, SDI field technicians operated
the EnSys Petro Test System, and EPA representatives
made  observations to  evaluate the device.    All the
developers were given the opportunity to choose not to
analyze samples  collected  in a particular  area or a
particular class of samples, depending on the intended uses
of their devices.  SDI chose not to analyze soil samples
collected in the PRA because according to SDI, the EnSys
Petro Test System was not designed to measure the heavy
lubricating oil present in the PRA.

Details of the approach used to address the primary and
secondary objectives for the demonstration are presented
in Sections 4.2.1 and 4.2.2, respectively.

4.2.1  Approach for Addressing Primary Objectives

This section presents the approach used to address each
primary objective.
                                                   25

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Primary Objective PI: Method Detection Limit

To determine the MDL for each field measurement device,
low-concentration-range soil  PE  samples  containing
weathered gasoline or diesel were to be analyzed.  The
low-range PE samples  were prepared using methanol,
which facilitated preparation of homogenous samples. The
target concentrations of the PE samples were set to meet
the following criteria:  (1) at  the minimum  acceptable
recoveries set by ERA, the samples contained measurable
TPH .concentrations, and (2) when feasible, the sample
TPH  concentrations  were  generally  between  1  and
10 times the MDLs claimed by the developers and the
reference  laboratory,  as recommended  by 40  Code  of
Federal  Regulations  (CFR)  Part 136,  Appendix B,
Revision 1.1.1. SDI and the reference laboratory analyzed
seven weathered gasoline and seven diesel PE samples to
statistically determine the MDLs for GRO and EDRO soil
samples. However, during the preparation of low-range
weathered gasoline PE samples, significant volatilization
of PHCs occurred because of th e matrix used for preparing
these samples. Because of the problems associated with
preparation of low-range weathered gasoline PE samples,
the results  for  these samples  could  not be  used  to
determine the MDLs.  Moreover, because the EnSys Petro
Test System is a semiquantitative device that  does not
report absolute TPH  concentrations, the device's MDL
was  not to be determined using a statistical approach;
rather, the device MDL claimed by SDI was to be verified
using a nonstatistical approach. Specifically, the device's
MDL was to be verified by evaluating whether the TPH
concentration ranges reported by the device overlapped the
TPH results obtained using the reference method.

Primary Objective P2: Accuracy and Precision

To  estimate the accuracy and precision of each field
measurement device, both environmental and PE samples
were analyzed. The evaluation of analytical accuracy was
based on the assumption that a field measurement device
may  be  used  to  (1) determine  whether  the  TPH
concentration in a given area exceeds an action level  or
(2)  perform a preliminary characterization of soil in a
given area. To evaluate whether the TPH concentration in
a soil sample exceeded an action level, the developers and
reference  laboratory were asked to determine whether
TPH concentrations in a given area or  PE sample type
exceeded the action levels listed in Table 4-1.  The action
levels chosen for environmental samples were based on
the predemonstration investigation analytical results and
state action levels.  The action levels chosen for the PE
samples were based in part on the ERA acceptance limits
for PE samples; therefore, each PE sample was expected
to  have  at least the  TPH concentration  indicated  in
Table 4-1.  However, because of the problems associated
with preparation of the low-concentration-range weathered
Table 4-1. Action Levels Used to Evaluate Analytical Accuracy
Site
Navy Base Ventura
County
Kelly Air Force Base
Petroleum company

Fuel Farm Area
Naval Exchange Service Station Area
Phytoremediation Areab
B-38 Area
Slop Fill Tank Area
Performance evaluation samples (GRO analysis)
Performance evaluation samples (EDRO analysis)
Typical TPH Concentration Range"
Low and high
Low to high
High
Low
Medium
Medium
High
Low
Medium
High
Action Level (mg/kg)
100
50
1,500
100
500
200
2,000
15
200
2,000
Notes:

mg/kg =  Milligram per kilogram

*   The typical TPH concentration ranges shown cover all the depth intervals in each area. Table 4-2 shows the depth intervals that were sampled
    in each area and the typical TPH concentration range for each depth interval. The action level for each area was used as the basis for evaluating
    sample analytical results regardless of the typical TPH concentration ranges for the various depth intervals.
"   SDI chose not to analyze soil samples collected in the Phytoremediation Area because according to SDI, the EnSys Petro Test System was not
    designed to measure the heavy lubricating oil present in the Phytoremediation Area.
                                                      26

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gasoline PE samples, the results for these samples could
not be used to address primary objective P2.

In addition,  neat (liquid) samples  of weathered gasoline
and diesel were analyzed by the developers and reference
laboratory to evaluate accuracy and precision. Because
extraction of the neat  samples was not  necessary, the
results for these samples provided accuracy and precision
information strictly associated with the analyses and were
not affected by extraction procedures.

Sample   TPH   results  obtained  using  each   field
measurement device and the  reference method were
compared to the action levels presented in Table 4-1 in
order to determine whether sample  TPH  concentrations
were above the action levels.  The results obtained using
the device  and reference  method  were  compared to
determine how many times the device's results agreed with
those of the reference  method for  a  particular area or
sample  type.    In addition,  for  each  quantitative
measurement device, the ratio of the TPH results of the
device to  the TPH results of the  reference method was
calculated.  The ratio was used to develop a frequency
distribution in order to determine how many of the device
and reference method  results were within 30 percent,
within 50 percent, and outside the  50 percent window.

To complete a  preliminary characterization of soil in a
given area using a field measurement device, the user may
have to  demonstrate to a regulatory agency that (1) no
statistically significant difference exists between the results
of the laboratory method selected  for the project (the
reference method) and  the device  results, indicating that
the device may be used as a substitute for the laboratory
method, or (2) a consistent correlation exists between the
device and laboratory method results, indicating that the
device results  can be  adjusted  using  the  established
correlation.   However, the statistical comparison  and
correlation activities conducted for the demonstration were
limited   to   the  evaluations  of   quantitative   field
measurement devices.

To evaluate analytical precision,  one set of blind field
triplicate environmental samples was collected from each
depth interval at one location in each demonstration area
except the B-38 Area, where  site  conditions allowed
collection of triplicates in the  top  depth interval only.
Blind triplicate low-, medium-, and high-concentration-
range PE samples were also used to evaluate analytical
precision because TPH concentrations in environmental
samples collected during the demonstration sometimes
differed from the analytical results for predemonstration
investigation samples.  The low- and medium-range PE
samples were prepared using methanol as a carrier, which
facilitated preparation of homogenous samples.

Additional information regarding analytical precision was
collected  by  having  the developers  and reference
laboratory analyze extract duplicates. Extract duplicates
were  prepared  by extracting a soil sample once and
collecting two aliquots of the extract. For environmental
samples, one sample  from each depth  interval was
designated as an extract duplicate. Each sample designated
as an extract duplicate was co llected from a location where
field  triplicates were collected.  To  evaluate  a given
quantitative field measurement device's ability to precisely
measure TPH, the relative standard deviation (RSD) of the
device and reference method TPH results for triplicate
samples was calculated.   In addition, to evaluate the
analytical precision of the device  and reference  method,
the relative percent difference (RPD) was calculated using
the TPH results for extract duplicates. For the EnSys Petro
Test  System,  a  semiquantitative device,  analytical
precision  was  assessed  in   a  qualitative   manner.
Specifically, to evaluate the overall precision, the  device's
TPH concentration ranges for the triplicate samples were
compared to  determine whether they were the  same or
different.  Similarly,  to evaluate the analytical precision,
the TPH concentration ranges for the extract duplicates
were compared to determine whether they were the same
or different.

Primary Objective P3: Effect of Interferents

To evaluate  the  effect of interferents on  each  field
measurement device's ability to accurately measure TPH,
high-concentration-range soil  PE  samples  containing
weathered gasoline or diesel with or without an interferent
were analyzed.  As explained in Chapter 1, the definition
of TPH is quite variable.  For the purposes of addressing
primary objective P3, the term "interferent" is used in a
broad sense and is applied to  both PHC and non-PHC
compounds. The six different interferents evaluated during
the demonstration were MTBE; tetrachloroethene (PCE);
Stoddard solvent; turpentine (an alpha and beta pinene
mixture); 1,2,4-trichlorobenzene;  and humic acid. The
boiling points and vapor pressures of (1) MTBE and PCE
are similar to those  of GRO; (2) Stoddard solvent and
turpentine are similar to those of GRO and EDRO; and
(3) 1,2,4-trichlorobenzene and humic acid are similar to
those of EDRO. The solubility, availability, and cost of
the interferents were also considered during interferent
                                                     27

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selection.  Specific reasons for the selection of the six
interferents are presented below.

•   MTBE is  an oxygenated gasoline additive that is
    detected   in  the  GRO  analysis   during   TPH
    measurement using a GC.

•   PCE is not a petroleum product but is detected in the
    GRO analysis during TPH measurement using a GC.
    PCE may  also be viewed as a typical halogenated
    solvent that may be present in some environmental
    samples.

•   Stoddard solvent is an aliphatic  naphtha compound
    with a carbon range of n-C 8 through n-C H and is partly
    detected in both the GRO and EDRO analyses during
    TPH measurement using a GC.

•   Turpentine is not a petroleum product but has a carbon
    range of n-C9 through n-C15 and is partly detected in
    both the GRO  and EDRO  analyses during TPH
    measurement using a GC.  Turpentine may also be
    viewed as a substance that behaves  similarly to  a
    typical naturally occurring oil or grease during TPH
    measurement using a GC.

•   The  compound  1,2,4-trichlorobenzene  is  not  a
    petroleum  product but is detected  in  the EDRO
    analysis.  This compound may also be viewed as a
    typical halogenated semivolatile organic compound
    that behaves  similarly to a chlorinated pesticide or
    PCB during TPH measurement using a GC.

•   Humic  acid  is  a  hydrocarbon  mixture that is
    representative of naturally occurring organic carbon in
    soil and was suspected to be detected during EDRO
    analysis.

Based on the  principles  of operation  of  the  field
measurement devices, several of the interferents were
suspected to be detected by the devices.

The PE samples  containing MTBE  and PCE were not
prepared  with diesel and  the PE samples  containing
1,2,4-trichlorobenzene and humic acid were not prepared
with weathered gasoline because these interferents were
not expected to impact the analyses and because practical
difficulties such as solubility constraints were associated
with preparation of such samples.
Appropriate control  samples were  also prepared  and
analyzed to address primary objective P3. These samples
included processed garden soil, processed garden soil and
weathered gasoline, processed garden soil and diesel, and
processed garden soil and humic acid samples.  Because
of solubility constraints,  control  samples containing
MTBE;  PCE;  Stoddard  solvent;   turpentine;   or
1,2,4-trichlorobenzene could not be prepared.  Instead,
neat (liquid) samples of these interferents were prepared
and used as quasi-control samples to evaluate the effect of
each interferent on the  field measurement device  and
reference method results.  Each PE sample was prepared in
triplicate and submitted to the developers and reference
laboratory as blind triplicate samples.

To evaluate the effects of interferents on a given field
measurement device's ability to accurately measure TPH
under primary objective P3, the  means and  standard
deviations of the TPH results for triplicate PE samples
were calculated. The mean for each group of samples was
qualitatively  evaluated to determine whether  the data
showed any trend—that is, whether an increase  in the
interferent concentration resulted in an increase or decrease
in the measured TPH concentration. A one-way analysis
of variance was performed to determine whether the group
means were the same or different.  For the EnSys Petro
Test System, a semiquantitative  device, the effects of
interferents  on TPH measurement were assessed in  a
qualitative manner.   Specifically,  the  device's TPH
concentration ranges for the control samples and the
samples   containing  interferents  were  qualitatively
evaluated to determine whether the data showed any trend.

Primary Objective P4: Effect of Soil Moisture Content

To evaluate the  effect of soil moisture content, high-
concentration-range soil PE samples containing weathered
gasoline or diesel were analyzed. PE samples containing
weathered gasoline were prepared at two moisture levels:
9 percent moisture and 16 percent moisture. PE samples
containing diesel were  also prepared at two  moisture
levels: negligible moisture (<1 percent) and  9 percent
moisture.  All the moisture levels were selected based on
the constraints associated with sample preparation.  For
example,  9 percent  moisture represents the  minimum
moisture level for containerizing samples in EnCores and
16 percent moisture represents the saturation level of the
soil used to prepare PE samples.  Diesel samples with
negligible moisture could be prepared because they did not
                                                    28

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require  EnCores  for containerization; based  on vapor
pressure data for diesel and weathered gasoline, 4-ounce
jars were considered to be appropriate for containerizing
diesel  samples but not for containerizing weathered
gasoline samples.  Each PE sample was  prepared in
triplicate.

To measure the effect of soil moisture content on a given
field measurement device's ability to accurately measure
TPH under primary  objective P4, the means and standard
deviations  of the TPH results for triplicate PE samples
containing  weathered gasoline and diesel at two moisture
levels were calculated. A tw o-tailed, two-sample Student's
t-test was performed to determine whether the device and
reference method results were impacted by moisture—that
is, to determine whether an increase in moisture resulted in
an  increase  or decrease in the  TPH concentrations
measured.    For the  EnSys   Petro  Test System,  a
semiquantitative  device,  the  effect of moisture  was
assessed by  qualitatively evaluating the device's TPH
concentration ranges at two different moisture levels.

Primary Objective P5: Time Required  for TPH
Measurement

The sample throughput (the number of TPH measurements
per  unit  of  time) was determined  for each  field
measurement device by measuring  the time required for
each activity associated with TPH measurement, including
device setup, sample extraction, sample analysis, and data
package preparation. The EPA provided each developer
with  investigative  samples stored  in  coolers.   The
developer unpacked the coolers and checked the chain-of-
custody forms to verify that it had received the correct
samples. Time measurement began when the developer
began to set up its device.  The total time required to
complete  analysis  of  all  investigative samples  was
recorded.   Analysis was  considered to be complete and
time measurement stopped when the developer provided
the EPA with a summary table of results, a run log, and
any supplementary information that the developer chose.
The summary table listed all samples analyzed and their
respective TPH concentrations.

For the reference laboratory, th e total analytical time began
to be measured  when the  laboratory received all  the
investigative samples, and time measurement continued
until the EPA representatives received a complete  data
package from the laboratory.
Primary Objective P6: Costs Associated with TPH
Measurement

To estimate the costs associated with TPH measurement
for each field measurement device, the following five cost
categories were identified: capital equipment, supplies,
support equipment, labor, and investigation-derived waste
(EDW) disposal.  Chapter 8 of this ITVR discusses the
costs estimated for the EnSys Petro Test System based on
these cost categories.

Table 4-2 summarizes the demonstration approach used to
address the primary objectives and includes demonstration
area characteristics, approximate sampling depth intervals,
and the  rationale for the analyses performed  by the
reference laboratory.

4.2.2  Approach for Addressing Secondary
        Objectives

Secondary  objectives were  addressed  based on field
observations made during the demonstration. Specifically,
EPA representatives observed TPH measurement activities
and documented them in a field logbook. Each developer
was given the opportunity to review the field logbook at
the end of each day of the demonstration. The approach
used to address each secondary objective for each field
measurement device is discussed below.

•   The skills and training required  for proper device
    operation (secondary objective SI) were evaluated by
    observing and noting the skills required to operate the
    device and prepare the data package and by discussing
    necessary user training with developer personnel.

•   Health  and safety concerns associated with device
    operation (secondary objective S2) were evaluated by
    observing  and  noting possible health  and  safety
    concerns during the demonstration, such as the types
    of  hazardous  substances handled by developer
    personnel during analysis, the number of times that
    hazardous  substances were  transferred from  one
    container to another during the analytical procedure,
    and  direct exposure  of  developer personnel to
    hazardous substances.

•   The portability of the device (secondary objective S3)
    was evaluated by observing and noting the weight and
    size of the device and additional equipment required
                                                    29

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        Table 4-2. Demonstration Approach
Site
Navy
BVC
Kelly
AFB
PC
Area
FFA
NEX
Service
Station
Area
PRA"
B-38
Area
SFT
Area
Approximate
Sampling Depth
Interval (foot bgs)
Upper \ayef
Lower layer5
7 to 8
8 to 9
9 to 10
10to 11
1.5 to 2.5
23 to 25
25 to 27
2 to 4
4 to 6
6 to 8
8 to 10
Sample Matrix
Ottawa sand
(PE sample)
Processed garden soil (PE sample)
Objective
Addressed1
P2
Objective
Addressed1
P1.P2
P2
Soil Characteristics
Medium-grained sand
Medium-grained sand
Silty sand
Sandy clay or silty sand and
gravel in upper depth interval and
clayey sand and gravel in deeper
depth interval
Silty clay with traces of sand in
deeper depth intervals
Soil Characteristics
Fine-grained sand
Sty sand
Contamination Type
Weathereddiesel with carbon range from
n-C10 through n-C40
Fairly weathered gasoline with carbon range
from n-Ce through n-C,4
Heavy lubricating oil with carbon range from
n-C14 through n-C40
Fresh gasoline and diesel or weathered
gasoline and trace amounts of lubricating oil
with carbon range from n-Q through n-C40
Combination of slightly weathered gasoline,
kerosene, JP-5, and diesel with carbon range
from n-C5 through n-Cj2
Contamination Type
Weathered gasoline
Diesel
Weathered gasoline
Diesel
Typical TPH
Concentration
Range6
Low
High
Low to
medium
Medium to
high
High
Low
High
Low
Medium
Typical TPH
Concentration
range"
Low
Medium and
high
Rationale for Analyses
by Reference Laboratory
Only EDRO because samples did not
contain PHCs in gasoline range
GRO and EDRO because samples
contained PHCs in both gasoline and
diesel ranges
Only EDRO because samples did not
contain PHCs in gasoline range
GRO and EDRO because samples
contained PHCs in both gasoline and
diesel ranges
Rationale for Analyses
by Reference Laboratory
GRO and EDRO because weathered
gasoline contains significant amounts of
PHCs in both gasoline and diesel
ranges
Only EDRO because diesel does not
contain PHCs in gasoline range
GRO and EDRO because weathered
gasoline contains significant amounts of
PHCs in both gasoline and diesel
ranges
Only EDRO because diesel does not
contain PHCs in gasoline range
U)
o

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Table 4-2.  Demonstration Approach (Continued)
Sample Matrix
Not applicable (neat liquid PE
sample)
Processed garden soil (PE sample)
Objective
Addressed9
P2
(Continued)
P3
Soil Characteristics
Not applicable
Silty sand
Contamination Type
Weathered gasoline
Diesel
Blank soi(control sample)
Weathered gasoline
Weathered gasoline and MTBE (1,100 mg/kg)
PCE (2,810 mg/kg), Stoddard solvent
(2,900 mg/kg), or turpentine (2,730 mg/kg)
Weathered gasoline and MTBE (1 ,700 mg/kg)
PCE (13,100 mg/kg), Stoddard solvent
(15,400 mg/kg), or turpentine (12,900 mg/kg)
Diesel
Diesel and Stoddard solvent (3,650 mg/kg) or
turpentine (3,850 mg/kg)
Diesel and Stoddard solvent (18,200 mg/kg)
or turpentine (1 9,600 mg/kg)
Diesel and 1 ,2,4-trichlorobenzene
(3,350 mg/kg) or humic acid (3,940 mg/kg)
Diesel and 1 ,2,4-trichlorobenzene
(16,600 mg/kg) or humic acid (19,500 mg/kg)
Humic acid (3,940 mg/kg)
Humic acid (19,500 mg/kg)
Typical TPH
Concentration
range6
High
High
Trace
High
Trace
Rationale for Analyses
by Reference Laboratory
GRO and EDRO because weathered
gasoline contains significant amounts of
PHCs in both gasoline and diesel
ranges
Only EDRO because diesel does not
contain PHCs in gasoline range
GRO and EDRO because processed
garden soil may contain trace
concentrations of PHCs in both gasoline
and diesel ranges
GRO and EDRO because weathered
gasoline contains significant amounts of
PHCs in both gasoline and diesel
ranges
Only EDRO because diesel does not
contain PHCs in gasoline range
GRO and EDRO because (1) Stoddard
solvent contains PHCs in both gasoline
and diesel ranges and (2) turpentine
interferes with both analyses
Only EDRO because 1,2,4-trichloro-
benzene and humic acid do not interfere
with GRO analysis
Oily EDRO because humic acid does
not interfere with GRO analysis
The contribution oftrace concentrations
(less than 15 mg/kg) GRO found in
processed garden soil during the
predemonstration investigation was
considered to be insignificant evaluation
of the effect of humic acid interference,
which occurs in the diesel range.

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        Table 4-2. Demonstration Approach (Continued)
Sample Matrix
Not applicable (neat liquid PE
sample)
Processed garden soil (PE sample)
Objective
Addressed1
P3
(Continued)
P4
Soil Characteristics
Not applicable
Silty and
Contamination Type
Weathered gasoline
Diesel
MTBE
PCE
Stoddard solvent
Turpentine
1 ,2,4-Trichlorobenzene
Weathered gasoline (samples prepared at
9 and 16 percent moisture levels)
Diesel (samples prepaid at negligible [less
than 1 percent] and 9 percent moisture levels)
Typical TPH
Concentration
rangeb
High
Not
applicable
High
Not
applicable
High
Rationale for Analyses
by Reference Laboratory
GRO and EDRO because weathered
gasoline contains significant amounts of
PHCs in both gasoline and diesel
ranges
Only EDRO because diesel does not
contain PHCs in gasoline range
Only GRO because MTBE and PCE do
not interfere with EDRO analysis
GRO and EDRO because Stoddard
solvent contains PHCs in both gasoline
and diesel ranges
GRO and EDRO because turpentine
interferes with both analyses
Only EDRO because 1 ,2,4-trichloro-
benzene does not interfere with GRO
analysis
GRO and EDRO because weathered
gasoline contains significant amounts of
PHCs in both gasoline and diesel
ranges
Only EDRO because diesel does not
contain PHCs in gasoline range
U)
to
        Notes:

        AFB
        bgs
        BVC
Air Force Base
Below ground surface
Base Ventura County
FFA    =  Fuel Farm Area
mg/kg  =  Milligram per kilogram
MTBE  =  Methyl-tert-butyl ether
NEX  =  Naval Exchange
PC   =  Petroleum company
PCE  =  Tetrachloroethene
PE    =   Performance evaluation
PHC  =   Petroleum hydrocarbon
PRA  =   Phytoremediation Area
SFT  =  Slop Fill Tank
                 Field observations of all sample analysesconducted during the demonstration were u&d to address primary objectives P5 and PGand the secondary objectives.
                 The typical TPH concentration range was basedbn reference laboratory results for the demonstration. The typical low, mediumand high ranges indicate TPH concentrations of less than
                 100 mg/kg; 100 to 1,000 mg/kg; and greater than 1,000 mg/kg, respectively.
                 Because of soil conditions encountered infte FFA during the demonstration, the samplhg depth intervals could not be accurate^ determined. Sample collector was initiated approximately
                 10 feet bgs, and attempts were made to collect 4-foot-long soil COBS. For each sampling location in the area, the sample core were divided into two samples based on visual observations.
                 The upper layer of the soil core made up one sample, and the lower layer of the soil core made up the second sample.
                 SDI chose not to analyze soil samples collected in the PRA becausaccording to SDI, the EnSys Petro Test System was not desiged to measure the heavy lubricating oil present in the
                 PRA.
                 Because of problems that arose during prepaation of PE samples with low concentrations of weathered gasoline, the results  fothese samples were not used to evaluate the field
                 measurement devices.

-------
    for TPH measurement as well as how easily the device
    was set up for use during the demonstration.

•   The durability of the device (secondary objective S4)
    was evaluated by noting the materials of construction
    of the device and additional equipment required for
    TPH measurement.  In addition, EPA representatives
    noted  likely device failures or repairs that may be
    necessary  during  extended   use  of the  device.
    Downtime required to make device repairs during the
    demonstration was also noted.

•   The availability of  the device and associated spare
    parts (secondary objective S5)  was evaluated  by
    discussing the availability of replacement devices with
    developer personnel and determining whether spare
    parts were available in retail stores or only from the
    developer. In addition, the availability of spare parts
    required during the demonstration was noted.

Field  observations  of the  analyses of all the samples
described in Table 4-2 were used to address the secondary
objectives for the demonstration.

4.3    Sample Preparation and Management

This section presents sample preparation and management
procedures used during  the demonstration. Specifically,
this  section  describes  how  samples were collected,
containerized, labeled,  stored, and shipped  during  the
demonstration.   Additional  details  about  the  sample
preparation and management procedures are presented in
the demonstration plan (EPA 2000).

4.3.1      Sample Preparation

The sample preparation procedures for both environmental
and PE samples are described below.

Environmental Samples

For  the  demonstration, environmental  samples  were
collected  in  the   areas  that  were  used  for  the
predemonstration investigation. For the EnSys Petro Test
System, the sampling  areas were (1) FFA and  NEX
Service Station Area at the Navy BVC site, (2) B-38 Area
at the Kelly AFB site, and (3) SFT Area at the PC site.
Samples were collected  in all areas using a Geoprobe ®.
The  liners  containing  environmental  samples  were
transported to the sample management trailer at the Navy
BVC site, where the liners were cut open longitudinally.
A geologist then profiled the samples based  on soil
characteristics to determine where the soil cores had to be
sectioned. The soil characterization performed for each
demonstration area is summarized in Chapter 3.

Each  core  sample section  was then transferred to a
stainless-steel bowl. The presence of any unrepresentative
material such as sticks, roots, and stones was noted in a
field logbook, and such material was removed to the extent
possible using gloved hands.  Any lump of clay in the
sample that was greater than about 1/8 inch in diameter
was   crushed   between  gloved  fingers  before
homogenization. Each soil sample was homogenized by
stirring it for at least 2  minutes using a stainless-steel
spoon or gloved hands until the sample  was visibly
homogeneous.    During  or  immediately  following
homogenization, any free water was poured from the
stainless-steel bowl containing the soil sample into a
container designated for IDW. During the demonstration,
the field sampling team used only nitrile gloves to avoid
the possibility of phthalate contamination from handling
samples with plastic gloves.  Such  contamination had
occurred during the predemonstration investigation.

After sample homogenization, the samples were placed in
(1) EnCores of approximately 5-gram capacity for GRO
analysis; (2) 4-ounce, glass jars provided by the reference
laboratory for EDRO and percent moisture analyses; and
(3) EnCores of approximately 25-gram capacity for TPH
analysis.  Using  a quartering  technique, each sample
container was filled by alternately spooning soil from one
quadrant of the mixing bowl and then from the opposite
quadrant until the container was full.  The 4-ounce, glass
jars were filled after all the EnCores for a given sample
had been filled.  After a sample container was filled, it was
immediately  closed  to minimize  volatilization of
contaminants.  To minimize the time required for sample
homogenization and filling  of sample containers, these
activities  were  simultaneously  conducted  by  four
personnel.

Because of the large number of containers  being filled,
some time elapsed between the filling of the first EnCore
and the filling of the last.  An attempt was made to
eliminate any bias by alternating between filling EnCores
                                                   33

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for the developers and filling EnCores for the reference
laboratory.  Table 4-3 summarizes the demonstration
sampling depth intervals, numbers of environmental and
QA/QC samples collected, and numbers of environmental
sample analyses associated with the demonstration of the
EnSys Petro Test System.

Performance Evaluation Samples

All PE samples for the demonstration were prepared by
ERA and shipped to the sample  management trailer at the
Navy B VC site. PE samples consisted of both soil samples
and liquid samples. ERA prepared soil PE samples using
two soil matrixes: Ottawa sand and processed garden soil
(silty sand).

To prepare the soil PE samples, ERA spiked the required
volume of soil based on the number of PE samples and the
quantity of soil per PE  sample requested.   ERA then

Table 4-3. Environmental Samples
                           homogenized the soil by manually mixing it.  ERA used
                           weathered gasoline or diesel as the spiking material, and
                           spiking was done at three levels to depict the three TPH
                           concentration  ranges:  low,  medium, and  high.   A
                           low-range sample was spiked to  correspond to a TPH
                           concentration of < 100 mg/kg; a medium-range sample was
                           spiked to correspond to a TPH concentration range of 100
                           to  1,000 mg/kg; and a high-range sample was spiked to
                           correspond to  a  TPH  concentration  of  more  than
                           1,000 mg/kg.  To spike each low- and medium-range soil
                           sample, ERA used methanol as a "carrier" to distribute the
                           contaminant evenly throughout  the sample.   Soil  PE
                           samples were spiked with  interferents at two different
                           levels ranging  from 50 to  500  percent of the  TPH
                           concentration expected to be present. Whenever possible,
                           the interferents were added at levels that best represented
                           real-world  conditions.   ERA analyzed the  samples
                           containing weathered gasoline before shipping them to the
Site
Navy
BVC
Kelly
AFB
PC
Area
FFA
NEX
Service
Station
Area
B-38
Area
SFT
Area
Depth
Interval
(foot bgs)
Upper layer
Lower layer
7 to 8
8 to 9
9 to 10
10 to 11
23 to 25
25 to 27
2 to 4
4 to 6
6 to 8
8 to 10
Number of
Sampling
Locations
3
3
3
3
3
3
3
3
5
5
5
5
Total
Total Number of
Samples, Including
Field Triplicates, to
SDI and Reference
Laboratory8
5
5
5
5
5
5
5
3
7
7
7
7
66
Number of
MS/MSD"
Pairs
1
1
1
1
1
1
1
1
1
1
1
1
12
Number of
Extract
Duplicates
1
1
1
1







1
12
Number of
TPH Analyses
by SDI
6
6
6
6
6
6
6
4
8
8
8
8
78
Number of Analyses
by Reference
Laboratory0
GRO
0
0
8
8
8
8
8
6
10
10
10
10
86
EDRO
8
8
8
8
8
8
8
6
10
10
10
10
102
Notes:

AFB   =  Air Force Base
bgs   =  Below ground surface
BVC   =  Base Ventura County
FFA     = Fuel Farm Area                      PC   =
MS/MSD = Matrix spike and matrix spike duplicate     SFT  =
NEX     = Naval Exchange
Petroleum company
Slop Fill Tank
    Field triplicates were collected at a frequency of one per depth interval in each sampling area except the B-38 Area. Because of conditions in the
    B-38 Area, triplicates were collected in the top depth interval only. Three separate, blind samples were prepared for each field triplicate.
    MS/MSD samples were collected at a frequency of one per depth interval in each sampling area for analysis by the reference laboratory. MS/MSD
    samples were not analyzed by SDI.
    All environmental samples were also analyzed for moisture content by the reference laboratory.
                                                      34

-------
Navy BVC  site.  The analytical results were  used to
confirm sample concentrations.

Liquid PE samples consisted of neat materials. Each liquid
PE sample consisted of approximately 2 mL of liquid in a
flame-sealed, glass ampule. During the demonstration, the
developers and reference laboratory were given a  table
informing them of the amount of liquid sample to be used
for analysis.

ERA grouped like PE samples together in a resealable bag
and placed all the PE samples in a cooler containing ice for
overnight shipment to the Navy BVC site. When the PE
samples arrived at the site, the samples were labeled with
the appropriate sample identification numbers and placed
in appropriate coolers for transfer to the developers on site
or for shipment to the reference laboratory as summarized
in Section 4.3.2.  Table 4-4 summarizes the contaminant
types and concentration ranges as well as the numbers of
PE samples and analyses associated with the demonstration
of the EnSys Petro Test System.

4.3.2  Sample Management

Following sample containerization, each environmental
sample was assigned a unique sample designation defining
the  sampling  area, expected type of  contamination,
expected concentration range, sampling location, sample
number,  and QC identification, as  appropriate.  Each
sample  container was labeled with the  unique  sample
designation, date, time, preservative, initials of personnel
who had filled the container, and analysis to be performed.
Each  PE sample  was also  assigned a unique sample
designation that identified it as a PE sample.  Each PE
sample  designation  also   identified  the   expected
contaminant type and range, whether the sample was soil
or liquid, and the sample number.

Sample custody began when samples were placed in iced
coolers in the possession of the designated field sample
custodian.  Demonstration samples were divided into two
groups to allow adequate time for the developers and
reference laboratory to extract and analyze  samples within
the method-specified holding times presented in Table 4-5.

The two groups  of  samples for reference  laboratory
analysis were placed in coolers containing ice  and chain-
of-custody forms and were sh ipped by overnight courier to
the  reference laboratory on the first and third days of the
demonstration. The two groups of samples for developer
analysis were placed in coolers containing ice  and chain-
of-custody  forms  and  were  hand-delivered to  the
developers at the Navy BVC site on the same days that the
reference laboratory received its two groups of samples.
During the  demonstration, each developer was provided
with a tent to provide shelter from direct sunlight during
analysis of demonstration samples. In addition, at the end
of each day, the developer placed any samples or sample
extracts in  its custody in coolers, and the coolers were
stored in a refrigerated truck.
                                                    35

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Table 4-4. Performance Evaluation Samples
Sample Type
Typical TPH
Concentration
Range8
Total Number of
Samples to SDI
and Reference
Laboratory
Number of
MS/MSD"
Pairs
Number of
Analyses by
SDI
Number of
Analyses by Reference
Laboratory0
GRO
EDRO
Soil Samples (Ottawa Sand) , - " .'••'/'" -,;,,/ - •,-'"-,' ' ' -'•
Weathered gasoline
Diesel
Low
7
7
0
0
7
7
7
0
7
7
Soil Samples (Processed Garden Soil) • ,, ;", ,,X;;;; " ,Y'-
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Table 4-4. Performance Evaluation Samples (Continued)
Sample Type
Typical TPH
Concentration
Range'
Total Number of
Samples to SDI
and Reference
Laboratory
Number of
MS/MSD"
Pairs
Number of
Analyses by
SDI
Number of
Analyses by Reference
Laboratory0
GRO
EDRO
Liquid Samples (Neat Material) {Continued} „. , 7 -, •>'• .*•
PCE
Stoddard solvent
Turpentine
1 ,2,4-Trichlorobenzene
Not applicable
High
Not applicable
Total
6
6
6
6
125
0
0
0
0
6
6
6
6
6
125
6
6
6
0
90
0
6
6
6
125
Notes:

mg/kg   =  Milligram per kilogram
MS/MSD =  Matrix spike and matrix spike duplicate
MTBE =
PCE  =
Methyl-tert-butyl ether
Tetrachloroethene
    The typical TPH concentration range was based on reference laboratory results for the demonstration. The typical low, medium, and high ranges
    indicate TPH concentrations of less  than 100 mg/kg; 100  to 1,000 mg/kg; and  greater than  1,000 mg/kg, respectively.  The typical TPH
    concentration range for the liquid sample concentrations was based on the definition of TPH used for the demonstration and knowledge of the
    sample (neat material).
    MS/MSD samples were analyzed only by the reference laboratory.

    All soil performance evaluation samples were also analyzed for moisture content by the reference laboratory.

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Table 4-5. Sample Container, Preservation, and Holding Time Requirements
Parameter0
GRO
EDRO
Percent moisture
TPH
GRO and EDRO
Medium
Soil
Soil
Soil
Soil
Liquid
Container
Two 5-gram EnCores
Two 4-ounce, glass jars with Teflon™-lined lids
Two 4-ounce, glass jars with Teflon™-lined lids
One 25-gram EnCore
One 2-milliliter ampule for each analysis
Preservation
4±2°C
4±2°C
4±2°C
4±2"C
Not applicable
Holding Time (days)
Extraction Analysis
2" 14
14" 40
Not applicable 7
Performed on site0
See note d
Notes:

±      = Plus or minus

"    The reference laboratory measured percent moisture using part of the soil sample from the container designated for EDRO analysis.
b    The extraction holding time started on the day that samples were shipped.
°    If GRO analysis of a sample was to be completed by the reference laboratory, the developers completed on-site extraction of the corresponding
     sample within 2 days.  Otherwise, all on-site extractions and analyses were completed within 7 days.

d    The reference laboratory cracked open each ampule and immediately added the specified aliquot of the sample to methanol for GRO analysis
     and to methylene chloride for EDRO analysis.  This procedure was performed in such a way that the final volumes of the extracts for GRO and
     EDRO analyses were 5.0 milliliters and 1.0 milliliter, respectively. Once the extracts were prepared, the GRO and EDRO analyses were performed
     within 14 and 40 days, respectively.
                                                               38

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                                              Chapter 5
                                       Confirmatory Process
The  performance results for each field  measurement
device were compared to those for an off-site laboratory
measurement method—that is, a reference method. This
chapter describes the rationale for the selection of the
reference method (Section 5.1) and reference laboratory
(Section  5.2) and  summarizes project-specific sample
preparation and analysis procedures associated with the
reference method (Section 5.3).

5.1    Reference Method Selection

During the demonstration, environmental and PE samples
were analyzed for TPH by the reference laboratory using
SW-846  Method  8015B  (modified).    This  section
describes  the  analytical  methods considered  for  the
demonstration and provides a rationale for the reference
method selected.

The  reference method used  was selected based on the
following criteria:

•  It is not a field screening method.

•  It is widely used and accepted.

   It measures light (gasoline) to heavy (lubricating oil)
   fuel types.

•  It can provide separate measurements of GRO and
   EDRO fractions of TPH.

•  It meets project-specific reporting limit requirements.

The analytical methods considered for the demonstration
and the reference method selected based on the above-
listed criteria are illustrated  in a  flow diagram  in
Figure 5-1.  The reference method selection process is
discussed below.

Analytical methods considered for the demonstration were
identified based on a review of SW-846, "Methods for
Chemical Analysis of Water and Wastes" (MCAWW),
ASTM, API, and state-specific methods. The analytical
methods considered collectively represent six  different
measurement technologies.  Of the methods reviewed,
those identified  as  field screening  methods,  such  as
SW-846 Method  4030,  were eliminated  from further
consideration in the reference method selection process.

A literature review was conducted to determine whether
the remaining methods are widely used and accepted in the
United States (Association for Environmental Health and
Sciences [AEHS] 1999).  As a result of this review, state-
specific methods such as the Massachusetts Extractable
Petroleum Hydrocarbon  (EPH) and Volatile Petroleum
Hydrocarbon (VPH) Methods (Massachusetts Department
of Environmental Protection 2000), the Florida Petroleum
Range Organic (PRO) Method (Florida Department  of
Environmental Protection 1996), and Texas Method 1005
(Texas Natural Resource Conservation Commission 2000)
were  eliminated  from  the selection  process.   Also
eliminated were the  gravimetric and infrared  methods
except for MCAWW Method 418.1 (EPA 1983). The use
and acceptability of MCAWW Method 418.1 will likely
decline because the extraction solvent used in this method
is Freon  113, a chlorofluorocarbon (CFC), and  use  of
CFCs will eventually be  phased out under the Montreal
Protocol. However, because several states still accept the
use of MCAWW Method 418.1 for measuring TPH, the
method was  retained for  further consideration  in the
selection process (AEHS  1999).
                                                   39

-------
 Analytical methods considered (technology)
        ASTM Method D 5831-96
      (ultraviolet spectrophotometry)

      State-specific methods such as
  Massachusetts EPH and VPH Methods,
  Florida PRO Method, and Texas Method
             1005(GC/FID)

         MCAWW Method 413.1
             (gravimetric)

         MCAWW Method 413.2
               (infrared)

         MCAWW Method 418.1
               (infrared)

            API PHC Method
               (GC/FID)

          SW-846 Method 4030
      (immunoassay and colorimetry)

         SW-846 Method 801 SB
               (GC/FID)

          SW-846 Method 8440
               (infrared)

          SW-846 Method 9071
             (gravimetric)

          SW-846 Method 9074
         (emulsion turbidimetry)
                                                                                       Reference method selected
State-specific methods
MCAWW Method 413.1
MCAWW Method 413.2
SW-846 Method 8440
SW-846 Method 9071
        No
   Measures light
  (gasoline) to heavy
   (lubricating oil)
     fuel types?
                                                                                    SW-846 Method 8015B (modified)
                                                                                                 Yes
Yes->
MCAWW Method 41 8.1
API PHC Method
SW-846 Method 801 5B
^
r
                      Yes—»
MCAWW Method 418.1
  API PHC Method
SW-846 Method 8015B
                                                                                                Meets
                                                                                       project-specific reporting limit
                                                                                             requirements?
State-specific methods
MCAWW Method 413.1
MCAWW Method 413.2
MCAWW Method 418.1
   API PHC Method
SW-846 Method 8015B
SW-846 Method 8440
SW-846 Method 9071
                                                           Considered a field
                                                           screening method?
                                         Yes—>
            Provides
      separate measurements
        of GRO and EDRO
         fractions of TPH?
                             MCAWW Method 418.1
                                        API PHC Method
                   ASTM Method D 5831-96
                    SW-846 Method 4030
                    SW-846 Method 9074
                                                                              reference method
Notes:

API = American Petroleum Institute, ASTM =American Society for Testing and MaterialspRO = diesel range organics, EPH = extrxtable petroleum hydrocarbon, GC/FID = gas chromatograph/flame
ionization detector, MCAWW = "Methods for Chemical Analysis of Water and Wastes," PHC = petroleum hydrocarbon, PRO = petroleurrange organics, SW-846 = "Test Methods for Evaluating
Solid Waste," VPH = volatile petroleum hydrocarbon

*    SW-846 Method 8015B provides separateGRO and DRO measurements and, when modified,can also provide EDRO measurements.

Figure 5-1.  Reference method selection process.

-------
Of the remaining methods, MCAWW Method 418.1, the
API PHC Method, and SW-846 Method 8015B can all
measure light (gasoline) to heavy (lubricating oil) fuel
types.  However, GRO and EDRO fractions cannot be
measured separately using MCAWW Method 418.1. As
a result, this method was  eliminated from the selection
process.

Both the API PHC Method and SW-846 Method 8015B
can be used to  separately measure the GRO and DRO
fractions of TPH. These methods can also be modified to
extend the DRO range to  EDRO by using a calibration
standard  that includes even-numbered alkanes in the
EDRO range.

Based on a review of state-specific action levels for TPH,
a TPH reporting limit of 10 mg/kg was used for the
demonstration.  Because the TPH reporting limit for the
API PHC Method (50 to 100 mg/kg) is >10 mg/kg, this
method was  eliminated from the selection process  (API
1994).   SW-846 Method 8015B  (modified) met the
reporting limit requirements for the demonstration. For
GRO, SW-846 Method 8015B (modified) has a reporting
limit of 5 mg/kg, and for EDRO,  this method has a
reporting  limit of  10  mg/kg.    Therefore, SW-846
Method  8015B (modified)  satisfied  all   the criteria
established for  selecting the reference method.  As an
added  benefit,  because this is a GC method, it also
provides   a  fingerprint   (chromatogram)  of   TPH
components.

5.2    Reference Laboratory Selection

This section provides the rationale for the selection of the
reference laboratory. STL Tampa East was selected as the
reference laboratory because it (1) has been performing
TPH analyses for many  years, (2) has passed  many
external audits by successfully implementing a variety of
TPH analytical  methods,  and (3) agreed to implement
project-specific analytical requirements. In January 2000,
a project-specific audit of the laboratory was conducted
and  determined that STL  Tampa East satisfactorily
implemented   the  reference method   during  the
predemonstration investigation. In addition, STL Tampa
East successfully analyzed double-blind PE samples and
blind  field triplicates for  GRO and EDRO during the
predemonstration investigation.  Furthermore,  in  1998
STL Tampa East was one of four recipients and in 1999
was one of six recipients of the Seal of Excellence Award
issued  by  the  American  Council  of  Independent
Laboratories.  In each instance, this award was issued
based on the  results of PE sample analyses and client
satisfaction surveys.  Thus, the selection of the reference
laboratory was based primarily on performance and not
cost.

5.3    Summary of Reference Method

The laboratory sample preparation and analytical methods
used for the demonstration are summarized in Table 5-1.
The SW-846 methods listed in Table 5-1  for GRO and
EDRO analyses were tailored to meet the definition  of
TPH for  the project (see Chapter  1).   Project-specific
procedures for soil sample preparation and analysis for
GRO and EDRO are summarized in Tables 5-2 and 5-3,
respectively.  Project-specific procedures were applied
(1) if a method used offered choices (for example, SW-846
Method 5035 for GRO extraction states that samples may
be collected with or without use of a preservative solution),
(2) if a method used did not provide specific details (for
example, SW-846 Method 5035 for GRO extraction does
not specify how  unrepresentative  material  should  be
handled  during  sample  preparation),   or  (3)  if  a
modification to a method used was required in order to
meet demonstration objectives  (for example,  SW-846
Method 801 SB for EDRO analysis states that quantitation
is performed by summing the areas of all chromatographic
peaks   eluting   between   the   end   of  the
1,2,4-trimethylbenzene or n-C10 peak, whichever occurs
later, and the n-octacosane peak; however, an additional
quantitation  was  performed to  sum the areas of  all
chromatographic peaks eluting  from the end of the
n-octacosane peak through the tetracontane peak in order
to meet demonstration objectives).

Before analyzing a liquid PE sample, STL Tampa East
added an aliquot of the liquid PE sample to the extraction
solvent used for soil samples.  A specified aliquot of the
liquid  PE sample was diluted in  methanol for  GRO
analysis and in methylene chloride for EDRO analysis
such that the final volume of the solution for GRO and
EDRO analyses was 5.0 and 1.0 mL, respectively.  The
solution was then analyzed for GRO and EDRO using the
same procedures as are used for soil sample extracts.
                                                  41

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Table 5-1. Laboratory Sample Preparation and Analytical Methods
Parameter
            Method Reference (Step)
                        Method Title
GRO
EDRO
Based on SW-846 Method 5035 (extraction)

Based on SW-846 Method 5030B (purge-and-trap)
Based on SW-846 Method 8015B (analysis)
Based on SW-846 Method 3540C (extraction)
Based on SW-846 Method 801 SB (analysis)
Percent moisture    Based on MCAWW Method 160.3°
Closed-System Purge-and-Trap and Extraction for Volatile Organics
in Soil and Waste Samples
Purge-and-Trap for Aqueous Samples
Nonhalogenated Volatile Organics by Gas Chromatography
Soxhlet Extraction
Nonhalogenated Volatile Organics by Gas Chromatography
Residue, Total (Gravimetric, Dried at 103-105 °C)
Notes:
MCAWW =  "Methods for Chemical Analysis of Water and Wastes"
SW-846  =  "Test Methods for Evaluating Solid Waste"
°   MCAWW Method 160.3 was modified to include calculation and reporting of percent moisture in soil samples.
                                                             42

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Table 5-2. Summary of Project-Specific Procedures for GRO Analysis
SW-846 Method Reference (Step)
Project-Specific Procedures
5035 (Extraction)
Low-level (0.5 to 200 micrograms per kilogram) or high-level (greater
than 200 micrograms per kilogram) samples may be prepared.
Samples may be collected with or without use of a preservative
solution.
A variety of sample containers, including EnCores, may be used when
high-level samples are collected without use of a preservative.
Samples collected in EnCores should be transferred to vials containing
the extraction solvent as soon as possible or analyzed within 48 hours.
For samples not preserved in the field, a solubility test should be
performed using methanol, polyethylene glycol, and hexadecane to
determine an appropriate extraction solvent.
Removal of unrepresentative material from the sample is not discussed.
Procedures for adding surrogates to the sample are inconsistently
presented. Section 2.2.1 indicates that surrogates should be added to
an aliquot of the extract solution. Section 7.3.3 indicates that soil
should be added to a vial containing both the extraction solvent
(methanol) and surrogate spiking solution.
Nine ml of methanol should be added to a 5-gram (wet weight) soil
sample.
When practical, the sample should be dispersed to allow contact with
the methanol by shaking or using other mechanical means for 2 min
without opening the sample container. When shaking is not practical,
the sample should be dispersed with a narrow, metal spatula, and the
sample container should be immediately resealed.
Because the project-specific reporting limit for GRO was 5 milligrams
per kilogram, all samples analyzed for GRO were prepared using
procedures for high-level samples.
Samples were collected without use of a preservative.
Samples were containerized in EnCores.
Samples were weighed and extracted within 2 calendar days of their
shipment. The holding time for analysis was 14 days after extraction. A
full set of quality control samples (method blanks, MS/MSDs, and
LCS/LCSDs) was prepared within this time.
Because the reference laboratory obtained acceptable results for
performance evaluation samples extracted with methanol during the
predemonstration investigation, samples were extracted with methanol.
During sample homogenization, field sampling technicians attempted to
remove unrepresentative material such as sticks, roots, and stones if
present in the sample; the reference laboratory did not remove any
remaining unrepresentative material.
The soil sample was ejected into a volatile organic analysis vial, an
appropriate amount of surrogate solution was added to the sample, and
then methanol was quickly added.
Five ml of methanol was added to the entire soil sample contained in a
5-gram EnCore.
The sample was dispersed using a stainless-steel spatula to allow
contact with the methanol. The volatile organic analysis vial was then
capped and shaken vigorously until the soil was dispersed in methanol,
and the soil was allowed to settle.
5030B (Purge-and-Trap) . ,,.,,,., „„,,,,.,,':• s!S ,,
Screening of samples before the purge-and-trap procedure is
recommended using one of the two following techniques:
Use of an automated headspace sampler (see SW-846 Method 5021)
connected to a GC equipped with a photoionization detector in series
with an electrolytic conductivity detector
Extraction of the samples with hexadecane (see SW-846 Method 3820)
and analysis of the extracts using a GC equipped with a flame
ionization detector or electron capture detector
SW-846 Method 5030B indicates that contamination by carryover can
occur whenever high-level and low-level samples are analyzed in
sequence. Where practical, analysis of samples with unusually high
concentrations of analytes should be followed by an analysis of
organic-free reagent water to check for cross-contamination. Because
the trap and other parts of the system are subject to contamination,
frequent bake-out and purging of the entire system may be required.
Samples were screened with an automated headspace sampler (see
SW-846 Method 5021) connected to a GC equipped with a flame
ionization detector.
According to the reference laboratory, a sample extract concentration
equivalent to 1 0,000 ng on-column is the minimum concentration of
GRO that could result in carryover. Therefore, if a sample extract had
a concentration that exceeded the minimum concentration for
carryover, the next sample in the sequence was evaluated as follows:
(1) if the sample was clean (had no chromatographic peaks), no
carryover had occurred; (2) if the sample had detectable analyte
concentrations (chromatographic peaks), it was reanalyzed under
conditions in which carryover did not occur.
                                                           43

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Table 5-2.  Summary of Project-Specific Procedures for GRO Analysis (Continued)
SW-846 Method Reference (Step)
Project-Specific Procedures
5030B (Purge-and-Trap) (Continued)
The sample purge device used must demonstrate adequate
performance.
Purge-and-trap conditions for high-level samples are not clearly
specified. According to SW-846, manufacturer recommendations for
the purge-and-trap devices should be considered when the method is
implemented. The following general purge-and-trap conditions are
recommended for samples that are water-miscible (methanol extract):
Purge gas: nitrogen or helium
Purge gas flow rate: 20 mL/min
Purge time: 15 ± 0.1 min
Purge temperature: 85 ± 2 "C
Desorb time: 1 .5 min
Desorb temperature: 1 80 "C
Backflush inert gas flow rate: 20 to 60 mL/min
Bake time: not specified
Bake temperature: not specified
Multiport valve and transfer line temperatures: not specified
A Tekmar 2016 autosampler and a Tekmar LSC 2000 concentrator
were used. Based on quality control sample results, the reference
laboratory had demonstrated adequate performance using these
devices.
The purge-and-trap conditions that were used are listed below. These
conditions were based on manufacturer recommendations for the purge
device specified above and the VOCARB 3000 trap.
Purge gas: helium
Purge gas flow rate: 35 mL/min
Purge time: 8 min with 2-min dry purge
Purge temperature: ambient temperature
Desorb time: 1 min
Desorb temperature: 250 °C
Backflush inert gas flow rate: 35 mL/min
Bake time: 7 min
Bake temperature: 270 °C
Multiport valve and transfer line temperatures: 1 1 5 and 1 20 °C
801 SB (Analysis)
GC Conditions
The following GC conditions are recommended:
Column: 30-meter x 0.53-millimeter-inside diameter, fused-silica
capillary column chemically bonded with 5 percent methyl
silicone, 1 .5-micrometer field thickness
Carrier gas: helium
Carrier gas flow rate: 5 to 7 mL/min
Makeup gas: helium
Makeup gas flow rate: 30 mL/min
Injector temperature: 200 °C
Detector temperature: 340 °C
Temperature program:
Initial temperature: 45 "C
Hold time: 1 min
Program rate: 45 to 1 00 °C at 5 °C/min
Program rate: 100 to 275 °C at 8 °C/min
Hold time: 5 min
Overall time: 38.9 min
The HP 5890 Series II was used as the GC. The following GC
conditions were used based on manufacturer recommendations:
Column: 30-meter x 0.53-millimeter-inside diameter, fused-silica
capillary column chemically bonded with 5 percent methyl
silicone, 1. 5-micrometer field thickness
Carrier gas: helium
Carrier gas flow rate: 15 mL/min
Makeup gas: helium
Makeup gas flow rate: 15 mL/min
Injector temperature: 200 °C
Detector temperature: 200 °C
Temperature program:
Initial temperature: 25 °C
Hold time: 3 min
Program rate: 25 to 120 °C at 25 °C/min
Hold time: 4 min
Program rate: 120 to 245 °C at 25 °C/min
Hold time: 5 min
Overall time: 20.4 min
Calibration
The chromatographic system may be calibrated using either internal or
external standards.
Calibration should be performed using samples of the specific fuel type
contaminating the site. When such samples are not available, recently
purchased, commercially available fuel should be used.
The chromatographic system was calibrated using external standards
with a concentration range equivalent to 100 to 10,000 ng on-column.
The reference laboratory acceptance criterion for initial calibration was a
relative standard deviation less than or equal to 20 percent of the
average response factor or a correlation coefficient for the
least-squares linear regression greater than or equal to 0.990.
Calibration was performed using a commercially available,
10-component GRO standard that contained 35 percent aliphatic
hydrocarbons and 65 percent aromatic hydrocarbons.
                                                            44

-------
Table 5-2.  Summary of Project-Specific Procedures for GRO Analysis (Continued)
SW-846 Method Reference (Step)
Project-Specific Procedures
801 5B (Analysis) (Continued)
Calibration (Continued)
Initial calibration verification is not required.
CCV should be performed at the beginning of every 12-hour work shift
and at the end of an analytical sequence. CCV throughout the 12-hour
shift is also recommended; however, the frequency is not specified.
CCV should be performed using a fuel standard.
According to SW-846 Method 8000, CCV should be performed at the
same concentration as the midpoint concentration of the initial
calibration curve; however, the concentration of each calibration point is
not specified.
A method sensitivity check is not required.
Initial calibration verification was performed using a second-source
standard that contained a 10-component GRO standard made up of
35 percent aliphatic hydrocarbons and 65 percent aromatic
hydrocarbons at a concentration equivalent to 2,000 ng on-column. The
reference laboratory acceptance criterion for initial calibration
verification was an instrument response within 25 percent of the
response obtained during initial calibration.
CCV was performed at the beginning of each analytical batch, after
every tenth analysis, and at the end of the analytical batch. The
reference laboratory acceptance criteria for CCV were instrument
responses within 25 percent (for the closing CCV) and 1 5 percent
(for all other CCVs) of the response obtained during initial calibration.
CCV was performed using a commercially available, 10-component
GRO standard that contained 35 percent aliphatic hydrocarbons and
65 percent aromatic hydrocarbons.
CCV was performed at a concentration equivalent to 2,000 ng
on-column.
A method sensitivity check was performed daily using a calibration
standard with a concentration equivalent to 100 ng on-column. The
reference laboratory acceptance criterion for the method sensitivity
check was detection of the standard.
Retention Time Windows
The retention time range (window) should be established using
2-methylpentane and 1 ,2,4-trimethylbenzene during initial calibration.
Three measurements should be made over a 72-hour period; the results
should be used to determine the average retention time. As a minimum
requirement, the retention time should be verified using a midlevel
calibration standard at the beginning of each 12-hour shift. Additional
analysis of the standard throughout the 12-hour shift is strongly
recommended.
The retention time range was established using the opening CCV
specific to each analytical batch. The first eluter, 2-methylpentane, and
the last eluter, 1 ,2,4-trimethylbenzene, of the GRO standard were used
to establish each day's retention time range.
Quantitation
Quantitation is performed by summing the areas of all chromatographic
peaks eluting within the retention time range established using
2-methylpentane and 1 ,2,4-trimethylbenzene. Subtraction of the
baseline rise for the method blank resulting from column bleed is
generally not required.
Quantitation was performed by summing the areas of all
chromatographic peaks from 2-methylpentane through
1 ,2,4-trimethylbenzene. This range includes n-C,0. Baseline rise
subtraction was not performed.
Quality Control
Spiking compounds for MS/MSDs and LCSs are not specified.
According to SW-846 Method 8000, spiking levels for MS/MSDs are
determined differently for compliance and noncompliance monitoring
applications. For noncompliance applications, the laboratory may spike
the sample (1) at the same concentration as the reference sample
(LCS), (2) at 20 times the estimated quantitation limit for the matrix of
interest, or (3) at a concentration near the middle of the calibration
range.
The spiking compound. mixture for MS/MSDs and LCSs was the
10-component GRO calibration standard.
MS/MSD spiking levels were targeted to be between 50 and
150 percent of the unspiked sample concentration. The reference
laboratory used historical information to adjust spike amounts or to
adjust sample amounts to a preset spike amount. The spiked samples
and unspiked samples were prepared such that the sample mass and
extract volume used for analysis were the same.
                                                           45

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Table 5-2. Summary of Project-Specific Procedures for GRO Analysis (Continued)
SW-846 Method Reference (Step)
Project-Specific Procedures
801 SB (Analysis) (Continued)
Quality Control (Continued)
According to SW-846 Method 8000, in-house laboratory acceptance
criteria for MS/MSDs and LCSs should be established. As a general
rule, the recoveries of most compounds spiked into a sample should fall
within the range of 70 to 130 percent, and this range should be used as
a guide in evaluating in-house performance.
The LCS should consist of an aliquot of a clean (control) matrix that is
similar to the sample matrix.
No LCSD is required.
The surrogate compound and spiking concentration are not specified.
According to SW-846 Method 8000, in-house laboratory acceptance
criteria for surrogate recoveries should be established.
The method blank matrix is not specified.
The extract duplicate is not specified.
The reference laboratory acceptance criteria for MS/MSDs and LCSs
were a relative percent difference less than or equal to 25 with 33 to
1 1 5 percent recovery. The acceptance criteria were based on
laboratory historical information. These acceptance criteria are similar
to those of the methods cited in Figure 5-1 .
The LCS/LCSD matrix was Ottawa sand.
The spiking compound mixture for LCSDs was the 10-component GRO
calibration standard.
The surrogate compound was 4-bromofluorobenzene. The reference
laboratory acceptance criterion for surrogates was 39 to 163 percent
recovery.
The method blank matrix was Ottawa sand. The reference laboratory
acceptance criterion for the method blank was less than or equal to the
project-specific reporting limit.
The extract duplicate was analyzed. The reference laboratory
acceptance criterion for the extract duplicate was a relative percent
difference less than or equal to 25.
Notes:

±
ccv
GC
LCS
LCSD
Plus or minus
Continuing calibration verification
Gas chromatograph
Laboratory control sample
Laboratory control sample duplicate
min      = Minute
ml      = Milliliter
MS      = Matrix spike
MSD     = Matrix spike duplicate
ng       = Nanogram
SW-846  = Test Methods for Evaluating Solid Waste"
                                                              46

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Table 5-3. Summary of Project-Specific Procedures for EDRO Analysis
SW-846 Method Reference (Step)
Project-Specific Procedures
3540C (Extraction), ' " ' "*', " " ' \" * , A- ' •' * ^,
Any free water present in the sample should be decanted and
discarded. The sample should then be thoroughly mixed, and any
unrepresentative material such as sticks, roots, and stones should be
discarded.
Ten grams of soil sample should be blended with 10 grams of
anhydrous sodium sulfate.
Extraction should be performed using 300 mL of extraction solvent.
Acetone and hexane (1:1 volume per volume) or methylene chloride
and acetone (1 :1 volume per volume) may be used as the extraction
solvent.
Note: Methylene chloride and acetone are not constant-boiling
solvents and thus are not suitable for the method. Methylene
chloride was used as an extraction solvent for method
validation.
The micro Snyder column technique or nitrogen blowdown technique
may be used to adjust (concentrate) the soil extract to the required final
volume.
Procedures for addressing contamination carryover are not specified.
During sample homogenization, field sampling technicians attempted to
remove unrepresentative material such as sticks, roots, and stones. In
addition, the field sampling technicians decanted any free water present
in the sample. The reference laboratory did not decant water or remove
any unrepresentative material from the sample. The reference
laboratory mixed the sample with a stainless-steel tongue depressor.
Thirty grams of sample was blended with at least 30 grams of
anhydrous sodium sulfate. For medium- and high-level samples, 6 and
2 grams of soil were used for extraction, respectively, and proportionate
amounts of anhydrous sodium sulfate were added. The amount of
anhydrous sodium sulfate used was not measured gravimetrically but
was sufficient to ensure that free moisture was effectively removed from
the sample.
Extraction was performed using 200 ml of extraction solvent.
Methylene chloride was used as the extraction solvent.
Kuderna Danish and nitrogen evaporation were used as the
concentration techniques.
According to the reference laboratory, a sample extract concentration of
100,000 micrograms per mL is the minimum concentration of EDRO
that could result in carryover. Therefore, if a sample extract had a
concentration that exceeded the minimum concentration for carryover,
the next sample in the sequence was evaluated as follows: (1 ) if the
sample was clean (had no chromatographic peaks), no carryover
occurred; (2) if the sample had detectable analyte concentrations
(chromatographic peaks), it was reanalyzed under conditions in which
carryover did not occur.
801 5B (Analysis) , , »
GC Conditions
The following GC conditions are recommended:
Column: 30-meter x 0.53-millimeter-inside diameter, fused-silica
capillary column chemically bonded with 5 percent methyl
silicone, 1 .5-micrometer field thickness
Carrier gas: helium
Carrier gas flow rate: 5 to 7 mL/min
Makeup gas: helium
Makeup gas flow rate: 30 mL/min
Injector temperature: 200 °C
Detector temperature: 340 °C
Temperature program:
Initial temperature: 45 °C
Hold time: 3 min
Program rate: 45 to 275 °C at 12 "C/min
Hold time: 12 min
Overall time: 34.2 min
An HP 6890 GC was used with the following conditions:
Column: 30-meter x 0.53-millimeter-inside diameter, fused-silica
capillary column chemically bonded with 5 percent methyl
silicone, 1 .5-micrometer field thickness
Carrier gas: hydrogen
Carrier gas flow rate: 1 .9 mL/min
Makeup gas: hydrogen
Makeup gas flow rate: 23 mL/min
Injector temperature: 250 °C
Detector temperature: 345 °C
Temperature program:
Initial temperature: 40 °C
Hold time: 2 min
Program rate: 40 to 345 °C at 30 "C/min
Hold time: 5 min
Overall time: 17.2 min
                                                           47

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Table 5-3.  Summary of Project-Specific Procedures for EDRO Analysis (Continued)
SW-846 Method Reference (Step)
Project-Specific Procedures
801 5B( Analysis) (Continued)
Calibration
The chromatographic system may be calibrated using either internal or
external standards.
Calibration should be performed using samples of the specific fuel type
contaminating the site. When such samples are not available, recently
purchased, commercially available fuel should be used.
ICV is not required.
CCV should be performed at the beginning of every 12-hour work shift
and at the end of an analytical sequence. CCV throughout the 12-hour
shift is also recommended; however, the frequency is not specified.
CCV should be performed using a fuel standard.
According to SW-846 Method 8000, CCV should be performed at the
same concentration as the midpoint concentration of the initial
calibration curve; however, the concentration of each calibration point is
not specified.
A method sensitivity check is not required.
The chromatographic system was calibrated using external standards
with a concentration range equivalent to 75 to 7,500 ng on-column. The
reference laboratory acceptance criterion for initial calibration was a
relative standard deviation less than or equal to 20 percent of the
average response factor or a correlation coefficient for the least-
squares linear regression greater than or equal to 0.990.
Calibration was performed using a commercially available standard that
contained even-numbered alkanes from C10 through C,0.
ICV was performed using a second-source standard that contained
even-numbered alkanes from C10 through C40 at a concentration
equivalent to 3,750 ng on-column. The reference laboratory
acceptance criterion for ICV was an instrument response within
25 percent of the response obtained during initial calibration.
CCV was performed at the beginning of each analytical batch, after
every tenth analysis, and at the end of the analytical batch. The
reference laboratory acceptance criteria for CCV were instrument
responses within 25 percent (for the closing CCV) and 15 percent
(for all other CCVs) of the response obtained during initial calibration.
CCV was performed using a standard that contained only
even-numbered alkanes from C,0 through Cia
CCV was performed at a concentration equivalent to 3,750 ng
on-column.
A method sensitivity check was performed daily using a calibration
standard with a concentration equivalent to 75 ng on-column. The
reference laboratory acceptance criterion for the method sensitivity
check was detection of the standard.
Retention Time Windows
The retention time range (window) should be established using
C,0 and C28 alkanes during initial calibration. Three measurements
should be made over a 72-hour period; the results should be used to
determine the average retention time. As a minimum requirement, the
retention time should be verified using a midlevel calibration standard at
the beginning of each 1 2-hour shift. Additional analysis of the standard
throughout the 12-hour shift is strongly recommended.
Two retention time ranges were established using the opening CCV for
each analytical batch. The first range, which was labeled diesel range
organics, was marked by the end of the 1 ,2,4-trimethylbenzene or n-C,0
peak, whichever occurred later, through the n-octacosane peak. The
second range, which was labeled oil range organics, was marked by the
end of the n-octacosane peak through the tetracontane peak.
Quantitation
Quantitation is performed by summing the areas of all chromatographic
peaks eluting between n-C,0 and n-octacosane.
Quantitation was performed by summing the areas of all
chromatographic peaks from the end of the 1 ,2,4-trimethylbenzene or
n-C,0 peak, whichever occurred later, through the n-octacosane peak.
A separate quantitation was also performed to sum the areas of all
chromatographic peaks from the end of the n-octacosane peak through
the tetracontane peak. Separate average response factors for the
carbon ranges were used for quantitation. The quantitation results were
then summed to determine the total EDRO concentration.
All calibrations, ICVs, CCVs, and associated batch quality control
measures were controlled for the entire EDRO range using a single
quantitation performed over the entire EDRO range.
                                                           48

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Table 5-3. Summary of Project-Specific Procedures for EDRO Analysis (Continued)
SW-846 Method Reference (Step)
Project-Specific Procedures
801 SB (Analysis) (Continued)
Quantitation (Continued)
Subtraction of the baseline rise for the method blank resulting from
column bleed Is appropriate.
Because phthalate esters contaminate many types of products
commonly found in the laboratory, consistent quality control should be
practiced.
The reference laboratory identified occurrences of baseline rise in the
data package. The baseline rise was evaluated during data validation
and subtracted when appropriate based on analyst discretion.
Phthalate peaks were not noted during analysis.
Quality Control
Spiking compounds for MS/MSDs and LCSs are not specified.
According to SW-846 Method 8000, spiking levels for MS/MSDs are
determined differently for compliance and noncompliance monitoring
applications. For noncompliance applications, the laboratory may spike
the sample (1) at the same concentration as the reference sample
(LCS), (2) at 20 times the estimated quantitation limit for the matrix of
interest, or (3) at a concentration near the middle of the calibration
range.
According to SW-846 Method 8000, in-house laboratory acceptance
criteria for MS/MSDs and LCSs should be established. As a general
rule, the recoveries of most compounds spiked into a sample should fall
within the range of 70 to 130 percent, and this range should be used as
a guide in evaluating in-house performance.
The LCS should consist of an aliquot of a clean (control) matrix that is
similar to the sample matrix.
No LCSD is required.
The surrogate compound and spiking concentration are not specified.
According to SW-846 Method 8000, in-house laboratory acceptance
criteria for surrogate recoveries should be established.
The method blank matrix is not specified.
The extract duplicate is not specified.
The spiking compound for MS/MSDs and LCSs was an EDRO standard
that contained even-numbered alkanes from C,0 through C<0.
MS/MSD spiking levels were targeted to be between 50 and
1 50 percent of the unspiked sample concentration. The reference
laboratory used historical information to adjust spike amounts or to
adjust sample amounts to a preset spike amount. The spiked samples
and unspiked samples were prepared such that the sample mass and
extract volume used for analysis were the same.
The reference laboratory acceptance criteria for MS/MSDs and LCSs
were a relative percent difference less than or equal to 45 with 46 to
124 percent recovery. The acceptance criteria were based on
laboratory historical information. These acceptance criteria are similar
to those of the methods cited in Figure 5-1 .
The LCS/LCSD matrix was Ottawa sand.
The spiking compound for LCSDs was the EDRO standard that
contained even-numbered alkanes from C10 through C40.
The surrogate compound was o-terphenyl. The reference laboratory
acceptance criterion for surrogates was 45 to 143 percent recovery.
The method blank matrix was Ottawa sand. The reference laboratory
acceptance criterion for the method blank was less than or equal to the
project-specific reporting limit.
The extract duplicate was analyzed. The reference laboratory
acceptance criterion for the extract duplicate was a relative' percent
difference less than or equal to 45.
Notes:

CCV
GC
ICV
LCS
LCSD
min
Continuing calibration verification           ml
Gas chromatograph                       MS
Initial calibration verification                MSD
Laboratory control sample                 n-Cx
Laboratory control sample duplicate         ng
Minute                                  SW-846
=  Milliliter
=  Matrix spike
=  Matrix spike duplicate
=  Alkane with "x" carbon atoms
=  Nanogram
=  Test Methods for Evaluating Solid Waste"
                                                               49

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                                              Chapter 6
                        Assessment of Reference Method Data Quality
This chapter assesses reference method data quality based
on QC check results and PE sample results. A summary of
reference method data quality is included at the end of this
chapter.

To ensure that the reference method results were of known
and adequate quality, EPA representatives performed a
predemonstration audit and an in-process audit of the
reference laboratory. The predemonstration audit findings
were used in developing the predemonstration design. The
in-process audit was performed when the laboratory had
analyzed a sufficient number of demonstration samples for
both GRO and EDRO and had prepared its  first data
package.   During  the  audit,  EPA  representatives
(1) verified that the laboratory had properly implemented
the EPA-approved demonstration plan and (2) performed
a critical review of the first data package.   All issues
identified during the audit were fully addressed by the
laboratory  before  it  submitted  the subsequent data
packages to the EPA. The laboratory also addressed issues
identified during the EPA final  review of the  data
packages. Audit findings are summarized in the DER for
the demonstration.

6.1    Quality Control Check Results

This section summarizes QC check results for GRO and
EDRO analyses performed using the reference method.
The QC checks associated with soil sample analyses for
GRO  and EDRO included method blanks, surrogates,
matrix spikes and matrix spike duplicates (MS/MSD), and
laboratory control samples and laboratory control sample
duplicates (LCS/LCSD).  In addition, extract duplicates
were analyzed  for soil environmental samples. The QC
checks associated with liquid PE sample analysis for GRO
included method blanks, surrogates, MS/MSDs, and
LCS/LCSDs.   Because liquid PE sample analyses for
EDRO did not include a preparation step, surrogates,
MS/MSDs, and LCS/LCSDs were not analyzed; however,
an instrument blank was  analyzed as a method blank
equivalent. The results for the QC checks were compared
to project-specific acceptance criteria. These criteria were
based on the reference laboratory's historical QC limits
and its  experience in analyzing the predemonstration
investigation samples using the reference method. The
reference  laboratory's QC limits were  established  as
described  in  SW-846  and were within the general
acceptance criteria recommended by SW-846 for organic
analytical methods.

Laboratory duplicates were also analyzed to evaluate the
precision associated with percent moisture analysis of soil
samples.  The acceptance criterion for the  laboratory
duplicate  results was an RPD  ^20.   All  laboratory
duplicate results met this  criterion.  The results for the
laboratory duplicates are not separately discussed in this
ITVR because soil sample TPH results were compared on
a wet weight basis except for those used to address primary
objective P4 (effect of soil moisture content).

6.1.1      GRO Analysis

This section summarizes the resu Its for QC checks used by
the reference laboratory during GRO analysis, including
method blanks, surrogates, MS/MSDs, extract duplicates,
and LCS/LCSDs. A summary of the QC check results is
presented at the end of the section.

Method Blanks

Method blanks were analyzed to verify that steps in the
analytical procedure did not introduce contaminants that
affected analytical results. Ottawa sand and deionized
water were used as  method blanks  for soil and liquid
                                                   50

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samples, respectively.  These blanks underwent all the
procedures required for sample preparation.  The results
for all method blanks met the acceptance criterion of being
less than or equal to the required project-specific reporting
limit (5 mg/kg). Based on method blank results, the GRO
analysis results were considered to be valid.

Surrogates

Each soil investigative and QC sample for GRO analysis
was  spiked  with  a surrogate, 4-bromofluorobenzene,
before extraction to determine whether significant matrix
effects existed within the sample  and to  estimate the
efficiency of analyte recovery during sample preparation
and analysis. A diluted, liquid PE sample was also spiked
with the surrogate during sample preparation. The initial
surrogate spiking levels for soil and liquid  PE samples
were  2 mg/kg and 40  micrograms per liter  (ug/L),
respectively.  The acceptance criterion was 39 to  163
percent surrogate recovery.  For samples analyzed at a
dilution  factor   greater  than  four,   the  surrogate
concentration was diluted to a level below the reference
laboratory's  reporting limit for the reference  method;
therefore, surrogate recoveries for these samples were not
used to assess impacts on data quality.

A total of 101 surrogate measurements were made during
analysis of  environmental and associated QC samples.
Fifty-six of  these samples were  analyzed at a dilution
factor less than or equal to four. The surrogate recoveries
for these 56 samples ranged from 43 to 345 percent with a
mean recovery of 150 percent and a median recovery of
136 percent. Because the mean  and median recoveries
were > 100 percent, an overall positive bias was indicated.

The surrogate recoveries for 16 of the 56 samples did not
meet the acceptance criterion. In each case, the surrogate
was recovered at a concentration above the upper limit
of the acceptance criterion.   Examination of the gas
chromatograms for the 16 samples revealed that some
PHCs or naturally occurring interferents present in these
environmental samples coeluted  with  the surrogate,
resulting in higher surrogate recoveries. Such coelution is
typical for hydrocarbon-containing samples analyzed using
a GC/FID technique, which was the technique used in the
reference  method.   The surrogate recoveries for  QC
samples such  as method blanks and  LCS/LCSDs  met
the acceptance criterion, indicating that the laboratory
sample  preparation  and analysis  procedures  were in
control.  Because  the coelution was observed only for
environmental  samples  and  because  the  surrogate
recoveries for QC samples met the acceptance criterion,
the  reference   laboratory  did  not  reanalyze  the
environmental samples with high surrogate recoveries.
Calculations performed to evaluate whether the coelution
resulted  in  underreporting  of GRO  concentrations
indicated an insignificant impact of less than 3 percent.
Based  on the  surrogate results for environmental  and
associated QC  samples, the GRO analysis results for
environmental samples were considered to be valid.

A total of 42 surrogate measurements were made during
the analysis of soil PE and  associated QC samples.
Thirty-four of these samples were analyzed at a dilution
factor less than or equal to four. The surrogate recoveries
for these 34 samples ranged from 87 to 108 percent with a
mean recovery of 96 percent and a median  recovery of
95 percent.  The surrogate recoveries for all 34 samples
met the acceptance criterion.  Based  on the  surrogate
results  for soil PE and associated QC samples, the GRO
analysis results for soil PE samples were considered to be
valid.

A total of 37 surrogate measurements were made during
the analysis of liquid PE and associated QC samples.  Six
of these samples were analyzed at a dilution factor  less
than or equal to four. All six samples were QC samples
(method blanks  and LCS/LCSDs).    The  surrogate
recoveries for these six samples ranged from  81 to
84 percent, indicating a small negative bias. However, the
surrogate recoveries for all six samples met the acceptance
criterion. Based on the surrogate results for liquid PE and
associated QC samples, the GRO analysis results for liquid
PE samples were considered to be valid.

Matrix Spikes and Matrix Spike Duplicates

MS/MSD results were evaluated to determine the accuracy
and precision of the analytical results with respect to the
effects of the sample matrix. For GRO analysis, each soil
sample designated as an MS or MSD was spiked with the
GRO calibration standard at an initial spiking level of
20 mg/kg. MS/MSDs were also prepared for liquid PE
samples. Each diluted, liquid PE sample designated as an
MS or MSD was spiked with the GRO calibration standard
at an initial  spiking level  of 40  (ig/L.  The acceptance
criteria for MS/MSDs were 3 3 to 115 percent recovery and
an RPD <;25.  When  the MS/MSD  percent recovery
acceptance criterion was not met, instead of attributing the
failure to meet the criterion to an inappropriate spiking
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level, the reference laboratory respiked the sample at a
more appropriate and practical spiking level. Information
on the selection of the spiking level and calculation of
percent recoveries for MS/MSD samples  is provided
below.

According  to  Provost and Elder (1983),  for  percent
recovery data to be reliable, spiking levels  should be at
least five times the unspiked sample concentration. For the
demonstration, however, a large number of the unspiked
sample concentrations were expected to range between
1,000 and 10,000 mg/kg, so use of such high spiking levels
was not practical.  Therefore, a target spiking level of 50
to 150 percent of the unspiked sample concentration was
used for the demonstration.  Provost and Elder (1983) also
present  an alternate  approach for  calculating  percent
recoveries for MS/MSD samples (100 times the ratio of the
measured  concentration in  a spiked sample  to the
calculated concentration in the sample). However, for the
demonstration, percent recoveries were calculated using
the traditional approach (100 times the ratio of the amount
recovered  to the amount spiked)  primarily because the
alternate approach is not commonly used.

For environmental samples, a total of 10 MS/MSD pairs
were analyzed.  Four sample pairs collected in the NEX
Service Station Area were designated as MS/MSDs. The
sample matrix in this area primarily consisted of medium-
grained sand.  The percent recoveries for all but one of the
MS/MSD  samples ranged  from 67 to 115 with RPDs
ranging from 2 to 14.  Only one  MS sample with a
162 percent recovery did not meet the percent recovery
acceptance criterion;  however,  the RPD  acceptance
criterion for the MS/MSD and the percent recovery and
RPD  acceptance criteria for the LCS/LCSD associated
with the analytical batch for this sample were met. Based
on the MS/MSD results, the GRO  analysis results for the
NEX Service Station Area samples were considered to be
valid.

Two  sample  pairs collected  in  the B-38 Area were
designated as MS/MSDs. The sample matrix in this area
primarily  consisted of  sand  and clay.   The  percent
recoveries for the MS/MSD samples ranged from 60 to 94
with RPDs of 1 and 13. Therefore, the percent recoveries
and RPDs for these samples met the  acceptance  criteria.
Based on the MS/MSD results, the GRO analysis results
for the B-38 Area samples were considered to be  valid.
Four sample pairs  collected  in the SFT Area  were
designated as MS/MSDs. The sample matrix in this area
primarily consisted of silty clay.  The percent recoveries
for the MS/MSD samples ranged from 0 to 127 with RPDs
ranging from 4 to 21.  Of the four sample pairs, two
sample pairs met the percent recovery acceptance criterion,
one sample pair exhibited percent recoveries less than the
lower acceptance limit, and one sample  pair exhibited
percent recoveries greater than the upper acceptance limit.
For the two sample  pairs that did not meet the percent
recovery acceptance  criterion,  the  RPD acceptance
criterion for the MS/MSDs and the percent recovery and
RPD acceptance criteria for the LCS/LCSDs associated
with the analytical batches for these samples were met.
Because of the varied percent recoveries for the MS/MSD
sample pairs, it was not possible to conclude whether the
GRO analysis results for the SFT Area samples had a
negative  or positive bias.  Although one-half of  the
MS/MSD  results  did not meet the  percent  recovery
acceptance criterion, the out-of-control situations alone did
not constitute adequate grounds for rejection of any of the
GRO analysis results for the SFT Area samples.  The out-
of-control situations may have been associated with
inadequate spiking levels (0.7 to 2.8 times the unspiked
sample  concentrations  compared   to  the  minimum
recommended value  of 5 times the concentrations).

Three soil PE sample pairs were designated as MS/MSDs.
The  sample matrix for these samples consisted of silty
sand. The  percent recoveries  for these samples ranged
from 88 to 103 with RPDs ranging from 4 to 6.  The
percent recoveries and RPDs for these samples met  the
acceptance  criteria.  Based on the MS/MSD results,  the
GRO analysis results for the soil  PE  samples  were
considered to be valid.

Two liquid PE sample pairs were designated as MS/MSDs.
The percent recoveries for these samples ranged from 77
to 87 with RPDs of 1 and 5. The percent recoveries  and
RPDs for these samples met the acceptance criteria. Based
on the MS/MSD results, the GRO analysis results for the
liquid PE samples were considered to be valid.

Extract Duplicates

For GRO analysis, after soil sample extraction, extract
duplicates  were analyzed to  evaluate  the precision
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associated with  the  reference laboratory's analytical
procedure.  The reference laboratory sampled duplicate
aliquots of the GRO extracts for analysis. The acceptance
criterion for extract duplicate precision was an RPD $25.
Two or more environmental  samples collected in each
demonstration area whose samples were analyzed for GRO
(the NEX Service Station,  B-38, and SFT Areas) were
designated as extract  duplicates. A total of 10 samples
designated as extract duplicates were analyzed for GRO.
The RPDs  for these  samples ranged from 0.5 to 11.
Therefore, the RPDs for all the extract duplicates met the
acceptance  criterion.   Based on the extract duplicate
results, the GRO analysis results were considered to be
valid.

Laboratory Control Samples and Laboratory
Control Sample Duplicates

For GRO analysis, LCS/LCSD results were evaluated to
determine the  accuracy and  precision associated with
control samples prepared by the reference laboratory. To
generate a soil LCS or LCSD, Ottawa sand was spiked
with the GRO calibration standard at a spiking level of
20 mg/kg. To generate an LCS or LCSD for liquid PE
sample analysis, deionized water was spiked with the GRO
calibration standard at a spiking level of 40 ug/L. The
acceptance criteria for LCS/LCSDs were 33 to 115 percent
recovery and an RPD  <;25. The LCS/LCSD acceptance
criteria were based on the reference laboratory's historical
data.

Ten pairs of soil LCS/LCSD samples were prepared and
analyzed. The percent recoveries for these samples ranged
from 87 to 110 with RPDs ranging from 2 to 14. In
addition,  two pairs of liquid  LCS/LCSD  samples were
prepared and analyzed. The percent recoveries for these
samples ranged from 91 to 92 with RPDs equal to 0 and 1.
Therefore, the percent recoveries and RPDs for the soil and
liquid LCS/LCSD samples met the acceptance criteria,
indicating that the GRO analysis procedure was in control.
Based on the LCS/LCSD results, the GRO analysis results
were considered to be valid.

Summary of Quality Control Check Results

Table 6-1 summarizes the QC check results for GRO
analysis.  Based on the QC check results, the conclusions
presented below were drawn regarding the accuracy and
precision of GRO analysis results for the demonstration.
The project-specific percent recovery acceptance criteria
were met for most environmental samples and all PE
samples. As expected, the percent recovery ranges were
broader for the environmental samples than for the PE
samples.  As indicated by the mean and median percent
recoveries, the QC check results generally indicated a
slight negative bias  (up  to 20 percent)  in the GRO
concentration measurements; the exceptions  were the
surrogate recoveries for environmental samples and the
LCS/LCSD recoveries for soil PE samples. The observed
bias did not exceed the generally acceptable bias (plus or
minus  [±] 30 percent) stated in SW-846 for organic
analyses and is typical for most organic analytical methods
for environmental samples. Because the percent recovery
ranges were sometimes above and sometimes below 100,
the observed bias did not appear to be systematic.

The project-specific RPD acceptance criterion was met for
all samples. As expected, the RPD range and the mean and
median RPDs for MS/MSDs  associated with the soil
environmental samples were greater than those for other
QC checks and matrixes listed in Table 6-1.  The low
RPDs observed indicated good precision in  the GRO
concentration  measurements  made   during  the
demonstration.

6.1.2      EDRO Analysis

This section summarizes the resu Its for QC checks used by
the reference laboratory during EDRO analysis, including
method and instrument blanks, surrogates, MS/MSDs,
extract duplicates, and LCS/LCSDs. A summary of the
QC check results is presented at the end of the section.

Method and Instrument Blanks

Method and instrument blanks were analyzed to verify that
steps  in  the  analytical procedures did  not  introduce
contaminants that affected analytical results. Ottawa sand
was used as a method blank for soil samples. The method
blanks underwent all the procedures required for sample
preparation. For liquid PE samples, the  extraction solvent
(methylene chloride) was used as an  instrument blank.
The results for all method and instrument blanks met the
acceptance criterion of being less  than or equal to the
required project-specific  reporting limit  (10 mg/kg).
Based on the method and instrument  blank results, the
EDRO analysis results were considered to be valid.
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Table 6-1. Summary of Quality Control Check Results for GRO Analysis
QC Check8
Surrogate
MS/MSD
Extract
duplicate
LCS/LCSD
Matrix
Associated
with QC Check
Soil
environmental
samples
Soil PE
samples
Liquid PE
samples
Soil
environmental
samples
Soil PE
samples
Liquid PE
samples
Soil
environmental
samples
Soil
environmental
andPE
samples
Liquid PE
samples
No. of
Measurements
Used to
Evaluate Data
Quality
56
34
6
20 (10 pairs)
6 (3 pairs)
4 (2 pairs)
10 pairs
10 pairs
2 pairs
Accuracy (Percent Recovery)
Acceptance
Criterion
39 to 163
33 to 115
Actual
Range
43 to 345
87 to 108
81 to 84
0 to 162
88 to 103
77 to 87
No. of
Measurements
Meeting
Acceptance
Criterion
40
34
6
15
6
4
Mean
150
96
83
81
94
83
Median
136
95
84
80
92
85
Not applicable
33 to 115
87 to 110
91 to 92
20
4
100
92
100
92
Preciion (Relative Percent Difference)
Acceptance
Criterion
Actual
Range
No. of
Measurements
Meeting
Acceptance
Criterion
Mean
Median
Not applicable
s25
1 to 21
4 to 6
1 to 5
0.5 to 1 1
2 to 14
Oto1
10 pairs
3 pairs
2 pairs
10 pairs
10 pairs
2 pairs
11
5
3
5
6
0.5
12
5
3
4
6
0.5
Notes:

z         =  Less than or equal to
LCS/LCSD =  Laboratory control sample andaboratory control sample duplicate
MS/MSD  =  Matrix spike and matrix spike duplicate
PE        =  Performance evaluation
QC       =  Quality control
    During the demonstration, 12 method blanks (10 for soil samples and! for liquid samples) were analyzed. The method blank resits met the project-specifc acceptance criteria.

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Surrogates

Each soil investigative and QC sample for EDRO analysis
was spiked with a surrogate, o-terphenyl, before extraction
to determine whether significant matrix effects existed
within the sample and to estimate the efficiency of analyte
recovery during sample preparation and analysis. For a
30-gram sample, the spike concentration was 3.3 mg/kg.
For samples with higher EDRO concentrations, for which
smaller  sample amounts were  used during extraction,
the spiking  levels were proportionately higher.   The
acceptance  criterion  was 45 to  143 percent surrogate
recovery. Liquid PE samples for EDRO analysis were not
spiked with a surrogate because the analysis  did not
include a sample preparation step.

A total of 185 surrogate measurements were made during
analysis of environmental and associated QC samples. Six
of these samples did  not meet the percent  recovery
acceptance  criterion.   Four  of the  six  samples were
environmental samples.  When the reference laboratory
reanalyzed the four samples, the surrogate recoveries for
the samples met the acceptance  criterion; therefore, the
reference laboratory reported the EDRO concentrations
measured during  the reanalyses.  The  remaining two
samples for which the surrogate recoveries did  not meet
the acceptance criterion were LCS/LCSD samples; these
samples had low surrogate recoveries. According to the
reference laboratory, these low recoveries were due to the
extracts going dry  during  the  extract concentration
procedure.  Because two samples were laboratory QC
samples, the reference laboratory reanalyzed them as well
as all the  other  samples  in the QC lot;  during the
reanalyses,  all surrogate recoveries met the acceptance
criterion. The surrogate recoveries for all results reported
ranged from 45 to 143 percent with mean and median
recoveries of 77 percent, indicating an overall negative
bias.  The surrogate  recoveries  for all reported sample
results met  the  acceptance  criterion.   Based on the
surrogate results for environmental and associated QC
samples, the EDRO analysis results were considered to be
valid.

A total of 190 surrogate measurements were made during
analysis of soil PE and associated QC samples. Five of
these samples did  not  meet   the percent  recovery
acceptance  criterion.  In  each  case, the surrogate was
recovered at a concentration below the lower limit of the
acceptance criterion.  Three of the five samples were soil
PE samples,  and the remaining  two  samples  were
LCS/LCSDs.  The reference laboratory reanalyzed the
three soil PE samples and the LCS/LCSD pair as well as
all the other samples in the QC lot associated with the
LCS/LCSDs;  during  the  reanalyses,  all  surrogate
recoveries met the acceptance criterion.  The surrogate
recoveries for all results reported  ranged from 46 to
143  percent  with  mean  and  median  recoveries  of
76 percent, indicating an  overall negative  bias.   The
surrogate recoveries for all reported sample results met the
acceptance criterion. Based on the surrogate results for
soil PE and associated QC samples, the EDRO analysis
results were considered to be valid.

Matrix Spikes and Matrix Spike Duplicates

MS/MSD results were evaluated to determine the accuracy
and precision of the analytical results with respect to the
effects of the sample matrix. For EDRO analysis, each soil
sample designated as an MS or MSD was spiked with the
EDRO calibration standard at an initial spiking level of
50 mg/kg when a  30-gram sample was used during
extraction. The initial spiking levels were proportionately
higher when smaller sample amounts were used during
extraction. The acceptance criteria for MS/MSDs were 46
to 124 percent recovery and an RPD  ^45.  When the
MS/MSD percent recovery acceptance criterion was not
met, instead of attributing the failure to meet the criterion
to an inappropriate spiking level, the reference laboratory
respiked  the samples at  a target spiking level between
50 and 150 percent of the unspiked sample concentration.
Additional information on  spiking level selection  for
MS/MSDs is presented in Section 6.1.1. No MS/MSDs
were prepared for liquid PE samples for EDRO analysis
because the analysis did not include a sample  preparation
step.

For environmental samples, a total of 13 MS/MSD pairs
were analyzed.  Two sample pairs collected  in the FFA
were designated as MS/MSDs. The sample matrix hi this
area primarily consisted  of medium-grained sand.  The
percent recoveries for the MS/MSD samples ranged from
0 to 183 with RPDs of 0 and 19. One of the two sample
pairs  exhibited  percent recoveries less than the lower
acceptance limit. In the second sample pair,  one sample
exhibited  a  percent  recovery  less  than  the lower
acceptance limit, and  one sample exhibited a percent
recovery greater than the upper acceptance limit. For both
sample pairs, the RPD  acceptance criterion  for the
MS/MSDs and the percent recovery and RPD acceptance
criteria for the LCS/LCSDs asso ciated with the analytical
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batches for these samples were met. Because of the varied
percent recoveries for the MS/MSD sample pairs, it was
not possible to conclude whether the EDRO analysis
results for the  FFA samples had  a negative or positive
bias.  Although the  MS/MSD results did  not meet the
percent recovery acceptance criterion, the out-of-control
situations alone did not constitute adequate grounds for
rejection of any of the EDRO analysis results for the FFA
samples. The  out-of-control situations may have been
associated with inadequate spiking levels (0.1 to 0.5 times
the unspiked  sample  concentrations  compared to the
minimum   recommended  value  of  5  times  the
concentrations).

Four sample pairs collected in the NEX Service Station
Area were designated as MS/MSDs. The sample matrix in
this area primarily consisted of medium-grained sand. The
percent recoveries for the MS/MSD samples ranged from
81 to 109 with RPDs ranging from 4 to 20. The percent
recoveries and RPDs for these samples met the acceptance
criteria.  Based  on the MS/MSD  results, the EDRO
analysis results for the NEX Service Station Area samples
were considered to be valid.

One sample pair collected in the PRA was designated as an
MS/MSD.  The sample matrix in  this area primarily
consisted of silty sand. The percent  recoveries for the
MS/MSD samples were 20 and 80 with an RPD equal to
19. One sample exhibited a percent recovery less than the
lower acceptance limit, whereas the percent recovery for
the other sample met the acceptance criterion.  The RPD
acceptance criterion for the MS/MSD and the percent
recovery and RPD acceptance criteria for the LCS/LCSD
associated with the analytical batch for this sample pair
were  met.   Although the percent recoveries  for the
MS/MSD  sample pair may  indicate a negative  bias,
because the MS/MSD results  for only one sample pair
were available, it was not possible to conclude that the
EDRO analysis results for the PRA samples had a negative
bias.   Although one of the percent recoveries for the
MS/MSD did not meet the acceptance criterion, the out-of-
control situation alone did not constitute adequate grounds
for rejection of any of the EDRO  analysis results for the
PRA samples. The out-of-control situation may have been
associated with inadequate spiking levels (0.4 times the
unspiked sample concentration compared to the minimum
recommended value of 5 times the concentration).

Two  sample pairs  collected  in  the  B:38 Area  were
designated as MS/MSDs.  The sample matrix in this area
primarily consisted  of sand and clay.   The  percent
recoveries for the MS/MSD samples ranged from 25 to 77
with RPDs of 6 and 11. Of the two sample pairs,  one
sample pair met the percent recovery acceptance criterion,
and one sample pair exhibited percent recoveries less than
the lower acceptance limit. For the sample pair that did
not meet the percent recovery acceptance criterion, the
RPD acceptance criterion  for the MS/MSDs and the
percent recovery and  RPD  acceptance criteria  for the
LCS/LCSDs associated with the analytical batch for the
sample pair were met. Although the percent recoveries for
one MS/MSD  sample pair indicated a negative bias,
because the percent recoveries for the other sample  pair
were acceptable, it was not possible to conclude  that the
EDRO analysis results for the B-38 Area  samples had a
negative bias. Although one-half of the MS/MSD results
did not meet the percent recovery acceptance criterion, the
out-of-control situations alone did not constitute adequate
grounds for rejection of any of the EDRO analysis results
for the B-38 Area samples.  The out-of-control situations
may have been associated with inadequate spiking levels
(1.4 times the unspiked sample concentrations compared
to the  minimum recommended  value  of 5  times the
concentrations).

Four sample pairs collected  in the SFT Area were
designated as MS/MSDs. The sample matrix in this area
primarily consisted of silty clay.  The percent recoveries
for the MS/MSD samples ranged from 0 to 223 with RPDs
ranging from 8 to 50.   Of the four sample pairs, three
sample pairs had one sample each that exhibited a percent
recovery  less than the lower acceptance  limit and one
sample pair had one  sample that exhibited  a  percent
recovery greater than the upper acceptance limit. The RPD
acceptance  criterion was met for all  but  one of the
MS/MSDs. The percent recovery and RPD acceptance
criteria for the LCS/LCSDs asso ciated with the analytical
batches for these samples were met. Because of the varied
percent recoveries for the MS/MSD sample pairs, it was
not possible to conclude whether the EDRO analysis
results for the SFT Area samples had a negative or positive
bias. Although one-half of the MS/MSD  results did not
meet the percent recovery acceptance criterion and one of
the four sample pairs did not meet the RPD acceptance
criterion, the out-of-control situations  alone did not
constitute adequate grounds for  rejection of any of the
EDRO analysis results for the SFT Area samples. The out-
of-control situations  may  have  been  associated with
inadequate spiking levels (0.4 to 0.7 times the unspiked
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sample  concentrations  compared  to  the  minimum
recommended value of 5 times the concentrations).

Five soil PE sample pairs were designated as MS/MSDs.
The sample matrix for these samples primarily consisted of
silty sand.  The percent recoveries  for these  samples
ranged from 0 to 146 with RPDs ranging from 3 to 17. Of
the five sample pairs, three sample pairs met the percent
recovery acceptance criterion, one sample pair exhibited
percent recoveries less than the lower acceptance limit, and
one sample pair exhibited percent recoveries greater than
the upper acceptance limit.  For the two sample pairs that
did not meet the percent recovery acceptance criterion, the
RPD  acceptance criterion for the MS/MSDs  and the
percent recovery and RPD acceptance criteria for the
LCS/LCSDs associated with the analytical batches for
these  samples were met.  Because of the varied percent
recoveries for the MS/MSD sample pairs, it  was not
possible to conclude whether the EDRO analysis results
for the soil PE samples had a negative or positive bias.
Although the percent recoveries for two of the five sample
MS/MSD pairs did not meet the acceptance criterion, the
out-of-control situations alone did not constitute adequate
grounds for rejection of any of the EDRO analysis results
for the soil PE samples.

Extract Duplicates

For EDRO analysis, after soil sample extraction, extract
duplicates  were analyzed  to  evaluate the  precision
associated  with  the reference  laboratory's analytical
procedure.  The reference laboratory sampled duplicate
aliquots  of the  EDRO  extracts  for  analysis.   The
acceptance criterion for extract duplicate precision was an
RPD s45. One or more environmental samples collected
in each  demonstration area were designated as extract
duplicates.  A total of 13 samples designated as extract
duplicates were analyzed for EDRO. The RPDs  for these
samples ranged from 0  to 11 except for one extract
duplicate pair collected in the SFT Area that had an RPD
equal to 34. The RPDs for all the extract duplicates met
the acceptance criterion.  Based on the extract duplicate
results, all EDRO results were considered to be valid.

Laboratory Control Samples and Laboratory
Control Sample Duplicates

For EDRO analysis, LCS/LCSD results were evaluated to
determine the accuracy  and precision associated with
control samples prepared by the reference laboratory. To
generate a soil LCS or LCSD, Ottawa sand was spiked
with the EDRO calibration standard at a spiking level of
50 mg/kg. The acceptance criteria for LCS/LCSDs were
46 to 124  percent recovery and an RPD s45.   The
LCS/LCSD  acceptance  criteria  were  based on  the
reference laboratory's historical data.  No LCS/LCSDs
were prepared for liquid PE samples for EDRO analysis
because the analysis did not include a sample preparation
step.

Twenty-two pairs of LCS/LCSD samples were prepared
and analyzed.  The percent recoveries for these samples
ranged from 47 to 88 with RPDs ranging from 0 to 29.
Therefore, the percent recoveries and RPDs  for these
samples met the acceptance criteria, indicating that the
EDRO analysis procedure was in control. Based on the
LCS/LCSD results, the  EDRO  analysis  results were
considered to be valid.

Summary of Quality Control Check Results

Table 6-2 summarizes the QC check results for EDRO
analysis.  Based on the QC check results,  the conclusions
presented below were drawn regarding the accuracy and
precision of EDRO analysis results for the demonstration.

The project-specific percent recovery acceptance criteria
were met for all  surrogates  and  LCS/LCSDs.  About
one-half  of the MS/MSDs  did  not meet  the percent
recovery acceptance criterion. As expected, the MS/MSD
percent recovery range was broader for environmental
samples than  for PE samples.  The mean and median
percent recoveries for all the QC check samples indicated
a  negative bias  (up  to  33  percent)  in  the  EDRO
concentration measurements. Although the observed bias
was slightly greater than the generally  acceptable bias
(± 30 percent) stated in SW-846 for organic analyses, the
observed recoveries were not atypical for most organic
analytical methods for environmental samples. Because
the percent recovery ranges were  sometimes above and
sometimes below 100, the observed bias did not appear to
be systematic.

The project-specific RPD acceptance criterion was met for
all samples except one environmental MS/MSD sample
pair.  As expected, the RPD range and the mean  and
median RPDs for MS/MSDs associated with the  soil
environmental samples were greater than those for other
QC checks and matrixes listed in Table 6-2.  The  low
RPDs observed indicated good precision in the EDRO
                                                   57

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        Table 6-2. Summary of Quality Gbntrol Check Results for EDRO Analysis
QC Check6
Surrogate
MS/MSD
Extract
duplicate
LCS/LCSD
Matrix
Associated
with QC Check
Soil
environmental
samples
Soil PE
samples
Soil
environmental
samples
Soil PE
samples
Soil
environmental
samples
Soil
environmental
andPE
samples
No. of
Measurements
Used to
Evaluate Data
Quality
179
185
26 (13 pairs)
10 (5 pairs)
1 3 pairs
44 (22 pairs)
Accuracy (Percent Recovery)
Acceptance
Criterion
45 to 143
46 to 124
Actual
Range
45 to 143
46 to 143
0 to 223
0 to 146
No. of
Measurements
Meeting
Acceptance
Criterion
179
185
14
6
Mean
77
76
67
75
Median
77
76
79
78
Not applicable
46 to 124
47 to 88
44
77
80
Precsion (Relative Percent Difference)
Acceptance
Criterion
Actual
Range
No. of
Measurements
Meeting
Acceptance
Criterion
Mean
Median
Not applicable
5:45
OtoSO
3 to 17
Oto34
Oto29
12 pairs
5 pairs
13 pairs
22 pairs
17
7
6
6
16
4
2
5
Ul
oo
        Notes:

        £         =  Less than or equal to
        LCS/LCSD =  Laboratory control sample andaboratory control sample duplicate
        MS/MSD   =  Matrix spike and matrix spike duplicate
        PE        =  Performance evaluation
        QC       =  Quality control
            During the demonstration, 22 method blanks for soil samples and 2 iatrument blanks for liquid samples were analyzed. The blah results met the project-specific acceptance criteria.

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concentration   measurements   made  during   the
demonstration.

6.2    Selected Performance Evaluation Sample
       Results

Soil  and liquid PE samples were analyzed during the
demonstration to  document the reference  method's
performance  in analyzing  samples  prepared under
controlled conditions. The PE sample results coupled with
the QC check results were used to establish the reference
method's performance  in such  a  way  that the overall
assessment of  the reference  method  would  support
interpretation  of  the  EnSys  Petro  Test  System's
performance,  which is discussed in Chapter 7.  Soil PE
samples were prepared  by adding weathered gasoline or
diesel to Ottawa sand or processed garden soil. For each
sample, an amount of weathered gasoline or diesel was
added to the sample matrix in order to prepare a PE sample
with a low (less than 100 mg/kg), medium (100  to
1,000 mg/kg), or high (> 1,000 mg/kg) TPH concentration.
Liquid PE samples consisted of neat materials. Triplicate
samples of each type of PE sample were analyzed by the
reference laboratory except  for the  low-concentration-
range PE samples, for which seven replicate samples were
analyzed.

As described in Section 4.2, some  PE  samples  also
contained interferents.  Section 6.2 does not discuss the
reference  method  results  for PE samples containing
interferents  because the  results address  a  specific
demonstration objective.  To facilitate comparisons, the
reference   method  results   that   directly  address
demonstration objectives  are discussed along with the
EnSys Petro Test System results in Chapter 7. Section 6.2
presents a comparison  of the reference method's mean
TPH results for selected PE samples to the certified values
and performance acceptance limits provided by ERA, a
commercial PE sample provider that prepared the PE
samples for the demonstration.  Although the reference
laboratory reported sample results for GRO and EDRO
analyses separately, because ERA provided certified values
and performance acceptance limits, the reference method's
mean TPH results (GRO plus EDRO analysis results) were
used for comparison.

For  soil samples  containing weathered  gasoline, the
certified  values  used for comparison to  the reference
method results  were based  on mean TPH results for
triplicate samples  analyzed  by ERA using  a  GC/FED
method. ERA extracted the PE samples on the day that PE
samples  were shipped  to  the  Navy  BVC  site  for
distribution to the reference laboratory and developers.
The reference laboratory completed methanol extraction of
the demonstration samples within 2 days of receiving
them. Between 5 and 7 days elapsed between the time that
ERA and the time that the reference laboratory completed
methanol extractions of the demonstration samples. The
difference in extraction times is not believed to have had
a significant effect on the reference method's TPH results
because the samples for GRO analysis were containerized
in EPA-approved EnCores and were stored at 4 ± 2 °C to
minimize volatilization. After methanol extraction of the
PE samples,  both ERA and the reference laboratory
analyzed the sample  extracts within the appropriate
holding times for the extracts.

For soil samples containing diesel, the certified values
were established  by calculating the TPH concentrations
based  on the amounts  of  diesel  spiked  into known
quantities of soil; these samples  were not analyzed by
ERA.  Similarly, the densities of the neat materials were
used as the certified values for the liquid PE samples.

The performance acceptance limits  for soil PE samples
were based on ERA's historical data on percent recoveries
and RSDs from multiple laboratories that had analyzed
similarly prepared ERA PE samples using a GC method.
The performance acceptance limits were determined at the
95 percent confidence level using  Equation 6-1.

Performance Acceptance Limits =  Certified Value
x (Average Percent Recovery +. 2(Average RSD))  (6-1)

According to SW-846, the 95 percent confidence  limits
should be treated as warning limits, whereas the 99 percent
confidence limits should be treated as control limits. The
99 percent confidence limits are calculated by using three
times the average RSD in Equation 6-1 instead of two
times the average RSD.

When establishing the performance acceptance limits,
ERA did not account for variables among  the multiple
laboratories, such as different extraction and analytical
methods, calibration  procedures,  and  chromatogram
integration  ranges (beginning and end points).   For this
reason, the performance acceptance limits should be used
with caution.
                                                    59

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Performance acceptance limits for liquid PE samples were
not available because  ERA  did not  have historical
information on percent recoveries and RSDs for the neat
materials used in the demonstration.

Table 6-3 presents the PE sample types, TPH concentration
ranges, performance acceptance limits, certified values,
reference method mean TPH concentrations, and ratios of
reference method mean TPH concentrations  to certified
values.

In addition to the samples listed in Table 6-3, three blank
soil PE samples (processed garden soil) were analyzed to
determine whether the soil PE sample matrix contained a
significant TPH concentration. Reference method GRO
results for all triplicate samples were below the reporting
limit of 0.54 mg/kg.  Reference method EDRO  results
were calculated by adding  the results for DRO and oil
range organics (ORO) analyses. For one of the triplicate
samples, both the DRO and ORO results were below the
reporting limits of 4.61 and 5.10 mg/kg, respectively. For
the remaining two triplicates, the DRO and ORO results
were 1.5 times greater than the reporting limits. Based on
the TPH  concentrations  in  the medium-  and  high-
concentration-range soil PE samples listed in Table 6-3,
the contribution of the processed garden soil to the TPH
concentrations was insignificant and ranged between 0.5
and 5 percent.

The reference method's mean  TPH results for the soil PE
samples listed in Table 6-3 were within the performance
acceptance limits except for the low-concentration-range
diesel samples. For the low-range diesel samples, (1) the
individual TPH concentrations for all seven replicates were
less than  the lower  performance acceptance limit  and
(2) the upper 95 percent confidence limit for TPH results
was also less than the lower performance acceptance limit.
However,  the reference method mean and individual TPH
results for the  low-range diesel  samples were within
the 99 percent confidence interval of 10.8 to 54.6 mg/kg,
indicating that the reference method results met the control
limits but not the warning limits.  Collectively,  these
observations   indicated  a   negative  bias   in  TPH
measurements for low-range diesel samples.
Table 6-3. Comparison of Soil and Liquid Performance Evaluation Sample Results
Sample Type8
TPH
Concentration
Range
Performance
Acceptance Limits
(mg/kg)
Certified Value
Reference Method Reference Method Mean
Mean TPH TPH Concentration/
Concentration Certified Value (percent)
Soil Sample (Ottawa Sand)
Diesel
Low
18.1 to 47.4
37.3 mg/kg
1 5.4 mg/kg
41
Soil Samples (Processed Garden Soil)
Weathered gasoline

Weathered gasoline at
16 percent moisture
Diesel

Diesel at less than 1 percent
moisture
Liquid Samples
Weathered gasoline
Diesel
Medium
High
High

Medium
High
High


High
High
389 to 1,548
1,110 to 4,430
992 to 3,950

220 to 577
1,900 to 4,980
2, 100 to 5,490


Not available
Not available
1 ,090 mg/kg
3,120 mg/kg
2,780 mg/kg

454 mg/kg
3,920 mg/kg
4,320 mg/kg


814,100 mg/L
851,900mg/L
705 mg/kg
2,030 mg/kg
1 ,920 mg/kg

252 mg/kg
2,720 mg/kg
2,910 mg/kg

* ;. "•>% -
648,000 mg/L
1,090,000 mg/L
65
65
69

56
69
67


80
128
Notes:

mg/kg = Milligram per kilogram
mg/L  = Milligram per liter

°   Soil samples were prepared at 9 percent moisture unless stated otherwise.
                                                     60

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As noted above, Table 6-3 presents ratios of the reference
method mean TPH concentrations to the certified values
for  PE samples.   The  ratios for  weathered gasoline-
containing soil samples ranged from 65 to 69 percent and
did not appear to depend on whether the samples were
medium- or high-range samples.  The ratio for neat,
weathered gasoline (liquid sample) was 80 percent, which
was 11 to 15 percentage points greater than the ratios for
the soil samples.   The difference in the ratios may be
attributed to  (1) potential loss of volatiles during soil
sample transport  and storage and  during soil sample
handling when extractions were performed and (2) lower
analyte recovery during soil  sample extraction.  The less
than 100  percent ratios observed indicated a negative bias
in  TPH   measurement  for  soil  and liquid  samples
containing weathered gasoline. The observed bias for the
liquid samples did not exceed the generally acceptable bias
(±30 percent) stated in SW-846 for most organic analyses.
However, the bias for soil samples exceeded the acceptable
bias by up to 5 percentage points.

The ratios for diesel-containing soil samples ranged from
41 to 69 percent and increased with increases in the TPH
concentration range.  The ratio for neat diesel  (liquid
sample) was 128 percent, which was substantially greater
than the ratios for soil samples. Collectively, the negative
bias observed for soil  samples and  the  positive  bias
observed  for liquid samples indicated a low analyte
recovery during soil sample extraction because the soil and
liquid samples were analyzed using the same calibration
procedures but only the soil  samples required extraction
before analysis. The extraction procedure used during the
demonstration is an EPA-approved method that is widely
used  by  commercial  laboratories in the United  States.
Details on the extraction procedure are  presented  in
Table 5-3 of this ITVR.

The positive bias  observed  for  liquid samples did not
exceed the generally acceptable  bias stated in  SW-846.
The negative bias observed for high-concentration-range
soil samples exceeded the acceptable bias by an average of
2 percentage points. However, the negative bias observed
for low- and  medium-range  samples  exceeded  the
acceptable bias  by  29  and  14  percentage  points,
respectively, indicating a negative bias.

Because the reference method results exhibited a negative
bias for soil PE samples when compared to ERA-certified
values, ERA's historical data on percent recoveries and
RSDs  from  multiple  laboratories  were  examined.
Table 6-4 compares ERA's historical percent recoveries
and RSDs to the reference method percent recoveries and
RSDs obtained during the demons tration. Table 6-4 shows
that ERA's historical recoveries also exhibited a negative
bias  for all sample  types except weathered gasoline in
water and that the reference method recoveries were less
than ERA's historical recoveries for all sample types
except diesel in water. The ratios of reference method
mean recoveries to  ERA historical mean recoveries for
weathered gasoline-containing samples indicated that the
reference method TPH results were 26 percent less than
ERA's historical recoveries.   The reference  method
recoveries for diesel-containing (1)  soil samples  were
34 percent less than the ERA historical recoveries and
(2) water samples were 63 percent greater than the ERA
historical  recoveries.   In  all cases, the RSDs for the
reference  method were significantly lower than  ERA's
historical  RSDs, indicating that the  reference method
achieved  significantly greater precision.  The  greater
precision observed for the reference method during the
demonstration may  be associated with the fact that the
reference method was implemented by a single laboratory,
whereas ERA's historical RSDs were based on results
obtained from multiple laboratories that may have used
different analytical protocols.

In summary, compared to ERA-certified values, the TPH
results for all PE sample types except neat diesel exhibited
a negative bias to a varying degree; the TPH results for
neat diesel exhibited a positive  bias of 28 percent. For
weathered gasoline-containing soil samples, the bias was
relatively independent of the TPH concentration range and
exceeded the generally acceptable bias stated in SW-846
by up to 5 percentage points. For neat gasoline samples,
the bias did not exceed the acceptable bias. For diesel-
containing soil samples, the bias  increased with decreases
in the TPH concentration range, and the bias for low-,
medium-,   and  high-range  samples  exceeded  the
acceptable bias  by 29,  14, and 2  percentage  points,
respectively.   For  neat  diesel  samples, the observed
positive bias did not exceed the acceptable bias. The low
RSDs  (5  to 9  percent) associated with the  reference
method indicated good precision in analyzing both soil and
liquid samples.  Collectively, these observations suggest
that  caution should  be exercised during  comparisons of
EnSys Petro Test System and reference method results for
low- and medium-range soil samples containing diesel.
                                                     61

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Table 6-4. Comparison of Environmental Resource Associates Historical Results to Reference Method Results
ERA Historical Results
Sample Type
Weathered gasoline in soil
Diesel in soil
Weathered gasoline in water
Diesel in water
Mean
Recovery
(percent)
88.7
87.7
109
78.5
Mean Relative
Standard Deviation
(percent)
26.5
19.6
22.0
22.8
Mean
Recovery8
(percent)
66
58
80
128
Reference Method Results
Reference Method Mean
Recovery/ERA Historical
Mean Recovery (percent)
75
66
73
163
Mean Relative
Standard Deviation0
(percent)
7
9
5
6
Notes:

ERA  = Environmental Resource Associates

°    The reference method mean recovery and mean relative standard deviation were based on recoveries and relative standard deviations observed
    for all concentration ranges for a given type of performance evaluation sample.
6.3     Data Quality

Based on the reference method's performance in analyzing
the QC check samples and selected PE  samples, the
reference  method  results were considered  to  be  of
adequate  quality for  the  following  reasons:  (1)   the
reference  method  was  implemented with acceptable
accuracy (± 30 percent) for all samples except low- and
medium-concentration-range   soil  samples  containing
diesel, which made up only 13 percent of the total number
of samples analyzed during the demonstration, and (2) the
reference method was  implemented with good precision
for all samples (the overall RPD range was 0 to 17). The
reference method results generally exhibited a negative
bias. However, the bias was considered to be significant
primarily  for low-  and  medium-range  soil  samples
containing diesel because the bias exceeded the generally
acceptable  bias  of ± 30 percent stated in  SW-846 by
29 percentage points for low-range and  14 percentage
points for medium-range samples. The reference method
recoveries  observed  were  typical  of the recoveries
obtained  by  most  organic  analytical  methods  for
environmental samples.
                                                      62

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                                              Chapter 7
                          Performance of the EnSys Petro Test System
To  verify a wide range of performance attributes,  the
demonstration had both primary and secondary objectives.
Primary  objectives were critical  to the  technology
evaluation  and were intended to produce quantitative
results regarding a technology's performance. Secondary
objectives provided information that was useful but did not
necessarily  produce quantitative results  regarding a
technology's performance.  This chapter discusses  the
performance of the EnSys Petro Test System based on the
primary objectives (excluding costs associated with TPH
measurement) and secondary objectives. Costs associated
with  TPH measurement (primary  objective  P6)  are
presented in Chapter 8. The demonstration results for both
the  primary and secondary objectives are summarized in
Chapter 9.

7.1      Primary Objectives

This section  discusses  the performance  results for  the
EnSys Petro Test System based on primary objectives PI
through P5, which are listed below.

PI.  Determine the MDL

P2.  Evaluate   the  accuracy  and  precision  of TPH
    measurement  for  a variety  of contaminated soil
    samples

P3.  Evaluate   the   effect  of  interferents  on  TPH
    measurement

P4.  Evaluate the effect  of soil moisture content on TPH
    measurement

P5.  Measure the time required for TPH measurement

To  address primary objectives PI through P5, samples
were  collected from four different sampling areas.   In
addition, soil and liquid PE samples were prepared  and
distributed to SDI and the reference laboratory.  The
numbers and types of environmental samples collected in
each sampling area and the numbers and types of PE
samples prepared are discussed in Chapter 4.

Primary objectives PI through P4 were addressed using
statistical and nonstatistical approaches, as appropriate.
Because the EnSys Petro Test System is a semiquantitative
device, the TPH concentration in a sample cannot be
reported  as  an  absolute  value;  therefore,  statistical
approaches could not be used to address  the  primary
objectives for the EnSys Petro Test System. The statistical
tests performed to address primary objectives for the
reference method are illustrated in the flow diagram in
Figure 7-1. Before a parametric test was performed, the
Wilk-Shapiro test was  used to determine whether the
reference method results were normally distributed at a
significance  level of 5 percent.  If the results were not
normally distributed, the Wilk-Shapiro test was performed
on transformed results (for example, logarithm and square
root transformations) to verify the normality assumption.
If the normality assumption was not met, a nonparametric
test was  performed.   Nonparametric tests are  not  as
powerful  as  parametric tests because the  nonparametric
tests do not account for the magnitude of the difference
between sample results. Despite this limitation, when the
normality  assumption  was not  met,  performing  a
nonparametric test was considered to be a better alternative
than performing no statistical comparison.

For the reference method, when the analyte concentration
in a given sample was reported as  below the reporting
limit,  one-half the reporting limit was used as the analyte
concentration forthat sample, as is commonly done, so that
necessary  calculations could  be  performed  without
rejecting the data. The appropriate reporting limits were
used in calculating the TPH concentration depending on
which TPH measurement components (GRO, DRO, and
ORO) were reported at concentrations below the reporting
                                                    63

-------
                                                                     TPH results
       Method detection limit
       (primary objective P1)
             Were
           TPH results
       normally distributed?
          (Wik-Shapiro
     Precision
(primary objective P2)
     Determined method
     detection limit using
  approach recommended in
     40 Code of Federal
    Regulations Part 136,
  Appendix B, Revision 1,1.1
    Was unable to determine
      method detection limit
 Calculated relative
 percent difference
for extract duplicate
    TPH results
rgzss'jr;    ~
                                        Effect of interferents
                                       {primary objective P3)
                                                 Were
                                              TPH results
                                         for three sample groups
                                           normally distributed?
                                              (Wilk-Shap
                                                 test)
                                              Were
                                          group variances
                                              equal?
                                           (Bartletfs test)
                                                                    Performed one-way
                                                                    analysis of variance
                                                                  (parametric) and Tukey
                                                                    (honest, significant
                                                                 difference) comparison of
                                                                   means (parametric) to
                                                                determine whether presence
                                                                 of interferents resulted in
                                                                  increase or  decrease in
                                                                       TPH results
                                            Performed Kruskal-Wallis
                                               one-way analysis of
                                            variance (nonparametric)
                                               and Kruskal-Wallis
                                              comparison of means
                                               (nonparametric) to
                                               determine whether
                                             presence of interferents
                                              resulted in increase or
                                             decrease in TPH results
Effect of soil moisture content
   (primary objective P4)
        TPH results
   for both sample groups
    normally distributed?
       (Wilk-Shapiro^ :t
           test)
                                                                                      *'"?j
                                                                                 ^f./.'^iijiMi
                                                                                 Performed two-sample
                                                                                    Student's West
                                                                                (parametric) to determine
                                                                                  whether increase in
                                                                                moisture content resulted
                                                                               in increase or decrease in
                                                                                      TPH results
                        'No
                                                                                  Performed Kruskal-Wallis
                                                                                    one-way analysis of
                                                                                  variance (nonparametric)
                                                                                     and Kruskal-Wallis
                                                                                    comparison of means
                                                                                     (nonparametric) to
                                                                                     determine whether
                                                                                    increase in moisture
                                                                                     content resulted in
                                                                                   increase or decrease in
                                                                                        TPH results
Figure 7-1. Summary of statistical analysis of TPH results.

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limits.   Caution  was  exercised  to  ensure  that these
necessary data manipulations did not alter the conclusions.

The  reference method GRO  results  were adjusted for
solvent dilution associated with the soil sample moisture
content because the method required  use of methanol, a
water-miscible solvent, for extraction of soil samples. In
addition,  based  on  discussions  with  the  reference
laboratory, all TPH results for the reference method were
rounded   to  three  significant   figures.     No  data
manipulations were required to evaluate EnSys Petro Test
System  performance.    The  developer's  perspective
regarding  this ITVR's evaluation of EnSys  Petro Test
System TPH results reported as >1,000 mg/kg is provided
in the appendix.

7.1.1  Primary Objective PI: Method Detection
       Limit

To  address  primary objective  PI, both SDI and the
reference  laboratory analyzed seven  low-concentration-
range weathered gasoline soil PE samples and seven low-
concentration-range diesel soil PE samples. As discussed
in Chapter 4, problems arose during preparation of the
low-range weathered  gasoline  samples;  therefore, the
results for the  soil PE samples  containing weathered
gasoline could not be used to determine MDLs.

Because the EnSys Petro Test System is a semiquantitative
device, the TPH  concentration in a sample cannot be
reported as an absolute value. Therefore, the device results
for the low-range soil PE diesel samples could not be used
to statistically determine the MDL.  Instead, the EnSys
Petro Test System MDL  was verified by  evaluating
whether the TPH concentration ranges measured using the
device overlapped the TPH concentrations measured using
the reference method.

Because  the  reference  method results were normally
distributed, the MDLs for the soil PE samples containing
diesel were  calculated using Equation  7-1  (40 CFR
Part 136,  Appendix B, Revision 1.1.1).  An  MDL thus
calculated is influenced by TPH concentrations because the
standard deviation will likely decrease with a decrease in
TPH concentrations.  As a result, the MDL will be lower
when low-concentration samples  are  used  for MDL
determination.  Despite this limitation, Equation 7-1  is
commonly used and provides a reasonable estimate of the
MDL.
                                               (7-1)
where
    S  =   Standard deviation of replicate TPH results
     (n-l,l-a=0.99)  _
                  Student's t-value appropriate  for a
                  99  percent confidence level and a
                  standard deviation estimate with n-1
                  degrees of freedom  (3.143 for n = 7
                  replicates)
Because GRO compounds were not expected to be present
in the soil PE samples containing diesel, the reference
laboratory performed only  EDRO analysis of  these
samples and reported the sums of the DRO and  ORO
concentrations as the TPH results.  The EnSys Petro Test
System and reference method results for these samples are
presented in Table 7-1.
Table 7-1. TPH Results for Low-Concentration-Range Diesel Soil
        Performance Evaluation Samples
EnSys Petro Test
System Result (mg/kg)
>15to<100
>15to<100
>15to<100
>15to<100
>100to<1,000
>15to<100
>15to<100
MDL Not calculated
Reference
Method Result
(mg/kg)
12.0
16.5
13.7
16.4
17.4
17.2
14.8
6.32
Did the EnSys Petro
Test System Result
Overlap the
Reference Method
Result?
No
Yes
No
Yes
No
Yes
No

Notes:
>  = Greater than
<  = Less than
MDL   =  Method detection limit
mg/kg  =  Milligram per kilogram
Based on the TPH results for the low-concentration-range
diesel soil PE samples, the MDL was determined to be
6.32 mg/kg for the reference method.  Because the ORO
concentrations  in  all these samples were  below  the
reference  laboratory's   estimated   reporting  limit
(5.1 mg/kg), the MDL for the reference method was also
calculated using only DRO results.  The MDL for  the
reference  method  based on  the DRO  results  was
6.29 mg/kg, whereas the MDL for the reference  method
based on the EDRO results was 6.32 mg/kg, indicating that
                                                    65

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the ORO concentrations below the reporting limit did not
impact the MDL for the reference method. The MDL of
6.32 mg/kg for the reference method compares well with
the MDL  of 4.72  mg/kg  published  in  SW-846
Method 8015C for diesel  samples extracted  using  a
pressurized fluid extraction method and analyzed for DRO.

Table 7-1  shows that the TPH results for the reference
method were near the detection limit for diesel (15 mg/kg)
claimed by SDI  for  the EnSys  Petro Test  System.
Specifically, three reference method results were below
and four were above 15  mg/kg; all seven results were
within 20  percent of the detection limit.  Because the
reference method exhibited a significant negative bias
(59 percent) for the low-concentration-range diesel soil PE
samples (see Table 6-3), all the reference method results
for these  samples could be  considered to be in  the
concentration range of >15 to <100 mg/kg, the reported
concentration range for six of the seven EnSys Petro Test
System results.  Thus, the device's TPH results for six of
the samples could be considered to compare well with the
reference method TPH results; the device result of > 100 to
< 1,000 mg/kg for one sample cannot be explained. In
summary,  the device was considered to have accurately
measured  the TPH concentrations in six of seven low-
range diesel soil PE samples.

7.7.2  Primary Objective P2: Accuracy and
       Precision

This section discusses the ability of the EnSys Petro Test
System to  accurately  and  precisely   measure  TPH
concentrations in a  variety of contaminated soils.  The
EnSys Petro Test System TPH results were compared to
the reference method TPH results. Accuracy and precision
are discussed in Sections 7.1.2.1 and 7.1.2.2, respectively.

7.1.2.1     Accuracy

The accuracy of EnSys Petro Test System measurement of
TPH was assessed by determining

•   Whether  the  EnSys  Petro  Test  System  TPH
    concentration ranges overlapped the reference method
    results

•   Whether the conclusion reached using the EnSys Petro
    Test System  agreed with that  reached using  the
reference   method  regarding  whether  the  TPH
concentration in a  given  sampling area or soil  type
exceeded a specified action level

During examination of these two factors, the data quality
of the reference method and EnSys Petro Test System TPH
results was considered.  For example, as discussed in
Chapter 6, the reference method generally exhibited a low
bias. However,  the bias observed for all samples except
low- and medium-concentration-range diesel soil samples
did not exceed the generally acceptable bias of ±30 percent
stated in SW-846 for organic analyses. Therefore, caution
was exercised during comparison of the EnSys Petro Test
System and reference method results, particularly those for
low- and medium-range diesel soil samples.

The following sections discuss how the EnSys Petro Test
System results  compared  with the reference  method
results by  addressing each of the two factors identified
above.

Pairwise Comparison of TPH Results

To evaluate whether the EnSys Petro Test System and
reference method TPH results were the same or different,
the device's TPH concentration ranges were compared to
the reference method TPH results.  Tables 7-2  and 7-3
present comparisons of the device and reference method
TPH  results for  environmental  and  PE  samples,
respectively.  The tables present the TPH results for each
sampling area or PE sample type.

Table 7-2  shows that the EnSys Petro  Test System TPH
concentration ranges overlapped the  reference method
results for only 8 of 50 (16 percent)  environmental
samples. No conclusions could be drawn for 16 samples
for which the reference method TPH results were greater
than  the   highest   detection  level  used   by  SDI
(1,000 mg/kg).  The best agreement between the EnSys
Petro Test System and  reference method results was
observed for B-38 Area samples (25 percent), followed by
samples from the SFT Area (21 percent), NEX Service
Station Area (8  percent), and FFA (0 percent).   Lack of
agreement  between  an  EnSys  Petro  Test  System
concentration range and a reference method result did not
appear to  be a function of the type  of contamination
(gasoline or diesel), sample TPH concentration range (low,
medium, or high), or type of soil (sand, silt, or clay).
                                                    66

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Table 7-2. Comparison of EnSys Petro Test System and Reference Method TPH Results for Environmental Samples
Sampling Area
Fuel Farm Area
Naval Exchange Service Station
Area
B-38 Area
Slop Fill Tank Area
TPH Result (mg/kg)
EnSys Petro Test
System
<15
>1,000
<15
>1,000
<15
> 1,000
>15to<100
> 1,000
<15
> 1,000
>100to<1,000
>1,000
>1,000
>100to<1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
> 1,000
> 1,000
> 1,000
> 1,000
>1,000
>1,000
>1,000
> 1,000
>100to<1,000
>100to<1,000
>15to<100
>100to<1,000
>100to<1,000
>100to<1,000
>100to<1,000
>100to<1,000
>100to<1,000
>100to<1,000
>1,000
>1,000
> 1,000
<15
>1,000
>15to<100
Reference
Method
68.2
15,000
90.2
12,000
44.1
13,900
1,330
8,090
93.7
12,300
28.8
144
617
293
280
1,870
1,560
9.56
270
881
1,120
14.2
219
1,180
1,390
15.2
54.5
2,570
3,030
15.9
79.0
41.5
61.4
67.3
193
69.4
43.8
51.6
105
269
397
339
6.16
37.1
43.9
Analysis Summary
Did the EnSys Petro Test System
TPH Concentration Range Overlap
the Reference Method TPH Result?"
No
Inconclusive
No
Inconclusive
No
Inconclusive
No
Inconclusive
No
Inconclusive
No
No
No
Yes
No
Inconclusive
Inconclusive
No
No
No
Inconclusive
No
No
Inconclusive
Inconclusive
No
No
Inconclusive
Inconclusive
No
No
Yes
No
No
Yes
No
No
No
Yes
No
No
No
Yes
No
Yes
EnSys Petro Test System Bias
(minimum percent bias)
Low (78)

Low (83)

Low (66)

Low (92)

Low (84)

High (250)
High (590)
High (62)

High (260)

High (10,000)
High (270)
High (14)

High (6,900)
High (360)

High (6,500)
High (1,700)

High (530)
High (27)

High (63)
High (49)

High (44)
High (130)
High (94)

High (270)
High (150)
High (200)

High (2,600)

                                                         67

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Table 7-2.  Comparison of EnSys Petro Test System and Reference Method TPH Results for Environmental Samples (Continued)
Sampling Area
Slop Fill Tank Area (continued)
TPH Result (mg/kg)
EnSys Petro Test
System
>15to<100
>1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>100to<1,000
>100to<1,000
Reference
Method
52.4
3,300
1,270
588
554
834
501
280
185
1,090
544
503
146
938
517
369
253
151
3,960
1,210
121
Analysis Summary
Did the EnSys Petro Test System
TPH Concentration Range Overlap
the Reference Method TPH Result?8
Yes
Inconclusive
Inconclusive
No
No
No
No
No
No
Inconclusive
No
No
No
No
No
No
No
No
Inconclusive
No
Yes
EnSys Petro Test System Bias
(minimum percent bias)

High (70)
High (81)
High (20)
High (100)
High (260)
High (440)

High (84)
High (99)
High (580)
High (7)
High (93)
High (170)
High (300)
High (560)

Low (17)

Notes:

>      =  Greater than
<      =  Less than
mg/kg =  Milligram per kilogram

°    No conclusion could be drawn for 16 samples for which the reference method TPH results were greater than the highest detection level used by
     SDI during the demonstration (1,000 mg/kg).  In these cases, SDI's results did not have the upper limits that defined concentration ranges.
                                                              68

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Table 7-3. Comparison of EnSys Petro Test System and Reference Method TPH Results for Performance Evaluation Samples
Sample Type
TPH Result
EnSys Petro
Test System
Reference
Method
Analysis Summary
Did the EnSys Petro Test System
TPH Concentration Range Overlap
the Reference Method TPH Result?8
Soil Samples (Processed Garden Soil) (TPH Results in Milligram per Kilogram)
Blank (9 percent moisture content)
Weathered
gasoline
Diesel
Medium-concentration range
(9 percent moisture content)
High-concentration range
(9 percent moisture content)
High-concentration range
(16 percent moisture
content)
Low-concentration range
(9 percent moisture content)
Medium-concentration range
(9 percent moisture content)
High-concentration range
(9 percent moisture content)
High-concentration range
(less than 1 percent
moisture content)
<10
<10
<10
> 1,000
> 1,000
> 1,000
> 1,000
> 1,000
> 1,000
> 1,000
>1,000
>1,000
>15to<100
>15to<100
>15to<100
>15to<100
>100to<1,000
>15to<100
>15to<100
>1,000
> 1,000
>100to<1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
5.12
13.1
13.5
702
743
671
1,880
2,020
2,180
1,740
1,980
2,050
12.0
16.5
13.7
16.4
17.4
17.2
14.8
226
265
267
2,480
2,890
2,800
2,700
2,950
3,070
Yes
No
No
No
No
No
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
No
Yes
No
Yes
No
Yes
No
No
No
Yes
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
EnSys Petro Test System Bias
(minimum percent bias)

Low (24)
Low (26)
High (42)
High (35)
High (49)

High (25)

High (9)

High (470)

High(1)
High (340)
High (280)

Liquid Samples (Neat Materials) (TPH Results in Milligram per Liter)
Weathered gasoline
Diesel
>200,500
>200,500
>200,500
>200,500
>200,500
>200,500
656,000
611,000
677,000
1,090,000
1,020,000
1,160,000
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive

Notes:

>    =   Greater than
<    =   Less than

"    No conclusions could be drawn for 18 soil and liquid samples for which the reference method TPH results were greater than the highest detection
     levels used by SDI during the demonstration (1,000 milligrams per kilogram for soil samples and 200,500 milligrams per liter for liquid samples).
     In these cases, SDI's results did not have the upper limits that defined concentration ranges.
                                                               69

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When the EnSys Petro Test System concentration range
and reference method result did not agree, the device result
was biased high relative to the reference method result
except for all the FFA samples and one SFT Area sample.
As shown in Table 7-2, the minimum bias ranged from 14
to 10,000 percent for NEX Service Station Area samples;
27 to 130 percent for the B-38 Area samples; and 7 to
2,600 percent for the SFT Area samples.  The minimum
median bias was 440, 56, and 150 percent for the NEX
Service Station, B-38, and SFT Area samples, respectively.
As a result, the high bias observed for the EnSys Petro Test
System  results for  environmental  samples cannot be
explained based solely on the negative bias associated with
reference method TPH measurements for GRO-containing
samples (up to 20 percent) and EDRO-containing samples
(up to 33 percent) discussed in Chapter 6.  The EnSys
Petro Test System results for the FFA samples were biased
low relative to the reference method results; the minimum
bias  ranged from 66 to 92 percent with a median of
83 percent.  The low bias observed for FFA samples is
inconsistent with the  negative bias associated  with
reference   method  TPH  measurements  for  EDRO-
containing samples and cannot be explained.

Table 7-3 shows that the EnSys Petro Test System TPH
concentration ranges overlapped the reference method
results for only 5 of  16 (31 percent) soil PE samples. No
conclusions could be drawn for 12 soil PE samples for
which the reference method TPH results were greater than
the highest detection level used by SDI for soil samples
(1,000 mg/kg). Similarly, no conclusions could be drawn
for the six liquid PE samples because the reference method
TPH results were greater than the highest detection level
used by SDI for liquid samples (200,500 mg/L). When the
EnSys Petro Test System and reference method results did
not agree, the device results  were biased (1) low for blank
soil samples and (2) high for medium-concentration-range
weathered gasoline  soil samples and low- and medium-
range diesel soil samples.

The minimum low biases for blank soil samples were 24
and 26 percent with a median of 25 percent.  The bias
observed for the blank samples may be explained by SDFs
selection of gasoline as the fuel product equivalent (see
Chapter 2). Had SDI used diesel as the fuel product
equivalent, the device results  for these  blank samples
would have been reported as <15 mg/kg, which would
have agreed with the reference method results.

The  minimum high  bias for the medium-concentration-
range weathered gasoline soil samples ranged from 35 to
49 percent with a median of 42 percent.  A significant
portion of the bias may be explained by the negative bias
associated with the reference method results for medium-
range weathered  gasoline  soil samples  (35 percent)
discussed in Section 6.2. The minimum high bias for the
low-range diesel soil samples ranged from 1  to 470 percent
with a median of 17 percent. The bias may be explained
by  the  significant negative bias  associated  with  the
reference method results for the low-range diesel  soil
samples (59 percent) discussed in  Section 6.2.  The
minimum  high biases for medium-range diesel soil
samples were 280 and 340 percent with a median of
310 percent, which cannot be explained.

Action Level Conclusions

Table 7-4 compares action level conclusions reached using
the EnSys Petro Test System and reference method results
for environmental and soil PE samples. Section 4.2 of this
ITVR explains how the action levels were selected for the
demonstration. No conclusions could be drawn for 17 of
100 samples. Of the samples for which conclusions could
be  drawn, the  percentage  of samples for which  the
conclusions agreed ranged from 25 to 90 for environmental
samples and from 33 to 100 for PE samples. Overall, the
conclusions were the  same for 67 percent of the samples.
The lack  of agreement observed for B-38  Area  soil
samples (25 percent)  and for the blank soil PE samples
(33 percent) was not surprising because the sample TPH
concentrations were mostly near (within 30 percent) the
action levels and because the EnSys Petro Test  System
detection levels were  the same as the action levels for the
two sets of samples, making it difficult to accurately assess
whether a sample concentration was above or below the
action level.

When the action level conclusions did not agree, the TPH
results  were further  interpreted to assess whether the
EnSys Petro Test System conclusion was conservative.
The EnSys Petro Test System conclusion was considered
to be conservative when the device's result was above the
action level and the reference method result was below the
action level. A regulatory agency would  likely  favor a
field measurement device whose results are conservative;
however, the party responsible for a site cleanup might not
favor a device that is  overly conservative because of the
cost associated with unnecessary cleanup.

EnSys Petro Test System conclusions that did not agree
with reference method conclusions were conservative for
NEX Service Station, B-38, and SFT Area samples and for
                                                    70

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Table 7-4. Action Level Conclusions
Sampling Area or Sample Type
Fuel Farm Area
Naval Exchange Service Station Area
B-38 Area
Slop Fill Tank Area
PE sample
PE sample
Soil PE
sample
containing
weathered
gasoline in
Soil PE
sample
containing
diesel in
Blank soil
(9 percent moisture content)
Blank soil and humic acid
(9 percent moisture content)
Medium-concentration range
(9 percent moisture content)
High-concentration range
(9 percent moisture content)
High-concentration range
(16 percent moisture content)
Low-concentration range
(9 percent moisture content)
Medium-concentration range
(9 percent moisture content)
High-concentration range
(less than 1 percent moisture
content)
High-concentration range
(9 percent moisture content)
Action
Level
(mg/kg)
100
50
100
500
10
200
200
2,000
2,000
15
200
2,000
2,000
Total
Total Number
of Samples
Analyzed
10
20
8
28
3
6
3
3
3
7
3
3
3
100
Total Number of
Samples for
Which Action
Level
Conclusions
Could Be Drawn"
10
20
8
25
3
5
3
0
0
7
2
0
0
83
Percentage of
Samples for Which
EnSys Petro Test
System and Reference
Method Conclusions
Agreed
90
75
25
60
33
100
100

57
100

67
When Conclusions Did
Not Agree, Were EnSys
Petro Test System
Conclusions
Conservative or Not
Conservative?1"
Not conservative
Conservative
Conservative
Conservative
Not conservative

Conservative

Notes:

mg/kg =  Milligram per kilogram
PE    =  Performance evaluation

"   Based on the detection levels selected by SDI during the demonstration (10,100, and 1,000 mg/kg for weathered gasoline-containing soil samples
    and 15,100, and 1,000 mg/kg for diesel-containing soil samples), no conclusions could be drawn for 17 samples.
b   A conclusion was considered to be conservative when the EnSys Petro Test System result was above the action level and the reference method
    result was below the action level. A conservative conclusion may also be viewed as a false positive.
low-concentration-range  soil  PE  samples containing
diesel.   One conclusion for an FFA sample and  two
conclusions  for  blank  soil  PE  samples  were  not
conservative. The conclusion for the FFA sample appears
to be an outlier because the re ference method result for the
sample was 13 times the action level. The conclusions for
the blank soil PE samples may be attributed to difficulty in
accurately measuring TPH at trace levels. In summary, the
EnSys Petro Test System action level conclusions were
considered   to  be  conservative  because  24  of 27
conclusions (89 percent) were conservative.
7.1.2.2
Precision
Both environmental and PE  samples were analyzed to
evaluate the precision associated with TPH measurements
using the EnSys Petro Test System and reference method.
The results of this evaluation are summarized below.

Environmental Samples

Blind field triplicates were analyzed to evaluate the overall
precision  of the sampling, extraction, and analysis steps
                                                        71

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associated with TPH measurement.  Each set of field
triplicates was collected from a well-homogenized sample.
Also, extract  duplicates  were  analyzed  to  evaluate
analytical precision only. Each set of extract duplicates
was  collected  by  extracting a given soil sample and
collecting two aliquots  of the  extract.   Additional
information  on  field triplicate  and extract  duplicate
preparation is included in Chapter 4.

Tables 7-5 and 7-6 present the EnSys Petro Test System
and reference method results for 11 sets of field triplicates
and  12 sets of extract duplicates, respectively.  EnSys
Petro Test System precision was evaluated by assessing the
comparability of the TPH concentration ranges reported for
field triplicates and extract duplicates. Reference method
precision was  estimated using RSDs for field triplicates
and RPDs for extract duplicates.

As shown in Table 7-5, the TPH concentration ranges
reported by the EnSys Petro Test System were the same for
each field triplicate set.  Of the  11 field triplicate sets,
two (18 percent) had a finite TPH concentration range of
< 15 mg/kg (field triplicate set 1) or > 100 to < 1,000 mg/kg
(field triplicate set 7).  However, the TPH results for the
remaining field triplicate sets (82 percent) were reported
as  > 1,000   mg/kg;  the  infinite  concentration  range
associated with these TPH results may have contributed to
the  outcome that  the results for a given set of field
triplicates were the same. Table 7-5 also shows that the
RSDs  for  the reference  method ranged from   4  to
39 percent with a median of 16 percent,  hi summary, the
field triplicate results for both  the  EnSys Petro Test
System and the reference method exhibited good overall
precision.

As shown in Table 7-6, the TPH concentration ranges
reported by the EnSys Petro Test System were the same for
each  extract duplicate set.   Three  of the  12 extract
duplicate sets (25 percent) had a finite TPH concentration
range of <15  mg/kg (extract  duplicate set 1), >15 to
<100 mg/kg  (extract  duplicate  set  8),  or  >100 to
<1,000 mg/kg (extract duplicate set 7). However, the TPH
results for the remaining extract duplicate sets (75 percent)
were reported as > 1,000 mg/kg; the infinite concentration
range associated with the TPH result (> 1,000 mg/kg) may
have contributed to the outcome that the results for a given
set of extract duplicates were the same.

Table 7-6 also shows that the RPDs for the reference
method ranged from 0 to 11 with a median of 3. As
expected, the median RPD for extract duplicates was less
than the median RSD for field triplicates for the reference
method. This finding indicated that greater precision was
achieved  when  only  the  analysis  step  could  have
contributed to TPH measurement error than when all three
steps  (sampling, extraction, and analysis) could have
contributed to such error.

Because the EnSys Petro Test System TPH results for the
field triplicates exhibited the highest precision that can be
achieved by a semiquantitative device, no conclusions
could be drawn regarding whether greater precision was
achieved  when  only  the  analysis  step  could  have
contributed to TPH measurement error.

Performance Evaluation Samples

Table 7-7 presents  the EnSys Petro Test System and
reference method TPH results for eight sets of replicates
for soil PE samples and two sets of replicate liquid PE
samples.

For the EnSys Petro  Test System, the TPH concentration
ranges were the same for 8 of the 10 sets of replicates.  In
the remaining two sets of replicates for which the TPH
concentration ranges were not the same, only one of seven
(replicate set 5) and one of three (replicate set 6) TPH
results were different.  Three of the  10 replicate sets
(30 percent) had  a  finite  TPH concentration range of
<10 mg/kg (replicate set 1), >15 to <100 mg/kg (replicate
set 5), or >100 to < 1,000 mg/kg (one sample each in
replicate sets 5 and 6).  However, the TPH results for the
remaining replicate  sets (70 percent)  were reported as
> 1,000   mg/kg   or  >200,500  mg/L;  the  infinite
concentration ranges associated  with the TPH results
(> 1,000 mg/kg and >200,500 mg/L) may have contributed
to the outcome that the results for a given set of replicates
were the same.

For the reference method, the RSD calculated for the blank
soil samples was  not considered in  evaluating the
method's precision  because one of the three blank soil
sample results (5.12 mg/kg) was estimated by adding one-
half the reporting limits for the GRO, DRO, and ORO
components  of TPH measurement.  The RSDs for the
remaining seven replicate sets ranged from 5 to 13 percent
with a median of 8 percent.  The RSDs for the two
triplicate sets of liquid samples were 5 and 6 percent with
a median of 5.5 percent,  hi summary, the EnSys Petro
Test System and reference method results for PE samples
exhibited good overall precision.
                                                    72

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Table 7-5.  Summary of EnSys Petro Test System and Reference Method Precision for Field Triplicates of Environmental Samples
Sampling Area
Fuel Farm Area
Naval Exchange Service
Station Area
B-38 Area
Slop Fill Tank Area
Field Triplicate
Set
1
2
3
4
5
6
7
8
9
10
11
EnSys Petro Test System
TPH Result
(milligram per kilogram)
<15
<15
<15
> 1,000
>1,000
>1,000
> 1,000
> 1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
> 1,000
>1,000
>1,000
>100to<1,000
>100to<1,000
>100to<1,000
>1,000
> 1,000
> 1,000
> 1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
>1,000
> 1,000
> 1,000
Were TPH
Concentration Ranges
for a Given Field
Triplicate the Same or
Different?
Same
Same
Same
Same
Same
Same
Same
Same
Same
Same
Same
Reference Method
TPH Result
(milligram per kilogram)
68.2
90.2
44.1
15,000
12,000
13,900
280
270
219
1,870
881
1,180
1,560
1,120
1,390
9.56
14.2
15.2
79
61.4
67.3
834
1,090
938
501
544
517
280
503
369
185
146
253
Relative Standard
Deviation (percent)
34
11
13
39
16
23
13
14
4
29
28
Notes:
         Greater than
         Less than
                                                            73

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Table 7-6. Summary of EnSys Petro Test System and Reference Method Precision for Extract Duplicates
Sampling Area
Fuel Farm Area
Naval Exchange Service
Station Area
B-38 Area
Slop Fill Tank Area
Extract
Duplicate
Set
1
2
3
4
5
6
7
8
9
10
11
12
EnSys Petro Test System
TPH Result
(milligram per
kilogram)
<15
<15
>1,000
>1,000
>1,000
> 1,000
>1,000
>1,000
>1.000
>1,000
>1,000
> 1,000
>100to<1,000
>100to<1,000
>15to<100
>15to<100
> 1,000
> 1,000
>1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
Were TPH Concentration
Ranges for a Given Extract
Duplicate Set the Same or
Different?
Same
Same
Same
Same
Same
Same
Same
Same
Same
Same
Same
Same
Reference Method
TPH Result
(milligram per kilogram)
44.1
44.1
13,700
14,000
226
213
1,190
1,170
1,420
1,360
15.5
14.9
79.6
78.4
41.4
41.5
829
838
528
473
271
289
189
181
Relative Percent
Difference
0
2
6
2
4
4
2
0
1
11
6
4
Notes:
     =   Greater than
     =   Less than
                                                            74

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Table 7-7.  Comparison of EnSys Petro Test System and Reference Method Precision for Replicate Performance Evaluation Samples
Sample Type
Replicate
Set
EnSys Petro Test System
TPH Result
Were TPH Concentration
Ranges for a Given Replicate
Set the Same or Different?
Reference Method
TPH Result
Relative Standard
Deviation (percent)
Soil Samples (Processed Garden Soil) (TPH Results in Milligram per Kilogram)
Blank (9 percent moisture content)
Weathered
gasoline
Diesel
Medium-range TPH
concentration
(9 percent moisture
content)
High-range TPH
concentration
(9 percent moisture
content)
High-range TPH
concentration
(16 percent moisture
content)
Low-range TPH
concentration
(9 percent moisture
content)
Medium-range TPH
concentration
(9 percent moisture
content)
High-range TPH
concentration
(9 percent moisture
content)
High-range TPH
concentration
(<1 percent moisture
content)
1
2
3
4
5
6
7
8
<10
<10
<10
>1,000
>1,000
> 1,000
>1,000
> 1,000
>1,000
>1,000
> 1,000
> 1,000
>15to<100
>15to<100
>15to<100
>15to<100
> 1 00 to < 1,000
>15tO<100
>15to<100
>1,000
>1,000
>100to<1,000
>1,000
> 1,000
> 1,000
>1,000
> 1,000
>1,000
Same
Same
Same
Same
Same for six of seven
Same for two of three
Same
Same
5.12
13.1
13.5
702
743
671
1,880
2,020
2,180
1,740
1,980
2,050
12.0
16.5
13.7
16.4
17.4
17.2
14.8
226
265
267
2,480
2,890
2,800
2,700
2,950
3,070
45
5
7
8
13
9
8
6
Liquid Samples (Neat Materials) (TPH Results in Milligram per Liter)
Weathered gasoline
Diesel
9
10
>200,500
>200,500
>200,500
>200,500
>200,500
>200,500
Same
Same
656,000
611,000
677,000
1,090,000
1,020,000
1,160,000
5
6


Notes:
    =    Greater than
    =    Less than
                                                            75

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Finally, for the reference method, the median RSD for the
soil PE samples (8 percent) was  less than that for the
environmental samples (16 percent), indicating that greater
precision was achieved for the samples prepared under
more controlled conditions (the PE samples).  A similar
comparison could not be made for the EnSys Petro Test
System becaues the device' s results were semiquantitative.

7.7.3  Primary Objective P3: Effect of
       Interferents

The effect of interferents on TPH measurement using the
EnSys  Petro Test System and reference method was
evaluated through  analysis of high-concentration-range
soil PE samples that contained weathered gasoline  or
diesel with or without an interferent. The six interferents
used were MTBE; PCE;  Stoddard solvent;  turpentine;
1,2,4-trichlorobenzene; and humic acid. In addition, neat
(liquid) samples of each interferent except humic acid were
used as quasi-control samples to evaluate the effect of each
interferent on the TPH results obtained using the EnSys
Petro  Test System and the reference method.  Liquid
interferent samples were submitted for analysis as blind
triplicate samples.  SDI and the reference laboratory were
provided with flame-sealed ampul es of each interferent and
were given specific instructions to prepare dilutions of the
liquid  interferents  for analysis. Two dilutions  of each
interferent were prepared; therefore, there were six EnSys
Petro Test System  and reference method TPH results for
each interferent.  Blank soil was mixed with humic acid at
two  levels to prepare  quasi-control samples for this
interferent. Additional details regarding the interferents
are provided in  Chapter 4.  The  results for the quasi-
control interferent samples are discussed first below,
followed by  the effects of the interferents on the TPH
results for soil samples.

7.1.3.1     Interferent Sample Results

Table  7-8 presents the EnSys Petro Test System and
reference  method TPH results, mean TPH results, and
mean responses for triplicate sets of liquid PE samples and
soil PE samples containing  humic  acid.  Each  mean
response was calculated by dividing the mean TPH result
for a triplicate set by the interferent concentration and
multiplying by 100. For liquid PE samples, the interferent
concentration was estimated using its  density and purity.

The mean responses  for the  EnSys  Petro Test System
ranged from  0 to >28 percent for the liquid  interferent
samples; the mean response for humic acid was 0 percent.
The TPH results for a given triplicate set and between the
triplicate sets  showed good agreement.  Because SDI
performed TPH measurements for each liquid interferent
at two different dilutions, a conclusion regarding the effect
of each interferent on TPH results was drawn using (1) the
higher mean TPH result between triplicate sets when the
TPH results were reported as "greater than" values and
(2) the lower mean TPH resu It between triplicate sets when
the  TPH results were reported as  "less than" values.
Therefore,  the mean response  for  MTBE  (0 percent)
indicated that this compound cannot be measured as TPH
using the EnSys Petro Test System.  However, the mean
responses for Stoddard solvent (>26 percent) indicated that
this compound can be measured as TPH using the device.
The mean responses for PCE (>25  percent); turpentine
(>24 percent);  and 1,2,4-trichlorobenzene (>28 percent)
indicated that these interferents will  likely result in false
positives during TPH measurement.   Also,  the mean
response of 0 percent for humic acid indicated that humic
acid would not result in either false positives or false
negatives during TPH measurement.

The mean responses for the reference  method ranged from
17 to 92 percent for the liquid  interferent samples; the
mean response for humic acid was 0 percent.  The TPH
results for a given triplicate set and between the triplicate
sets showed good agreement.  The  mean responses for
MTBE (39 percent) and  Stoddard solvent (85 percent)
indicated that these compounds can be measured as TPH
using the reference method. The mean responses for PCE
(17.5 percent);  turpentine (52 percent); and 1,2,4-trichloro-
benzene (50 percent) indicated that these interferents will
likely result in false positives during TPH measurement.
The mean response of 0 percent  for humic acid indicated
that humic acid would not result in either false positives or
false negatives during TPH measurement.

7.13.2     Effects of Interferents on TPH Results for
           Soil Samples

The effects of  interferents  on TPH measurement for soil
samples containing weathered gasoline or  diesel were
examined through analysis  of  PE  samples containing
(1)   weathered  gasoline  or   diesel  (control)   and
(2) weathered  gasoline or diesel plus a given interferent
at two levels. Information on the selection of interferents
is provided in Chapter 4.

Triplicate sets  of control samples and samples containing
interferents were prepared for analysis using the EnSys
Petro Test System and reference method.  Because the
                                                     76

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Table 7-8. Comparison of EnSys Petro Test System and Reference Method Results for Interferent Samples
Interferent and Concentration"
EnSys Petro Test System
TPH Result
Mean TPH
Result
Mean Response6
(percent)
Reference Method
TPH Result
Mean TPH
Result
Mean Response6
(percent)
Liquid Interferent Samples (TPH Results in Milligram per Liter)
Methyl-tert-butyl ether
(740,000 milligrams per liter)
Tetrachloroethene
(1,621,000 milligrams per liter)
Stoddard solvent
(771,500 milligrams per liter)
Turpentine
(845,600 milligrams per liter)
1 ,2,4-Trichlorobenzene
(1 ,439,000 milligrams per liter)
<2,005
<2,005
<2,005
>10,050to<100,500
<1,005
<1,005
>400,500
>400,500
>400,500
>80,500
>80,500
>80,500
>200,500
>200,500
>200,500
>40,500
>40,500
>40,500
>200,500
>200,500
>200,500
>40,500
>40,500
>40,500
>400,500
>400,500
>400,500
>80,500
>80,500
>80,500
<2,005
< 1,005°
>400,500
>80,500
>200,500
>40,500
>200,500
>40,500
>400,500
>80,500
0
0
>25
>5
>26
>5
>24
>5
>28
>6
309,000
272,000
270,000
303,000
313,000
282,000
269,000
270,000
277,000
290,000
288,000
307,000
561,000
628,000
606,000
703,000
Not reported
713,000
504,000
459,000
442,000
523,000
353,000
349,000
711,000
620,000
732,000
754,000
756,000
752,000
284,000
299,000
272,000
295,000
598,000
708,000
468,000
408,000
688,000
754,000
38
40
17
18
78
92
55
48
48
52
Interferent Samples (Processed Garden Soil) (TPH Results in Milligram per Kilogram)
Humic acid at 3,940 milligrams
per kilogram
Humic acid at 19,500
milligrams per kilogram
<15
<15
>100to<1,000
>15to<1,000
<15
<15
<15d
<15"
0
0
8.99
8.96
8.12
69.3
79.1
78.5
9.00
76.0
0
0
Notes:
>    =   Greater than       <    =    Less than
°    A given liquid interferent concentration was estimated using its density and purity.
"    The mean response was calculated by dividing the mean TPH result for a triplicate set by the interferent concentration and multiplying by 100.
c    Because the EnSys Petro Test System TPH results for five of six samples containing methyl-tert-butyl ether were below the lowest detection level
     used by SDI, the device result of >10,050 to <100,500 milligrams per liter (an analytical outlier) was not considered.
"    Because the EnSys Petro Test System TPH results for four of six samples containing humic acid were below the lowest detection level used by
     SDI, the device results of >100 to <1,000 and >15 to <1,000 milligrams per kilogram (analytical outliers) were not considered.
                                                                77

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EnSys Petro Test System is a semiquantitative device, the
TPH concentration of a sample cannot be reported as an
absolute value, and a statistical approach could not be used
to evaluate the effect of interferents on TPH measurement.
For the reference method, a parametric or nonparametric
test was selected for statistical evaluation of the analytical
results using the approach presented in Figure 7-1.

TPH results for samples with and without interferents,
statistical tests performed, and statistical test conclusions
for the reference method are presented in Table 7-9.  The
null hypothesis for the statistical tests was that mean TPH
results for samples  with and  without interferents were
equal. The effects of the interferents are discussed below
for both the EnSys Petro Test System and the reference
method.

Effect of Methyl-Tert-Butyl Ether

The effect of MTBE was evaluated for soil PE samples
containing weathered gasoline.  Based on the  liquid PE
sample (neat material)  analytical results, MTBE  was
expected to have no effect on the TPH results for the
EnSys Petro Test System; however, it was expected to bias
the reference method results high.

Table 7-9  shows that no  conclusions  could  be  drawn
regarding the effect of MTBE on EnSys Petro Test System
TPH results for soil PE samples; the TPH concentrations
in soil PE samples containing weathered gasoline with and
without MTBE exceeded the highest detection  level used
by SDI during the demonstration (1,000 mg/kg).

For the reference method,  at the interferent levels used,
MTBE was expected to bias the TPH results high by
21 percent (low level) and 33 percent (high level).  The
expected  bias  would be  lower (17  and  27 percent,
respectively) if MTBE in soil samples was assumed to be
extracted  as  efficiently  as weathered  gasoline in soil
samples.  However, no effect on TPH measurement  was
observed  for  soil  PE  samples analyzed  during the
demonstration.  A significant amount of MTBE, a highly
volatile compound, may have been lost during PE sample
preparation, transport, storage, and handling, thus lowering
the MTBE concentrations  to levels that would not have
increased the TPH results beyond the reference method's
precision (7 percent).
Effect of Tetrachloroethene

The effect of PCE was evaluated for soil PE samples
containing weathered gasoline.  Based on the liquid PE
sample  (neat  material) analytical  results,  PCE  was
expected to bias the  EnSys  Petro  Test  System  and
reference method TPH results high.

Table 7-9 shows  that no  conclusions could  be  drawn
regarding the effect of PCE on EnSys Petro Test System
TPH results for soil PE samples; the TPH concentrations
in soil PE samples containing weathered gasoline with and
without PCE exceeded the highest detection level used by
SDI during the demonstration (1,000 mg/kg).

For the reference method, at the interferent levels used,
PCE was  expected to bias  the TPH results high by
24 percent (low level) and 113 percent (high level).  The
expected bias would be  lower (20  and 92 percent,
respectively) if PCE in soil samples  was assumed to be
extracted as efficiently as weathered gasoline in soil
samples. The statistical tests showed that the probability
of the three means being equal was < 5 percent.  However,
the tests also showed that at the high level, PCE biased the
TPH results high, which appeared to be reasonable based
on the conclusions drawn from the analytical results for
neat PCE.  As to the reason for PCE at the  low level
having no effect on the TPH results, volatilization  during
PE sample preparation, transport, storage, and handling
may have lowered the PCE concentrations to levels that
would not have increased the  TPH  results beyond the
reference method's precision (7 percent).

Effect of Stoddard Solvent

The  effect  of Stoddard  solvent  was  evaluated for
weathered gasoline and diesel soil PE samples. Based on
the liquid PE sample  (neat material) analytical results,
Stoddard solvent was  expected  to bias the EnSys Petro
Test System and reference method results high.

Table 7-9 shows  that no  conclusions could be  drawn
regarding the effect of Stoddard solvent on EnSys Petro
Test System TPH results for soil PE samples; the TPH
concentrations in soil PE samples containing weathered
gasoline and diesel with and without Stoddard solvent
exceeded the highest detection  level  used by SDI  during
the demonstration (1,000 mg/kg).
                                                    78

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Table 7-9.  Comparison of EnSys Petro Test System and Referece Method Results for Soil Performance Evaluation Samples Containftg Interferents
Sample Matrix and
Interferenf
EnSys Petro Test System"
TPH Result
(mg/kg)
Mean TPH
Result
(mg/kg)
Were Mean TPH Results
for Samples With and
Without Interferents the
Same or Different?
Reference Method
TPH
Result
(mg/kg)
Mean TPH
Result
(mg/kg)
Statistical Tests
Were Mean TPH Results
for Samples With and
Without Interferents the
Same or Different?
Probability of Mean TPH
Results for Samples With
and Without Interferents
Being the Same (percent)
Soil Samples Without Interferents
Weathered gasoline
Diesel
> 1,000
> 1,000
>1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
Not applicable
Not applicable
1,880
2,020
2,180
2,480
2,890
2,800
2,030
2,720
Not applicable
Not applicable
Soil Samples With Interferents
Weathered
gasoline
MTBE
(1,100mg/kg)
MTBE
(1,700mg/kg)
PCE
(2,810mg/kg)
PCE
(13,100 mg/kg)
Stoddard
solvent
(2,900 mg/kg)
Stoddard
solvent
(15,400 mg/kg)
>1,000
>1,000
> 1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
> 1,000
> 1,000
> 1,000
> 1,000
> 1,000
> 1,000
>1,000
>1,000
> 1,000
> 1,000
>1,000
> 1,000
>1,000
> 1,000
> 1,000
>1 ,000
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
1,900
1,750
2,210
2,150
2,320
2,560
2,540
2,160
2,450
4,740
4,570
4,040
4,350
4,760
4,110
10,300
14,300
1 1 ,000
1,950
2,340
2,380
4,450
4,410
11,900
One-way analysis of
variance (parametric)
and Tukey (honest,
significant difference)
pairwise comparison
of means (parametric)
Same
Mean with interferent at
high level was different
from means without
interferent and with
interferent at low level
All three means (with and
without interferents) were
significantly different from
one another
11.21
0.00
0.00

-------
        Table 7-9. Comparison of EnSys Petro Test System and Referace Method Results for Soil Performance Evaluation Samples Containig Interferents (Continued)
Sample Matrix and
Interferenf
EnSys Petro Test System6
TPH Result
(mg/kg)
Mean TPH
Result
(mg/kg)
Were Mean TPH Results
for Samples With and
Without Interferents the
Same or Different?
Reference Method
TPH
Result
(mg/kg)
Mean TPH
Result
(mg/kg)
Statistical Tests
Were Mean TPH Results
for Samples With and
Without Interferents the
Same or Different?
Probability of Mean TPH
Results for Samples With
and Without Interferents
Being the Same (percent)
Soil Samples With Interferents (Continued) :
Diesel
Weathered
gasoline
Diesel
Stoddard
solvent
(3,650 mg/kg)
Stoddard
solvent
(18,200 mg/kg)
Turpentine
(2,730 mg/kg)
Turpentine
(12,900 mg/kg)
Turpentine
(3,850 mg/kg)
Turpentine
(19,600 mg/kg)
1 ,2,4-Trichloro-
benzene
(3,350 mg/kg)
1,2,4-Trichloro-
benzene
(16,600 mg/kg)
>1,000
>1,000
>1,000
> 1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
> 1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
> 1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1 ,000
>1,000
>1,000
> 1,000
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
Inconclusive
4,390
4,640
4,520
8,770
6,580
8,280
4,410
3,870
4,440
12,800
11,200
14,600
5,860
5,810
5,610
15,000
13,300
13,300
3,220
3,750
3,550
7,940
6,560
6,690
4,520
7,880
4,240
12,900
5,760
13,900
3,510
7,060
One-way analysis of
variance (parametric)
and Tukey (honest,
significant difference)
pairwise comparison
of means (parametric)
Kruskal-Wallis one-
way analysis of
variance
(nonparametric) and
Kruskal-Wallis
pairwise comparison
of means
(nonparametric)
One-way analysis of
variance (parametric)
and Tukey (honest,
significant difference)
pairwise comparison
of means (parametric)
All three means (with and
without interferents) were
significantly different from
one another
All three means (with and
without interferents) were
significantly different from
one another
Mean without interferent
was same as mean with
interferent at low level;
mean with interferent at
low level was same as
mean with interferent at
high level
Mean with interferent at
high level was different
from means without
interferent and with
interferent at low level
0.00
0.00
2.65
0.01
oo
o

-------
Table 7-9. Comparison of EnSys Petro Test System and Referace Method Results for Soil Performance Evaluation Samples Containig Interferents (Continued)
Sample Matrix and
Interferenf
EnSys Petro Test Systemb
TPH Result
(mg/kg)
Mean TPH
Result
(mg/kg)
Were Mean TPH Results
for Samples With and
Without Interferents the
Same or Different?
Reference Method
TPH
Result
(mg/kg)
Mean TPH
Result
(mg/kg)
Statistical Tests
Were Mean TPH Results
for Samples With and
Without Interferents the
Same or Different?
Probability of Mean TPH
Results for Samples With
and Without Interferents
Being the Same (percent)
Soil Samples With Interferents (Continued)
Diesel
(Continued)
Humic acid
(3,940 mg/kg)
Humic acid
(19,500 mg/kg)
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
>1,000
Inconclusive
Inconclusive
2,150
2,080
2.360
2,660
2,420
2,270
2,200
2,450
One-way analysis of
variance (parametric)
and Tukey (honest,
significant difference)
pairwise companson
of means (parametric)
Mean without interferent
was same as mean with
interfered at high level;
mean with interferent at
low level was same as
mean with interferent at
high level
3.87
Notes:

>      =
mg/kg  =
MTBE  =
PCE   =
Greater than
Milligram per kilogram
Methyl-tert-butyl ether
Tetrachloroethene
      All samples were prepared at a 9 percent moisture level.
      Because the EnSys Petro Test System is a semiquantitative devicea statistical approach could not be used to draw conclusionsregarding the effect of a given interferent on TPH
      measurement. In addition, based on the detection levels selectedby SDI during the demonstration, the TPH results for samplesArith and without interferents were reported as >1,000 mg/kg.
      Therefore, no conclusions could bedrawn regarding the effect of a given interferent on TPH measurement.

-------
For the reference method, at the interferent levels used,
Stoddard solvent was expected to bias the TPH results high
by 121 percent (low level) and 645 percent (high level) for
weathered gasoline soil PE samples and by 114 percent
(low level) and 569 percent (high level) for diesel soil PE
samples.   The expected  bias would be lower (99 and
524 percent, respectively, for weathered gasoline soil PE
samples and 61 and 289 percent, respectively, for diesel
soil PE samples) if Stoddard solvent in soil samples was
assumed to be  extracted as  efficiently as weathered
gasoline and diesel hi soil samples. The statistical tests
showed that the  mean TPH results with and without the
interferent were different for both weathered gasoline and
diesel soil PE samples, which confirmed the conclusions
drawn from  the analytical  results for neat Stoddard
solvent.

Effect of Turpentine

The effect of turpentine was  evaluated for weathered
gasoline and diesel soil PE samples. Based on the liquid
PE sample (neat material) analy tical results, turpentine was
expected to  bias the  EnSys  Petro Test  System and
reference method results high.

Table  7-9 shows  that  no conclusions could  be drawn
regarding  the effect of turpentine on  EnSys Petro Test
System TPH  results  for soil  PE  samples;  the TPH
concentrations in soil PE samples containing weathered
gasoline and diesel with and without turpentine exceeded
the highest detection  level used by SDI during the
demonstration (1,000 mg/kg).

For the reference method, at the interferent levels used,
turpentine was expected to bias the TPH results high by
69  percent (low  level)  and 327 percent (high level) for
weathered gasoline soil PE samples and by 72 percent (low
level)  and  371 percent (high  level) for diesel soil PE
samples.   The expected  bias would be lower (56 and
266 percent, respectively, for weathered gasoline soil PE
samples and 39 and 200 percent, respectively, for diesel
soil PE samples) if turpentine in soil samples was assumed
to be extracted as efficiently as weathered gasoline and
diesel in soil samples. The statistical tests showed that the
mean TPH results with and without the interferent were
different for weathered gasoline soil PE samples, which
confirmed  the conclusions drawn  from the  analytical
results for neat turpentine.  However, for diesel soil PE
samples, (1) the mean TPH result without the interferent
and the mean TPH result with the interferent at the low
level were equal and (2)  the mean TPH results with the
interferent  at  the low  and  high  levels were equal,
indicating that turpentine at the low level did not affect the
TPH results  for  the diesel soil PE samples but that
turpentine at the high level did affect the TPH results. The
conclusion reached for the interferent at the low level was
unexpected and did not seem reasonable based on a simple
comparison of means that differed by a factor of three.
The  anomaly might have  been associated with  the
nonparametric test used to evaluate the effect of turpentine
on  TPH  results  for   diesel  soil  PE   samples,   as
nonparametric tests do not account for the magnitude of
the difference between TPH results.

Effect of 1,2,4-TrichIorobenzene

The effect of 1,2,4-trichlorobenzene was evaluated for
diesel soil PE samples.  Based on the liquid PE sample
(neat material) analytical results, 1,2,4-trichlorobenzene
was expected to bias the EnSys Petro Test System and
reference method results high.

Table 7-9 shows that no  conclusions  could be drawn
regarding the effect of 1,2,4-trichlorobenzene on EnSys
Petro Test System TPH  results for soil PE samples; the
TPH concentrations in soil PE samples containing diesel
with and without 1,2,4-trichlorobenzene exceeded the
highest   detection level  used  by   SDI  during  the
demonstration (1,000 mg/kg).

For the reference method,  at the  interferent levels used,
1,2,4-trichlorobenzene was expected to  bias the TPH
results high by 62 percent (low level)  and  305 percent
(high level).  The expected bias would be lower (33 and
164 percent, respectively) if 1,2,4-trichlorobenzene in soil
samples was  assumed to be extracted as efficiently as
diesel in soil samples. The statistical tests showed that the
probability of three means  being equal was <5 percent.
However, the tests also showed that when the interferent
was present at the high level, TPH results were biased
high.  The effect observed at the high level confirmed the
conclusions drawn from the analytical results for neat
1,2,4-trichlorobenzene.  The statistical tests indicated that
the mean TPH result with the interferent at the low level
was not  different from the mean TPH  result  without
the  interferent,  indicating that  the  low level  of
1,2,4-trichlorobenzene did not affect TPH measurement.
However, a simple comparison of the mean TPH results
revealed  that  the low level of 1,2,4-trichlorobenzene
increased the  TPH result to nearly the result based on the
expected bias of 33 percent. Specifically,  the mean TPH
result with the interferent at the low level was 3,510 mg/kg
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rather than the expected value of 3,620 mg/kg.  The
conclusions drawn from the statistical tests were justified
when the variabilities associated with the mean  TPH
results were taken into account.

Effect of Humic Acid

The effect of humic acid was evaluated for diesel soil PE
samples.  Based  on the  analytical  results for soil PE
samples  containing  humic acid, this interferent was
expected to  have no effect on the TPH results for the
EnSys Petro Test System and reference method.

Table 7-9 shows that no  conclusions could  be drawn
regarding the effect of humic  acid on EnSys Petro Test
System  TPH  results for  soil PE  samples;  the  TPH
concentrations in soil PE samples containing diesel with
and without humic acid exceeded the highest detection
level used by SDI during the demonstration (1,000 mg/kg).

For the  reference method, humic acid appeared to  have
biased the TPH results low. However, the bias  decreased
with an increase hi the humic acid level. Specifically, the
negative bias was  19 percent at  the  low level and
10 percent at the high level. For this reason, no conclusion
was drawn regarding the effect of humic acid on  TPH
measurement using the reference method.

7.1.4   Primary Objective P4: Effect of Soil
        Moisture Content

To measure the effect  of soil moisture  content on the
ability of the EnSys Petro Test System and  reference
method to accurately measure TPH,  high-concentration-
range soil PE samples containing weathered gasoline or
diesel at two moisture levels were analyzed. The EnSys
Petro Test System and  reference method results  were
converted from a wet weight basis to a dry weight basis in
order to evaluate the effect of moisture  content on the
sample  TPH results.   Because the EnSys Petro  Test
System  is   a  semiquantitative   device,  the   TPH
concentration  in  a  sample cannot  be reported as  an
absolute value, and a statistical approach could not be used
to evaluate the effect of soil  moisture content on  TPH
measurement.  Therefore, a qualitative  evaluation was
performed to determine whether the device's TPH results
were  impacted by  soil  moisture content—that  is,  to
determine whether an increase in soil moisture resulted in
an  increase  or  decrease in  the TPH  concentrations
measured. The reference method dry weight TPH results
were normally distributed; therefore, a two-tailed,  two-
sample  Student's t-test was performed  to  determine
whether the reference method results were impacted by soil
moisture content.  The null hypothesis for the t-test was
that the two  means were equal  or that  the  difference
between the means was equal to zero.  Table 7-10 shows
the sample moisture levels, TPH results, mean TPH results
for sets of triplicate samples, whether the mean  TPH
results at different soil moisture levels were the same, and
the probability of the null hypothesis being true.

Table 7-10 shows that no conclusions could  be drawn
regarding the effect of soil moisture  content on EnSys
Petro  Test System TPH results for soil PE samples; the
TPH  concentrations in soil PE samples containing
weathered gasoline and diesel  exceeded the  highest
detection level used by SDI during the  demonstration,
which was 1,000 mg/kg on  a wet weight basis.  The
apparent differences in mean TPH concentrations resulted
from  conversion of the concentrations to a dry weight
basis.

Table 7-10 also shows  that reference method  results for
weathered gasoline soil samples and diesel soil samples at
different moisture levels were statistically the same at a
significance  level of 5  percent; therefore, the reference
method results were not Impacted by soil moisture content.
Based on a simple comparison of the  results, this
conclusion appeared to be reasonable.

7.1.5  Primary Objective PS:  Time Required for
        TPH Measurement

During the demonstration, the time  required for  TPH
measurement  activities, including EnSys Petro  Test
System setup, sample extraction, sample analysis and data
package  preparation,   and  device   disassembly,  was
measured. During the demonstration,  either two or  three
field  technicians  performed the  TPH  measurement
activities using the EnSys Petro Test  System.   Time
measurement began at the start of each demonstration day
when the technicians began to set up the device and ended
when they disassembled the device. Time not measured
included (1) the time spent by the technicians verifying
that they  had received all the  demonstration samples
indicated on chain-of-custody forms, (2) the times when
the technicians took breaks, and (3) the time that the
technicians  spent  away  from the demonstration site
preparing and analyzing calibration standards. In addition
to the total time required for TPH measurement, the time
required  to  perform sample extraction and  the  time
required to perform sample analysis and prepare the data
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Table 7-10. Comparison of Results for Soil Performaice Evaluation Samples at Different Moisture Levels
Sample Type and Moisture Level
Weathered gasoline at 9 percent
moisture level
Weathered gasoline at 16 percent
moisture level
Diesel at less than 1 percent
moisture level
Diesel at 9 percent moisture level
EnSys Petro Test System
TPH Result on Dry
Weight Basis
(milligram per
kilogram)
>1,100
>1,100
>1,100
>1,200
>1.200
>1.200
> 1.000
> 1,000
> 1.000
>1,100
>1,100
>1,100
Mean TPH Result
(milligram per
kilogram)
>1,100
>1,200
> 1,000
>1,100
Were Mean TPH
Results at Different
Moisture Levels the
Same or Different?8
Inconclusive
Inconclusive
Reference Method
TPH Result on Dry
Weight Basis
(milligram per
kilogram)
2,070
2,220
2,400
2,070
2,390
2,440
2,740
3,180
3,070
2,720
2,970
3,100
Mean TPH Result
(milligram per
kilogram)
2,230
2,300
3,000
2,930
Were Mean TPH
Results at Different
Moisture Levels the
Same or Different?1
Same
Same
Probability of Null
Hypothesis Being
Truec
(percent)
66.52
71.95
Notes:

> =  Greater than

1     Because the EnSys Petro Test System is a semiquantitative devfe, a statistical approach could notbe used to draw conclusions regarding the effect of soil moisture content on TPH
     measurement. In addition, based on the detection levels selectedby SDI during the demonstration, the TPH results for samplesvith different moisture levels were reported as >1,000 milligrams
     per kilogram on a wet weight basis. The small differences in the mean TPH concentradris resulted from conversion of the conceitrations to a dry weight basis. Therefore, no conclusions could
     be drawn regarding the effect of moisture content on TPH measurement.

b     A two-tailed, two-sample Student's t-test parametric) was used to evaluate the effect of soil moisture content on TPH results.

c     The null hypothesis for the t-test was that the two means wereequal or that the difference between the two means was equal taero.

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package for the first analytical batch  of soil samples
during each day of the demonstration were measured. The
number and type of samples in a batch were selected by
SDL

The time required to complete TPH measurement activities
using the EnSys Petro Test System is shown in Table 7-11.
When a given activity was performed by two or three field
technicians simultaneously, the time measurement for the
activity was the total time spent by the technicians.  The
time required for each activity was rounded to the nearest
5 minutes.

Overall, SDI required  39 hours, 35 minutes, for TPH
measurement of 66 soil environmental samples, 89 soil PE
samples, 36 liquid PE samples, and 12 extract duplicates.
In addition, SDI performed m-xylene reference standard
duplicate QC checks at a rate of one per analytical batch
(five samples).  Information regarding the time required for
each measurement activity during the 2-day demonstration
and for extraction and analysis  of the first analytical batch
of soil samples during  each day of the demonstration is
provided below.

EnSys Petro Test System setup required 15 minutes each
day, totaling 30 minutes for the  entire demonstration. This
activity included device setup; performing calibration
checks for the differential photometer and digital balance;
and organization  of  extraction,  analysis,  and  waste
disposal supplies.  The setup time was not separately
measured for the first sample batch on the first day of the
demonstration; instead, the setup time recorded for the first
sample batch on the second day of the demonstration was
used as an estimate.

The sample extraction time and the sample analysis and
data  package  preparation time  were not separately
measured   for  each  analytical  batch   during   the
demonstration because these activities  were performed
concurrently by two or more SDI technicians. A total of
38 hours, 45 minutes, was required to  perform 155 soil
sample extractions and 210 TPH analyses using the EnSys
Petro Test System. The 210 analyses included analyses of
155  soil  samples, 36  liquid  samples, and 12  extract
duplicates as well as reanalyses of 7 samples. During most
of the  demonstration, two SDI technicians performed
measurement activities.    On the  first  day   of the
demonstration, a third SDI technician assisted with sample
extractions  for  2  hours,  25 minutes, and with  sample
analyses for 1 hour, 30 minutes.

The time required for extraction of the first analytical batch
of soil samples during each day of the demonstration was
recorded. SDI designated five samples for each analytical
batch. The number of samples was based on the capacity
of  the foam workstation provided  in  the Common
Accessory Kit.  A total of 20 minutes  was required to
extract the first  batch of soil samples on the first day of
Table 7-11. Time Required to Complete TPH Measurement Activities Using the EnSys Petro Test System

                                                                   Time Required3
Measurement Activity
EnSys Petro Test System setup
Sample extraction
Sample analysis and data package
preparation11
EnSys Petro Test System disassembly
Total
First Sample Batch, First Day
1 5 minutes"
20 minutes
35 minutes
10 minutes'
1 hour, 20 minutes
First Sample Batch, Second Day
15 minutes
15 minutes
25 minutes
1 0 minutes'
1 hour, 5 minutes
2-Day Demonstration Period
30 minutes
38 hours, 45 minutes0
20 minutes
39 hours, 35 minutes
Notes:
    The time required for each activity was rounded to the nearest 5 minutes.
    The device setup time was not separately measured for the first sample batch on the first day of the demonstration; instead, the setup time recorded
    for the first sample batch on the second day of the demonstration was used as an estimate.
    The sample extraction time and the sample analysis and data package preparation time were not separately measured for each analytical batch
    during the demonstration because two or three SDI technicians concurrently performed these activities.
    The data package preparation time was not separately measured during the demonstration because the raw TPH results recorded on the field data
    form constituted the data package submitted by SDI; no additional calculations were required in the field.
    The device disassembly time was not separately measured during the demonstration. The disassembly time reported was estimated based on
    field observations. Specifically, this estimate was based on the device setup time, excluding the time required for (1) differential photometer and
    digital balance calibration checks and (2) organization of extraction, analysis, and waste disposal supplies.
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first day of the demonstration; therefore, an average of
4 minutes was required for extraction of a sample. A total
of 15 minutes was required to extract the first batch of
samples on the second day of the demonstration; therefore,
an average of 3 minutes was required for extraction of a
sample.  The decrease in the average extraction time for
the first batch of soil samples on the second day of the
demonstration suggested that the field technicians became
more familiar with the EnSys Petro Test System extraction
procedures as the demonstration progressed.

The time required to analyze samples and prepare the data
package for the first analytical batch of soil samples during
each day of the demonstration was also recorded. On the
first day of the demonstration, a total of 35 minutes was
required to analyze the first batch of samples and record
the TPH result in the data package,  or  an average of
7  minutes per sample.   On  the second  day of the
demonstration,  a total of 25 minutes  was  required  to
analyze the first batch of samples and record the TPH
result in the data package, or an average of 5 minutes per
sample. The decrease in the average sample analysis and
data recording time for the first batch of soil samples on
the second day of the demonstration suggested that the
field technicians became more familiar with the EnSys
Petro  Test  System   analysis  procedures  as  the
demonstration progressed.

The EnSys Petro  Test System disassembly  time was
estimated to  be 10 minutes on each day, or a total  of
20  minutes for the  entire demonstration.  Disassembly
included packing the reusable items of the  EnSys Petro
Test  System  required  for  TPH measurement.    The
disassembly time was not separately measured during the
demonstration  but  was  estimated  based  on   field
observations. Specifically, this estimate was  based on the
device  setup  time,  excluding the  time required for
(1) differential photometer and digital balance calibration
checks and (2) organization of extraction, analysis, and
waste disposal supplies.

For the reference method, time measurement began when
the reference  laboratory received  all the investigative
samples and continued until the EPA received the first
draft data package from the laboratory.  The reference
laboratory  took 30 days to deliver the first  draft data
package to the EPA.  Additional time taken by the
reference laboratory to address EPA comments on all the
draft laboratory data packages was not included as part of
the time required for TPH measurement.
7.2    Secondary Objectives

This section discusses the performance results for the
EnSys Petro  Test System in  terms of the secondary
objectives stated in Section 4.1. The secondary objectives
were addressed based on (1) observations of the EnSys
Petro Test System's performance during the demonstration
and (2) information provided by SDL

7.2.1   Skill and Training Requirements for
       Proper Device Operation

The EnSys Petro Test System is easy to operate, requiring
one field technician  with basic  wet chemistry  skills
acquired on the job or in a university.  Because the sample
extraction time may need to be adjusted based on soil type,
basic knowledge of soil types is also recommended so that
the technician can differentiate among sand, silt, and clay
soil types and adjust the extraction time accordingly. For
the demonstration, SDI chose to conduct sample analyses
using  either two or three technicians in order to increase
the sample throughput. One or two technicians performed
sample  extraction while one technician  concurrently
performed multiple analyses.

To simplify sample analysis for the user, SDI customizes
the EnSys Petro Test System to include dilution ampules
that allow the  user to obtain semiquantitative results  in
order  to meet project-specific requirements.  SDI has 20
preset dilution ampules readily  available for gasoline and
diesel analyses but develops nonstandard dilution ampules
upon request. For the demonstration, SDI used 100- and
1,000-mg/kg preset dilution ampules  to analyze gasoline-
and diesel-containing soil samples.

Each  item in the EnSys Petro Test System is labeled  to
assist the user with sample analysis activities. Containers
that are  similar  in  appearance but contain  different
reagents are color-coded.  For example, dilution ampules
used for gasoline-containing soil samples are color-coded
blue and green for 100- and 1,000-mg/kg  dilutions,
respectively.   Also, the  labels on  the  15-mL bottles
containing chromogen, substrate,  and stop  solution are
color-coded  yellow,  green,  and  red,  respectively.
Methanol for use in sample extraction and extract dilution
is provided in premeasured, sealed ampules.  In addition,
items  included in the Sample Extraction Kit and the 12T
Soil Test  Kit are  kept organized within  the  foam
workstation provided in the Common Accessory Kit. As
a result, the likelihood of user error during sample analysis
is minimized.
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Each  foam workstation has the capacity to allow five
samples to be analyzed in one batch at up to three dilution
levels. More than five samples can be analyzed at a given
time  by  setting up  multiple  workstations,  but  the
advisability of doing so depends on the user's experience
with the EnSys Petro Test System. Because the SDI field
technicians have extensive experience  with the EnSys
Petro  Test System, SDI used up to three workstations, at
any given time, during the demonstration.

The sample analysis procedure for the EnSys Petro Test
System can be learned in the field with a few  practice
attempts.  The system contains user guides that must be
followed to  properly operate  the system.  In addition,
during regular business hours, SDI provides technical
support  over  the telephone  at  no additional cost.
According to  SDI,  the  user  guides  supplemented  by
technical support over the telephone  are adequate for a
user to learn the sample analysis procedure. However, SDI
also offers a 1-day, on-site training program for $999,
which includes the cost of instructor travel and per diem
and the cost of one EnSys Petro Test System for training
purposes. SDI does not provide a training video for the
system.

With  the EnSys  Petro Test System, the user can easily
estimate TPH concentrations by measuring the difference
in color intensities between the reference standard and the
sample extract or multiple dilutions of the sample extract.
During the demonstration, SDI analyzed each sample at
three detection levels by diluting the sample extract twice
using the 100- and 1,000-mg/kg dilution ampules. The
resulting TPH concentration  ranges used to  estimate
sample concentrations were <10; >10 to <100; >100 to
< 1,000; and > 1,000 mg/kg for GRO-containing samples
and<15;>15to<100;>100tol,000mg/kg
for EDRO-containing samples.   No calculations  are
required to compensate for the extract dilutions.

After the demonstration, SDI made minimal revisions to
the TPH results reported in the field. Specifically, of the
203 TPH results reported in the field at the end of the
demonstration, fewer than 5 percent were corrected based
on EPA review  of the data package.  The corrections
primarily involved data entry errors.

7.2.2  Health and Safety Concerns Associated
        with Device Operation

Sample analysis using the EnSys Petro Test System
requires  handling  of small  quantities  of  multiple,
potentially   hazardous   reagents   supplied   in
sealed containers.   These  reagents  include methanol
(100 percent); N,N-dimethylformamide (2 percent), the
hazardous component of tetramethylbenzidine; and sulfuric
acid (0.5 percent). Therefore, the user should employ good
laboratory practices during  sample analysis. Example
guidelines for good laboratory practices are described in
ASTM's "Standard Guide for Good Laboratory Practices
in Laboratories Engaged in  Sampling and Analysis of
Water" (ASTM 1998).

During the demonstration, SDI field technicians operated
the EnSys Petro Test System in modified Level D personal
protective equipment (PPE) to prevent eye and skin contact
with reagents. The PPE included safety glasses, disposable
gloves, and work boots as well as work clothes with long
sleeves and long pants. Sample analyses were performed
outdoors in a well-ventilated area; therefore, exposure to
volatile reagents through inhalation was  not a concern.
Health and safety information for reagents in the EnSys
Petro Test System is included in material safety data sheets
available from SDI.

The user should also exercise caution when handling the
dilution ampules, which are made of glass.  During the
demonstration, one SDI field technician received a minor
cut on a finger after accidentally touching the sharp edge
of an open dilution ampule.

7.2.3  Portability of the Device

The EnSys Petro  Test  System is  easily  transported
between  sampling areas in the field.   As stated in
Table 2-2, the system consists of three kits: the (1) Sample
Extraction Kit, (2)  12T Soil Test Kit, and (3) Common
Accessory Kit. Each Sample Extraction Kit weighs about
3  pounds and is housed in a cardboard box  that is
19 inches long, 7.25 inches wide, and 5 inches high. Each
12T Soil Test Kit weighs about 5 pounds and is housed in
a cardboard box that is 18.5 inches long, 7.5 inches wide,
and 5 inches high. Each Common Accessory Kit weighs
about 19 pounds and is housed in a hard-plastic carrying
case that is 19.5 inches long, 15 inches wide, and 6 inches
high. The differential photometer, which is included in
the Common Accessory Kit, weighs 0.8  pound and is
5.3 inches long, 3.4 inches wide, and 2.6 inches high. The
differential photometer, digital balance, and digital timer
are battery-operated. Because no AC power source is
required, the system can be easily transported between
sampling areas.
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To operate the EnSys Petro Test System, a shaded sample
preparation and analysis area is required. The area must be
large enough to accommodate the items  in one Sample
Extraction  Kit  and  one  Common  Accessory  Kit.
Disposable items in the 12T Soil Test Kit have designated
positions in the foam workstation included in the Common
Accessory Kit. According to SDI, the sample preparation
and analysis area must be shaded because the chromogen
(tetramethylbenzidine)  and  substrate  (hydrogen
peroxide) added during  the color development  step are
photosensitive and should be kept out of direct sunlight.
A staging area may also be required to store Sample
Extraction Kits  and 12T  Soil Test  Kits;  the size  of
the staging  area  depends on the  number  of  samples
to be analyzed and is  thus project-specific.   For the
demonstration, SDI performed sample preparation and
analysis under one  8-  by 8-foot tent that housed two
8-foot-long,  folding tables; three  folding  chairs; one
20-gallon laboratory pack for flammable waste; and one
55-gallon drum for general refuse.

7.2.4  Durability  of the Device

The Common Accessory Kit of the  EnSys Petro Test
System  contains several reusable items, including the
Artel DP™ differential  photometer, ACCULAB ® digital
balance, Gilson M-25 Microman® positive displacement
pipettor, and Eppendorf™ repeater pipettor. Based on
observations made during the demonstration, the EnSys
Petro Test System is a durable field measurement device;
none of the system's reusable items malfunctioned or was
damaged. These items are manufactured or distributed by
established scientific equipment suppliers and are housed
by SDI in a hard-plastic carrying case to prevent damage
to the items  during transport of the  Common Accessory
Kit.   The items were  also unaffected by the  varying
temperature and humidity conditions encountered between
8:00 a.m. and  5:00 p.m. on any  given day  of  the
demonstration.   During the daytime, the  temperature
ranged from about 17 to 24 °C, while the relative humidity
ranged from 53 to 88 percent. During sample analysis, the
light, disposable items in the system were housed in the
foam workstation, so wind speeds up to 20 miles per hour
also did not affect system operation.
7.2.5  A variability of the Device and Spare Parts

During the demonstration, none of the reusable items in
the EnSys Petro Test System required replacement.  Had
one of these items required replacement, it would not have
been available in local stores. A replacement item can be
obtained from SDI by overnight courier service if the order
is placed by 2:00 p.m.  eastern time.  If the need for a
replacement item is identified after 2:00 p.m. eastern time
and the item is needed  the next  day, the item might be
obtained from various  scientific equipment  suppliers,
depending on then- shipping procedures and  locations.
Spare parts for reusable items such as the differential
photometer are not included  in  the EnSys Petro Test
System.  SDI recommends that malfunctioning reusable
items be returned to SDI for service; according to SDI,
repairs should not be attempted in the field by the user.
Because SDI provides  a  1-year  warranty for reusable
items, SDI will replace such items and supply them to the
user  by overnight courier service at no additional cost
during the warranty period.

The power supply for the differential photometer consists
of four rechargeable,  nickel-cadmium  batteries.   The
batteries require 8 to 10 hours to achieve a full recharge
after discharge, and they supply enough power for about
500 readings between recharges. Because the batteries are
hard-wired into the differential photometer, it should be
returned to SDI for service if the  batteries malfunction.
The  power supplies for the digital balance  (one 9-volt
battery) and digital timer (one G-13  cell button battery)
can be purchased from local stores and replaced in the field
if necessary.

Disposable items in the EnSys Petro Test System should be
obtained from SDI. All the disposable items, including the
antibody-coated test tubes, are manufactured only by SDI.
The disposable items provided to a given user on a given
occasion all come from the same  lot.  Because SDI
conducts QC checks for each lot individually, if the user
performs analyses with  items from more than one lot or
uses  reagents obtained from a scientific supply store, SDI
assumes no responsibility for the quality of the sample
analysis results.
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                                              Chapter 8
                                         Economic Analysis
As discussed throughout this ITVR, the EnSys Petro Test
System  was demonstrated by using it to analyze soil
environmental samples, soil PE samples, and liquid PE
samples. The environmental samples were collected from
three  contaminated sites, and the  PE  samples  were
obtained from a commercial provider, ERA. Collectively,
the environmental and PE samples provided the different
matrix types and the different levels and types of PHC
contamination needed  to  perform   a  comprehensive
economic analysis for the EnSys Petro Test System.

During the demonstration, the EnSys Petro Test System
and the  off-site laboratory reference  method were each
used to perform more  than 200 TPH analyses.   The
purpose of the economic analysis was to estimate the total
cost  of  TPH  measurement  for the  EnSys  Petro Test
System and then compare this co st to that for the reference
method. The cost per analysis was not estimated for the
EnSys Petro Test System because the cost per analysis
would increase  as  the number  of samples  analyzed
decreased. This increase would be primarily the result of
the distribution of the initial capital equipment cost across
a smaller number of samples.  Thus, this increase in the
cost per analysis cannot be fairly compared to the reference
laboratory's fixed cost per analysis.

This chapter provides  information on  the  issues and
assumptions   involved  in   the  economic  analysis
(Section 8.1), discusses the costs associated with using the
EnSys Petro Test System (Section 8.2), discusses the costs
associated with using the reference method (Section 8.3),
and presents a comparison of the economic analysis results
for the EnSys Petro Test System and the reference method
(Section 8.4).
8.1    Issues and Assumptions

Several factors affect TPH measurement costs. Wherever
possible in this chapter, these factors are identified in such
a way that decision-makers can independently complete a
project-specific economic analysis.  The following five
cost categories were included in the economic analysis for
the demonstration:  capital equipment, supplies, support
equipment, labor, and IDW disposal.  The issues and
assumptions associated with these categories and the costs
not included in the analysis are briefly discussed below.
Because the reference method costs were based on a fixed
cost per analysis, the issues and assumptions discussed
below apply only to the EnSys Petro Test System unless
otherwise stated.

8.1.1   Capital Equipment Cost

The capital equipment cost was the cost associated with the
rental of the Common Accessory Kit, one of the  three
primary components of the EnSys Petro Test System used
during the demonstration. The Common Accessory Kit is
available for purchase or rental from SDI; the kit can be
rented from SDI on a daily, weekly, or monthly basis. The
kit can be rented on a daily basis for 9 percent of the
purchase price; as a result, the break-even point between
the purchase price and the daily rental cost is  12  days.
Because  the  kit was  used  for  2 days during the
demonstration, the  capital equipment cost was the cost
associated with the rental of the kit for 2 days, the less
expensive alternative. The purchase price and rental cost
information was obtained from  a  standard price list
provided by SDI.
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8.1.2  Cost of Supplies

The cost of supplies was estimated based on the supplies
required to analyze all demonstration samples using the
EnSys Petro Test System that were not included in the
capital equipment cost category.  Supplies used by SDI
during the demonstration included the disposable items of
two primary components of the EnSys Petro Test System:
the Sample Extraction Kit and 12T Soil Test Kit. During
the demonstration, the quantities of kits used by SDI were
noted each day.  The purchase price of each kit was
obtained  from a  standard price list provided by  SDI.
Because a user cannot return unused supplies, no salvage
value  for  supplies  that  were not  used  during  the
demonstration was included in the cost of supplies.

8.1.3  Support Equipment Cost

Because   the  EnSys  Petro  Test  System   contains
photosensitive reagents (chromogen and substrate), SDI
required  a shelter such as  a  tent to perform sample
analyses.  In addition, because of the large number of
samples analyzed during  the  demonstration,  the  EPA
provided support equipment, including tables and chairs,
for the field technicians' comfort during sample extraction
and analysis.  For the economic  analysis, the support
equipment costs were estimated based on price quotes from
independent sources.

8.1.4  Labor Cost

The labor cost was estimated based on the time required
for EnSys Petro Test System setup, sample preparation,
sample analysis, and summary data package preparation.
The  data package  included, at  a minimum,  a  result
summary  table,  a  run  log, and  any  supplementary
information submitted by SDI.  The measurement of the
time required for SDI to complete all analyses and submit
the data package to the EPA was rounded to the nearest
half-hour. For the economic analysis, it was assumed that
a field technician who had  worked for a fraction of a day
would be paid for an entire 8-hour day. Based on this
assumption, a daily rate for a field technician was used in
the analysis.

During the demonstration, EPA representatives evaluated
the skill level required for the field technicians to complete
analyses and calculate TPH concentrations. Based on the
field  observations,  a field technician  with basic wet
chemistry skills acquired on the job or in a university and
a few hours of device-specific training was considered to
be qualified to operate the EnSys Petro Test System. For
the economic analysis, an hourly rate of $16.63 was used
for a field technician (R.S. Means Company [Means]
2000), and a multiplication factor of 2.5 was applied to
labor costs in order to account for overhead costs. Based
on this hourly rate and multiplication factor, a daily rate of
$332.60 was used for the economic analysis.

8.1.5  Investigation-Derived Waste Disposal Cost

During the demonstration, SDI was provided with two
20-gallon laboratory packs for collecting hazardous wastes
generated (one for flammable wastes and one for corrosive
wastes) and was charged for each laboratory pack used.
Unused samples and sample extracts, residual solvent from
sample extractions  and dilutions,  used  EnCores, and
unused chemicals that could not be returned to SDI were
disposed of in a laboratory pack.  SDI was  required to
provide any containers necessary to containerize individual
wastes  prior  to then: placement in a laboratory pack;
however, SDI did not need additional containers.

During the demonstration, SDI generated an additional
4 gallons of liquid waste.  This waste, which consisted
of   spent  sample  extract,  detergent  solution,
tetramethylbenzidine, hydrogen peroxide, and sulfuric
acid, was collected in a 5-gallon bucket provided by the
demonstration site representatives.  Because the liquid
waste was determined to be noncorrosive, the contents of
the bucket were disposed of on site hi accordance with
demonstration site waste disposal guidelines, and the cost
for disposing of this waste was not included  in the IDW
disposal cost estimate.

Items such as used plastic weigh boats, wooden spatulas,
and PPE were  disposed of with municipal  garbage in
accordance  with demonstration  site waste disposal
guidelines; the  associated waste disposal cost was not
included in the IDW disposal cost estimate.

8.1.6  Costs Not Included

Items whose  costs were not included in  the economic
analysis are identified below along with a rationale for the
exclusion of each.

Oversight of Sample Analysis Activities.  A typical user
of the EnSys Petro Test System would not be required to
pay  for customer oversight of sample analysis. EPA
                                                    90

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representatives  audited  all  activities  associated  with
sample analysis during the demonstration, but costs for
EPA oversight were not included in the economic analysis
because these activities  were project-specific.  For the
same reason, costs for EPA oversight of the reference
laboratory were also not included in the analysis.

Travel and Per Diem  for Field Technicians.  Field
technicians  may  be available locally.   Because  the
availability of field technicians is primarily a function of
the location of the project site, travel and per diem costs
for field technicians were not included in the economic
analysis.

Sample Collection and Management. Costs for sample
collection and management activities, including sample
homogenization and labeling, were not included in the
economic analysis because these activities were project-
specific and were  not  device- or  reference method-
dependent.

Shipping.  Costs for shipping (1) the EnSys Petro Test
System to the demonstration site and (2) sample coolers to
the reference laboratory were not included in the economic
analysis  because  such  costs vary  depending on  the
shipping  distance and the service used (for example, a
courier or overnight shipping versus economy shipping).

Items Costing Less Than $10. The cost of inexpensive
items such as ice used for sample preservation in the field
was not included  in the  economic analysis because the
estimated cost was less than $10.

8.2    EnSys Petro Test System Costs

This section presents information on the individual costs of
capital equipment, supplies, support equipment, labor, and
IDW disposal for the EnSys Petro Test System as well as
a  summary of these  costs.  Additionally, Table  8-1
summarizes the EnSys Petro Test System costs.

8.2.1       Capital Equipment Cost

The capital equipment cost was the cost associated with
the  rental  of the  Common  Accessory  Kit  (Item
No. 6997020) for 2 days. Table 2-2 lists the items in the
Common  Accessory  Kit, which  are reusable.   The
Common Accessory Kit  can be purchased for $ 1,999 or
rented  on a  daily ($175), weekly ($450), or monthly
($800) basis. Because daily rental was the cheapest option
in the context of the demonstration, the daily rental cost
was used to calculate the capital equipment cost for the kit.
Thus, the  capital  equipment  cost of the  Common
Accessory Kit for the demonstration was $350.

Items in the Common Accessory Kit that can be purchased
separately from SDI if additional quantities are needed
include the Artel DP™ Differential Photometer ($1,000),
ACCULAB® digital balance ($135), digital timer ($29),
Eppendorf™ repeater pipettor ($507), and Gilson M-25
Microman® positive displacement pipettor ($325). During
the  demonstration,  the  photometer batteries required
recharging. Because the batteries could not be recharged
when the photometer was  in use,  SDI used a spare
photometer to complete TPH measurements. Because the
initial photometer was not damaged and did not require
repair, the cost of the spare photometer was not included in
the economic analysis.  Also, during the demonstration,
SDI  used three foam workstations to conduct sample
analyses, but only one foam workstation is included hi the
Common Accessory Kit.  Because SDI provides spare
foam workstations to users at no additional cost, no cost
for the two additional workstations was included in the
economic analysis.

8.2.2      Cost of Supplies

The cost of supplies was associated with the purchase of
Sample Extraction Kits (Item No. 70423 01EA) and 12T
Soil  Test Kits (Item No. 7042301).  Table  2-2 lists the
items in the Sample Extraction Kit and 12T Soil Test Kit,
which are disposable. During the demonstration, SDI used
18 Sample Extraction Kits at $120 each and 15 12T Soil
Test Kits at $366 each. Thus, the total cost of the supplies
used by SDI during the demonstration was $7,650.

Of the items in  the Sample Extraction Kit and 12T Soil
Test Kit, only a few items in the 12T Soil Test Kit can be
purchased separately if additional quantities are needed.
Items in the 12T Soil Test Kit that can be purchased
separately include the 5- and 12.5-mL Combitips ® for the
repeater pipettor at $1.20 each and the 50- to 250-uL
Microman® positive displacement pipettor tips, which can
be purchased in  packages of 12 ($10), 24 ($15), 60 ($25),
and 200 ($70).  During the demonstration, no additional
quantities of these items were required; all items required
to perform  TPH  measurements were  included  in the
Sample Extraction Kits and 12T Soil Test Kits used.
                                                    91

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Table 8-1. EnSys Petro Test System Cost Summary
Item
Capital equipment
Rental of Common Accessory Kit
Supplies
Sample Extraction Kit
12T Soil Test Kit
Support equipment
Tent
Tables and chairs (two each)
Labor
Field technicians
Investigation-derived waste disposal
Total Cost*
Quantity

1 unit for 2 days

18 units
1 5 units

1 unit
1 set for 1 week

5 person-days
1 20-gallon container

Unit Cost ($)

175/day

120
366

159
39

332.60
345.00

Itemized Cost ($)

350

2,160
5,490

159
39

1,663
345
$10,210
Note:
    The total dollar amount was rounded to the nearest $10.
8.2.3  Support Equipment Cost

SDI was provided with one 8- by 8-foot tent to prevent
decomposition of photosensitive reagents (chromogen and
substrate) and to protect the EnSys Petro Test System and
the field technicians from inclement weather during the
demonstration. SDI was also provided two tables and two
chairs for use during sample preparation and  analysis
activities.  The purchase cost for the tent ($159) and the
rental cost for two tables and two chairs for 1 week ($39)
totaled $198.

8.2.4  Labor Cost

To complete all sample analyses and prepare the summary
data package, three field technicians were required during
the first  day  of the  demonstration,  and two  field
technicians were required during the second day. Based on
a daily labor rate of $332.60 pe r person, the total labor cost
for the EnSys Petro Test System was $1,663.

8.2.5  Investigation-Derived Waste Disposal Cost

SDI used one laboratory pack  to  collect flammable
hazardous waste generated during the demonstration. The
IDW  disposal cost  included  the purchase  cost of the
laboratory pack ($38) and the cost associated with disposal
of the laboratory pack in a landfill ($307) (Means 2000).
The total IDW disposal cost was $345.
8.2.6  Summary of EnSys Petro Test System
       Costs

The total cost for performing more than 200 TPH analyses
using the EnSys Petro Test System and for preparing a
summary data package  was $10,210  (rounded to  the
nearest $10).  The  TPH analyses were performed for
66 soil environmental samples, 89 soil  PE samples, and
36 liquid PE samples.  In addition to these 191 samples,
12 extract duplicates were analyzed for specified soil
environmental samples.  When SDI performed multiple
dilutions or reanalyses  for a sample, these were not
included in the number of samples analyzed.

During the demonstration, SDI analyzed five samples in a
given analytical batch at three  detection levels.  Five
samples were the maximum number that could be analyzed
using one foam workstation. In addition to analyzing all
demonstration samples in such a manner, SDI reanalyzed
seven sample extracts.   Collectively, these  activities
required SDI to use one additional Sample Extraction Kit
and 10 additional 12T Soil Test Kits, or 6 and 200 percent
more of these components, respectively, than would
otherwise have been needed.  The additional Sample
Extraction Kit was required only to reanalyze the seven
sample extracts, whereas the additional 12T Soil Test Kits
were  required to perform all the  TPH measurement
activities.
                                                   92

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The total cost of $10,210 for analyzing the demonstration
samples using the EnSys Petro Test System included $350
for capital equipment;  $7,650  for  supplies;  $198 for
support equipment; $1,663 for labor; and $345 for IDW
disposal. Of these five costs, the two largest were the cost
of supplies (75 percent of the total cost) and the labor cost
(16 percent of the total cost).

8.3     Reference Method Costs

This  section  presents the costs associated  with the
reference  method  used to analyze the demonstration
samples for TPH.  Depending on the nature of a given
sample, the reference laboratory analyzed the sample for
GRO,  EDRO,  or  both  and  calculated  the  TPH
concentration  by  adding   the   GRO and  EDRO
concentrations, as appropriate. The reference method costs
were  calculated using unit cost information  from the
reference  laboratory  invoices.  To allow an accurate
comparison of the EnSys Petro Test System and reference
method costs, the reference method costs were estimated
for the same number of samples as was analyzed by SDL
For example, although the reference  laboratory analyzed
MS/MSD samples for TPH and all soil samples for percent
moisture, the  associated sample analytical costs were not
included in the reference method costs because SDI did not
analyze MS/MSD samples for TPH or soil samples for
percent moisture during the demonstration.

Table 8-2 summarizes the reference method costs, which
totaled  $41,290.  This cost covered  preparation  of
demonstration samples and then" analysis for TPH.  In
addition, at no additional cost, the reference laboratory
provided (1)  analytical  results  for internal  QC  check
samples such as method blanks and LCS/LCSDs and (2) an
electronic data deliverable and two paper copies of full,
EPA Contract Laboratory  Program-style' data packages
within 30  calendar  days of the  receipt of  the  last
demonstration sample by the reference laboratory.

8.4     Comparison of Economic Analysis Results

The total costs for the EnSys Petro Test System ($10,210)
and  the reference  method  ($41,290)  are listed  in
Tables  8-1  and  8-2,  respectively.   The  total  TPH
measurement cost for the EnSys Petro Test System was
75 percent less than that for  the reference  method.
Although the  EnSys Petro Test System analytical results
did not have the same level of detail (for example,
quantitative  data) as  the  reference method analytical
results or comparable QA/QC data, the EnSys Petro Test
System provided semiquantitative TPH analytical results
on site at significant cost savings. In addition, use of the
EnSys Petro Test System in the field will likely produce
additional cost  savings  because the results  will  be
available within  a  few  hours of sample  collection;
therefore, critical  decisions  regarding  sampling  and
analysis can be made in the field, resulting in a more
complete data set.  However, these savings cannot be
accurately estimated and thus were not included in the
economic analysis.
Table 8-2. Reference Method Cost Summary
Item
Soil environmental samples
GRO
Extract duplicates
EDRO
Extract duplicates
Soil performance evaluation samples
GRO
EDRO
Liquid performance evaluation samples
GRO
EDRO
Total Cost*
Number of Samples Analyzed

56
10
66
12

55
89

27
24

Cost per Analysis ($)

111
55.50
142
71

111
142

111
106.50

Itemized Cost ($)

6,216
555
9,372
852

6,105
12,638

2,997
2,556
$41,290
Note:
    The total dollar amount was rounded to the nearest $10.
                                                    93

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                                              Chapter 9
                               Summary of Demonstration Results
As discussed throughout this ITVR, the EnSys Petro Test
System was demonstrated by using it to analyze 66 soil
environmental samples, 89 soil PE samples, and 36 liquid
PE samples. In addition to these 191 samples, 12 extract
duplicates prepared using the environmental samples were
analyzed. The environmental samples were collected from
four individual areas at three contaminated sites, and the
PE samples were obtained from a commercial provider,
ERA. Collectively, the environmental and PE samples
provided the different matrix types and the different levels
and types of PHC contamination needed to perform a
comprehensive evaluation of the EnSys Petro Test System.

The EnSys Petro Test System performance and cost data
were compared to those for an off-site laboratory reference
method, SW-846  8015B (modified).  As discussed in
Chapter 6, the reference method results were considered to
be of adequate quality for the following reasons: (1) the
reference  method  was  implemented with  acceptable
accuracy (±30 percent) for all the samples except low- and
medium-concentration-range  soil  samples  containing
diesel, which made up only 13 percent of the total number
of samples analyzed during the demonstration, and (2) the
reference method was implemented with good precision
for all samples.  The reference method results generally
exhibited  a negative bias.   However, the bias was
considered to be significant primarily for  low- and
medium-range soil  samples  containing diesel.    The
reference   method  recoveries  observed  during the
demonstration were typical of the recoveries obtained by
most  organic analytical methods for  environmental
samples.
This chapter compares the performance and cost results
for the  EnSys Petro Test System  with  those  for the
reference method, as appropriate.  The performance and
cost results are discussed in detail in Chapters 7 and 8,
respectively. Tables 9-1 and 9-2 summarize the results for
the primary and secondary objectives, respectively.  As
shown in these tables, during the demonstration, the EnSys
Petro Test System exhibited the  following desirable
characteristics  of  a  field  TPH  measurement  device:
(1) good precision  and (2) high sample throughput.  In
addition, the EnSys  Petro Test System exhibited moderate
measurement costs.

A significant number of the EnSys Petro Test System TPH
results were determined to be inconclusive because the
detection level  used by SDI were not  appropriate  to
address the demonstration objectives.  Overall, the device's
results did not compare well with those of the reference
method; in general, the device exhibited a high positive
bias. In addition, the device showed a significant response
to several interferents that are not PHCs—for example,
>25 percent to PCE; >24  percent to turpentine; and
>28 percent to  1,2,4-trichlorobenzene.  These findings
indicated that the accuracy of TPH measurement using the.
device will likely  be impacted by  the presence  of
halogenated solvents, naturally occurring  oil and grease,
and chlorinated semivolatile organic contaminants such as
chlorinated  pesticides  and   PCBs  in  soil  samples.
Collectively, the demonstration findings indicated that the
user should exercise caution when considering the device
for a site-specific field TPH measurement application.
                                                   94

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Table 9-1. Summary of EnSys Petro TestSystem Results for the Primary Objectives
 Primary Objective
                Evaluation Basis'
                                                                                                               Performance Results
                                                         EnSys Petro Test System
                                                          Reference Method
 P1
     Determine the method
     detection limit
Method detection limit based on TPH analysis of
seven low-concentration-range diesel soil PE
samples
The device's TPH concentation ranges for six
of seven samples overlapped the reference
method results.
6.32 mg/kg
 P2  Evaluate the accuracy
     and precision of TPH
     measurement
Pairwise comparison of EnSys Petro Test System and
reference method TPH results for (1) 66 soil
environmental samples collected from four areas;
(2) 28 soil PE samples, including blank, weathered
gasoline, and diesel soil samples; and (3) 6 liquid PE
samples consisting of neat weathered gasoline and
diesel
The EnSys Petro Test System results for 16 of 66 sd environmental samples were inconclusive.  Of the
remaining 50 results, the device's TPH concentraton ranges overlapped the reference method results
for only 8 samples (16 percent); 36 EnSys Petro Test System results were biased high, and 6 results
were biased low.

The EnSys Petro Test System results for 12 of 28 sd PE samples were inconclusive. Of the remaining
16 results, the device's TPH concentration rangesoverlapped the reference method results for only
5 samples (31 percent); 9 EnSys Petro Test Systenresults were biased high, and 2 results were biased
low.

The EnSys Petro Test System results for £ 6 liquid PE samples were inconclusive.
                           Comparison of project-specific action level
                           conclusions of the EnSys Petro Test System with
                           those of the reference method for 66 soil
                           environmental and 34 soil PE samples
                                                The EnSys Petro Test System results for 3 of 66 sd environmental samples were inconclusive. Of the
                                                remaining 63 results, the device's conclusions agreed/vith those of the reference method for 41 samples
                                                (65 percent); 21  EnSys Petro Test System concluains were false positives, and 1 was a false negative.

                                                The EnSys Petro Test System results for 14 of 34 sd PE samples were inconclusive. Of the remaining
                                                20 results, the device's conclusions agreed wittthose of the reference method for 15 samples
                                                (75 percent); 3 EnSys Petro Test System conclusiona/vere false positives, and 2 were false negatives.
                           Overall precision for soil environmental, soil PE, and
                           liquid PE sample replicates
                                                Soil environmental samples (11 triplicate sets)
                                                    The TPH concentration ranges were the
                                                    same for each field triplicate set.
                                                                           Soil PE samples (8 replicate sets)
                                                                               The TPH concentration ranges were the
                                                                               same for 6 of the 8 sets of replicates. Of
                                                                               the remaining 2 replicate sets, only one
                                                                               sample TPH concentration range in each
                                                                               set was different from the others.
                                                                           Liquid PE samples (2 triplicate sets)
                                                                               The TPH concentration ranges were the
                                                                               same for each triplicate set.
                          Analytical precision forextract duplicates for soil
                          environmental samples (12 for the EnSys Petro Test
                          System and 12 for the reference method)
                                                The TPH concentration ranges were the same
                                                for each extract duplicate set.
                                         Soil environmental samples (11 triplicate sets)
                                              RSD range: 4 to 39 percent
                                              Median RSD: 16 percent
                                                                                         Soil PE samples (7 replicate sets)
                                                                                              RSD range: 5 to 13 percent
                                                                                              Median RSD: 8 percent
                                                                                         Liquid PE samples (2 triplicate sets)
                                                                                              RSDs: 5 and 6 percent
                                                                                              Median RSD: 5.5 percent
                                         RPD range: 0 to 11
                                         Median RPD: 3

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Table 9-1.  Summary of EnSys Petro Test Sysfem Results for the Primary Objectives (Continued)
Primary Objective
P3 Evaluate the effect of
interferents on TPH
measurement
P4 Evaluate the effect of
soil moisture content
on TPH measurement
P5 Measure the time
required for TPH
measurement (sample
throughput)
P6 Estimate TPH
measurement costs
Evaluation Basis'
Mean responses for neat materials, including MTBE;
PCE; Stoddard solvent; turpentine; and
1 ,2,4-trichlorobenzene, and for soil spiked with
humic acid (two triplicate sets each)
Comparison of TPH results (simple, nonstatistical
comparison for the EnSys Petro Test System and
one-way analysis of variance for the reference
method) for weathered gasoline and diesel soil PE
samples without and with interferents at two levels
Interferents for weathered gasoline soil PE samples:
MTBE, PCE, Stoddard solvent, and turpentine
Interferents for diesel soil PE samples: Stoddard
solvent; turpentine; 1 ,2,4-trichlorobenzene; and
humic acid
Comparison of TPH results (simple, nonstatistical
comparison for the EnSys Petro Test System and
two-sample Student's t-test for the reference method)
for weathered gasoline and diesel soil PE samples at
two moisture levels: 9 and 16 percent for weathered
gasoline samples and less than 1 and 9 percent for
diesel samples
Total time from sample receipt through preparation of
the draft data package
Total cost (costs of capital equipment, supplies,
support equipment, labor, andlDW disposal) for TPH
measurement of 66 soil environmental samples,
89 soil PE samples, 36 liquid PE samples, and
12 extract duplicates
Performance Results
EnSys Petro Test System
MTBE: 0 percent
PCE: >25 percent
Stoddard solvent: >26 percent
Turpentine: >24 percent
1,2,4-Trichlorobenzene: >28 percent
Humic acid: 0 percent
The TPH results were inconclusive for all
interferents.
The TPH results were inconclusive for both
weathered gasoline and diesel soil PE
samples.
39 hours, 35 minutes, for TPH measurement
of 66 soil environmental samples, 89 soil PE
samples, 36 liquid PE samples, and 12 extract
duplicates
$10,210 (including the daily rental cost of the
EnSys/EnviroGard* Common Accessory Kit,
which can be purchased for $1 ,999)
Reference Method
MTBE: 39 percent
PCE: 17.5 percent
Stoddard solvent: 85 percent
Turpentine: 52 percent
1 ,2,4-Trichlorobenzene: 50 percent
Humic acid: 0 percent
MTBE, a petroleum hydrocarbon, did not cause
statistically significant interference at either of the two
levels.
PCE caused statistically significant interference only at
the high level.
Stoddard solvent, a petroleum hydrocarbon, caused
statistically significant interference at both levels for
weathered gasoline and diesel samples.
Turpentine caused statisticallysignificant interference
(1 ) at both levels for weathered gasoline samples and
(2) only at the high level for diesel samples.
1,2,4-Trichlorobenzene causedstatistically significant
interference only at the high level.
Humic acid results were inconclusive.
Soil moisture content did not have a statistically
significant impact.
30 days for TPH measurement of 74 soil environmental
samples, 89 soil PE samples, 36 liquid PE samples, and
13 extract duplicates
$41,290

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Table 9-1. Summary of EnSys Petro Test Sysfem Results for the Primary Objectives (Continued)

Notes:
>      =  Greater than                  PCE
IDW   =  Investigation-derived waste      PE
mg/kg  =  Milligram per kilogram          RPD
MTBE  =  Methyl-tert-butyl ether          RSD
Tetrachloroethene
Performance evaluation
Relative percent difference
Relative standard deviation
    All statistical comparisons were madeat a significance level of 5 percent.

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Table 9-2.  Summary of EnSys Petro Test System Results for the Secondary Objectives
Secondary Objective
S1
S2
S3
S4
S5
Skill and training
requirements for proper
device operation
Health and safety concerns
associated with device
operation
Portability of the device
Durability of the device
Availability of device and
spare parts
Performance Results
The device can be operated by one person with basic wet chemistry skills.
The device's user guides are considered to be adequate training materials for proper device operation.
The sample analysis procedure for the device can be learned in the field with a few practice attempts.
Minimal effort is required to estimate a TPH concentration range using the device; the sign (negative or
positive) associated with the differential photometer reading allows the user to determine the TPH
concentration range for a given sample. At the end of the demonstration, SDI reported 203 TPH results.
Of these, fewer than 5 percent required corrections, which primarily involved data entry errors.
No significant health and safety concerns were noted; when the device is used in a well-ventilated area,
basic eye and skin protection (safety glasses, disposable gloves, work boots, and work clothes with long
sleeves and long pants) should be adequate for safe device operation.
The device is battery-operated and requires no alternating current power source. The device can be easily
moved between sampling areas in the field, if necessary.
The device is housed in a hard-plastic carrying case to prevent damage to the device. During the
demonstration, none of the device's reusable items malfunctioned or was damaged. The moderate
temperatures (17 to 24 °C) and high relative humidities (53 to 88 percent) encountered during the
demonstration did not affect device operation.
All items in the device are available from SDI. During a 1-year warranty period, SDI will supply replacement
parts for the device by overnight courier service at no cost unless the reason for a part failure involves
misuse of the device.
                                                           98

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                                            Chapter 10
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Fritz,  James  S.,  and  George  H.  Schenk.    1987.
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   Inc. Boston, Massachusetts. Fifth Edition.

Gary,  J.H., and  G.E. Handwerk.  1993.   Petroleum
   Refining: Technology and Economics. Marcel Dekker,
   Inc. New York, New York.

Massachusetts Department of Environmental Protection.
   2000. "VPH/EPH Documents." Bureau of Waste Site
   Cleanup. Accessed on April 13.  On-Line Address:
   www.state.ma.us/dep/bwsc/vp  eph.htm
Means.    2000.    Environmental Remediation
   Data-Unit Price. Kingston, Massachusetts.
Cost
Provost,  Lloyd  P., and Robert  S. Elder.    1983.
    "Interpretation of Percent Recovery Data." American
    Laboratory. December. Pages 57 through 63.

Rittenburg, James  H.    1990.   Development  and
    Application of Immunoassay for Food Analysis.
    Elsevier Applied Science. London, England, and New
    York, New York.
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SDI. 1999. "PETRO Soil Test Technical Guide."         Zilis, Kimberly, Maureen McDevitt, and Jerry Parr. 1988.
                                                        "A  Reliable Technique for Measuring Petroleum
SDI.    2000.     "Harnessing  the  Antibody—The       Hydrocarbons in the Environment." Paper Presented
    Fundamentals of Enzyme Immunoassay."                 at the Conference on Petroleum Hydrocarbons and
                                                        Organic Chemicals in Groundwater.  National Waste
Speight, J.G.  1991. The Chemistry and Technology of       Water Association. Houston, Texas.
    Petroleum.  Marcel Dekker, Inc.  New York, New
    York.

Texas Natural Resource Conservation Commission. 2000.
    "Waste Updates."  Accessed on April 13. On-Line
    Address:   www.tnrcc.state.tx.us/permitting/
    wastenews.htm#additional
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                                                Appendix
                     Supplemental Information Provided by the Developer
This appendix contains supplemental information provided
by SDL  After the introduction, this appendix discusses
sample screening and device specificity.

Introduction

The  EnSys  Petro  Test  System used  in the  SITE
demonstration is one of 10 distinctly different devices that
SDI offers for on-site TPH measurement. The selection of
the "best" device for a particular application depends on
the type  of contamination  present, the  contaminant
concentrations expected, the data quality objective (such as
semiquantitative or  quantitative  data),  the number of
samples to be analyzed,  cost, and other considerations.
Usually most of these variables are known before on-site
analysis begins, and an SDI representative assists the user
in selecting the appropriate device.

For the demonstration, the EnSys Petro Test System was
chosen because it responds well to a variety of fuel types,
particularly gasoline and diesel.  The EnSys Petro Test
System does not detect heavier fuels or measure aliphatic
hydrocarbon compounds. The device has a wide dynamic
range and is listed in EPA SW-846 Method 4030.

Sample Screening (Erring on the Positive  Side)

The EnSys Petro Test System is a semiquantitative device
that  rapidly screens soil samples for the  presence of
petroleum fuel compounds; the device effectively detects
the presence of PHCs. Because the antibody employed in
this device has a different sensitivity to each of the various
petroleum products, if the  device is calibrated using a
"typical" fuel calibrator, the device will not quantitatively
report results for a specific petroleum product.  Where
there are mixtures of fuels, such as in the samples used in
the SITE demonstration, the EnSys Petro Test System is
calibrated to the least reactive fuel known to be present in
order to ensure that all PHCs are detected. This approach
can lead to elevated results for those PHCs to which the
device is most  sensitive.  To perform a quantitative
determination for a petroleum product, the fuel type
present must be known and the device must be calibrated
accordingly.

The EnSys Petro Test  System is set up to have a positive
bias of about 30 percent in order to ensure that even when
the device is calibrated with the specific petroleum product
of  interest,  the  concentrations  present  will not  be
underreported. This is particularly important in screening
scenarios where a nondetect or low-level result could have
serious  consequences; an  elevated result  is  clearly a
positive and at worst will trigger additional testing. Not all
SDI measurement devices are biased high; however, it is
important to be conservative  with a device frequently
employed in screening for hot spots.

Device Specificity

The ORO  or  heavy-range  petroleum  products will
probably not be detected  with the EnSys Petro Test
System. The device is used almost exclusively for GRO
and DRO measurement.
 This appendix was written solely by SDI. The statements presented in this appendix represent the developer's point of view and summarize the
 claims made by the developer regarding the EnSys Petro Test System. Publication of this material does not represent the EPA's approval or
 endorsement of the statements made in this appendix; performance assessment and economic analysis results for the EnSys Petro Test System are
 discussed in the body of this ITVR.
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If a site contains a  mixture of gasoline and diesel
compounds,  a  simple correlation between device and
laboratory  results  for the same samples will allow
appropriate device calibration prior to field analysis.

The liquid  samples analyzed in the demonstration clearly
had high TPH concentrations.  Despite the high TPH
concentrations, the device could not detect PHCs in some
samples. Until SDI understands the exact nature of these
samples, it cannot address the device's performance during
the demonstration.

During the  demonstration, SDI used three detection levels
to estimate the TPH concentration ranges for all samples.
These detection levels were not always consistent with the
project-specific action levels, which varied depending on
sample source and type.  As a result, many TPH results
that were reported as > 1,000 mg/kg were determined to
be  inconclusive when compared to the action levels
(1,500 and 2,000 mg/kg) that were above the highest
detection level (1,000 mg/kg).

For several samples analyzed dur ing the demonstration, the
EnSys Petro Test System exhibited a more consistent
response than the reference method, as was indicated by
the precision associated with the replicate sample TPH
measurements.

Soil  samples analyzed during the demonstration were
collected from different locations around the country and
thus  were not typical  of a single site.   A preliminary
comparison  of EnSys Petro Test System and reference
method TPH results would allow the user to develop a
conversion factor that would take into account site-specific
factors, including soil type and contamination weathering.
Application of such a conversion factor would result in
better comparability between the device and reference
method TPH results.
 This appendix was written solely by SDI. The statements presented in this appendix represent the developer's point of view and summarize the
 claims made by the developer regarding the EnSys Petro Test System. Publication of this material does not represent the EPA's approval or
 endorsement of the statements made in this appendix; performance assessment and economic analysis results for the EnSys Petro Test System are
 discussed in the body of this ITVR.
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