&EPA
         United States
         Environmental Protection
         Agency
           Office of
           Research and Development
           Washington, DC 20460
EPA/600/R-03/148
May 2004
Innovative Technology
 Verification Report
   Field Measurement Technology for
     Mercury in Soil and Sediment

      NITON'S XLi/XLt 700 Series
     X-Ray Fluorescence Analyzers

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                                 EPA/600/R-03/148
                                 May 2004
     Innovative Technology
       Verification Report


  NITON'S XLi/XLt 700  Series
X-Ray Fluorescence Analyzers
                 Prepared by

        Science Applications International Corporation
                Idaho Falls, ID
             Contract No. 68-C-00-179
              . 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
The U.S. Environmental Protection Agency through its Office of Research and Development funded
and managed the research described here under contract  to Science Applications International
Corporation. It has been subjected to the Agency's peer and administrative review and has been
approved for publication as an EPA document. Mention of trade names or commercial products does
hot constitute endorsement or recommendation for use.

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                    Office of Research and Development
                                         Washington, DC 20460

               MEASUREMENT AND MONITORING TECHNOLOGY PROGRAM
                                 VERIFICATION STATEMENT

TECHNOLOGY TYPE: Field Measurement Device

APPLICATION: Measurement for Mercury

TECHNOLOGY NAME: NITON'sฎ XLi/XLt 700™ Series Environmental Analyzers

COMPANY:    NITON LLC
ADDRESS:    900 Middlesex Turnpike, Building 8
              Billerica, Massachusetts 01821

WEB SITE: www.niton.com

TELEPHONE: (978) 670-7460

VERIFICATION PROGRAM DESCRIPTION

The U.S. Environmental Protection Agency (EPA) created the Superfund Innovative Technology Evaluation (SITE) and
Measurement and Monitoring Technology (MMT) Programs to facilitate deployment of innovative technologies through
performance verification and  information dissemination. The goal 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 the demonstrations of two XLi/XLt 700 Series X-ray Fluorescence
Analyzers developed by NITON Inc.

PROGRAM OPERATION

Under the SITE and MMT Programs, with the full participation of the technology developers, the EPA evaluates and
documents the performance of innovative technologies by developing demonstration plans, conducting field tests,
collecting and analyzing demonstration data, and preparing reports. The technologies are evaluated under rigorous
quality assurance (QA) protocols to produce well-documented data of known quality.  The EPA National  Exposure
Research Laboratory, which demonstrates field sampling, monitoring, and measurem enttechnologies, selected Science
Applications International Corporation as the verification organization to assist in field testing five field measurement
devices for mercury in  soil and sediment.  This demonstration was funded by the SITE  Program.

DEMONSTRATION DESCRIPTION

In May 2003, the EPA conducted a field demonstration of the XLi/XLt 700 Series Analyzers XLi 702 (isotope) and XLt
792 (X-ray tube) and four other field measurement devices for mercury in soil and sediment. This verification statement
focuses on these two  analyzers; a similar statement has been prepared for each of the other four devices.  The
performance of each of these two X-ray fluorescence analyzers was compared to that of an off-site laboratory using
the reference  method, "Test Methods for Evaluating Solid Waste" (SW-846) Method 7471B (modified). To verify a wide
range of performance attributes, the demonstration had both primary and secondary objectives. The primary objectives
were:

    (1) Determining the instrument sensitivity with  respect to  the Method  Detection Limit (MDL) and Practical
      Quantitation Limit (PQL);
    (2) Determining the analytical accuracy associated with the field measurement technologies;
    (3) Evaluating the  precision of the field measurement technologies;

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     (4) Measuring the amount of time required for mobilization and setup, initial calibration, daily calibration, sample
       .analysis, and demobilization; and
     (5) Estimating the costs associated with mercury measurements for the following four categories: capital, labor,
        supplies, and  investigation-derived waste (IDW).

Secondary objectives for the demonstration included:

     (1) Documenting  the ease of use, as well as the skills and training required to properly operate the devices;
     (2) Documenting  potential health and safety concerns associated with operating the devices;
     (3). Documenting  the portability of the devices;
     (4) Evaluating the devices durability based on their materials of construction and engineering design; and
     (5) Documenting the availability of the devices and associated spare parts.

The XLi/XLt 700 Series Analyzers analyzed 62 field soil samples, 23 field sediment samples, 42 spiked field samples,
and 70 performance evaluation (PE) standard reference material (SRM) samples in the demonstration. The field
samples were collected in four areas contaminated with mercury, the spiked samples were from these same locations,
and the PE samples were obtained from  a commercial provider.

Collectively, the field and PE samples provided the different matrix types and the different concentrations of mercury
needed to perform a comprehensive evaluation of the XLi/XLt 700 Series Analyzers. A complete description of the
demonstration and a summary of the results are available  in the Innovative Technology Verification Report: "Field
Measurement Technology for Mercury in  Soil and Sediment—NITON's  XLi/XLt 700 Series X-Ray Fluorescence
Analyzers" (EPA/600/R-03/148).

TECHNOLOGY DESCRIPTION

The NITON XL 700 series analyzer is an energy dispersive X-ray fluorescence (EDXRF) spectrometer that uses either
a Cd-109 radioactive isotope (XLi mod el) or a low powered miniature X-ray tube with  a silver target (XLt model) to excite
characteristic X-rays of a test sample's constituent elements. These characteristic X-rays are continuously detected,
identified, and quantified by the spectrometer during  sample analysis. The energy of each X-ray detected identifies a
particular element  present in the sample, and the rate at which X-rays of a given  energy are counted provides a
determination of the quantity of that element that is present in the sample.

Detection ofthe characteristic mercury X-rays is achieved using a highly-efficient, therm o-electrically cooled,solid-state
detector. Signals from this detector are amplified, digitized, and then quantified via  integral multichannel analysis and
data processing units.  Results are displayed in ppm (mg/kg) of total elemental mercury.

The NITON XLt 700 Series Analyzer with X-ray tube excitation provides the user with the speed and efficiency of X-ray
tube excitation, while reducing the regulatory demands typically encountered with isotope-based systems.  In most
cases, the X-ray tube  equipped XLt  700 analyzer can be shipped  between most states and countries with minimal
paperwork and  expense. The XLi and XLt 700 Series Analyzers offer testing modes for soil and other bulk samples;
filters, wipes and other thin samples;  and lead-based paint. Testing applications include management of remediation
projects, site assessments, and compliance testing. They provide simultaneous analysis of up to 25 elements, including
all eight of the characteristic metals underthe Resource Conservation and Recovery Act (RCRA). XRF analysis is non-
destructive, so screened samples can be sent to an accredited laboratory for confirmation of results obtained on-site.

NITON's software corrects automatically for variations in soil matrix and density, making it applicable for both in-situ
and intrusive testing.

ACTION LIMITS

Action limits and concentrations of interest vary and are project specific. There are, however, action  limits which can
be considered as potential reference points. The EPA Region IX Preliminary Remedial Goals  (PRGs) for mercury are
23 mg/kg in residential soil and 310 mg/kg in industrial soil.
                                                    IV

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VERIFICATION OF PERFORMANCE

To  ensure data  usability,  data  quality  indicators  for accuracy,  precision, representativeness, completeness,
comparability, and sensitivity were assessed for the reference method based on project-specific QA objectives. Key
demonstration findings are summarized below for the primary objectives.

Sensitivity: The two primary sensitivity evaluations performed for this demonstration were the MDL and PQL.  Both
will vary dependent upon whether the matrix is a soil, waste, or aqueous solution.  Only soils/sediments were tested
during this demonstration, and therefore, MDL calculations and PQL determinations for this evaluation are limited to
those matrices.  By definition, values measured below the PQL should not be considered accurate or precise and those
below the MDL are not distinguishable from background noise.

Method Detection Limit - The evaluation of an MDL requires seven different measurements of a  low concentration
standard or sample following the procedures established in the 40 Code of Federal Regulations (CFR) Part 136, the
range of the MDL for the NITON X-ray tube instrument is between 13.9 and 69.8 mg/kg.  It is  likely that the MDL is
closer to the lower end of this range based upon the results for sample lot 62 (referee laboratory value = 14.6 mg/kg)
and sample lot 47 (SRM value = 32.4 mg/kg) which both had one of the seven results reported as below the NITON
detection level indicating  that these values are on the edge of  the instruments detection capability.  The lowest
calculated MDL for the NITON Isotope instrument is 39.3 mg/kg. Based, upon results presented in the report, the MDL
for the NITON Isotope field instrument is close to 32 mg/kg. The equivalent calculated MDL for the  referee laboratory
is 0.0026 mg/kg.

Practical Quantitation Limit- The NITON X-ray PQL is somewhere between 62.9 mg/kg and 99. 8 mg/kg.  The %D for
the 99.8 mg/kg SRM is 8.2%. The NITON Isotope PQL is also between 62.9 mg/kg and 99.8 mg/kg. The %D for the
99.8 mg/kg SRM is 9.2%.  The referee laboratory PQL confirmed during the demonstration is 0.005mg/kg, with a %D
Accuracy: The results from the XLi/XLt 700 Series Analyzers were compared to the 95% prediction interval for the SRM
materials and to the referee laboratory results (Method 7471.B).  NITON X-ray data were within SRM 95% prediction
interva Is 93% of thetime, which suggests significantequivalence to certified standards. NITON Isotope data were within
SRM 95% prediction intervals 91% of the time, which also suggest significant equivalence to certified standards.

The statistical comparison between the NITON X-ray field data and the referee laboratory results suggest that the two
data sets are not the same. The statistical comparison between the NITON Isotope fie Id data and the referee laboratory
results also suggest that these two data sets are not the same.  Because the NITON data compare favorably to the
SRM values, the differences between NITON and the referee laboratory are likely the result of matrix interferences for
field sample analysis. The number of NITON X-ray average values less than 30% different from the referee laboratory
results or SRM reference values; however, was 14 of 26 different sample lots.  Only 1 of 26 NITON average results
have relative percent differences greater than 100% for this same group of samples.  The number of NITON  Isotope
average values less than 30% different from the referee laboratory results or SRM  reference values was 14 of 24
different sample lots. Zero of 24 NITON Isotope average results  have relative percent differences greater than 100%
for this same group of samples. Both NITON X-ray and NITON Isotope results; therefore, can provide a reasonable
estimate of accuracy for field determination.

Precision: The precision of the NITON X-ray and NITON Isotope field instruments is betterthen the referee laboratory
precision. The overall average RSD is 20.0% for the referee laboratory, compared to the NITON X-ray overall average
RSD of 13.1% and the NITON Isotope overall average RSD of 14.4%. Both the laboratory and NITON precision goals
are within the predicted  25% RSD objective for precision expected from both  analytical and sampling variance.

Measurement Time: From the time of sample receipt, NITON required 17.5 hours (35 man hours) to prepare a draft
data package of mercury results for 197 samples for both devices. Two  technicians performed all setup,  sample
preparation and analysis, and equipment demobilization. Individual measurements took approximately 120 seconds
each (after sample preparation), but the total time per analysis averaged 5.3 minutes when all field activities and data
package preparation were included and only one technician per device .is included in  the calculation.

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Measurement Costs: The cost per analysis based upon 197 samples, wherr renting the XLi 702, is $39.52 per sample.
The cost per analysis for the 197 samples, excluding rental fee, is $13.18 per sample. Based on the 3-day field
demonstration, the total cost for equipment rental and necessary supplies is estimated at $7,786. The cost breakout
by category is: capital costs, 66.7%; supplies, 3.6%; support equipment, 3.5%; labor, 7.7%; and IDW, 18.5%.

The cost peranalysis based upon 197 samples, when renting the XLt 792, is $47.69 persample. The cost per analysis
for the 197 samples, excluding rental fee, is $13.18 persample. Based on the 3-day field demonstration, the total cost
for equipment rental and necessary supplies is estimated at $9,396. The cost breakout by category is: capital costs,
72.4%; supplies, 3.0%; support equipment, 2.9%; labor, 6.4%; and IDW, 15.3%.

Key demonstration findings are summarized below for the secondary objectives.

Ease of Use: Based on observations made during the demonstration, the XLi/XLt 700  Series Analyzers are very easy
to operate, requiring one  field technician with a high school education. A  free 8-hour training course on instrument
operation and radiation safety is mandatory prior to operating the instruments. The analyzers contain an integrated
touch-screen display with an advanced and intuitive user interface.

Potential Health  and Safety Concerns: No significant  health and safety concerns were noted during  the
demonstration.  Potential  exposure to radiation from the excitation sources (Cd-109, Am-241, Fe-55 and X-ray tube)
was the only health and safety concern during the demonstration. The analyzers should never be pointed at anyone
while the sources are exposed.  No solvents  or acids are used for sample preparation. According to NITON, the
sources are designed to remain secure even under extreme conditions, so that even if the instrument is broken, crushed
or burned there should be no leakage of radioactive material.

Portability: The XLi/XLt 700 Series Analyzers are handheld portable single piece units  weigh only 0.8 kg (XLi 702) and
1.4  kg (XLt 792). There are no cables and no separate processing units. The analyzers have an attractive ergonomic
form. During the demonstration, the analyzers each operated on  1 battery pack that lasted for 4-8 hours.

Durability: Based on observations during the demonstration, the analyzers were-well constructed, field-rugged and
durable. They are constructed of high-strength  injection molded plastic. During the three days in which the instrument
was observed, there was  no downtime, maintenance or repairs. The equipment apparently was not affected by the
almost continuous  rain.

Availability of the Devices: The XLi/XLt 700 Series Analyzers are readily available for lease or purchase. During
most of the year, NITON is typically able to rent an analyzer to a customer in 10-14 days  (10 isotope rentals and 3 X-ray
tube rentals).  There are also radiation licensing requirements forthese devices.  NITON offers over 100 user/radiation
training classes to help expedite the process. Supplies not provided by NITON are readily available from supply firms.

PERFORMANCE SUMMARY

In summary, during the demonstration, the XLi 702 and XLt 792 exhibited the following desirable characteristics of a
field mercury measurement device: (1) good  accuracy compared to standard reference materials, (2) good precision,
(3) high sample throughput, (4) low measurement costs, and  (5) ease of use. During  the demonstration the XLi 702
and XLt 792 were found to have the following limitations: (1) a PQL that exceeds the residential soil PRG action limit.
The XLi/XLt 700 Series Analyzers are handheld devices for rapid field measurements of mercury in soil and sediment.
  NOTICE: EPA verifications are based on an evaluation of technology performance under specific, predetermined criteria and appropriate
  quality assurance procedures. The EPA makes 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.
                                                    VI

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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 knowledge base needed to manage ecological resources wisely, understand
how pollutants affect public health, and prevent or reduce environmental risks.

The National Exposure Research Laboratory is the Agency's center  for investigation of technical and management
approaches for identifying 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 (RCRA) 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 monitoring and measurement technologies are needed to assess the degree of contamination ata site, provide
data that can be used to determine the risk to public health or the environment, 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 federal government or the private sector. Through the SITE Program,
developers  are given the opportunity to  conduct a  rigorous demonstration of their  technologies under actual field
conditions. By completing the demonstration and distributing the results, the agency establishes a baseline for acceptance
and use of these  technologies. The MMT  Program is  managed by the Office  of Research and  Development's
Environmental Sciences Division in Las  Vegas, NV.
                                                          Gary Foley, Ph. D.
                                                          Director
                                                          National Exposure Research Laboratory
                                                          Office of Research and Development
                                                   VII

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                                               Abstract


NITON's XLi/XLt 700 Series X-ray fluorescence analyzers were demonstrated under the U.S. Environmental Protection
Agency Superfund Innovative Technology Evaluation Program in May 2003 atthe Oak Ridge National Laboratory (ORNL)
in Oak Ridge, TN. The purpose of the demonstration was to collect reliable performance and cost data for the XLi 702
and XLt 792 and four  other field measurement devices for mercury in soil and sediment. The key objectives of the
demonstration were: 1) determine sensitivity of each instrument with respect to a vendor-generated method detection limit
(MDL) and practical quantitation limit (PQL); 2) determine analytical accuracy associated with vendor field measurements
using field samples and standard reference materials (SRMs); 3) evaluate the precision of vendor field measurements;
4) measure time  required to perform  mercury measurements; and  5)  estimate  costs associated with  mercury
measurements for capital, labor, supplies, and investigation-derived wastes.

The demonstration involved analysis of SRMs, field samples collected from four sites, and spiked field samples for
mercury. The performance results for a given field measurement device were compared to those of an off-site laboratory
using reference method, "Test Methods for Evaluating Solid Waste" (SW-846) Method 7471B.

The sensitivity, accuracy, and precision measurements were successfully completed for both instruments. Results with
the XLi 702 were found to be very precise and accurate when compared to standard reference materials. During the
demonstration, NITON required 17.5 hours (assumes one technician) for analysis of 197 samples. The measurement
costs were estimated to be $7,786 for NITON's XLi 702 rental option, or $39.52 per sample; $13.18 per sample excluding
rental costs.

Results for the XLt 792 was found to be very precise and accurate when compared to standard reference materials. During
the demonstration, NITON required 17.5 hours (assumes one technician) for analysis of 197 samples. The measurement
costs were estimated to be $9,396 for NITON's XLi 792  rental option, or $47.69 per sample; $13.18 per sample excluding
rental costs.

The XLi/XLt 700 Series Analyzers exhibited good  ease of use and durability, as well as no major health and  safety
concerns. The analyzers are hand-held single units and  extremely portable. The  demonstration findings collectively
indicated that the XLi/XLt 700 Series Analyzers are rapid, lightweight, hand-held portable field measurement devices for
mercury in soil.
                                                   viii

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                                              Contents
Notice	  ii
Verification Statement	iii
Foreword	  vii
Abstract	viii
Contents	'.	ix
Tables	  xii
Figures	,	xiii
Abbreviations, Acronyms, and Symbols	xiv
Acknowledgm ents  	xvi

Chapter                                                                                            Page

1       Introduction 	  1
        1.1     Description of the SITE Program  	  1
        1.2     Scope of the Demonstration	2
               1.2.1    Phase I	 .  2
               1.2.2    Phase II	,	2
        1.3     Mercury  Chemistry and Analysis  	3
               1.3.1    Mercury Chem istry 	3
               1.3.2    Mercury Analysis	4

2       Technology Description	6
        2.1     Description of X-Ray Fluorescence	6
               2.1.1   Theory of E DXRF Analysis  	6
               2.1.2   System Components	7
        2.2     NITON XLi/XLt 700 Series Technology Description	7
        2.3     Developer Contact Information	8

        Field Sample  Collection Locations and Demonstration Site	9
        3.1     Carson River  	 10
               3.1.1   Site Description	 10
               3.1.2   Sample Collection	 10
       ^3.2     Y-12  National Security Complex   	'... 11
               3.2.1   Site Description	 11
               3.2.2   Sample Collection	 11
                                                    IX

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                                      Contents (Continued)
Chapter                                                                                           Page

        3.3     Confidential Manufacturing Site		 11
               3.3.1    Site Description	 11
               3.3,2    Sample Collection	 12
        3.4     Puget Sound	•	 12
               3.4.1    Site Description	:	"12
               3.4.2    Sample Collection	 12
        3.5     Demonstration Site	 13
        3.6     SAIC GeoMechanics Laboratory 	 14

4       Demonstration Approach	 15
        4.1     Demonstration Objectives  .	'.	15
        4.2     Demonstration Design 	 16
               4.2.1    Approach for Addressing Primary Objectives	 16
               4.2.2    Approach for Addressing Secondary Objectives	20
        4.3     Sample Preparation and Management 	21
               4.3.1    Sample Preparation	21
               4.3.2    Sample Management  	24
        4.4     Reference Method Confirmatory Process  	25
               4.4.1    Reference Method Selection	-25
               4.4.2    Referee Laboratory Selection 	25
               4.4.3    Summary of Analytical Methods  	27
        4.5     Deviations from the Demonstration Plan	28

5       Assessment of Laboratory Quality Control  Measurements	29
        5.1     Laboratory QA Sum mary	29
        5.2     Data Quality Indicators for Mercury Analysis  	29
        5.3     Conclusions and  Data Quality Limitations  	30
        5.4     Audit Findings	32

6       Performance of the XLi/XLt 700 Series Analyzers  	33
        6.1     Primary Objectives	33
               6.1.1    Sensitivity  	33
               6.1.2    Accuracy	37
               6.1.3    Precision	48
               6.1.4    Time  Required for Mercury Measurement  	53
               6.1.5    Cost	.54
        6.2     Secondary Objectives  	•	54
               6.2.1    Ease  of Use	54
               6.2.2    Health and Safety Concerns	:	56
               6.2.3    Portability of the Device	57
               6.2.4    Instrument Durability	57
               6.2.5    Availability of Vendor Instruments and Supplies	58

7       Econom ic Analysis  	59
        7.1     Issues and Assumptions	59

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                                     Contents (Continued)
Chapter                                                                                        Page

              7.1.1   Capital Equipment Cost	 59
              7.1.2   Cost of Supplies  	'.	60
              7.1.3   Support Equipment Cost	60
              7.1.4   Labor Cost		60
              7.1.5   Investigation-Derived Waste Disposal Cost	60
              7.1.6   Costs Not Included		61
        7.2    XLi/XLt 700 Series Analyzers Costs	61
              7.2.1   Capital Equipment Cost	61
              7.2.2   Cost of Supplies  	63
              7.2.3   Support Equipment Cost	63
              7.2.4   Labor Cost	 63
              7.2.5   Investigation-Derived Waste Disposal Cost	63
              7.2.6   Summary of XLi/XLt 700 Series Costs  	63
        7.3    Typical Reference Method Costs . ..	 . .	65

8       Summary of Demonstration Results	66
        8.1    Primary Objectives	66
        8.2    Secondary Objectives	67

9       Bibliography	70

Appendix A -   NITON Comments 	:	-	71
Appendix B -   Statistical Analysis 	74
                                                  XI

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                                               Tables
Table                                                                                             Page

1-1    Physical and Chemical Properties of Mercury	4
1-2    Methods for Mercury Analysis in Solids or Aqueous Soil Extracts  	5
3-1    Summary of Site Characteristics	  10
4-1    Demonstration Objectives	  15
4-2    Summary of Secondary Objective Observations Recorded During the Demonstration  	  20
4-3    Field Samples Collected from the Four Sites 	'	22
4-4  .  Analytical Methods for Non-Critical Parameters		  28
5-1    MS/MSD Summary		  30
5-2    LCS Summary	  30
5-3   . Precision Summary	31
5-4    Low Check Standards	31
6-1    Distribution of Samples Prepared for NITON and the Referee Laboratory	  33
6-2    NITON SRM Comparison (XLt)		38
6-3    NITON SRM Comparison (XLi)	  38
6-4    ALSI SRM Com parison	  38
6-5    Accuracy Evaluation by Hypothesis Testing (XLt)	40
6-6    Accuracy Evaluation by Hypothesis Testing (XLi)	41
6-7    Number of Sample Lots Within Each%D Range (XLt)	43
6-8    Number of Sample Lots Within Each %D Range (XLi)	45
6-9    Concentration of Non-Target Analytes  	47
6-10   Evaluation of Precision (XLt)	.-	49
6-11   Evaluation of Precision (XLi)	  51
6-12   Mercury Measurement Tjmes	  54
7-1    Capital Cost Summary for the XLi/XLt  700 Series Analyzers  	  62
7-2    Labor Costs	  63
7-3    IDW Costs	  63
7-4    Summary of Rental Costs for the XLi 702 (Isotope)	64
7-5    Summary of Rental Costs for the XLt (X-Ray Tube)	64
7-6    XLi 702 (Isotope) Costs by Category		65
7-7    XLt (X-Ray Tube) Costs by Category	65
8-1    Distribution of Sam pies Prepared for NITON and the Referee Laboratory	  67
8-2    Summary of NITON XLi/XLT 700 Series Analyzers Results for the Primary Objectives	68
8-3    Summary of NITON XLi/XLt 700 Series Analyzers Results for the Secondary Objectives  	  69
B-1    Unified Hypothesis Test Summary Information for the NITON XLi Instrument	76
B-2    Unified Hypothesis Test Summary Information for the NITON XLt Instrument	77
                                                  xii

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                                               Figures
Figure                                                                                            Page

2-1    Basic x-ray fluorescence process	,	 6
2-2    Photograph of the NITON XLi/XLt 700 Series instruments during the field demonstration	7
3-1    Tent and field conditions during the demonstration at Oak Ridge, TN	  13
3-2    Demonstration site and Building 5507	  13
4-1    Test sample preparation at the SAIC  GeoMechanics Laboratory	23
6-1    Data plot for the NITON XLt low concentration sample results	43
6-2    Data plot for the NITON XLt high concentration sample results	44
6-3    Data plot for the NITON XLi low  concentration sample results	45
6-4    Data plot for the NITON XLi high concentration sample results	46
6-5    Main menu screen shot	  55
6-6    Screen shot of sample spectra	55
6-7    Multi-element data report 	56
7-1    Capital equipment costs for the XLi (isotope)	62
7-2    Capital equipment costs for the XLt (X-ray tube)	62
A-1  .  Comparison of precision, all samples, laboratory and model XLt	73
                                                  XIII

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                        Abbreviations, Acronyms, and Symbols
%            Percent
%D           Percent difference
ฐC            Degrees Celsius
ug/kg         Microgram per kilogram
g/L           Gram per liter
AAS          Atomic absorption spectrometry
ALSI          Analytical Laboratory Services, Inc.
bgs           Below ground surface
cm           Centimeter
CFR          Code of Federal Regulations
Cl            Confidence Interval
COC          Chain of Custody
DOE          Department of Energy
EDXRF        Energy Dispersive X-ray Fluorescence
EPA          United States Environmental Protection Agency
FPXRF        Field Portable X-ray  Fluorescence
g             Gram
H&S          Health and Safety
Hg           Mercury
HgCI2         Mercury (II) chloride
IDL           Instrument detection limit
IDW          Investigation-derived waste
ITVR          Innovative Technology Verification Report
kg            Kilogram
L             Liter
LCS          Laboratory control sample
LEFPC        Lower East Fork Poplar Creek
m            Meter
MDL    .      Method detection limit
mg           Milligram
mg/kg         Milligram per  kilogram
mL           Milliliter
mm           Millimeter
MMT          Monitoring and Measurement Technology
MS/MSD       Matrix Spike/Matrix Spike Duplicate
NERL         National Exposure Research Laboratory
ng            Nanogram
ORD          Office of Research and Development
ORNL         Oak Ridge National Laboratory
                                                 XIV

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                Abbreviations, Acronyms, and Symbols (Continued)
ORR         Oak Ridge Reservation
OSWER      Office of Solid Waste and Emergency Response
PPE          Personal protective equipment
ppm          Parts per million
PQL          Practical quantitation limit
QA          Quality assurance
QAPP        Quality Assurance Project Plan
QC          Quality control
RPD          Relative percent difference
RSD          Relative standard deviation
SAIC         Science Applications International Corporation
SITE         Superfund Innovative Technology Evaluation
SOP          Standard operating procedure
SRM          Standard reference material
SW-846      Test Methods for Evaluating Solid Waste; Physical/Chemical Methods
TOC          Total organic carbon
TOM          Task Order Manager
UL           Underwriters Laboratory
UEFPC       Upper East Fork of Poplar Creek
Y-12          Y-12 Oak Ridge Security Complex, Oak Ridge, TN
                                               xv

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                                       Acknowledgments
The U.S. Environmental Protection Agency (EPA) Supeffund Innovative Technology Evaluation wishes to acknowledge
the support of the following individuals in performing the demonstration and preparing this document:  Elizabeth Phillips
of the U.S.  Department of Energy Oak Ridge National Laboratory (ORNL); Stephen Childs, Thomas Early, Roger Jenkins,
and Monty Ross of the UT-Battelle ORNL; Dale Rector of the Tennessee Department of Environment and Conservation
(TDEC) Department of Energy Oversight; VolkerThomsen, Debbie Schatzlein, and David Mercuro of NITON, lnc;Leroy
Lewis of the  Idaho National Engineering and Environmental Laboratory, retired; Ishwar Murarka of the  EPA Science
Advisory Board, member; Danny Reible of Louisiana State University; Mike Bolen, Joseph Evans, Julia Gartseff, Sara
Hartwell, Cathleen Hubbard, Kevin Jago, Andrew Matuson, Allen Motley, John  Nicklas, Maurice Owens, Nancy Patti,
Fernando Padilla, Mark Pruitt, James Rawe, Herb Skovronek, and Joseph Tillman of Science Applications International
Corporation (SAIC); Scott Jacobs and Ann Vega of the EPA National Risk Management Research Laboratory's Land
Remediation  and Pollution Control Division; and Brian Schumacher of the EPA National Exposure Research Laboratory.

This document was QA reviewed by  George Brilis of the EPA National Exposure Research  Laboratory.
                                                 xvi

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                                              Chapter 1
                                            Introduction
The U.S. Environmental Protection Agency (EPA) under
the Office of Research and Development (ORD), National
Exposure  Research  Laboratory. (NERL),  conducted a
demonstration to evaluate the performance of innovative
field measurement devices  for their ability to measure
mercury concentrations in soils and  sediments.   This
Innovative Technology Verification Report (ITVR) presents
demonstration performance results and associated costs
of  NITON'S  XLi/XLt  700  Series  X-ray  fluorescence
instruments, designated as XLi 702 and XLt 792.  The
vendor-prepared comments regarding the demonstration
are presented in Appendix A.

The demonstration was conducted  as  part of the  EPA
Superfund  Innovative  Technology Evaluation  (SITE)
Monitoring and Measurement Technology (MMT) Prog ram.
Mercury contaminated soils and sediments, collected  from
four sites  within  the continental U.S., comprised  the
majority of samples analyzed during the evaluation. Some
soil and sediment samples were spiked with mercury (II)
chloride (HgCI2) to provide concentrations not occurring in
the field samples. Certified  standard reference material
(SRM) samples were also used to provide samples  with
certified mercury concentrations and to increase the matrix
variety.

The demonstration was conducted at the Department of
Energy (DOE) Oak Ridge National Laboratory (ORNL) in
Oak Ridge, TN during  the week of May  5, 2003.  The
purpose of the  demonstration  was to obtain  reliable
performance and cost data for field measurement devices
in  order to  1) provide potential  users  with a  better
understanding of the devices' performance and operating
costs under well-defined field conditions and 2) provide the
instrument vendors with documented results that can assist
them in promoting acceptance and use of their devices.
The results  obtained  using the  five field  mercury
measurement devices were compared to the mercury
results obtained for identical sample sets (samples, spiked
samples, and SRMs) analyzed ata referee laboratory. The
referee  laboratory, which  was  selected  prior to the
demonstration, used  a  well-established  EPA reference
method.

1.1    Description of the 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 EPA's 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 tomeetthree main
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 SITE Program includes the following elements:
   The MMT Program evaluates innovative technologies
   that sample, detect, monitor, or measure hazardous
   and  toxic substances in soil, water,  and sediment
   samples. These technologies are expected to provide

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    better, faster, or more cost-effective methods for
    producing real-time data during site characterization
    and   remediation   studies   than   conventional
    technologies.

    The  Remediation  Technology Program  conducts
    dem onstrations of innovative treatment technologies to
    provide  reliable performance, cost, and  applicability
    data for site cleanups.

    The  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 in
    the support of the technologies. A significant number
    of these activities are performed by EPA's  Technology
    Innovation Office.

The Field Analysis  of Mercury in  Soils and Sediments
demonstration was  performed  under the MMT Program.
The MMT Program  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. The main 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 that address field sampling, monitoring,
    and characterization problems in a 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, NV. 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  technical
support  to  ensure  the  effective  implementation of
environmental regulations and strategies.

1.2    Scope of the Demonstration
The  demonstration project consisted of two separate
phases:  Phase I   involved  obtaining  information  on
prospective  vendors  having  viable  mercury detection
instrumentation. Phase II consisted of field and planning
activities leading up to and including the demonstration
activities. The following subsections provide detail on both
of these project phases.

1.2.1  Phase I
Phase   I  was initiated  by  making  contact   with
knowledgeable sources on the subject of "mercury in soil"
detection devices.  Contacts included individuals within
EPA,  Science  Applications  International  Corporation
(SAIC), arid industry where measurement of mercury in soil
was  known to be conducted.  Industry contacts included
laboratories and private developers of mercury detection
instrumentation. In  addition, the EPA Task Order Manager
(TOM)  provided contacts for "industry players" who had
participated in previous MMT demonstrations. SAIC also
investigated university and other research-type contacts for
knowledgeable sources within the subject area.
These contacts led to additional knowledgeable sources on
the subject, which in turn led to various Internet searches.
The  Internet  searches were very successful in finding
additional companies  involved  with  mercury detection
devices.

All in all, these research activities generated an original list
of approximately 30 companies potentially involved in the
measurement of mercury in soils.  The list included both
international  and   U.S.  companies.   Each  of these
companies was contacted by phone or email to  acquire
further information.  The contacts resulted in 10companies
that appeared to have viable technologies.

Due  to instrument design (i.e.,  the instrument's ability to
measure mercury  in  soils  and sediments), business
strategies, and stage of technology development, only 5 of
those 10 vendors participated in the field demonstration
portion  of phase II.

1.2.2  Phase II

Phase  II  of the  demonstration  project involved strategic
planning, field-related activities for the dem onstration, data
analysis, data interpretation, and preparation of the ITVRs.

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Phase II included pre-demonstration and demonstration
activities, as described in the following subsections.

1.2.2.1  Pre-Demonstration Activities

The pre-demonstration activities were completed in the fall
2002. There were six objectives for the pre-demonstration:

    Establish concentration ranges for testing vendors'
    analytical equipment during the demonstration.

•   Collect soil and sediment field samples to be used in
    the demonstration.

•   Evaluate sample homogenization procedures.

•   Determine mercury concentrations in  homogenized
    soils and sediments.

    Select a reference method and qualify potential referee
    laboratories for the demonstration.

•   Provide soil and sediment samples to the vendors for
    self-evaluation of their instruments, as a precursor to
    the demonstration.

As  an integral part  of meeting these objectives, a pre-
demonstration  sampling  event was  conducted   in
September 2002 to collect field samples of soils and
sediments containing different levels of mercury. The field
samples were obtained from the following locations:

    Carson River Mercury site - near Dayton, NV

    Y-12 National Security Complex - Oak Ridge, TN

•   A confidential manufacturing facility - eastern U.S.

    Puget Sound - Bellingham Bay, WA

Immediately after collecting field sample material from the
sites noted above, the general mercury concentrations in
the  soils   and. sediments  were confirmed  by quick
turnaround   laboratory  analysis   of  field-collected
subsamples using method SW-7471B.  The field sample
materials were then shipped to a soil preparation laboratory
for homogenization. Additional pre-demonstration activities
are detailed in Chapter 4.

1.2.2.2  Demonstration Activities

Specific objectives  for this  SITE demonstration were
developed  and defined  in a  Field Demonstration  and
Quality Assurance Project Plan (QAPP) (EPA Report #
EPA/600/R-03/053). The Field Demonstration QAPP is
.available   through   the   EPA  ORD  web   site
(http://www.epa.gov/ORD/SITE) or from the EPA Project
Manager.  The demonstration objectives were subdivided
into two categories:   primary  and  secondary.  Primary
objectives are goals of the demonstration study that need
to  be  achieved  for technology  verification.    The
measurements  used  to achieve  primary  objectives are
referred to as critical. These measurements  typically
produce quantitative  results that can  be verified using
inferential and descriptive statistics.

Secondary  objectives  are  additional  goals   of  the
demonstration  study  developed   for  acquiring other
information of interest about the technology that is not
directly related  to verifying the primary objectives.  The
measurements required for achieving secondary objectives
are considered to be noncritical. Therefore, the analysis of
secondary objectives  is typically more qualitative  in nature
and often  uses  observations and sometimes descriptive
statistics.

The field portion of the demonstration involved evaluating
the capabilities  of five mercury-analyzing instruments to
measure  mercury concentrations  in soil and sediment.
During the demonstration, each instrument vendor received
three  types  of samples 1)  homogenized field  samples
referred to as "field samples",  2) certified SRMs, and 3)
spiked field samples (spikes).

Spikes were prepared byadding known quantities of HgCI2
to field samples.  Together, the field samples, SRMs, and
spikes are referred to as "demonstration samples" for the
purpose of this ITVR.  All  demonstration  samples were
independently analyzed by  a  carefully selected referee
laboratory. The experimental design for the demonstration
is detailed in Chapter 4.


1.3    Mercury Chemistry and Analysis

1.3.1 Mercury Chemistry

Elemental mercury is the only metal that occurs as a liquid
at ambient   temperatures. Mercury naturally  occurs,
primarily within the ore, cinnabar, as mercury sulfide (HgS).
Mercury easily forms  amalgams with many other metals,
including gold. As a result, mercury has historically been
used to recover gold from ores.

Mercury is ionically stable; however, it is very volatile for a
metal. Table 1-1 lists selected  physical and chemical
properties  of elemental mercury.

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 Table 1-1. Physical and Chemical Properties of Mercury

 Properties                 Data
 Appearance

 Hardness

 Abundance

 Density @ 25 'C

 Vapor Pressure @ 25 *C

 Volatilizes @

 Solidifies @
Silver-white, mobile, liquid.

Liquid

0.5% in Earth's crust

13.53g/mL

0.002 mm

356 ฐC

-39 -C
Source: Merck Index, 1983
Historically, mercury releases to the environment included
a number  of  industrial processes  such as  chloralkali
manufacturing, copper and zinc smelting operations, paint
application,  waste oil  combustion,  geothermal  energy
plants, municipal waste incineration, ink manufacturing,
chemical manufacturing,  paper  mills,  leather tanning,
pharmaceutical production, and textile manufacturing.  In
addition, industrial  and  domestic  mercury-containing
products, such as thermometers,  electrical switches, and
batteries, are disposed of as solid wastes in landfills (EPA,
July 1995).  Mercury is also an indigenous compound at
many abandoned mining sites and is, of course, found  as
a natural ore.
At mercury-contaminated sites, mercury exists in mercuric
form (Hg2*), mercurous form (Hg22+), elementalform (Hgฐ),
and alkylated form (e.g., methyl or ethyl mercury).  Hg22*
and  Hg2* are the more stable forms under  oxidizing
conditions.   Under   mildly reducing conditions,  both
organically bound mercury and inorganic mercury may be
degraded to elemental  mercury,  which can  then be
converted readily to methyl or ethyl mercury by biot'c and
abiotic processes. Methyl and ethyl mercury are the most
toxic forms of mercury; the alkylated mercury compounds
are volatile and soluble in water.
Mercury (II) forms relatively strong complexes with CI" and
CO32".  Mercury (II) also forms complexes with inorganic
ligands such as fluoride (F~),  bromide (Br~),  iodide (I"),
sulfate (SO42-), sulfide  (S2'), and phosphate  (PO,,3") and
forms strong complexes with  organic ligands, such  as
sulfhydryl groups, amino acids, and humic and fulvic acids.
The  insoluble  HgS  is formed  under  mildly reducing
conditions.

1.3.2  Mercury Analysis
There are several laboratory-based, EPA promulgated
methods for the analysis of mercury in  solid and liquid
hazardous waste matrices.  In addition, there are several
performance-based methods  for the determination  of
various  mercury  species.  Table 1-2 summarizes the
commonly used methods for measuring  mercury  in both
solid and liquid matrices, as identified through a review of
the EPA Test Method Index and SW-846. A discussion of
the choice of reference  method is presented in Chapter 4.

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Table 1-2.  Methods for Mercury Analysis in Solids or Aqueous Soil Extracts
    Method        Analytical            Type(s)of             Approximate
                 Technology        Mercury analyzed      Concentration Range
                                                                             Comments
  SW-7471B    CVAAS
  SW-7472    ASV  .
  SW-7473
TD,
amalgamation,
and AAS
  SW-7474    AFS
    inorganic mercury   10-2,000 ppb
•   organo-mercury

    inorganic mercury   0.1-10,000 ppb
•   organo-mercury

    inorganic mercury   0.2 - 400 ppb
•  . organo-mercury
                      inorganic mercury   1 ppb - ppm
                      organo-mercury
Manual cold vapor technique widely
used for total mercury determinations

Newer, less widely accepted method


Allows for total decomposition analysis
                                              Allows for total decomposition analysis;
                                              less widely used/reference
  EPA 1631     CVAFS
  EPA 245.7   CVAFS
  EPA 6200    FPXRF
                  •    inorganic mercury   0.5 -100 ppt
                      organo-mercury
                      inorganic mercury   0.5 - 200 ppt
                      organo-mercury
                      inorganic mercury   >30 mg/kg
                                              Requires "trace" analysis procedures;
                                              written for aqueous matrices; Appendix
                                              A of method written for sediment/soil
                                              samples

                                              Requires "trace" analysis procedures;
                                              written for aqueous matrices; will
                                              require dilutions of high-concentration
                                              mercury samples

                                              Considered a screening protocol
AAS = Atomic Absorption Spectrometry
AAF = Atomic Fluorescence Spectrometry
AFS = Atomic Fluorescence Spectrometry
ASV = Anodic Stripping Voltammetry
CVAAS = Cold Vapor Atomic Absorption Spectrometry
CVAFS = Cold Vapor Atomic Fluorescence Spectrometry
FPXRF = Field Portable X-ray Fluorescence
EPA = U.S. Environmental Protection Agency
mg/kg = milligram per kilogram
ppb = parts per billion
ppm = parts per million
ppt = parts per trillion
SW = solid waste
TD = thermal decomposition

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                                              Chapter 2
                                    Technology Description
This chaptercontainsgeneral information on field portable
X-ray fluorescence (FPXRF) analyzers, including the theory
of operation, system components, radioisotope sources,.
and mode of operation.  The chapter also provides a
detailed description of the NITON  XLi/XLt 700  Series
Analyzers.

2.1    Description of X-Ray Fluorescence
Energy  dispersive X-ray fluorescence  (EDXRF) is a
method of detecting metals and non-metallic elements in
soil and sediment. Some of the elements that EDXRF can
identify are arsenic, barium, cadmium, chrom ium, copper,
lead, mercury, selenium, silver and  zinc.  Field-portable
X-ray fluorescence units thatoperate on battery power and
use a radioactive source were first developed for use in
analysis of lead-based,  paint. FPXRF analyzers are being
used  in the field  to  identify and  characterize  metal-
contaminated sites, and to guide remedial work.

2.1.1  Theory of EDXRF Analysis
EDXRF  analysis detects and measures many elements
simultaneously. Generally, EDXRF units can detect and
quantify elements from atomic number 19 (potassium)
through  94 (plutonium). There are two types of EDXRF
units. They can use either an X-ray tube or a radioisotope
as a source of X-rays.  Both  types of EDXRF analyzers
were evaluated during the demonstration.
In XRF analysis, a process known as photoelectric effect
is used  in analyzing samples. Fluorescent  X-rays  are
produced by exposing  a sample to an X-ray source that
has an excitation energy similar to, but greater than, the
binding energy of the inner-shell electrons of the elements
in the sample. Some of the source X-rays will be scattered,
but  a portion will be absorbed by the elements in  the
sample. Because of their higher energy level, they will
cause ejection of the inner shell electrons.  The electron
vacancies, that result will be filled by electrons cascading in
from outer shells.  However, since electrons in the outer
shells have  higher energy states than the inner-shell
electrons they are replacing, the outer shell electrons must
give off energy as they cascade down. The energy is given
off in the form of X-rays, and the phenomenon is referred
to  as X-ray fluorescence (Figure  2-1).  Because every
element has a different electron shell configuration, each
element emits a unique  X-ray at a set energy level or
wavelength that is characteristic  of that element. The
elements present  in a  sample  can  be  identified  by
observing the energy level of the characteristic X-rays,
while the intensity  of the X-rays  is proportional to the
concentration and can be used to perform quantitative
analysis.
  Sj*rajr emtasd
Figure 2-1. Basic X-ray fluorescence process.

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2.1.2 System Components
A  FPXRF  system  has two  basic components:  the
radioisotope source and the detector. The source irradiates
the sample  to produce characteristic X-rays. The detector
measures both the energy and the characteristic X-rays
that are emitted and their intensity to identify and quantify
the elements present in the sample.

The radioisotope sources currently being used are Fe-55,
Cd-109,and Am-241. FPXRF units have been developed
that use  more than  one source, which allows them  to
analyze a greater number and range of elements. Typical
arrangements of such  multi-source  instruments include
Cd-109 and Am-241 or Fe-55, Cd-109, and Am-241.
FPXRF units use either gas-filled  or solid-state  detectors.
Solid state  detectors include Si(Li), Hgl2, and silicon-PIN
diode. The Si(Li)  is capable of the highest resolution, but is
quite temperature sensitive. The Si(Li) has a resolution of
170 electron volts (eV)  if cooled to at least -90 ฐC, either
with liquid nitrogen or by thermoelectric cooling that uses
the Peltier  effect. The Hgl2 detector can  operate at a
moderately subambient temperature, is  cooled by use of
the Peltier effect, and has a resolution of 270 to 300 eV.
The silicon-PIN diode detector is cooled only slightly by the
Peltier effect, and has a resolution of 250 eV.

 2.2   NITON XLi/XLt 700 Series Technology
       Description

The  NITON XLi/XLt 700 Series  sample  analyzers  are
energy  dispersive  X-ray   fluorescence   (EDXRF)
spectrometers that use either a radioactive isotope (XLi
model  702) or a  low powered miniature X-ray tube with a
silvertarget (XLt model 792) to excite characteristic X-rays
of a test sample's constituent elements  (Figure  2-2).
These characteristic X-rays are  continuously detected,
identified,  and  quantified  by   the spectrometer during
sample analysis.  The  energy of each X-ray detected
identifies a  particular element present in the sample, and
the rate at  which X-rays of a  given  energy are counted
provides a  determination of the quantity of that element
that is present in the sample.

Detection of the  characteristic mercury X-rays is achieved
using a highly-efficient, thermo-electrically cooled,  solid-
state detector.  Signals from this detector are  amplified,
digitized,  and then  quantified  via integral multichannel
analysis and data processing units.  Sample test results
are displayed in  parts per million (milligrams per kilogram)
of total elemental mercury.
The  NITON XLt  700 Series Analyzer  with X-ray tube
excitation provides the user with the speed and efficiency
of X-ray tube  excitation, while reducing the regulatory
demands   typically   encountered  with  isotope-based
systems.  In most cases, the X-ray tube can be shipped
from state  to state and  country to  country with minimal
paperwork and expense.
Figure 2-2.  Photograph of the NITON XLi/XLt 700 Series
instruments during the field demonstration.
Applications and Specifications - The XLi and XLt 700
Series analyzers offer testing modes forsoil and other bulk
samples; filters, wipes and other thin samples; and lead-
based paint. Testing applications  include management of
remediation projects, site assessments, and compliance
testing.  They provide simultaneous analysis of up to 25
elements, including  all eight of the  characteristic metals
listed under the Resource Conservation and Recovery Act
(RCRA).  XRF analysis  is non-destructive, so screened
samples  can be  sent to an  accredited  laboratory  for
confirmation of results obtained on-site.

NITON's  software corrects automatically for variations in
soil matrix and density, making it applicable for both in-situ
and intrusive testing.

Operation  - For in-situ  analysis, the  analyzer is placed
directly on the ground oron bagged soil samples. Because
contamination patterns tend to be heterogeneous, a large
number of data points can be produced using in-situ testing
to delineate contamination patterns.  In-situ testing with
either the XLi 702 or XLt 792 is in full compliance with U.S.

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EPA Method 6200. In-situ testing allows for testing many
locations in a short time, and is ideal for rapid site-profiling,
locating sources of contamination, and monitoring and fine-
tuning remediation efforts on-the-spot.  In-situ analysis is
not appropriate for wet sediment samples.  In that case,
sediments must be dried, and can then  be measured either
bagged or in sample cups.

For intrusive  testing,  the XLi/XLt 700  Series  can  test
prepared   (dried,  ground,  sifted,  homogenized),
representative soil samples  for laboratory grade analysis
whenever  analytical-grade data quality is required.  Both
the XLi and XLt  700  Series Soil Analyzers  come with
sample-preparation protocols. During  the demonstration,
all samples were tested intrusively.

The NITON instruments are factory-calibrated.  NITON's
Compton normalization software automatically corrects for
any differences in sample  density and matrix, so site-
specific calibration standards are never required. The units
also analyze  for  zinc, arsenic, and  lead  since these
elem ents may cause interference at certain concentrations.
The vendor states that  total analysis time usually does not
exceed 120 seconds (after sample preparation).

Depending on the data  quality needed for a project, longer
counttimes can be employed. As count times increase, the
detector collects  a  larger number of X-rays from the
sample, including more X-rays from interfering elements
that are present at comparable lower concentrations. The
longer the count time, the lower the detection limit.

Sample preparation, for  those samples  not analyzed
directly in-situ, may include grinding and/or sieving dried
samples, using either mortar and pestle or electric grinder.
Wet sam pies, at a minimum are filtered to remove standing
water, then dried.  Although EPA  Method 6200 specifies
that mercury samples should not be oven-dried due to the
potential volatilization loss of mercury, NITON has oven-
dried sample material without negative impact. During the
demonstration,  some  samples which contained  free-
standing water were dried in a  toaster oven for about 2
hours.

2.3    Developer Contact Information

Additional information about NITON'S XLi/XLt 700 Series
Analyzers can be obtained from the following source:

NITON Corporation
Jonathan J. Shein
900 Middlesex Turnpike Building 8
Billerica, MA. 01821
Telephone:(800)875-1578
Fax:(978)670-7430
Email: sales@niton.com
Internet: www.niton.com

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                                              Chapter 3
             Field Sample Collection Locations and Demonstration Site
As previously described in Chapter 1, the demonstration in
part  tested the ability of all five vendor  instruments to
measure '. mercury  concentrations  in  demonstration
samples. The demonstration samples consisted of field-
collected samples, spiked field samples, and SRMs. The
field-collected  samples   comprised  the  majority  of
demonstration samples.  This chapter describes the four
sites from which the field  samples were collected, the
demonstration site, and the  sample homogenization
laboratory. Spiked samples were prepared from these field
samples.

Screening of potential mercury-contaminated field sample
sites was conducted during Phase I of the project.  Four
sites were selected for acquiring  mercury-contaminated
samples thatwere diverse in appearance, consistency, and
mercury concentration. A key criterion was the source of
the contamination.  These sites included:
    Carson River Mercury site - near Dayton, NV

    The Y-12  National Security Complex (Y-12) - Oak
    Ridge, TN

    A confidential manufacturing facility -eastern U.S.

•    Puget Sound - Bellingham Bay, WA

Site  Diversity — Collectively,  the four  sites provided
sampling areas  with  both  soil and  sediment,  having
variable physical consistencies and variable  ranges of
mercury contamination.  Two of the sites (Carson River
and Oak Ridge) provided  both soil and sediment samples.
A third site (a manufacturing  facility) provided just  soil
samples and  a fourth  site (Puget Sound) provided only
sediment samples.

Access and  Cooperation - Site  representatives were
instrumental in providing site access, and in some cases,
guidance on  the. best  areas  to  collect samples from
relatively high and low mercury concentrations. In addition,
representatives from the host demonstration site (ORNL)
provided a facility for conducting the demonstration.

At three of the sites, the soil and/or sediment sample was
collected,  homogenized  by hand  in the  field,  and
subsampled  for  quick turnaround analysis.    These
subsamples  were sent  to analytical laboratories  to
determine the general range of mercury concentrations at
each of the sites.  (The Puget Sound site did not require
confirmation  of  mercury contamination due  to recently
acquired mercury analytical data from another, ongoing.
research project.) The field-collected  soil and sediment
samples from all four sites were then shipped to SAIC's
GeoMechanics Laboratory for  a more thorough sample
homogenization (see Section 4.3.1) and subsampled for
redistribution to vendors  during the  pre-demonstration
vendor self-evaluations.

All five of the  technology  vendors performed a self-
evaluation   on   selected  samples  collected  and
homogenized during this pre-demonstration phase of  the
project. For the self-evaluation, the laboratory results and
SRM values were supplied to the vendor, allowing  the
vendor to determine how well it performed the analysis on
the  field samples.  The  results  were used to gain a
preliminary understanding of the field samples  collected
and to  prepare for the demonstration.

Table  3-1  summarizes key characteristics  of  samples
collected at each of the four sites. Also included are  the
sample matrix, sample descriptions, and  sample depth
intervals. The analytical results presented in Table 3-1  are
based  on  referee laboratory  mercury results for  the
demonstration samples.

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 Table 3-1. Summary of Site Characteristics
Site Name
Carson River
Mercury site

Y-12 National
Security Complex
Confidential
manufacturing site
Puget Sound -
Bellingham Bay

Sampling Area
Carson River
Six Mile Canyon
Old Hg Recovery Bldg.
Poplar Creek
Former plant building
Sediment layer
Underlying Native Material
Sample
Matrix
Sediment
Soil
Soil
Sediment
Soil
Sediment
Sediment
Depth
water/sediment
interface
3 - 8 cm bgs
0 - 1 m bgs
0 - 0.5 m bgs
3.6 -9 m bgs
1.5 -1.8m thick
0.3 m thick
Description
Sandy silt, with some
organic debris present
(plant stems and leaves)
Silt with sand to sandy silt
Silty-clay to sandy-gravel
Silt to coarse sandy gravel
Silt to sandy silt
Clayey-sandy silt with
various woody debris
Medium-fine silty sands
Hg Concentration
Range
10ppb-50ppm
10ppb-1,000ppm
0.1 - 100 ppm
0.1 - 100 ppm
5- 1,000 ppm
10 -400 ppm
0.16- 10 ppm
bgs = below ground surface.

3.1    Carson River

3.1.1  Site Description
The Carson River Mercury site begins near Carson City,
NV, and extends downstream to the Lahontan Valley and
the Carson  Desert. During the Comstock mining era of the
late 1800s,  mercury was imported to the area  for
processing  gold and  silver ore.  Ore mined from the
Comstock Lode was transported to mill sites, where it was
crushed  and mixed  with mercury to amalgamate the
precious metals. The Nevada mills were located in Virginia
City, Silver  City, Gold Hill, Dayton, Six Mile Canyon, Gold
Canyon, and adjacent to the Carson River between New
Empire and Dayton. During the mining era, an estimated
7,500 tons  of mercury were discharged  into the Carson
River  drainage,   primarily  in  the   form   of
mercury-contaminated tailings (EPA Region 9, 1994).

Mercury contamination is present at Carson Riveras either
elemental mercury and/or inorganic mercury sulfides with
less  than   1%,  if  any,  methylmercury.    Mercury
contamination exists in soils preseat at the former gold and
silver mining mill sites; waterways adjacentto the mill sites;
and sediment, fish, and wildlife over more than a 50-mile
length of the Carson River. Mercury is also present in the
sediments and adjacent flood  plain of the Carson River,
and in the sediments of Lahontan Reservoir, Carson Lake,
Stillwater Wildlife Refuge, and Indian Lakes. In addition,
tailings with  elevated mercury levels are still present at, and
around,  the historic mill sites, particularly  in Six Mile
Canyon (EPA, 2002a).
3.1.2  Sample Collection

The Carson River Mercury site provided both soil and
sediment  samples  across the range of contaminant
concentrations desired for the demonstration.   Sixteen
near-surface soil samples were collected between 3-8 cm
below ground surface (bgs). Two sediment samples were
collected  at the  water-to-sediment interface.   All 18
samples were collected on September 23-24, 2002 with a
hand shovel. Samples were collected in Six Mile Canyon
and along the Carson River.

The sampling sites were selected  based upon historical.
data from  the site.  Specific sampling locations in the Six
Mile Canyon were selected based  upon local terrain and
visible soil conditions (e.g., color and particle size).  The
specific sites were selected to obtain soil samples with as
much variety in mercury concentration as possible. These
sites  included hills, run-off pathways, and dry river bed
areas.  Sampling locations along the Carson River were
selected based upon historical mine locations, localterrain,
and river flow.

When collecting the soil samples, approximately 3 cm of
surface soil was scraped to the side. The sample  was
then  collected  with  a  shovel,  screened  through  a
6.3-millimeter (mm) (0.25-inch) sieve  to remove larger
material, and collected in 4-liter (L) scalable bags identified
with a permanent marker. The sediment samples  were
also collected with a shovel, screened through a 6.3-mm
sieve to remove  larger material,  and'collected in 4-L
scalable bags identified with a permanent marker.  Each of
the 4-L scalable  bags was  placed into a second 4-L
                                                    10

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scalable bag, and the sample label was placed onto the
outside bag. The sediment samples were then placed into
10-L buckets, lidded, and identified with a sample label.

3.2   Y-12 National  Security Complex

3.2.1 Site Description
The Y-12 site is located at the DOE ORNL in Oak Ridge,
TN.  The  Y-12 site  is  an active manufacturing and
developmental   engineering  facility  that  occupies
approximately 800 acres  on the northeast corner of the
DOE Oak Ridge Reservation (ORR) adjacentto the city of
Oak Ridge, TN.  Built in 1943 by the U.S. Army Corps of
Engineers as part of the World War II Manhattan Project,
the original mission of the  installation was development of
electromagnetic  separation  of  uranium  isotopes and
weapon components manufacturing, aspartof the national
effort to produce the  atomic bomb. Between 1950 and
1963, large quantities of elemental mercury were used at.
Y-12 during lithium isotope  separation pilot studies and
subsequent  production   processes   in  support of
thermonuclear weapons programs.

Soils at the Y-12 facility are contaminated with mercury in
many areas.  One of the  areas of known high levels of
mercury-contaminated soils is in the vicinity of a former
mercury use facility (the "Old Mercury Recovery Building"
- Building 8110). At this location, mercury-contaminated
material and soil were processed  in a Nicols-Herschoff
roasting furnace to recover mercury. Releases of mercury
from this process, and from a  building  sump used to
secure the  mercury-contaminated materials  and  the
recovered mercury, have  contaminated the surrounding
soils (Rothchild, et al., 1984).  Mercury contamination also
occurred in the sediments of the East Fork of Poplar Creek
(DOE, 1998).   The  Upper  East  Fork of Poplar Creek
(UEFPC) drains the entire Y-12 complex.  Releases of
mercury via building drains connected to the  storm sewer
system, building basement dewatering sump discharges,
and spills to soils, all  contributed  to contamination of
UEFPC.  Recent investigations showed that bank soils
containing mercury along  the UEFPC  were  eroding and
contributing to mercury loading. Stabilization of the bank
soils along this reach of the creek was recently completed.

3.2.2 Sample Collection

Two matrices were sampled at Y-12 in Oak Ridge, TN,
creek sediment and soil. A total of 10  sediment samples
was collected; one sediment sample was collected from
the  Lower East  Fork of Poplar Creek  (LEFPC) and nine
sediment samples were collected from the UEFPC. A total
of six soil samples was collected from the Building 8110
area.  The  sampling  procedures that were  used are
summarized below.

Creek Sediments - Creek sediments were collected on
September 24-25, 2002  from the East Fork- of  Poplar
Creek.  Sediment samples were  collected from various
locations in a downstream to upstream sequence (i.e., the
downstream  LEFPC sample was collected first and the
most upstream point of the UEFPC was sampled last).

The  sediment samples from Poplar Creek were collected
using a  commercially available clam-shell sonar dredge
attached to a rope. The dredge was slowly lowered to the
creek bottom surface, where it was pushed by foot into the
sediment.  Several drops of the sampler (usually seven or
more) were made to collect enough material for screening.
On  some  occasions,  a  shovel  was used to remove
overlying "hardpan"  gravel  to expose finer  sediments at
depth.  One creek sample  consisted  of creek bank
sediments, which was collected using a stainless steel
trowel.

The  collected sediment was then  poured onto  a 6.3-mm
sieve to remove oversize sample material. Sieved samples
were then  placed in  12-L scalable plastic buckets.  The
sediment samples in these buckets were homogenized
with  a plastic ladle and subsamples were collected in 20-
milliliter (mL) vials for quick  turnaround analyses.

Soil  - Soil  samples were collected  from pre-selected
boring locations September 25, 2002.  All samples were
collected in the immediate  vicinity of  the Building 8110
foundation using a commercially available bucket  auger.
Oversize material was hand picked from the excavated soil
because the soil was too wet to be passed through a sieve.
The   soil  was  transferred   to  an  aluminum  pan,
homogenized by hand, and subsampled to  a 20-mL vial.
The  remaining  soil was  transferred to  4-L  plastic
containers.


3.3    Confidential Manufacturing Site

3.3.1  Site Description

A confidential manufacturing site, located in the eastern
U.S., was selected for participation in this demonstration.
The site contains elemental mercury, mercury amalgams,
and mercury oxide in shallow sediments (less than 0.3 m
deep) and deeper soils (3.65 to 9  m bgs).  This site
provided soil with concentrations from 5-1,000 mg/kg.

The  site is the  location of  three former processes that
resulted in mercury contamination.   The  first process
                                                   11

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involved amalgamation of zinc with mercury. The second
process involved the manufacturing of zinc oxide.  The
third process involved the  reclamation of silver and gold
from  mercury-bearing  materials  in  a  retort furnace.
Operations led to the  dispersal of elemental  mercury,
mercury compounds such as chlorides and oxides, and
zinc-mercury amalgams.   Mercury values have been
measured ranging from 0.05 to over 5,000 mg/kg, with
average values of approximately 100 mg/kg.

3.3.2 Sample Collection

Eleven  subsurface  soil  samples  were  collected on
September 24, 2002.  All samples were collected with a
Geoprobeฎ unit using plastic sleeves.  All samples were
collected at the location of a former facility plant.  Drilling
locations  were  determined based on historical  data
provided by the site operator. The intention was to gather
soil samples across a range of concentrations.  Because
the surface soils were from relatively clean fill, the sampling
device was pushed to a depth of 3.65 m using a blank rod.
Samples  were then collected at  pre-selected  depths
ranging from 3.65 to 9 m bgs.  Individual cores were 1-m
long.  The plastic sleeve for each 1-m core was marked
with a permanent marker; the depth interval and the bottom
of each core was marked.  The filled plastic tubes were
transferred to  a staging table where appropriate depth
intervals were selected for m ixing. Selected tubes were cut
into 0.6-m intervals, which were emptied into a  plastic
container  for premixing soils. When feasible, soils were
initially screened to remove materials larger than 6.3-mm
in diameter.  In many cases, soils were too wet and clayey
to allow screening; in these cases, the soil was broken into
pieces by  hand and, by using a wooden spatula, oversize
materials were manually removed.  These soils  (screened
or hand  sorted) were then mixed until  the soil appeared
visually uniform in color and texture. The mixed soil was
then placed into a 4-L sample container for each chosen
sample interval.  A  subsample of the mixed soil  was
transferred into a 20-mL vial,  and  it was sent for quick
turnaround mercury, analysis. This process was repeated
for each subsequent sample interval.

3.4    Puget Sound

3.4.1 Site Description

The Puget Sound site consists of contaminated offshore
sediments.  The particular area  of the site  used for
collecting  demonstration samples  is  identified as  the
Georgia Pacific, Inc. Log Pond.  The Log Pond is located
within the  Whatcom Waterway in Bellingham Bay, WA, a
well-established  heavy industrial land use area with a
maritime shoreline designation.   Log Pond  sediments
measure approximately 1.5 to 1.8-m  thick, and contain
various  contaminants  including  mercury,   phenols,
polyaromatic hydrocarbons, polychlorinated biphenyls, and
wood debris.  Mercury was used as a  preservative in the
logging industry. The area was capped in late 2000 and
early  2001  with  an average  of 7 feet of  clean capping
material, as part of a Model Toxics Control Act interim
cleanup  action.   The  total  thickness  ranges  from
approximately 0.15m  along the site perimeterto 3m within
the interior of the project area. The  restoration project
produced 2.7 acres of shallow sub-tidal and 2.9 acres of
low intertidal habitat, all of which had previously exceeded
the Sediment Management  Standards cleanup criteria
(Anchor Environmental, 2001).

Mercury concentrations have been measured ranging from.
0.16 to 400 mg/kg (dry wt).  The  majority (98%) of the
mercury  detected  in near-shore  ground waters  and
sediments of the Log  Pond is believed  to be comprised of
complexed divalent (Hg2*) forms such as mercuric sulfide
(Bothner, et al., 1980  and Anchor Environmental, 2000).

3.4.2 Sample Collection
Science Applications  International  Corporation (SAIC) is
currently performing a SITE remedialtechnology evaluation
in the Puget Sound (SAIC, 2002). As part of ongoing work
at that site, SAIC collected additional sediment for use
during this MMT project. Sediment samples collected on
August 20-21, 2002 from  the Log  Pond in Puget Sound
were obtained beneath approximately 3-6 m of water, using
a vibra-coring system capable of capturing cores to 0.3 m
below the  proposed  dredging prism.   The  vibra-corer
consisted of  a  core  barrel  attached  to a power head.
Aluminum core  tubes, equipped with  a stainless  steel
"eggshell" core catcher to retain material, were inserted
into the core barrel.   The vibra-core was lowered  into
position on the bottom and advanced to the appropriate
sampling depth.  Once sampling  was completed, the
vibra-core was retrieved and the core liner removed from
the core  barrel. The core sample was examined at each
end to verify that sufficient sediment was retained for the
particular sample. The condition and quantity of material
within  the  core was then  inspected  to  determine
acceptability.

The  following  criteria were  used  to  verify whether an
acceptable core sample was collected:

    Target penetration depth (i.e., into native material) was
    achieved.
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    Sediment recovery of at least 65% of the penetration
    depth was achieved.

    Sample appeared  undisturbed and intact without any
    evidence of obstruction/blocking within the core tube or
    catcher.

The percent sediment recovery was determined by dividing
the length of material recovered  by the depth  of core
penetration below the mud line. If the sample was deemed
acceptable, overlying water was siphoned from the top of
the core tube and each end of the tube capped and sealed
with duct tape.  Following core collection, representative
samples  were  collected  from  each  core  section
representing a different vertical horizon. Sediment was
collected from the  center of the core  that had not been
smeared by, or in contact with, the core tube. The volumes
removed were placed in a decontaminated stainless steel
bowl or pan and mixed until homogenous in texture and
color (approximately 2  minutes).

After all sediment  for  a  vertical horizon composite was
collected and  homogenized, representative aliquots were
placed in the appropriate pre-cleaned sample containers.
Samples of both the sediment and the underlying native
material were collected in a similar manner. Distinct layers
of sediment and native material were easily recognizable
within each core.

3.5    Demonstration Site
The  demonstration   was  conducted   in   a  natural
environment, outdoors, in Oak Ridge, TN.  The area was
a grass covered hill with some parking areas, all of which
were surrounded by trees. Building 5507, in the center of
the demonstration area, provided facilities for lunch, break,
and sample storage for the project and personnel.

Most of the demonstration was performed during rainfall
events ranging from steady to torrential.  Severe puddling
of rain occurred to the extent that boards needed to be
placed under chairs to  prevent them from sinking into the
ground. Even when it was not raining, the relative humidity
was high, ranging from  70.6 to 98.3 percent.  Between two
and four of the tent sides were used to keep rainfall from
damaging the  instruments.   The temperature in the
afternoons ranged from 65-70 degrees Fahrenheit, and the
wind speed was less than 10 mph. The latitude is 36ฐN,
the longitude 35ฐW, and the elevation 275 m. (Figure 3-1
is  a photograph of  the site during the demonstration and
Figure 3-2 is a photograph of the location.)
Figure 3-1. Tent and field conditions during the
demonstration at Oak Ridge, TN.
Figure 3-2. Demonstration site and Building 5507.
                                                    13

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3.6    SAIC GeoMechanics Laboratory

Sample homogenization was completed  at  the  SAIC
GeoMechanics Laboratory in Las Vegas, NV. This facility
is an  industrial-type building  with separate facilities for
personnel offices  and material  handling.  The  primary
function of the laboratory is for rock mechanics  studies.
The laboratory has rock mechanics equipment, including
sieves, rockcrushers, and sample splitters. The personnel
associated with this laboratory are experienced in the areas
of sample preparation and sample homogenization.  In
addition to  the sample homogenization  equipment, the
laboratory contains several benches,  tables, and open
space. Mercury air monitoring equipment was used during
the sample  preparation activities for personnel safety.
                                                   14

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                                                  Chapter 4
                                       Demonstration Approach
This chapter describes the demonstration approach that
was used for  evaluating the field mercury measurement
technologies  at  ORNL  in  May, .2003.   It  presents the
objectives, design, sample preparation.and management
procedures,  and  the  reference  method  confirmatory
process used  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  measurement  technologies.      A   SITE
                                  demonstration  must  provide   detailed  and  reliable
                                  performance and cost data, so that potential technology
                                  users   have  adequate  information  to  make  sound
                                  judgements   regarding   an   innovative   technology's
                                  applicability  to  a  specific  site,  and  to.  compare  the
                                  technology to conventional technologies.

                                  Table  4-1 summarizes  the  project  objectives  for  this
                                  demonstration.  In accordance with QAPP Requirements
                                  for Applied Research Projects (EPA,1998), the technical
                                  project objectives for the  demonstration were categorized
                                  as primary and secondary.
Table 4-1. Demonstration Objectives

        Objective
                             Description
  Method of Evaluation
 Primary Objectives
 Primary Objective # 1


 Primary Objective # 2
 Primary Objective # 3

 Primary Objective # 4


 Primary Objective # 5
Determine sensitivity of each instrument with respect to vendor-generated MDL and
PQL.

Determine potential analytical accuracy associated with vendor field measurements.
Evaluate the precision of vendor field measurements.

Measure time required to perform five functions related to mercury measurements:
1) mobilization and setup, 2) initial calibration, 3) daily calibration, 4) sample
analysis, and 5) demobilization.
Estimate costs associated with mercury measurements for the following four
categories: 1) capital. 2) labor. 3) supplies, and 4) investigation-derived wastes.
Independent laboratory
confirmation of SRMs,
field samples, and
spiked field samples.
Documentation during
demonstration; vendor-
provided information.
 Secondary Objectives
 Secondary Objective # 1
 Secondary Objective # 2
 Secondary Objective # 3
 Secondary Objective # 4

 Secondary Objective # 5
Document ease of use, skills, and training required to operate the device properly.
Document potential H&S concerns associated with operating the device.
Document portability of the device.
Evaluate durability of device based on materials of construction and engineering
design.
Document the availability of the device and its spare parts.
Documentation of
observations during
demonstration; vendor-
provided information.

Post-demonstration
investigation.	
                                                        15

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Criticaldata support primary objectives and noncritical data
support secondary objectives. With the exception of the
cost information, primary objectives required the use of
quantitative  results   to  draw   conclusions  regarding
technology performance.  Secondary objectives pertained
to information that was useful  and did  not  necessarily
require the use of quantitative results to draw conclusions
regarding technology performance.

4.2     Demonstration Design

4.2.1  Approach  for  Addressing  Primary
Objectives

The  purpose of  this demonstration was to evaluate the
performance of  the vendor's instrumentation against  a.
standard laboratory procedure.  In addition, an  overall
average relative  standard deviation (RSD) was calculated
for all measurements made by the vendor and the referee
laboratory.  RSD comparisons used descriptive statistics,
not inferential statistics, between the vendor and laboratory
results.  Other statistical comparisons (both inferential and
descriptive) for sensitivity, precision, and accuracy were
used, depending upon actual demonstration results.
The  approach  for addressing  each  of  the  primary
objectives is discussed .in the following  subsections.  A
detailed explanation of the precise statistical determination
used for evaluating primary objectives No. 1 through No. 3
is presented in Chapters.

4.2.1.1  Primary  Objective #1: Sensitivity

Sensitivity  is the ability of a method or instrument to
discriminate  between  small   differences   in  analyte
concentration (EPA, 2002b).  It can be discussed in terms
of an instrument  detection limit (IOL), a method detection
limit  (MDL), and as a practical  quantitation limit  (PQL).
MDL is not a measure of sensitivity in the same respectas
an IDL  or PQL.  It  is  a measure of precision  at  a
predetermined,  usually low,  concentration.  The   IDL
pertains to  the ability of the instrument to determine with
confidence the difference between a sample that contains
the analyte  of interest at a low concentration and a sample
that does not contain that analyte.  The  IDL is generally
considered to be the minimum true concentration of an
analyte  producing  a  non-zero  signal  that  can  be
distinguished  from the  signals .generated when  no
concentration  of the  analyte  is  present and  with an
adequate degree of certainty.

The IDL is not rigidly defined in terms of  matrix, method,
laboratory,  or analyst variability,  and it is  not usually
associated with a statistical level of confidence. IDLs are,
thus, usually lower than MDLs and rarely serve a purpose
in terms of project objectives (EPA, 2002b).  The PQL
defines a specific concentration with an associated level of
accuracy.  The MDL defines a lower  limit at which a
method  measurement  can  be  distinguished  from
background noise.   The PQL  is  a more meaningful
estimate of sensitivity. The MDL and PQL were chosen as
the two distinct parameters for evaluating sensitivity.  The
approach   for  addressing  each  of  these  indicator
parameters is discussed separately in  the following
paragraphs.

MDL

MDL is the estimated measure of sensitivity as defined in
40  Code of Federal  Regulations (CFR) Part 136.  The
purpose  of the  MDL measurement is  to estimate  the
concentration atwhich an individual field instrument is able
to detect  a minimum  concentration  that is  statistically
.different from instrument background or noise.  Guidance
for the definition of the MDL is provided in EPA G-5i (EPA,
2002b).

The determination of  an MDL  usually requires  seven
different measurements of a low concentration standard or
sample. Following procedures established in 40 CFR Part
136 for water matrices, the demonstration  MDL definition
is as follows:
where: t(n_1i0.M) =

       n       =
       s       =
                      99th percen tile of the t-distribution
                      with n -1 degrees of freedom
                      number of measurements
                      standard deviation  of  replicate
                      measurements
PQL

The PQL is another important measure of sensitivity. The
PQL  is defined in  EPA G-5i  as  the  lowest  level an
instrument is  capable of producing a result  that has
significance in terms of precision and bias.  (Bias  is the
difference  between  the measured value and  the true
value.)  It is generally considered the lowest standard on
the instrument calibration curve.  It is often 5-10  times
higher than the MDL, depending upon the  analyte, the
instrument being used, and  the method  for  analysis;
however, it should not be rigidly defined in this manner. .

During the demonstration, the PQL  was to be defined by
the vendor's reported calibration or based  upon  lower
                                                    16

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concentration samples or SRMs.   The  evaluation of
vendor-reported   results   for  the  PQL  included  a
determination of the percent difference (%D) betweentheir
calculated value and the true value.  The true value is
considered the value reported by the referee laboratory for
field samples or spiked field  samples, or,  in  the case of
SRMs, the certified value provided by the  supplier.  The
equation used for the %D calculation is:
              %D
; F
                    true    calculated
                        'true
               x100
where: Ct,
    true concentration as determined
    by the referee laboratory or SRM
    reference value
    calculated    test sample
    concentration
The PQL and %D were reported for the vendor.  The %D
for the referee laboratory, at the same concentration, was
also reported for purposes of comparison.  No statistical
comparison was made between.these two values; only a
descriptive comparison was made for purposes of this
evaluation. (The %D requirement forthe referee laboratory
was defined as 10% or less. The  reference method PQL
was approximately 10 ug/kg.)

4.2.1.2 Primary Objective #2: Accuracy

Accuracy was calculated bycomparing the measured value
to a  known  or true value.    For  purposes  of  this
demonstration, three  separate standards  were used to
evaluate  accuracy. These included:  1) SRMs, 2) field
samples   collected  from  four  separate   mercury-
contaminated sites, and 3)spiked field samples. Foursites
were used for evaluation of the NITON field instruments.
Samples  representing field samples and spiked field
samples  were  prepared  at the SAIC GeoMechanics
Laboratory. Inordertopreventcrosscontamination,SRMs
were  prepared in a separate location.  Each of these
standards is  discussed  separately in  the  following
paragraphs.

SRMs

The primary standards used to determine accuracy for this
demonstration were SRMs.  SRMs  provided very tight
statistical comparisons, although they did not provide all
matrices of interest nor all ranges of concentrations. The
SRMs were obtained from reputable suppliers,  and had
reported concentrations  at associated 95% confidence
intervals (CIs) and 95% prediction intervals. Prediction
intervals were used for comparison because they represent
a statistically infinite number of analyses, and therefore,
would include all possible correct results 95% of the time.
All SRMs were analyzed by the referee  laboratory and
selected SRMs were analyzed by the vendor, based upon
instrument capabilities and concentrations of SRMs that
could be obtained. Selected SRMs covered an appropriate
range for  each  vendor.  Replicate  SRMs were also
analyzed by the vendor and the laboratory.

The  purpose for SRM analysis by  the referee laboratory
was to provide a check on laboratory accuracy. During the
pre-demonstration,  the referee laboratory  was chosen, in
part, based upon the analysis of SRMs.  This was done to
ensure a competent laboratory would be used  for the
demonstration. Because of the need to provide confidence
in laboratory analysis during thedemonstration, the referee
laboratory  analyzed SRMs  as an on-going check for
laboratory bias.

Evaluation of vendor and laboratory analysis of SRMs was
performed  as follows.   Accuracy was  reported  for
individual   sample  concentrations  of  replicate
measurements made at the same concentration.
Two-tailed 95%  CIs were computed  according to  the
following equation:
                                                       (n-1,0.975)
                                                                •s/^/n
                                     where: t(r_1f 0.975)=
                      97.5th    percentile of the
                      t-distribution with n-1 degrees of
                      freedom
                      number of measurements
                      standard  deviation of replicate
                      measurements
                                     The number of vendor-reported SRM results and referee
                                     laboratory-reported SRM  results that were within  the
                                     associated  95%  prediction  interval were  evaluated.
                                     Prediction intervals were computed in a similar fashion to
                                     the Cl, except that the Student's T value use "n" equal to
                                     infinity and, because prediction intervals represented "n"
                                     approaching infinity, the square root of "n" was dropped
                                     from the equation.

                                     A final measure of accuracy determined from SRMs is a
                                     frequency distribution thatshows the percentage of vendor-
                                     reported measurements that are within a specified window
                                     of the reference value. For example, a distribution within
                                                    17

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a 30% window of a reported concentration, within a 50%
window,  and  outside  a  50%  window of a  reported
concentration. This distribution aspect could be reported
as average, concentrations of replicate results from the
vendor for a particular concentration and matrix compared
to the same sample  from the  laboratory.   These are
descriptive statistics and  are  used  to better describe
comparisons, but they are not intended as inferential tests.

Field Samples

The second accuracy standard used forthis demonstration
was  actual field samples  collected from  four separate
mercury-contaminated sites. This accuracy determination
consisted of a comparison of vendor-reported results for
field  samples to the referee laboratory results for the same
field  samples. The field samples were used to ensure that
"real-world" samples were tested for each  vendor.  The
field  samples consisted of variable mercury concentrations
within  varying soil and sediment matrices.  The  referee
laboratory  results  are  considered  the  standard  for
comparison to each vendor.

Vendor sample  results  for a given  field sample were
compared to replicates analyzed by the laboratory for the
same field sample. (A hypothesis testwas used with alpha
= 0.01. The null hypothesis was  that sample results were
similar. Therefore, if the null hypothesis is rejected, then
the sample sets are considered  different.) Comparisons
fora  specific matrix or concentration were made in orderto
provide additional information on that specific matrix or
concentration.   Comparison of the vendor values to
laboratory values were similar to the comparisons noted
previously for SRMs,  except that  a more definitive or
inferential statistical evaluation was used. Alpha = 0.01
was  used  to  help  mitigate inter-laboratory variability.
Additionally, an aggregate  analysis  was used to mitigate
statistical anomalies (see Section 6.1.2).

Spiked Field Samples

The  third accuracy standard for this demonstration was
spiked field samples.  These spiked field samples were
analyzed by the vendors and by the referee laboratory in
replicate  in  order to  provide  additional  measurement
comparisons to a known value.  Spikes were prepared to
cover additional concentrations not available from SRMs or
the samples collected in the field. They were grouped with
the field sample comparison noted above.

4.2.1.3 Primary Objective #3:  Precision

Precision  can  be defined as  the degree  of  mutual
agreement of  independent measurements  generated
through repeated application of a process under specified
conditions. Precision is usually thought of as repeatability
of a specific measurement, and it is often reported asRSD.
The  RSD  is computed  from a  specified number of
replicates.  The more replications of a measurement, the
more confidence  is  associated with a  reported RSD.
Replication of a  measurement may be  as few as  3
separate measurements to 30 or more measurements of
the  same  sample,  dependent  upon  the degree of
confidence desired in the specified result.  The precision
of an analytical  instrument may vary depending upon the
matrix being measured, the concentration of the analyte,
and whether the measurement is made for an SRM  or a
field sample.

The experimental design for this demonstration included a
mechanism  to  evaluate the precision of  the vendors'
technologies.   Field samples  from  the four mercury-
contaminated field sites were evaluated by each vendor's
analytical   instrument.     During the  demonstration,
concentrations were predetermined only as  low, medium,
or high.  Ranges of test samples (field samples, SRMs,
and  spikes)  were  selected  to cover  the appropriate
analytical ranges of the vendor's instrumentation.  It  was
known prior to the demonstration that  not all vendors were
capable of measuring similar concentrations (i.e., some
instruments were better at measuring low concentrations
and  others  were  geared  toward higher concentration
samples or had other attributes such as cost or ease of use
that  defined  specific  attributes  of  their  technology).
Because of this,  not all vendors analyzed the same
samples.

During  the demonstration, the  vendor's instrumentation
was  tested with samples from the  four different sites,
having  different matrices when possible (i.e., depending
upon available concentrations)  and  having  different
concentrations (high, medium, and low) using a variety of
samples.   Sample  concentrations  for  an  individual
instrument were chosen  based upon  vendor attributes in
terms of expected low, medium, and  high concentrations
that the  particular instrument was capable of measuring.

The referee laboratorymeasured replicates of all samples.
The  results were used for  precision  comparisons to the
individual  vendor.  The  RSD for  the vendor and  the
laboratory were  calculated individually, using the following
equation:


               %RSD = -x100
                        I
                                                    18

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where: S  = standard deviation of replicate results
       x = mean value of replicate results

Using descriptive statistics, differences between vendor
RSD and referee laboratory RSD were determined. This
included  RSD comparisons  based upon  concentration,
SRMs, field samples, and different sites.  In addition, an
overall average RSD was calculated for all measurements
made by the vendor and the laboratory. RSD comparisons
were  based   upon  descriptive  statistical  evaluations
between the vendor and the laboratory, and results were
compared accordingly.

4.2.1.4 Primary  Objective #4: Time per Analysis

The amount of time required for performing the analysis
was measured and reported for five categories:

    Mobilization and setup
    Initial calibration
    Daily calibration
    Sample analyses
    Demobilization

Mobilization and setup included the time needed to unpack
and prepare the instrument for operation. Initial calibration
included the time to perform  the vendor  recommended
on-site calibrations.  Daily calibration  included the time to
perform  the  vendor-recommended  calibrations   on
subsequent field days. (Note that this  could have been the
same as  the  initial calibration, a  reduced  calibration, or
none.) Sample  analyses included the time to  prepare,
measure, and calculate the results for the  demonstration
and the necessary quality control (QC) samples performed
by the vendor.

The time per analysis was determined by dividing the total
amount of time required to perform the analyses by the
number of samples analyzed (197).  In the numerator,
sample analysis time included preparation, measurement,
and calculation of results for demonstration samples  and
necessary QC samples performed by the vendor.  In the
denominator, the total number of analyses included only
demonstration samples analyzed by  the vendor, not QC
analyses nor reanalyses of samples.
Downtime that was required  or that occurred  between
sample analyses as a part of operation and handling was
considered a part of the sample analysis time. Downtime
occurring due to instrument  breakage or  unexpected
maintenance was not counted  in the assessment, but it is
noted in  this final report as  an additional time.  Any
downtime  caused by instrument saturation or  memory
effect was addressed, based  upon its  frequency and
impact on the'analysis.

Unique time measurements are also addressed in this
report (e.g., if soil samples were analyzed directly, and
sediment samples required additional time to dry before the
analyses started, then a statement was made noting that
soil samples were analyzed in X amount of hours, and that
sediment samples required drying time before analysis).

Recorded times were rounded to the nearest 15-minute
interval. The number of vendor personnel used was noted
and factored into the time calculations. No comparison on
time per analysis is made between  the vendor and the
referee laboratory.

4.2.1.5 Primary Objective #5: Cost

The  following  four cost  categories were considered  to
estimate costs associated with mercury measurements:

    Capital costs
•    Labor costs
•    Supply costs
•    Investigation-derived waste (IDW) disposal costs

Although both vendor and laboratory costs are presented,
the calculated costs  were not compared with the referee
laboratory. A summary of how each cost category was
estimated for the measurement device is provided below.

    The capital cost was estimated based on published
    price list's for purchasing, renting,  or leasing each field
    measurement device.  If the device was purchased,
    the capital cost estimate did riot include salvage value
    for the device after work was completed.

    The labor cost was based on the number of people
    required to analyze samples during the demonstration.
    The labor rate was based on a standard hourly rate for
    a technician orother appropriate operator. During the
    demonstration, the skill level required was confirmed
    based on vendor input regarding  the operation of the
    device to produce mercury concentration results and
    observations made in the field. The labor costs were
    based on:  1) the actual number of hours required to
    complete all .analyses, quality assurance (QA), and
    reporting; and 2) the assumption that a technician who
    worked for a portion of a day was  paid for an entire
    8-hour day.

    The supply costs were based on any supplies required
    to analyze the field  and SRM samples during  the
    demonstration.   Supplies  consisted  of items  not
    included in the capital category, such as extraction
                                                   19

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    solvent, glassware, pipettes, spatulas, agitators, and
    'similar materials. The type and quantity of all supplies
    brought to the field and used during the demonstration
    were noted and documented.

    Any  maintenance and  repair  costs  during  the
    demonstration were documented or provided by the
    vendor.. Equipment costs were estimated  based on
    this information and standard cost analysis guidelines
    used in the SITE Program.

    The IDW disposal  costs  included decontamination
    fluids and equipment,  mercury-contaminated soil and.
    sediment  samples,  and used sample  residues.
    Contaminated personal protective equipment (PPE)
    normally used  in  the laboratory was  placed into a
    separate container. The disposal costs for the IDW
    were included in the overall analytical  costs for  each
    vendor.

After all of the cost categories were estimated, the cost per
analysis was calculated. This cost value was based on the
number of analyses performed. As the numberof samples
analyzed increases, the initial capital costs  and  certain
other costs were distributed across a greater number of
samples. Therefore, the per unit cost decreased. Forthis
reason, two costs were reported:  1) the initial capital costs
and 2) the operating costs per analysis. No comparison to
the referee laboratory's method cost was made; however,
a generic cost comparison was made.  Additionally, when
determining  laboratory costs, the  associated cost  for
laboratory audits and data validation should  be considered.
4.2.2  Approach  for Addressing Secondary
       Objectives

Secondary  objectives  were   evaluated   based  on
observations made during the dem onstration.  Because of
the number  of vendors  involved, technology observers
were required to make simultaneous observations of two
vendors each during the demonstration. Four procedures
were  implemented  to  ensure  that  these  subjective
observations made by the observers were as consistent as
possible.

First, forms were developed for each of the five secondary
objectives.   These forms assisted in  standardizing the
observations. Second, the observers m et each day before
the evaluations, began, at significant break periods, and
after each  day of  work  to   discuss  and  compare
observations regarding each device. Third, an additional
observer was assigned to independently evaluate only the
secondary objectives  in order to  ensure that a consistent
approach  was applied  in  evaluating  these objectives.
Finally, the SAIC TOM circulated among the evaluation
staff during the demonstration to  ensure that a consistent
approach was being followed by all personnel. Table 4-2
summarizes  the   aspects  observed  during   the
demonstration  for  each secondary  objective.   The
individual approaches to each  of these objectives  are
detailed further in the  following subsections.
Table 4-2. Summary of Secondary Objective Observations Recorded During the Demonstration

                                                 SECONDARY OBJECTIVE
General
Information
- Vendor Name
- Observer Name
- Instrument Type
- Instalment Name
- Model No.
- Serial No.
Secondary Objective # 1
Ease of Use
- No. of Operators
- Operator Names/Titles
- Operator Training
- Training References
- Instrument Setup Time
- Instrument Calibration Time
- Sample Preparation Time
- Sample Measurement Time
Secondary Objective # 2
H&S Concerns
- Instrument Certifications
- Electrical Hazards
- Chemicals Used
- Radiological Sources
- Hg Exposure Pathways
- Hg Vapor Monitoring
- PPE Requirements
- Mechanical Hazard
• Waste Handling Issues
Secondary Objective # 3
Instrument Portability
- Instrument Weight
- Instrument Dimensions
- Power Sources
- Packaging
- Shipping & Handling
• Secondary Objective # 4
Instrument Durability
- Materials of Construction
- Quality of Construction
- Max Operating Temp.
- Max Operating Humidity
- Downtime
- Maintenance Activities
- Repairs Conducted
H&S =  Health and Safety
PPE =  Personal Protective Equipment
                                                   20

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4.2.2.1 Secondary Objective #1: Ease of Use

The skills and training required for proper device operation
were  noted; these included any degrees or specialized
training required by the operators. This information was
gathered by interviews (i.e., questioning) of the operators.
The number of operators required was also noted.  This
objective was also evaluated by subjective  observations
regarding the easeof equipment useand major peripherals
required to measure mercury concentrations in soils and
sediments. The operating  manual  was  evaluated  to
determine  if it is easily useable and understandable.

4.2.2.2 Secondary Objective  #2:  Health and Safety
       Concerns

Health and safety (H&S) concerns associated with device
operation  were noted during the demonstration. Criteria
included hazardous materials used, the frequency and
likelihood of potential exposures, and any direct exposures
observed  during the  demonstration.  In .addition, any
potential for exposure to mercury during sample digestion
and analysis was evaluated,  based  upon  equipment
design. Other H&S concerns, such as basic electrical and
mechanical  hazards,   were  also noted.    Equipment
certifications, such as Underwriters Laboratory (UL), were
documented.

4.2.2.3 Secondary Objective  #3:  Portability of the
       Device

The portability of the device was evaluated  by observing
transport,   measuring   setup  and  tear  down   time,
determining the size and weight of the  unit and peripherals,
and assessing the ease with which  the instrument was
repackaged for movement to another  location.  The use of
battery power or the need for an AC outlet was also noted.

4.2.2.4 Secondary Objective #4: Instrument Durability

The durability of each  device and major peripherals was
assessed   by  noting  the  quality  of materials  and
construction.  All device failures,  routine  maintenance,
repairs, and  downtime were  documented during the
demonstration.   No  specific tests  were  performed  to
evaluate durability; rather, subjective observations  were
made using a field form as guidance.

4.2.2.5 Secondary Objective #5: Availability of Vendor
       Instruments and Supplies

The availability  of  each device  was  evaluated  by
determining whether additional units  and spare parts are
readily available from  the vendor or retail  stores.  The
vendor's.office (or a web page) and/or  a retail store was
contacted to  identify and  determine  the availability  of
supplies  of the tested measurement  device and  spare
parts. This portion of the evaluation was performed after
the field demonstration,  in  conjunction  with  the cost
estimate.

4.3    Sample Preparation and Management

4.3.1  Sample Preparation

4.3.1.1 Field Samples

Field samples were collected during the pre-demonstration
portion of the project, with the ultimate goal of producing a
set of consistent test soils and sediments to be distributed
among all participating vendors and the referee laboratory
for analysis during the demonstration.  Samples were
collected from the following four sites:

•   Carson River Mercury site (near Dayton, NV)
    Y-12 National Security Complex (Oak Ridge, TN)
••   Manufacturing facility (eastern U.S.)
    Puget Sound (Bellingham, WA)

The field samples collected during the pre-demonstration
sampling events comprised a variety of matrices, ranging
from material having  a high clay content to material
composed  mostly of gravelly, coarse sand.  The field
samples  also differed with respect  to moisture content;
several were collected as wet sediments. Table 4-3 shows
the number of distinct field samples that were  collected
from each of the four field sites.
Prior to the start of the demonstration, the field samples
selected  for  analysis during the  demonstration  were
processed at the SAIC GeoMechanics Laboratory in Las
Vegas,  NV.    The  specific sample homogenization
procedure used by this laboratory largely depended on the
moisture content and physical consistency of the sample.
Two specific  sample homogenization procedures were
developed  and tested  by  SAIC  at the GeoMechanics
Laboratory  during the pre-demonstration portion of the
project.  -The methods  included  a non-slurry sample
procedure and a slurry sample procedure.
A  standard operating, procedure  (SOP) was developed
detailing both methods. The procedure was found to  be
satisfactory, based upon the results of replicate samples
during the pre-demonstration. This SOP  is included  as
Appendix A of the Field Demonstration Quality Assurance
Prq/ecfP/an(SAIC,August2003, EPA/600/R-053). Figure
4-1 summarizes  the homogenization steps of the SOP,
beginning with sample mixing. This procedure was used
                                                   21

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for preparing both pre-demonstration and demonstration
samples.  Prior to the mixing process (i.e., Step 1 in Figure
4-1),  all field samples  being processed  were  visually
inspected to ensure that oversized materials were removed
and that there  were  no clumps that  would  hinder
homogenization.   Non-slurry samples were air-dried in
accordance with the SOP so that they could be  passed
multiple times through a riffle splitter.  Due to the high

Table 4-3. Field Samples Collected from the Four Sites
                                   moisture content of many of the samples, they were not
                                   easily air-dried and could not be passed  through a riffle
                                   splitter  while  wet.   Samples with very  high  moisture
                                   contents,  termed "slurries," were  not  air-dried, and
                                   bypassed the riffle splitting  step.  The homogenization
                                   steps for each type of matrix are briefly summarized  as
                                   follows.
  Field Site
No. of Samples / Matrices
Collected
Areas For Collecting Sample Material
Volume Required
Carson River
Y-12
Manufacturing Site
Puget Sound
12 Soil
6 Sediment
10 Sediment
6 Soil
12 Soil
4 Sediment
Tailings Piles (Six Mile Canyon)
River Bank Sediments
Poplar Creek Sediments
Old Mercury Recovery Bldg. Soils
Subsurface Soils
High-Level Mercury (below cap)
Low-Level Mercury (native material)
4 L each for soil
1 2 L each for sediment
12 L each for sediment
4 L each for soil
4 L each
12 Leach
Preparing Slurry Matrices

For slurries (i.e., wet sediments),  the mixing steps were
sufficiently thorough that the sample containers could be
filled directly from the mixing  vessel.  There were  two
separate mixing steps for the slurry-type samples. Each
slurry was initially mixed mechanically within the sample
container (i.e., bucket) in which the sample was shipped to
the SAIC GeoMechanics Laboratory. Asubsample of this
premixed sample  was  transferred to a second  mixing
vessel.  A mechanical drill  equipped  with a paint mixing
attachment was used to mix the subsample. As shown in
Figure 4-1,  slurry samples bypassed the sample  riffle
splitting step. To ensure all sample bottles  contained the
same material, the entire set of containers to be filled was
submerged into the slurry as a group. The filled vials were
allowed to  settle  for a  minimum  of  two days, and  the
standing water was removed using a Pasteur pipette. The
removal of the standing water from the slurry samples was
the only change to the homogenization procedure between
the pre-demonstration and the demonstration.

Preparing "Non-Slurry" Matrices

Soils and sediments  having no  excess moisture were
initially mixed (Step 1) and then homogenized  in  the
sample  riffle  splitter (Step 2).  Prior to these steps, the
material  was air-dried and subsampled to  reduce  the
volume of material to a size that was easier to handle.
                                  As shown in Figure 4-1 (Step 1), the non-slurry subsample
                                  was manually stirred with a spoon or similar equipment
                                  until the  material was  visually  uniform.   Immediately
                                  following manual mixing, the subsample was mixed and
                                  split six times for more complete homogenization (Step 2).
                                  After the  sixth and final split, the sample material was
                                  leveled to form a flattened, elongated rectangle and cut into
                                  transverse sections to fill the containers (Steps 3 and 4).
                                  After homogenization, 20-mL sample vials were filled and
                                  prepared for shipment (Step 5).

                                  For the demonstration, the vendor analyzed' 197 samples,
                                  which included replicates of up to 7 samples per sample
                                  lot.   The  majority of  the samples distributed  had
                                  concentrations within the range of the vendor's tech no logy.
                                  Some samples had expected concentrations at or below
                                  the estimated level of detection  for each of the vendor
                                  instruments. These samples were designed to evaluate
                                  the reported  MDL  and  PQL  and also to assess the
                                  prevalence of false positives. Field samples distributed to
                                  the vendor included sediments and soils collected from  all
                                  four sites  and  prepared by  both the slurry and dry
                                  homogenization  procedures.  The field  samples were
                                  segregated into broad sample sets: low, medium, and high
                                  mercury concentrations.  This gave the vendor the same
                                  general understanding of the sample to be analyzed  as
                                  they would  typically have  for field application  of their
                                  instrument.
                                                    22

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           Test material mixed until

               visually uniform

          For non-slurries
          Mix manually

          For slurries
          a) Mix mechanically the entire
          sample volume

          b) Subsample slurry, transfer to
          mixing vessel, and mix
          mechanically
                Slurries transferred
               directly to 20 mL vials
              (vials submerged into slurry)
                                                               Non-slurries to
                                                                riffle splitter
                                    Combined splits
                                    are reintroduced
                                    into splitter (6 X)








1 J

^— ^
L : ^^
\
4T , , . A 1 1 1 1 1 1 II
Transfer cut i
sections to
20 mL vials 3 ฃ
4


/ RIFFLE \\ I
SPLITTER VI I
v— —. 	 $i
J^vvX.
/Elongated
rectangular pile
(from 6" split)
.
iiiiiir\^iiiiiMiiiiiMiii\
TEFLON SURFACE 1
Sample aliquots made
by transverse cuts
across sample piles

                                  Samples shiped @ 4 ฐC to
                                  referee lab and Oak Ridge
                                      (Container numbers will vary)
Figure 4-1.  Test sample preparation at the SAIC GeoMechanics Laboratory.
                                                23

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In addition,  selected field  samples  were spiked  with
mercury (II) chloride to generate samples with additional
concentrations  and  test  the  ability  of  the  vendor's
instrumentation to measure the  additional  species  of
mercury.  Specific  information  regarding the  vendor's
sample distribution is included in Chapters.

4.3.1.2 Standard Reference Materials

Certified SRMs were analyzed by both the vendors and the
referee laboratory.  These  samples were homogenized
matrices which had  known concentrations of  mercury.
Concentrations were certified values, as provided by the
supplier,  based on independent confirmation via multiple
analyses of. multiple  lots and/or multiple analyses .by
different  laboratories (i.e., round robin testing).  These
analytical results  were  then used to determine "true"
values, as well as statistically derived intervals (a  95%
prediction interval) that provided  a range within which the
true values were expected to fall.

The  SRMs selected were  designed to encompass the
same contaminant  ranges indicated  previously:  low-,
medium-, and  high-level  mercury concentrations.    In
addition,  SRMs of varying matrices were included in the
demonstration to challenge the vendor technology as well
as the referee laboratory. The referee laboratory analyzed
all SRMs. SRM samples were intermingled with site  field
samples and labeled in the same m anner as field samples.

4.3.1.3 Spiked Field Samples

Spiked  field  samples  were prepared   by  the SAIC
GeoMechanics Laboratory  using mercury (II)  chloride.
Spikes were  prepared  using  field samples from  the
selected  sites.   Additional information was  gained by
preparing spikes   at  concentrations  not  previously
obtainable. The SAIC GeoMechanics Laboratory's ability
to prepare spikes was tested prior to the  demonstration
and evaluated in order to determine expected variability
and accuracy of the spiked sample. The spiking procedure
was evaluated by preparing  several different spikes using
two different spiking procedures (dry and wet).  Based
upon results of replicate  analyses, it was determined that
the wet, or slurry, procedure was the only effective method
of obtaining a homogeneous spiked sample.

4.3.2  Sample Management

4.3.2.1  Sample Volumes, Containers, and Preservation

A subset from the pre-demonstration  field samples  was
selected  for use  in  the  demonstration,  based on the
sample's mercury concentration range and sample  type
(i.e., sediment versus soil).  The SAIC GeoMechanics
Laboratory  prepared  individual batches of field sample
material to fill sample containers for each vendor. Once all
containers from a field sample were filled, each container
was labeled and  cooled to 4 ฐC.   Because  mercury
analyses were to be performed both by the vendors in the
field and by the referee laboratory, adequate sample size
was taken  into  account.    Minimum  sample  size
requirements for the vendors varied from 0.1  g or less to
8-10 g.  Only  the referee laboratory analyzed separate
sample aliquotsfor parameters otherthan mercury. These
additional parameters included arsenic, barium, cadmium,
chromium,  lead, selenium,  silver, copper, zinc, oil and
grease, and total organic carbon (TOC). Since the mercury
method  (SW-846 7471B)  being used by  the referee
laboratory requires 1  g foranalysis, the sample size sent to
all participants  was  a 20-rnL vial (approximately 10 g),
which ensured  a sufficient volume and mass for analysis
by all vendors.

4.3.2.2  Sample Labeling

The sample labeling  used for the 20-mL vials consisted of
an internal code developed by SAIC. This "blind" code was
used throughout the entire demonstration.   The  only
individuals  who knew  the  key  to the  coding of the
homogenized samples to the specific field samples were
the SAIC  TOM, the SAIC  GeoMechanics  Laboratory
Manager, and the SAIC QA Manager.

4.3.2.3  Sample Record   Keeping,   Archiving,  arid
        Custody
Samples were shipped to  the laboratory and  the
demonstration site the week prior to the demonstration. A
third set of vials was archived at the SAIC GeoMechanics
Laboratory as reserve samples.

The sample shipment to Oak Ridge was retained at all
times in  the custody of SAIC at their Oak Ridge office until
arrival of the  demonstration field crew.  Samples were
shipped under chain  of custody (CoC) and with custody
seals on both the coolers  and the inner  plastic  bags. Once
the demonstration crew arrived, the coolers were retrieved
from the SAIC office. The  custody seals on the plastic
bags inside the cooler were broken by the vendor upon
transfer.

Upon  arrival at the  ORNL  site,  the vendor  set up the
instrumentation at the direction and oversight of SAIC.  At
the start of sample testing, the vendor was provided with a
sample  set representing field samples collected from a
particular field site,  intermingled  with  SRM  and spiked
samples.   Due to  variability  of vendor   instrument
                                                    24

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measurem ent ranges for mercury detection, not all vendors
received  samples  from  the same field material.  All
samples were stored in an ice coolerpriorto demonstration
startup and were stored in an on-site sample refrigerator
during the demonstration. Each sample set was identified
and distributed as a set with respect to the site from which
if was  collected.  This was done  because, in any field
application, the location and general type of the samples
would be known.

The  vendor was responsible for analyzing all samples
provided,  performing  any  dilutions or  reanalyses as
needed, calibrating the instrument if applicable, performing
any necessary maintenance, and reporting all results. Any
samples  that were  not analyzed  during the  day were
returned to the vendor for analysis at the beginning of the
next day.  Once analysis of the samples from the first
location were completed by the vendor, SAIC provided  a
set of samples from the second location. Samples were
provided  at the  time that  they were requested  by the
vendor.   Once  again, the  transfer of samples was
documented using a COC form.

This  process  was  repeated  for  samples  from each
location. SAIC maintained custody of all remaining sample
sets  until  they were transferred to the  vendor.   SAIC
maintained custody of samples that already had been
analyzed and followed the waste handling procedures in
Section 4.2.2 of the Field Demonstration QAPP to dispose
of these wastes.
4.4
Reference
Process
Method    Confirmatory
The  referee laboratory analyzed  all samples that were
analyzed by the  vendor technologies in the field.  The
following subsections provide information on the selection
of the  reference  method,  selection of  the  referee
laboratory, and details regarding, the performance of the
reference  method  in  accordance with  EPA protocols.
Other parameters  that were  analyzed  by  the referee
laboratory are also discussed briefly.

4.4.1   Reference Method Selection
The selection of SW-846 Method 7471B as the reference
method  was  based on  several factors,  predicated on
information obtained from the technology vendors, as well
as the  expected contaminant types  and  soil/sediment
mercury concentrations expected  in  the test matrices.
There are several laboratory-based, promulgated methods
for the analysis of total mercury.   In addition, there  are
several performance-based methods for the determination
of various mercury  species.   Based  on the vendor
technologies, it was determined that a reference method
for total mercury would be needed (Table  1-2 summarizes
the methods evaluated, as identified through a review of
the EPA Test Method Index and SW-846).

In selecting  which of the potential methods  would be
suitable as a reference method, consideration was given to
the following questions:

   Was the method widely used and accepted? Was the
   method an EPA-recommended, or similar regulatory
   method?  The selected reference  method should be
   sufficiently used  so that  it could be cited  as an
   acceptable  method  for  monitoring  and/or  permit
   compliance among regulatory authorities.

   Did the selected reference method  provide QA/QC
   criteria that  demonstrate acceptable 'performance
   characteristics over time?

   Was the method suitable for the species of mercury
   that were expected to be encountered? The reference
   method  must be capable  of determining,  as  total
   mercury, all forms of the contaminant known or likely
   . to be present in the matrices.
   Would the method achieve the necessary detection
   limits  to  evaluate  the  sensitivity of each vendor
   technology adequately?

   Was the method suitable for the concentration range
   that was expected in the test matrices?

Based  on  these  considerations, it was  determined that
SW-846 Method  7471B  [analysis of mercury  in solid
samples by  coldwapor atomic absorption spectrometry
(AAS)]  would be the best reference method.  SW-846.
method  7474,  an  atomic  fluorescence  spectrometry
method using Method 3052 for microwave digestion of the
solid) had also  been  considered  a  likely  technical
candidate; however,  because this method was not as
widely used or referenced, Method 7471B was considered
the better choice.

4.4.2  Referee Laboratory Selection

During the planning of the pre-demonstration phase of this
project, nine laboratories were sent a  statement of work
(SOW) for the analysis of mercury to be performed as part
of the pre-demonstration.  Seven of the nine laboratories
responded to the SOW with appropriate bids. Three of the
seven laboratories were selected as candidate laboratories
based  upon  technical  merit,  experience, and pricing.
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These laboratories received and analyzed blind samples
andSRMs during pre-demonstration activities. The referee
laboratory to be used for the demonstration was selected
from these three candidate laboratories.  Final selection of
the referee laboratory was based upon: 1) the laboratory's
interest in  continuing  in  the  demonstration,  2)  the
laboratory-reported SRM results, 3) the laboratory MDL for
the reference  method selected, 4) the precision of the
laboratory calibration curve, 5) the  laboratory's ability to
support the demonstration (scheduling conflicts, backup
instrumentation, etc.), and 6) cost.

One of the three candidate laboratories was eliminated
from selection based on a technical consideration. It was
determined that this laboratory would  not be able to meet
demonstration quantitation limit requirements.  (Its lower
calibration standard was approximately 50 ug/kg and the
vendor comparison requirements  were well below this
value.)  Two  candidates  thus remained,  including  the
eventual demonstration laboratory, Analytical Laboratory
Services, Inc. (ALSI) :

        Analytical Laboratory Services, Inc.
        Ray Martrano, Laboratory Manager
        34 Dogwood Lane
        Middletown, PA 17057
        (717) 944-5541

In order to make a  final decision on  selecting a referee
laboratory, a preliminary audit was performed by theSAIC
QA Manager at the remaining  two candidate laboratories.
Results of the SRM samples were compared for the two
laboratories. Each laboratory analyzed each sam pie (there
were two SRMs) in triplicate. Both laboratories were within
the 95% prediction interval for each SRM. In addition, the
average result from the two SRMs was compared to the
95% CI for the SRM.

Calibration curves from  each laboratory were reviewed
carefully. This included calibration curves generated from
previously performed analyses and those generated for
other laboratory clients. There were two QC requirements
regarding calibration curves; the correlation coefficient had
to be  0.995 or greater  and the  lowest  point on  the
calibration curve had to be within  10%  of the predicted
value.  Both laboratories were able to achieve these two
requirements for all curves  reviewed and for  a lower
standard of 10 ug/kg, which was the  lower standard
required for the demonstration,  based upon information
received from each of the vendors. In addition, an analysis
of seven  standards was reviewed  for  MDLs.   Both
laboratories were able to achieve an MDL that was below
1 ug/kg.

It should be noted that vendor sensitivity claims impacted
how low this lower quantitation standard should be.  These
claims were somewhat vague, and the actual quantitation
limit each vendor could achieve was uncertain prior to the
demonstration (i.e., some vendors claimed a sensitivity as
low as 1 pg/kg, but it was uncertain at the time if this limit
was actually a PQL or a detection limit). Therefore, it was
determined that,  if necessary, the laboratory actually
should be able to achieve even a lower PQL than 10 M9/kg-
For both laboratories, SOPs based upon SW-846 Method
7471B were reviewed. Each SOP followed this reference
method.   In addition,  interferences  were  discussed
because   there   was   some  concern  that  organic
interferences  may have been present in  the  samples
previously analyzed by the laboratories.  Because these
same  matrices  were   expected  to  be  part  of  the
demonstration, there was some concern associated with
how these interferences would be eliminated.  This  is
discussed at the end of this subsection.

Sample throughput was somewhat important because the
selected  laboratory was to  receive all demonstration
samples at the same time (i.e., the samples were to be
analyzed at the same  time  in order to  eliminate any
question of variability associated with loss of contaminant
due to holding time). This meant that the laboratory would
receive approximately 400  samples for analysis over the
period of  a  few days.  It was  also desirable for the
laboratory to produce  a data report within  a 21-day
turnaround time for purposes of the demonstration. Both
laboratories  indicated  that  this   was   achievable.
Instrumentation  was reviewed and examined at both
laboratories.  Each  laboratory  used a  Leeman mercury
analyzer for  analysis. One of the two  laboratories had
backup  instrumentation in case  of problems.   Each
laboratory indicated that its Leeman mercury analyzer was
relatively new and had not been a  problem in the past.

Previous  SITE program experience was another factor
considered as part of these pre-audits. This is because the
SITE  program generally  requires a very high level  of QC,
such that most laboratories are not familiar with the QC
required unless they have previously participated in the
program.  A second aspect of the SITE program is that it
generally requires analysis of relatively "dirty" samples and
many laboratories are not use to  analyzing such "dirty"
samples.    Both  laboratories  have  been   longtime
participants in this program.
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Other QC-related  issues  examined  during the  audits
included: 1) analyses of other SRM samples not previously
examined, 2) laboratory control charts, and 3) precision
and accuracy results.  Each of these issues was closely
examined.  Also, because of the desire to increase the
representativeness of the samples for the demonstration,
each laboratory was asked if sample aliquotsizes could be
increased to 1 g (the method requirement noted 0.2  g).
Based upon previous results, both laboratories routinely
increased sample  size to 0.5 g,  and each  laboratory
indicated that increasing the sample size would not be a
problem. Besides these QC issues, other less tangible QA
elements  were  examined.   This  included   analyst
experience,  management  involvement   in  the
demonstration, and internal laboratory QA management.
These elements were also factored into the final decision.

Selection Summary

There were very few factors that separated the quality of
these two laboratories. Both were exemplary in performing
mercury analyses.   There were, however, some minor
differences based upon this evaluation that were noted by
the auditor. These were as follows:

•  ALSI had  backup instrumentation available.  Even
   • though neither laboratory reported any problems with
   its primary instrument (the Leeman mercury analyzer),
   ALSI did have a backup instrument in case there were
   problems with the primary instrument, or in the event
   that the laboratory needed to perform other mercury
   analyses during the demonstration time.

   As noted, the  low  standard  requirement  for  the
   calibration curve was  one of the QC requirements
   specified for this demonstration in order to ensure that
   a  lower  quantitation could be achieved.   This  low
   standard was 10 pg/kg for both laboratories.  ALSI,
   however, was able to show experience in being able to
   calibrate  much  lower than  this,  using  a second
   calibration curve.  In the event that the vendor was
   able to  analyze at concentrations  as low as 1 ug/kg
   with precise and accurate determinations, ALSI was
   able to  perform analyses at lower concentrations  as
   part of the demonstration. ALSI used a second, lower
   calibration curve for any analyses required below 0.05
   mg/kg.   Very  few vendors  were able to  analyze
   samples at concentrations at this low a level.
   Management practices and analyst experience were
   similar at both laboratories. ALSI had participated in a
   few  more SITE  demonstrations than  the  other
    laboratory, but  this difference  was  not  significant
    because  both  laboratories had proven themselves
    capable of handling the additional QC requirements for
    the SITE program.  In addition, both laboratories had
    internal QA management procedures to  provide the
    confidence needed to achieve SITE requirements.
    Interferences for the samples previously analyzed were
    discussed and  data were reviewed. ALSI  performed
    two separate analyses for each sample. This included
    analyses   with  and  without  stannous  chloride.
    (Stannous chloride  is the  reagent used  to release
    mercury into the vapor phase for analysis. Sometimes
    organics can cause interferences in the vapor phase.
    Therefore, an analysis with no stannous chloride would
    provide information  on organic interferences.) The
    other laboratory did not routinely perform this analysis.
    Some samples were thought  to contain  organic
    interferences, based on previous sample results. The
    pre-demonstration results reviewed indicated that no
    organic interferences were present. Therefore, while
    this was  thought  to  be a  possible discriminator
    between the two laboratories in terms  of analytical
    method performance, it became moot for the samples
    included in this demonstration.
The factors above were considered in the final evaluation.
Because there were only minor differences in the technical
factors,  cost of analysis was used as the discriminating
factor.   (If there  had  been  significant  differences in
laboratory quality,  cost would not have been a  factor.)
ALSI  was  significantly  lower  in cost  than  the other
laboratory.  Therefore, ALSI was  chosen as the  referee
laboratory for the demonstration.

4.4.3   Summary of Analytical Methods

4.4.3.1  Summary of Reference Method

The critical measurement for this study was the analysis of
mercury in soil and sediment samples.  Samples analyzed
by the  laboratory  included field  samples,  spiked field
samples,  and  SRM  samples.    Detailed  laboratory
procedures for subsampling, extraction, and analysis were
provided in the SOPs included as Appendix B of the Field
Demonstration QAPP.   These are briefly  summarized
below.

Samples were analyzed for mercury using Method 7471B,
a cold-vapor  atomic absorption method, based  on  the
absorption of radiation at the 253.7-nm  wavelength by
mercury vapor. The mercury is  reduced to the elemental
state and stripped/volatilized from solution in a closed
system.  The mercury vapor passes through  a  cell
                                                   27

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positioned in the light path of the AA spectrophotometer.
Absorbance (peak height) is measured as a function of
mercury concentration. Potassium permanganate is added
to eliminate possible interference from sulfide. As  per the
method, concentrations as high as 20 mg/kg of sulfide, as
sodium sulfide, do not interfere with the recovery of added
inorganic mercury in reagent water. Copper has also been
reported  to interfere; however, the  method  states that
copper concentrations as high as 10 mg/kg have no effect
on recovery of mercury  from spiked samples.  Samples
high in chlorides require additional permanganate (as much
as 25 ml) because, during the oxidation step, chlorides are
converted to free chlorine, which also absorbs radiation at
254 nm.  Free chlorine is removed by using an excess (25
mL)  of hydroxylamine sulfate reagent.  Certain  volatile
organic materials that absorb at this wavelength  may also
cause interference.    A  preliminary analysis  without
reagents can determine if this  type  of interference is
present.

Prior to analysis, the contents of the sample container are
stirred, and the sample mixed prior to removing an aliquot
for the mercury analysis. An aliquot of soil/sediment (1 g)
is placed in the bottom of a biochemical oxygen demand
bottle, with reagent water and aqua regia added.  The
mixture is heated in a water bath at 95 ฐC for 2 minutes.
The solution is cooled and reagent water and potassium
permanganate solution are added to the sample bottle.
The bottle contents are thoroughly mixed, and the bottle is
placed in the  water bath for  30  minutes  at 95 ฐC. After
cooling, sodium chloride-hydroxylamine sulfate is added to
reduce the  excess permanganate.  Stannous chloride is
then added and the bottle attached  to the analyzer; the
sample  is aerated and  the  absorbance  recorded.  An
analysis without stannous chloride is also included as an
interference  check  when  organic   contamination  is
suspected.  In the event of  positive results of  the non-
stannous chloride analysis, the  laboratory was  to report
those results to SAIC so that a determination of organic
interferences could  be made.
4.4.3.2  Summary  of   Methods
        Measurements.
                for   Non-Critical
A  selected  set  of non-critical parameters  was   also
measured during the demonstration.  These  parameters
were measured to provide a better insight into the chemical
constituencyof the field samples, including the presence of
potential interferents. The results of the tests  for potential
interferents were reviewed  to  determine if a trend was
apparent in the event that inaccuracy or low precision was
observed.   Table  4-4 presents the  analytical method
reference  and  method type for  these  non-critical
parameters.

Table 4-4. Analytical Methods for Non-Critical Parameters

 Parameter	  Method Reference    Method Type	
 Arsenic, barium,
 cadmium,
 chromium, lead,
 selenium, silver,
 copper, and zinc
SW-846 3050/6010   Acid digestion, ICP
Oil and Grease
TOC
Total Solids
EPA 1664
SW-846 9060
EPA2540G
n-Hexane
extraction,
Gravimetric
Carbonaceous
analyzer
Gravimetric
4.5     Deviations  from  the  Demonstration
        Plan
There were no deviations to the demonstration plan.  -
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                                             Chapter 5
              Assessment of Laboratory Quality Control Measurements
5.1    Laboratory QA Summary

QA may be defined as a system of activities, the purpose
of which is to provide assurance that defined standards of
quality are met with a stated level of confidence.  A QA
program  is a  means  of integrating the quality planning,
quality assessment, QC, and quality improvement efforts
to meet  user requirements.  The  objective of the QA
program is to reduce measurement errors to agreed-upon
limits, and to  produce results of acceptable and known
quality. The QAPP specified the necessary guidelines to
ensure that the  measurement system for laboratory
analysis was in control, and provided detailed information
on the analytical approach to  ensure that data of high
quality could be obtained  to achieve project objectives.
The laboratory analyses were critical to project success, as
the laboratory results were  used  as a  standard for
comparison to the  field method results. The field methods
are of unknown quality, and  therefore, for comparison
purposes the laboratory analysis needed to be a known
quantity.  The following sections provide information on the
use of data quality indicators, and a detailed summary of
the QC analyses associated with project objectives.

5.2    Data  Quality   Indicators for Mercury
       Analysis

To assess the quality of the data generated by the referee
laboratory, two important data quality indicators of primary
concern are precision and accuracy.  Precision can be
defined as the degree of mutual agreement of independent
measurements generated through repeated  application of
the process under specified conditions. Accuracy is the
degree of agreement of a measured value with the true or
expected value.    Both accuracy  and precision were
measured by  the  analysis of matrix  spike/matrix spike
duplicates (MS/MSDs).  The  precision of  the  spiked
duplicates is evaluated by expressing, as a percentage, the
difference between results of  the  sample  and sample
duplicate results. The relative percent difference (RPD) is
calculated as:
   RPD
 (Maximum Value - Minimum Value)
(Maximum Value + Minimum Value)/2
x100
To determine and evaluate accuracy, known quantities of
the target analytes were spiked into selected field samples.
All spikes were post-digestion spikes because of the high
sample   concentrations   encountered   during   the
demonstration.     Pre-digestion  spikes,  on  high-
concentration samples would either have been  diluted or
would have required additional studies to determine the
effect of spiking more analyte and subsequent recovery
values.  To determine matrix spike recovery, and hence
measure accuracy, the following equation was applied:
               %R=Cgs,  C"sx100
                     '  C.
where,
       GSS    =      Analyte  concentration in spiked
                     sample
       Cus    =      Analyte concentration in unspiked
                     sample
       Cja    =      Analyte  concentration added to
                     sample

Laboratory  control  samples (LCSs) were  used as an
additional measure of accuracy in the event of significant
                                                  29

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matrix interference.  To determine the percent recovery of
LCS analyses, the equation below was used:

         „.„   Measured Concentration   .„„
         %R= -=r,	:	—	:	x1DO
              Theoretical Concentration
While several precautions were taken to generate data of
known quality through control of the measurement system,
the data must also be representative of true conditions and
comparable   to   separate   sample   aliquots.
Representativeness refers  to the  degree with  which
analytical  results accurately and precisely reflect actual
conditions present at the locations chosen for sample
collection. Representativeness was evaluated as part of
the pre-demonstration and combined with the  precision
measurement  in  relation  to sample aliquots.  Sample
aliqupting  by the SAIC GeoMechanics Laboratory tested
the ability of the  procedure to  produce homogeneous,
representative,  and comparable  samples. 'All  samples
were  carefully  homogenized   in   order  to  ensure
comparability between  the  laboratory and  the vendor.
Therefore, the RSD measurement objective of 25% or less
for replicate sample lot analysis was intended to assess not
only precision but representativeness and comparability.

Sensitivity was  another critical factor assessed for  the
laboratory method of analysis.  This was measured as a
practical quantitation limit and was determined by the  low
standard on the calibration curve. Two separate calibration
curves were run by the laboratory when necessary.  The
higher calibration curve was used for the majority of  the
samples and had a lower calibration limit of 25 ug/kg. The
lower calibration curve was used  when  samples were
below this  lowercalibration standard.  The lowercalibration
curve had  a lower limit standard of 5 ug/kg. The lower limit
standard of the calibration curve was run with each sample
batch as a check standard and was  required to  be within
10% of  the  true value (QAPP QC  requirement).  This
additional check on analytical sensitivity was performed to
ensure  that  this  lower   limit  standard  was  truly
representative  of  the  instrument and method  practical
quantitation limit.
5.3    Conclusions
       Limitations
and    Data    Quality
Critical sample  data and associated QC analyses were
reviewed to determine whether the data collected were of
adequate  quality to  provide  proper evaluation  of  the
project's technical objectives.  The results of  this review
are summarized below.
                             Accuracy objectives for mercury analysis by Method 7471B
                             were assessed  by the evaluation of 23 spiked duplicate
                             pairs, analyzed in accordance with standard procedures in
                             the same manner as the samples.  Recovery values for the
                             critical compounds were well within objectives specified in
                             the QAPP, except for two spiked samples summarized in
                             Table 5-1. The results of these samples, however, were
                             only slightly outside specified limits, and given the number
                             of total samples (46 or 23 pairs), this is  an insignificant
                             number of results that did not fall with in specifications. The
                             MS/MSP results therefore, are supportive of the overall
                             accuracy objectives.
                             Table 5-1. MS/MSD Summary
                              Parameter                  Value
                              QC Limits

                              Recovery Range

                              Number of Duplicate Pairs

                              Average Percent Recovery

                              No. of Spikes Outside QC
                              Specifications
80%-120%

85.2%-126%

23

108%
                             An additional measure of accuracy was LCSs. These were
                             analyzed with every sample batch (1  in 20 samples) and
                             results are presented in Table 5-2. All results were within
                             specifications, thereby supporting the conclusion that QC
                             assessment met project accuracy objectives.
                             Table 5-2. LCS Summary
Parameter
QC Limits
Recovery Range
Number of LCSs
Average Percent Recovery
No. of LCSs Outside QC
Specifications
Value
90%- 110%
90% - 100%
24
95.5%
0
                             Precision was assessed through the  analysis of  23
                             duplicate spike pairs for mercury. Precision specifications
                             were established prior to the demonstration as a RPD less
                                                    30

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than  20%.    All  but  two  sample  pairs  were  within
specifications, as noted in Table 5-3. The results of these
samples,  however, were only slightly  outside specified
limits, and given the number of total samples (23 pairs),
this is an  insignificant number of results that did not fall
within specifications. Therefore, laboratory analyses met
precision specifications.
Table 5-3. Precision Summary
 Parameter                  Value
QC Limits
MS/MSD RPD Range
Number of Duplicate Pairs
Average MS/MSD RPD
No. of Pairs Outside QC
Specifications
RPD< 20%
0.0% to 25%
23
5.7%
2
Sensitivity results were within specified project objectives.
The  sensitivity objective was evaluated as the  PQL, as
assessed by the low standard on the calibration curve. For
the majority of samples, a calibration curve of 25-500 ug/kg
was  used.  This is because the majority, of samples fell
within  this calibration range  (samples  often  required
dilution). There were, however, some samples below this
range and a second curve was used. The calibration range
for this lower curve was 5-50 ug/kg. In order to ensure that
the lower concentration on the calibration curve was a true
PQL, the laboratory ran  a low check  standard (lowest
concentration on the calibration curve) with every batch of
samples.  This standard was required to be within 10%  of
the specified value. The results of this low check  standard
are summarized in Table 5-4.
Table 5-4. Low Check Standards
 Parameter                  Value
 QC Limits

 Recovery Range

 Number of Check Standards
 Analyzed

 Average* Recovery
Recovery 90% -110%

88.6%-111%

23


96%
There were a few occasions where this standard did not
meet specifications.  The  results  of these  samples,
however, were  only slightly outside  specified limits, and
given the  number  of total  samples (23), this  is  an
insignificant number of results that did  not fall  within
specifications.  In addition, the laboratory reanalyzed the
standard when specifications  were not achieved, and the
second determination always fell within the required limits.
Therefore  laboratory  objectives  for  sensitivity  were
achieved according to QAPP specifications.

As noted previously, comparability and representativeness
were assessed through the analysis of replicate samples.
Results of these replicates are presented in the discussion
on primary  project objectives for precision. These results
show that data were within project and QA objectives.

Completeness objectives wereachieved for the project. All
samples were analyzed and data were provided for 100%
of the samples received  by the laboratory.  No sample
bottles were lost or broken.

Other measures of data quality included method blanks,
calibration checks, evaluation  of linearity of the calibration
curve, holding time specifications, and an  independent
standard verification included with each  sample  batch.
These results were reviewed for every sample batch run by
ALSI, and were within specifications.  In addition, 10% of
the reported results were checked against the raw data.
Raw data  were reviewed to  ensure that  sample results
were within the  calibration  range of the  instrument,  as
defined by the calibration curve. A 6-point calibration curve
was generated at the start of each  sample batch of 20. A
few  data points were found  to be incorrectly reported.
Recalculations were  performed for these data, and any
additional data points that were suspected outliers were
checked to  ensure correct results were reported. Very few
calculation  or dilution errors were found. All errors were
corrected so that the appropriate data were reported.

Another measure of compliance were the non-stannous
chloride runs performed by the laboratory forevery sample
analyzed. This was done to check for organic interference.
There were no samples that were found  to have any
organic  interference  by this method.  Therefore, these
results met  expected QC specifications and data were not
qualified in  any fashion.

Total solids data were also  reviewed  to  ensure  that
calculations were performed appropriately and dry weights
reported when required.  All  of  these QC  checks met
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QAPP  specifications.   In  summary,  all data  quality
indicators and QC specifications were reviewed and found
to be well within project specifications. Therefore, the data
are considered suitable for purposes of this evaluation.

5.4   Audit Findings

TheSAIC SITE QA Manager conducted audits of both field
activities and of the subcontracted laboratory as part of the
QA measures for this  project.   The  results  of these
technical system reviews are discussed below.
The   field  audit  resulted  in  no   findings   or  non-
conformances.  The audit performed at the subcontract
laboratory was conducted during the time of project sample
analysis.   One  non-conformance  was identified  and
corrective action  was initiated. It was discovered that the
laboratory  PQL was not meeting specifications due to a
reporting error. The analyst was generating the calibration
curves as specified above; however, the lower limit on the
calibration  curve was  not being  reported.   This  was
immediately  rectified  and  no other  findings or non-
conformances were identified.
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                                              Chapter 6
                    Performance of the XLi/XLt 700 Series Analyzers
NITON analyzed 197 samples from May 5-7, 2003 in Oak
Ridge, TN. Results for these samples were reported by
NITON, and a  statistical  evaluation  was performed  by
SAIC.  Since X-ray is non-destructive for soil samples,
NITON prepared each sample once and analyzed the.
sample on both the XLt and XLi instruments.  Additionally,
the observations made during  the demonstration  were
reviewed,  and  the remaining  primary  and secondary
objectives were  completed. The results of the studies for
the primary and secondary objectives, identified in Chapter
1, are discussed in Sections 6.1 and 6.2, respectively.
                                  Samples with high amounts of water (based upon visual
                                  examination) were dried in a toaster oven. Those samples
                                  identified  as  "dried" by NITON  were compared to the
                                  laboratory "dry  weight" result.  All other samples were
                                  compared to the laboratory "as received" result.

                                  The distribution of the  samples prepared for NITON and
                                  the referee laboratory is presented in Table 6-1. From the
                                  four sites, NITON  received  samples  at 35  different
                                  concentrations for a total of 197 samples. These 197
                                  samples consisted of 23 concentrations in replicates of 7
                                  and 12 concentrations  of 3.
Table 6-1. Distribution of Samples Prepared for NITON and the Referee Laboratory
       Site
Concentration Range
                                              Soil
       Sample Type
Sediment	Spiked Soil
                                                                         SRM
Carson River
(Subtotal = 31)
Puget Sound
(Subtotal = 34)
Oak Ridge
(Subtotal = 54)
Manufacturing
(Subtotal = 78)
Subtotal
(Total = 197)
Low (1-500 ppb)
Mid (0.5-50 ppm)
Hiah(50->1.000 com)
Low(1 ppb- 10 ppm)
Hiah (1 0-500 oom)
Low (0.1-10 ppm)
Hiah H 0-800 pom)
General (5-1,000 ppm)

0
7
3
3
0
0
13
36
62
0
0
0
0
10
3
10
0
23
0
0
7
0
7
0
14
14
42
0
0
14
0
14
0
14
28
70
6.1    Primary Objectives

6.1.1  Sensitivity

Sensitivity objectives are explained in Chapter 4. The two
primary   sensitivity  evaluations  performed  for  this
demonstration were the MDL and PQL.  Determinations of
these two measurem ents are explained in the paragraphs
below, along with a comparison to the referee laboratory.
                                 These determinations set the standard for the evaluation of
                                 accuracy  and  precision  for  both  of NITON'S field
                                 instruments (XLi 702 and XLt 792).  Any sample analyzed
                                 by NITON and subsequently reported as below their level
                                 of detection, was  not  used as part  of any additional
                                 evaluations.  This was done because the expectation that
                                 values below the lower limit of instrument sensitivity would
                                 not reflect the true instrument accuracy and precision.
                                                  33

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The sensitivity measurements of MDL and  PQL are both
dependent upon the matrix and method. Hence, the MDL
and PQL will vary, depending upon whether the matrix is a
soil, waste, or water. Only soils and sediments were tested
during this demonstration and therefore, MDL calculations
for this evaluation reflect soil and sediment matrices.  PQL
determinations are not independent calculations, but are
dependent upon results provided  by the vendor for the
samples tested.

Comparison of the MDL and PQL to laboratory sensitivity
required that a  standard evaluation be performed for all
instruments  tested during  this  demonstration.  PQL, as
previously noted, is defined in EPA G-5i as the lowest level
of method and  instrument performance with a specified
accuracy and precision. This is often defined by the lowest
point on the calibration curve.  Because the NITON field
instruments do not use a calibration curve for the analysis
of samples,  but instead depend upon instrument counts
and an associated standard deviation to  determine the
lower level of quantitation,  our approach was to  let the
vendor  provide  the  lower limits  of quantitation  as
determined  by  their  particular  standard  operating
procedure, and then test these limits  by comparing the
results  to  referee  laboratory results, or comparing the
results  to  results for  a standard  reference material, if
available.   Comparison of  these .data  are,  therefore,
presented for the lowest level sample results, as provided
by the vendor. If the vendor provided "non-detect" results,
then no formal evaluation of that sample was presented.
In addition, that sample (or samples) was not used in the
evaluation of precision and accuracy.

Method Detection Limit - The standard procedure for
determining  MDLs  is  to  analyze a  low  standard  or
reference  material seven times, calculate  the standard
deviation and multiply the standard deviation by  the T
value  for  seven measurements at the 99th  percentile
(alpha = 0.01). (This value is 3.143 as determined from a
standard statistics table.) This procedure for determination
of an  MDL is defined  in 40 CFR Part 136,  and while
determinations for MDLs may  be defined differently for
other instruments, this method was previously noted in the
demonstration   QAPP  and  is  intended  to  provide a
comparison to other similar MDL evaluations. The purpose
is to provide a lower level of detection with a statistical
confidence at which the instrument will detect the presence
of a substance above  its  noise  level.   There is no
associated accuracy or precision provided or implied.

Several blind standards and field samples were provided to
NITON  at  their  estimated lower limit of sensitivity.  The
NITON lower limit of sensitivity for both instruments was
previously estimated at 20 mg/kg.  Because there are
several d if fe re ntSRMs and fie Id samples at concentrations
close to the MDL, evaluation of the MDL was performed
using more than a single concentration.  Samples chosen
for calculation were based upon: 1) concentration and how
close it was to the estimated MDL, 2) number of analyses
performed for the same  sample (e.g..more than 4), and 3)
if non-detects were reported by NITON for a sample used
to calculate the MDL. Then the next highest concentration
sample was selected based upon the premise that a non-
detect result reported for one of several samples indicates
the selected sample is  on the "edge" of the instruments
detection capability.

NITON XLt (X-ray) Evaluation

Afield sample with an average concentration of 14.6 mg/kg
as reported by the referee laboratory (sample lot 62 from
the Puget Sound site) was run by NITON 7 times.  One
result was reported as below their detection limit and the
other 6 results had  a reported average concentration  of
27.4  mg/kg and  a standard deviation of 4.14 mg/kg.
Calculation of the respective MDL  is 13.9 mg/kg. Because
Niton reported a result below their  detection limit additional
samples were selected  for calculating the MDL.

Seven replicates were run by NITON for an SRM with a
reference value  of 32.6 mg/kg  (sample lot 47).   The
average concentration reported by NITON for this sample
was 78 mg/kg and the standard deviation was 6.4 mg/kg.
This particular sample  lot was not used in the general
calculations because of problems  noted with  reported
results from allthe vendors who analyzed this SRM and the
laboratory reported result. Specifically this sample lot was
thrown out because all vendor  results and the referee
laboratory results were outside acceptable SRM reported
values. It was therefore determined that there was likely a
problem with this SRM.  Nonetheless this was considered
an accuracy problem and because MDL calculations are
determined using precision results  (standard deviation
calculations)  and because this  SRM  has a  reported
concentration of 32.6 it would  likely still be an acceptable
value for determining an MDL. There are only six valid
results reported by NITON as  one result was reported  as
below their detection limit. The MDL calculation using this
sample is 21.5 mg/kg.

It should be noted that if the SRM value of 32.6 mg/kg were
correct (there is evidence to suggest that this may be
incorrect for the sample lot received  but it is likely close to
this value) then this concentration would likely be close to
                                                    34

-------
the NITON M DL, as they reported one of the seven tested
samples below their limit of detection.

Seven replicates were run by NITON for an SRM that had
a reference value  of 99.8 mg/kg (sample lot 49).  The
average concentration reported by NITON for this sample
was 108 mg/kg and  the standard deviation was 22.2
mg/kg.  Calculation of the  MDL for this sample is 69.8
mg/kg.

The average of all three of these values (if an average
were used) is 35.1  mg/kg. It is probably more accurate,
however,  to report  that the  range of the  MDL,  as
determined  statistically by 40 CFR part 136 is  between
13.9 and 69.8 mg/kg.  It is likely that the MDL is closer to
the lower end of this range  based  upon the results for
sample lot 62 (referee laboratory value = 14.6 mg/kg) and
sample lot 47 (SRM value = 32.4 mg/kg) which both had 1
of the 7 results reported as below the NITON detection
level indicating that these values are on the edge of the
instruments  detection capability.  It is also more likely to
conclude that the MDL is  closer to the lower end of this
range   because   MDLs   calculated  for  the  lower-
concentration samples are also at the lower end of the
calculated range of results.

As  a further check of the MDL, sample lot 18 had a
reported average concentration bythereferee laboratoryof
10.1 mg/kg.  This was consistently reported by NITON as
below their MDL thereby  confirming  that the calculated
MDL, noted previously was above this value.

Based  upon the  results presented  above, the three
different MDL calculations for this instrument have reported
values of 13.9, 21.5, and 69.8 mg/kg.  It appears that the
MDL for this instrument is close to the lower end of this
range. The  equivalent MDL for the  referee laboratory
based upon analysis of a low standard analyzed 7 times is
0.0026 mg/kg.  The calculated result is only intended as a
statistical estimation  and  not a true test of  instrument
sensitivity.

Practical Quantitation Limit  - This value is usually
calculated by determining a low standard on the instrument
calibration curve and it is estimated as the lowest standard
at which the instrument  will accurately  and precisely
determine a given concentration within specified QC limits.
For the NITON  field  instruments, there is no calibration
curve, and therefore the low  standard from a calibration
curve is not a valid estimation of the PQL. The PQL is
often around 5-10 times the MDL.  This PQL estimation,
however, is  method- and  matrix-dependent.  In order to
determine the PQL, several low standards were provided
to NITON and subsequent %Ds were calculated.

The  lower limit of sensitivity previously  provided by the
vendor (20 mg/kg) appears to be below their calculated.
MDL and below the vendor PQL. The PQL should have a
precision  and   accuracy that matches  the  instrument '
capabilities within a certain operating range of analysis.
The relationship between sensitivity and precision is such
that the lower the concentration, the higher the variation in
reported sample results. Five times the estimated MDL
(estimated PQL) would result in a value of 69.5 to 349
mg/kg. The average calculated PQL would be 209 mg/kg;
however, based upon sample results, this is clearly above
the PQL noted  during the demonstration.   Therefore,
values closerto 69.5 mg/kg were chosen for estimating the
PQL and associated %D between the NITON .reported
average and the reference value if it is  an  SRM,  or the
average value  reported by the referee laboratory.  Also
compared are  the 95%  CIs for additional  descriptive
information.

Sample lot 65 had a reported average value by the referee
laboratory of 62.9 mg/kg. The average value reported by
NITON for this  sample was 84.6 mg/kg  with a standard
deviation of 35.0 mg/kg. The 95% Cl for this sample is
52.2 to 117 mg/kg.  The %D for this sample  is 34.5%.

The result for the 32.6 mg/kg SRM noted above (sample lot
47) had a reported average concentration of 77.5 mg/kg.
The standard deviation was 6^44 mg/kg and the 95% Cl is
71.5 to 83.5 mg/kg. The %D for this sample  is 137%, and
therefore,  this  concentration appears to be below  the
instrument PQL.

The result for the 99.8 mg/kg SRM (sample  lot 49) had a
reported  average concentration of  108 mg/kg.  The
standard deviation was 22.2 mg/kg and the 95% Cl is 79.3
to 120 mg/kg. The %D for this sample is 8.2%.

It could be inferred that the NITON XLt field instrument
PQL may be somewhere between 62.9 and 99.8 mg/kg.-
The  SRM with  a reference value of 32.6  mg/kg  had a
reported %D of 137% and  therefore  was lower than the
PQL.

NITON XLi (Isotope) Evaluation

Seven replicates were analyzed by NITON for an SRM that
had a reference value of 99.8 mg/kg (sample lot 49). The
average concentration reported by NITON for this sample
was  109 mg/kg and the standard deviation was 35.6
mg/kg. Another SRM that had a reference value  of 32.6
mg/kg (sam pie lot 47) had an average concentration from
                                                    35

-------
seven  separate  replicates reported  by NITON as 92.7
mg/kg  and a standard deviation of 12.5 mg/kg.  A field
sample with an average concentration of 14.6 mg/kg as
reported by the referee laboratory (sample lot 62 from the
Puget Sound site) was analyzed by NITON  seven times.
All but one result was reported as below their detection
limit. This suggests that this sample is below the NITON
XLi MDL.   Calculations  of the respective MDLs, based
upon 2 of the 3 samples/standards noted above, are 112
and 39.3 mg/kg.  The average of these two values is 75.6
mg/kg.

As a further  check  of the MDL, sample lot 18 (Carson
River) had a reported average concentration by the referee
laboratory of  10.1 mg/kg. This was consistently reported
by NITON  as  below their MDL, thereby confirming  that the
calculated MDL noted previously was above this value.
Sample lot 47 (SRM) had a reference value of 32.6 mg/kg
(noted  previously) and  the average  result  reported by
NITON was 92.7 mg/kg.  The %D for this sample is 184%.
This would  suggest that  NITON'S  MDL  is  below the
average calculated above.

Based  upon these results,  the MDL for this  instrument is
close to 32 mg/kg, however, this, is not the average of the
MDL calculations, but close to the lowercalculated value of
39.3 mg/kg.  The estimated sensitivity provided by NITON
of 20 mg/kg is probably close to the observed MDL value.
In fact, sam pie lot 46 (SRM with a reference value of 21.4
mg/kg) was analyzed 7  times and reported an average
value of 121  mg/kg for 5 of 7 analyses. The other two
analyses were reported as non-detect, suggesting that this
is close to  or below the  instrument's capability. The
equivalent calculated MDL for the referee  laboratory  is
0.0026 mg/kg. The calculated result is only intended as a
statistical  estimation, and  not a true test of instrument
sensitivity.

Practical  Quantitation  Limit - This value is  usually
calculated by determining a low standard on the instrument
calibration curve, and it is estimated as the lowest standard
at which  the  instrument will accurately and precisely
determine  a given concentration within specified QC limits.
The PQL is often around 5-10 times the MDL.  This POL
estimation, however, is method- and  matrix- dependent.
In orderto  determine the  PQL,  several low standards were
provided to NITON  and  %Ds were calculated from the
results.

The lower limit of sensitivity previously provided by the
vendor (20 mg/kg) appears to be close to their MDL and
below the vendor PQL. The PQL should have a precision
and accuracy that matches the instrument capabilities
within  a certain  operating  range of  analysis.   The
relationship between sensitivity and precision is such that
the lower the concentration, the  higher the variation in
reported sample results.  Five times the estimated MDL
(estimated PQL) would result in values of 196.5 and .560
mg/kg. The average calculated PQL would be 378 mg/kg,
however, based upon sample results this  is clearly far
above the PQL noted during the demonstration. Therefore,
values closer to 32 mg/kg were chosen for estimating the
PQL and associated %D between  the NITON reported
average and the reference value if it  is an SRM,  or the
average value reported bythe referee laboratory. The 95%
CIs  are  also  compared  for  additional  descriptive
information.

Sample lot 65 had a reported average value by the referee
laboratory of 62.9  mg/kg.  The average value reported by
NITON for this  sample was 80.3  mg/kg with a standard
deviation of 26.9 mg/kg.  The 95%  Cl for this sample is
55.4 to 105 mg/kg. The %D forthis  sample is 27.7%.

The result for the 32.6 mg/kg SRM noted above (sample lot
47) had a reported average concentration of 92.7 mg/kg.
The standard deviation is 12.5 mg/kg  and the 95% Cl is
81.1 to 104 mg/kg. The %D forthis sample is 184% and
therefore, this concentration appears to be  below the
instrument PQL.

The result for the 99.8 mg/kg SRM (sample lot 49) had a
reported average concentration  of 109 mg/kg.    The
standard deviation is 35.6 mg/kg and the 95% Cl is 76.1 to
132 mg/kg. The %D for this sample is 9.2%.
It can be inferred that the NITON XLi field instrument PQL
is  between 62.9  and 99.8 mg/kg.   The  SRM  with a
reference value  of 32.6 mg/kg had a reported %Dof 184%
and therefore, was lower than the  PQL.

Sensitivity Summary

The low standard calculations suggest that the MDL for the
NITON XLt field instrument is 42 mg/kg (average of MDL
calculations). Based upon the results presented above, the
MDL for the NITON  XLi field instrument is close to 32
mg/kg.  The  lowest calculated MDL, however, is 39.3
mg/kg. The equivalent calculated MDL for the referee
laboratory is  0.0026  mg/kg.  The  MDL determination,
however, is onlya statistical calculation thathas been used
in the past by EPA, and is currently not considered a "true"
MDL by SW-846 methodology. SW-846 fs suggesting that
performance-based methods be used, and that PQLs be
determined using low standard calculations.
                                                    36

-------
The  referee  laboratory  PQL  confirmed  during  the
demonstration is 0.005 mg/kg.  The %D is <10%.  The
NITON XLt field instrument PQL is between 62.9 and 99.8
mg/kg.  The %D for the 99.8 mg/kg SRM is 8.2%.  The
NITON XLi field instrument PQL is between 62.9 and 99.8
mg/kg. The %D for the 99.8 mg/kg SRM is 9.2%.

6.1.2 Accuracy

Accuracy is  the instrument measurement compared to a
standard or true value.   For this demonstration, three
separate standards were used for determining accuracy.
The primary standard is SRMs.  The SRMs are traceable
to national systems. These were obtained from reputable
suppliers with reported concentrations and an associated
95% Cl and 95%  prediction interval.   The Cl  from the
reference material is used as a measure of.comparison
with the Cl calculated from replicate analyses for the same
sample analyzed by the laboratory or vendor. Results are
considered comparable if CIs of the SRM overlap with the
CIs computed from the replicate analyses by the vendor.
While this is not a definitive measure of comparison, it
provides  some assurance  that  the   two values  are
equivalent.

Prediction  intervals  are  intended  as a   measure of
comparison for a single laboratory or vendor result with the
SRM. When computing a prediction interval, the equation
assumes an infinite number of analyses, and it is used to
compare individual sample results.  A 95%  prediction
interval would, therefore, predict the correct result  from a
single analysis  95% of the time for an  infinite number of
samples, if the result is comparable to that of the SRM. It
should be noted that the corollary to this statement is that
5% of the time a result will be outside the prediction interval
if determined for an infinite number of samples. If several
samples are analyzed, the percentage of results within the
prediction interval will be slightly above or below 95%. The
more samples analyzed, the more likely the percentage of
correct results will  be close to 95% if the  result for the
method being tested.is comparable to the SRM.

All SRMs were analyzed in replicates of three or seven by
both the vendor and by the referee laboratory.  In  some
instances analyses  performed  by the  vendor  were
determined  to  be invalid measurements and   were,
therefore, not included with the reported results.  There
were 9 differentSRMs analyzed by both the vendor and the
laboratory for a total of 57 data points by the vendor and 62
data points by the laboratory. One specially prepared SRM
(sample  lot  55) was not included because analyses
performed by the vendor and the laboratory suggested that
the SRM value was in question.   Because this was a
specially prepared  SRM and had less documentation in
regards to  the  reference value, and because  both the
referee  laboratory  and vendor results while statistically
equivalent were statistically different from the SRM value,
this SRM was not included in the evaluation.

The second accuracy determination used a comparison of
vendor results of field samples and  SRMs to the referee
laboratory results for these same samples. Field samples
were used to ensure that "real-world" samples were tested
by the vendor. The referee laboratory result is considered
as the standard  for comparison to the vendor result. This
comparison is in the form of a hypothesis test with alpha =
0.01. (Detailed equations along with additional information
aboutthis statistical comparison is included in Appendix B.)

It should be noted  that there is evidence of a laboratory
bias.  This bias was determined by comparing average
laboratory  values  to SRM  reference  values,  and is
discussed below. The laboratory bias is low in comparison
to the reference value. A bias correction was not made
when comparing individual samples (replicate analyses)
between the laboratory and vendor; however, setting alpha
= 0.01 helps mitigate for this  possible bias by widening the
range of acceptable results between the two data sets.

An aggregate analysis, or unified hypothesis test was also
performed for all 24 sample lots for the  NITON XLi field
instrument and on 26 sample lots for the NITON XLt field
instrument.   (A detailed discussion of this  statistical
comparison is included  in Appendix B.)  This  analysis
provides additional statistical evidence in relation to the
accuracy evaluation.  A bias  term is  included in this
calculation in order to account for the laboratory data bias
previously noted.

The third measure of accuracy is obtained by the analysis
of spiked field samples.  These were  analyzed by the
vendor and the  laboratory in replicate in order to provide
additional measurement comparisons and are treated the
same as the other field samples. Spikes were prepared to
coveradditionalconcentrations not available from SRMs or
field samples.  There is no comparison to the spiked
concentration, only  a comparison between the vendor and
the laboratory reported value.

The purpose for SRM analyses by the referee laboratory is
to provide a check  on laboratory accuracy.  During the
pre-demonstration, the referee laboratory was chosen, in
part, based  upon the analysis of SRMs. This was done in
orderto ensure that a competent laboratory would be used
for the demonstration. The pre-demonstration laboratory
                                                    37

-------
qualification  showed  that the  laboratory  was  within
prediction intervals for all SRMs analyzed. The percentage
of total results within the prediction interval for the vendor
are reported in Tables 6-2 and 6-3, and the laboratory in
Table 6-4. Because of the need to provide confidence in
laboratory analysis during the demonstration, the referee
laboratory also analyzed SRMs as an ongoing check of
laboratory bias.  As noted in Table 6-3, not all laboratory
results  were  within  the  prediction  interval.   This  is
discussed in more detail below. All laboratory QC checks,
however,  were  found  to  be within  compliance (see
Chapter 5).
Table 6-2. NITON SRM Comparison (XLt)
Sample Lot
No.
51
48
50
53
54
49
52

SRM Value/ 95% Cl
405/365-445-
77.78/71.53-84.03
203/183-223-
910/821-999-
1120/ 1010-1230-
99.8/81.9-118
608/ 490 - 726 •
Total Samples
% of samples w/in
prediction interval
NITON Avg./ 95% Cl
312/301-323
128/89.4-167
195/183-207
712/664-760
896/ 863 - 929
108/87.5-128
496/475-517

Cl Overlap
(yes/no)
no
no
yes
no
no
yes
ves

No. of
Samples
Analyzed
7
4
7
7
7
7
7
46
95% Prediction
Interval
194-615
45.58 - 109.97
97.4 - 308
437 - 1380
582 - 1701
31.3-168
292 - 924

NITON No. w/in
Prediction
Interval
7
1
7
7
7
7
7
43
93%
        Cl is estimated based upon n=30.  A 95% prediction interval was provided by the SRM supplier but no Cl was given.
Table 6-3. NITON SRM Comparison (XLi)
Sample Lot
No.

51
48
50
53
54
49
52



SRM Value/ 95% Cl


405/ 365 - 445-
77.78/71.53-84.03
203/183-223'
910/821-999-
1120/1010-1230-
99.8/81.9-118
608/ 490 - 726 •
Total Samples
% of samples w/in
prediction interval
a Cl is estimated based upon n=30.
Table 6-4. ALSI
Sample Lot
No.

51
48
50
53
54
49
52



SRM Comparison
SRM Value/ 95% Cl


405/365-445-
77.78/71.53-84.03
203/183-223'
910/821 -999-
1120/1010-1230 '
99.8/81.9-118
608/ 490 - 726 '
Total Samples
% of samples w/in
prediction interval
NITON Avg./ 95% Cl


305/ 269 - 343
171/100-242
217/164-270
720/673-767
917/837-997
109/76.1-142
504/465-543



Cl Overlap
(yes/no)

no
no
yes
no
no
yes
ves



A 95% prediction interval was provided

ALSI Avg./ 95% Cl


291/ 254 - 328
87.1/60.6-114
167/ 140-194
484/ 325 - 643
71 1/ 573 - 849
84.2/74.5-93.9
424/338-510




Cl Overlap
(yes/no)

no
yes
yes
no
no
yes
yes



No. of
Samples
Analyzed
7
4
7
7
7
7
7
46


95% Prediction
Interval

194-615
45.58 - 109.97
97.4 - 308
437 - 1380
582 - 1701
31.3-168
292 - 924



NITON No. w/in
Prediction
Interval
7
0
. 7
7
7
7
7
42
91%

by the SRM supplier but no Cl was given.

No. of
Samples
Analyzed
7
7
7
7
7
7
7
49



95% Prediction
Interval

194-615
45.58-109.97
97.4 - 308
437 - 1380
582 - 1701
31.3-168
292 - 924




ALSI No. w/in
Prediction
Interval
7
6
7
4
5
7
7
43
88%

        Cl is estimated based upon n=30.  A 95% prediction interval was provided by the .SRM supplier but no Cl was given.
                                                      38

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Evaluation of vendor and laboratory analysis of SRMs was
performed in  the following  manner.    Accuracy was
determined  by comparing  the  95% Cl  of the sample
analyzed by the vendor and laboratory to the 95% Cl for
the SRM.  (95% CIs around the true value are provided by
the SRM supplier.) This information  is provided in Tables
6-2  and  6-3, with  notations  when  the CIs  overlap,
suggesting comparable results.  In addition, the number of
SRM results forthe vendor's analytical instrumentation and
the referee laboratory that are within the associated 95%
prediction interval are reported.  This is a more definitive
evaluation of laboratory and vendor accuracy.

SRM Analysis for NITON XLt (X-ray)

The single most important number from these tables  is the
percentage of  samples within the 95% prediction interval.
As noted for the NITON XLt data, this percentage is 93%
with n = 46. This suggests that the NITON data are within
expected accuracy, accounting for statistical variation. For
5  of the 7 determinations, NITON  average results are
below the  reference value.  This would suggest that there
is  a possible bias  associated  with the NITON  data;
however, this is not necessarily significant based upon the
minimum number of  sample lots evaluated. There were
fewer SRMs than expected because NITON's detection
limit was much lower than predicted (see Section 6.1.1).
This resulted in three  SRM results that could not be used.

The percentage of samples  within  the 95%  prediction
interval for the laboratory data  is 88%.  For  6 of the  7
determinations, ALSI  average  results are below the
reference  value.  This suggests that the ALSI data are
potentially  biased low.    Because  of  this  bias, the
percentage of  samples outside  the  prediction interval is-
slightly below the anticipated number of results, given that
the number of samples analyzed (49)  is relatively high.
Nonetheless,  the  referee  laboratory  data  should be
considered accurate and not significantly different from the
SRM value. Because there is no bias correction term in
the individual hypothesis tests (Table 6-5), alpha is set at
0.01 to help mitigate  for laboratory bias.  This, in effect,
widens the scope of vendor data that would fall within an
acceptable range of the referee laboratory.

SRM Analysis for NITON XLi (Isotope)

The single most important number from these tables  is the
percentage of  samples within the 95% prediction interval.
As noted forthe NITON XLi data, this percentage is 91%,
with  n = 46. This suggests that the NITON data are  within
expected accuracy, accounting for statistics I variation. For
5  of the 7 determinations, NITON  average  results are
below the reference value. This would suggest that there
is  a possible bias  associated with the  NITON  data,
however, as noted above this is not necessarily significant
based upon the minimum number of sample lots evaluated.
There were fewer SRMs than expected because NITON's
detection limit was much lower than predicted (see Section
6.1.1).  This resulted in three SRM results thatcould not be
used.
The percentage of samples within  the 95% prediction
interval for the laboratory data is  88%.  For 6 of  the  7
determinations,  ALSI  average results  are below  the
reference value.  This suggests that the ALSI data are
potentially  biased  low.   Because  of this  bias,  the
percentage of samples outside the prediction interval  is
slightly below the anticipated number of  results given that
the number of samples analyzed  (49) is relatively high.
Nonetheless,  the referee laboratory  data should be
considered accurate and not significantly differentfrom the
SRM value.  Because there is  no bias correction term in
the individual hypothesis tests (Table  6-6), alpha is set at
0.01 to  help mitigate for laboratory bias. This, in effect,
widens the scope of vendor data that would fall within an
acceptable range of the referee laboratory.

Hypothesis Testing

Sample results from field and spiked field samples for the
vendor compared to similar tests by the referee laboratory
are used as another accuracy check.  Spiked samples
were used to cover concentrations not found in the field
samples, and  they are considered the same as the field
samples for purposes  of  comparison.   Because of the
limited  data available for determining  the accuracy of the
spiked  value,  these  were not  considered  the  same as
reference standards.   Therefore, these samples  were
evaluated in the  same  fashion  as field samples, but they
were not compared to individual spiked concentrations.

Using a hypothesis test with alpha = 0.01, vendor results
for all   samples  (per  instrument) were compared  to
laboratory results to determine  if sample populations are
the same or significantly different. This was performed for
each sample lot separately.  Because this test does not
separate  precision  from  bias, if  NITON's or ALSI's
computed standard deviation was large due to a highly
variable result (indication of poor precision), the two CIs
could overlap. Conversely, if the variance is small then
relatively small differences between the two sample means
could be significant. The fact that there was no significant
difference between the two results could be due to high
sample variability or could be a result of the small variance
(i.e. high precision)   for that particular  sample  lot.
                                                    39

-------
Accordingly, associated RSDs have also been reported in
Tables 6-5 and 6-6 along with results of the hypothesis
testing for each sample lot.   Results of these  analyses
should therefore be considered accordingly; based upon
the minimum number of samples tested for each different
sample lot for each instrument.
Table 6-5.  Accuracy Evaluation by Hypothesis Testing (NITON XLt)
Sample Lot No 7 Site
221 Oak Ridge
NITON
ALSI
247 Oak Ridge
NITON
ALSI
267 Oak Ridge
NITON
ALSI
31/ Oak Ridge
NITON
ALSI
517 Oak Ridge
NITON
ALSI
65/ Oak Ridge
NITON
ALSI
671 Oak Ridge
NITON
ALSI
251 Puget Sound
NITON
ALSI
271 Puget Sound
NITON
ALSI
487 Puget Sound
NITON
ALSI
50/ Puget Sound
NITON
ALSI
237 Carson River
NITON
ALSI
537 Carson River
NITON
ALSI
547 Carson River
NITON
ALSI
637 Carson River
NITON
ALSI
197 Manufacturing Site
NITON
ALSI
207 Manufacturing Site
NITON
ALSI
Avg. Cone.
mg/kg

116
81.6

417
. 207

156
123

1360
947

312
291

84.6
62.9

1330
835

43.7
39.1

126
136

128
87.1

195
167

. 174
117

712
484

896
711

202 .
169

45.5
28.7

54.3
63.9
RSD or CV

7.9%
9.4%

9.6%
48.4%

12.4%
13.5%

3.3%
13.2%

3.9%
13.4%

35.0%
8.5%

4.5%
14.8%

11.5%
10.7%

13.3%
16.9%

18.9%
32.9%

6.6%
17.2 %

22.2%
5.7%

7.3%
35.5%

4.0%
21.0%

9.2%
6.5%

19.5%
32.2%

19.2%
25.4%
Number of
Measurements

3
3

7
7

7
7

3
3

7
7

7
7

7
7

3
3

7
7

4
6

7
7

3
3

7
7

7
7

7
7

4 .
7

3
7
Significantly Different at
Alpha = 0.01
yes


yes


yes


no


no


no


yes


no


no


no


no


no


no


no


yes


no


no


Relative Percent
Difference (NITON
to ALSO
34.8%


67.3%


23.7%


35.8%


7.0%


28.7%


45.7%


4.6%


-7.6%


38.0 %


15.5%


39.2%


38.1%


23.0%


17.8%


45.3%


-16.2%


                                                    40

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Table 6-5.  Continued
Sample Lot NoJ Site


281 Manufacturing Site
NITON .
ALSI
291 Manufacturing Site
NITON
ALSI
30/ Manufacturing Site
NITON
ALSI
321 Manufacturing Site
NITON
ALSI
33/ Manufacturing Site
NITON
ALSI
491 Manufacturing Site
NITON
ALSI
521 Manufacturing Site
NITON
ALSI
641 Manufacturing Site
NITON
ALSI
66/ Manufacturing Site
NITON
ALSI
CV = Coefficient of variance
Avg. Cone.
mg/kg


318
251

335
374

376
451

300
592

379
1204

108
84.2

496
424

404
285

985 .
892

Table 6-6. Accuracy Evaluation by Hypothesis
Sample Lot No7 Site


221 Oak Ridge
NITON
ALSI
24/ Oak Ridge
NITON
ALSI
26/ Oak Ridge
NITON
ALSI
31/ Oak Ridge
NITON
ALSI
517 Oak Ridge
NITON
ALSI
65/ Oak Ridge .
NITON
ALSI
67/ Oak Ridge
NITON
ALSI
Avg. Cone.
mg/kg


141
81.6

438
207

157
123

1279
947

305
291

80.3
62.9

1296
835
RSD or CV



8.2%
15.6%

27.8%
17.4%

13.8%
11.4%

7.8%
12.7%

10.8%
13.3%

20.5%
12.5%

4.7%
21.9%

8.7%
8.9%

3.8%
11.2%

Number of
Measurements


3
3

3
7

3
3

7
7

6
7

7
7

7
7

7
7

7
7

Significantly Different at
Alpha = 0.01

no


no


no


yes


yes


no


. no


yes


no



Relative Percent
Difference (NITON
to ALSI)
23.6%


-11.0%


-18.1%


-65.5%


•-104%


24.8%


15.7%


34.5%


34.5%



Testing (NITON XL! )
RSD or CV



15.8%
9.4%

23.7%
48.4%

15.8%
13.5% '

6.4%
13.2%

13.1%
13.4%

33.5%
62.9%

5.0%
14.8%
Number of
Measurements


3
3

7
7

7
7

3
3

7
7

7
7

7
7
Significantly Different at
Alpha = 0.01

no


yes


no


no


no


no


no


Relative Percent
Difference (NITON
to ALSI)
53.4%


71.6%


23.7%


29.8%


4.7%


24.3%


43.3%


                                                         41

-------
 Table 6-6. Continued
Sample Lot NoV Site
277 Puget Sound
NITON
ALSI
481 Puget Sound
NITON
ALSI
50/ Puget Sound
NITON
ALSI
231 Carson River
NITON
ALSI
53/ Carson River
NITON
ALSI
541 Carson River
NITON
ALSI
63/ Carson River
NITON
ALSI
201 Manufacturing Site
NITON
ALSI
281 Manufacturing Site
NITON
ALSI
291 Manufacturing Site .
NITON
ALSI
307 Manufacturing Site
NITON
ALSI
321 Manufacturing Site
NITON
ALSI
33/ Manufacturing Site
NITON
ALSI
49/ Manufacturing Site
NITON
ALSI
521 Manufacturing Site
NITON
ALSI
641 Manufacturing Site
NITON
ALSI
66/ Manufacturing Site
NITON
ALSI
Avg. Cone.
mg/kg

97.0
136

171
87.1

217
167

153
117

720
484

917
711

223
169

73.4
63.9

370
251

319
374

362
451

309
592

416
1204

109
84.2

504
424

400
285

974
892
RSD or CV

21.1%
16.9%

25.9%
32.9%

10.0%
17.2 %

11.7%
5.7%

7.0%
35.5%

9.4%
21.0%

11.2%
6.5%

18.3%
25.4%

8.6%
15.6%

16.2%
17.4%

17.5%
11.4%

3.9%
1Z7%

9.5%
13.3%

32.8%
12.5%

8.3%
21.9%

7.1%
8.9%

3.6%
11.2%
Number of
Measurements

7
7

4
6

7
7

3
3

7
7

7
7

7
7

3
7

3
3

3
7

3
3

7
7

6
7

7
7

7
7

7
7

6
7
Significantly Different at
Alpha = 0.01
yes


no


yes


no


no


no


yes


no


yes


no


no


yes


yes


no


no


yes


no


Relative Percent
Difference (NITON
to ALSI)
33.5%


65.0%


26.0%


26.7%


39.2%


25.3%


27.6%


13.8%


38.3%


-15.9%


-21.9%


-62.8%


-97.3%


25.7%


17.2%


33.6%


8.8%


CV = Coefficient of variance
NITON XLt (X-ray) Evaluation

Of the 26 sample lots, 8 results are significantly different,
based upon the hypothesis test noted above. Most of the
relative percent differences are positive which indicates
that the  NITON  result is generally  higher  than the
laboratory result. This is indicative of the previously noted
low bias associated with the laboratory data.  There are
                                                      42

-------
some NITON  results that  are  less than the laboratory
result, therefore,  no overall NITON high or low bias is
apparent. It appears that NITON data are subject to more
random variability.

In determining the number of results significantly above or
below thevalue reported bythe referee laboratory, 14 of26
NITON average results were found to have relative percent
differences less than 30% for sample concentrations above
the estimated PQL.   Only 1 of 26 NITON average results
have relative percentdifferences greater than 100% forthis
same group of samples (see Table 6-7).  Interferences
                              may be a problem but, because of the random variability
                              associated with the data, no interferences are specifically
                              apparent.

                              In addition to the statistical summary presented above,
                              data plots (Figures 6-1  and 6-2) are included in order to
                              present  a  visual  interpretation of  the  accuracy.   Two
                              separate plots have been included  for the  NITON X-ray
                              data.  These  two plots are divided based  upon sample
                              concentration in  order to  provide  a  more detailed
                              presentation.
Table 6-7. Number of Sample Lots Within Each %D Range (NITON XLt)

	<30%	 >30%. <50%	>50%. <100%
                                                    >100%
                                                                       Total
     Positive %D
    Negative %D
       Total
10
 4
14
20
 6
26
Only those sample lots with the average result greater than the PQL are tabulated.
                   -1. Data plot for the NITON XLt low concentration sample results
                                                     43

-------
                 16DD
                 14HD
                 1ZID
              —. 1UJO
              8  em
            Figure 6-2. Data plot for the NITON XLt high concentration sample results.
Concentrations of samples analyzed by NITON  ranged
approximately from 10 to over 1,200 mg/kg. The previous
statistical summary eliminated some of these data based
upon whether concentrations were interpreted to be in the
analytical range of the NITON X-ray field instrument. This
graphical presentation presents all data points. It shows
NITON X-ray data compared to ALSI data plotted  against
concentration. Sample groups are shown by connecting
lines.  Breaks between groups indicate  a different set of
samples at a different concentration. Sam pie groups were
arranged from lowest to highest concentration.

As can be seen by this presentation, samples analyzed by
NITON below about 100 mg/kg did not match well with the
ALSI  results  with  some  exceptions.    For  higher
concentrations, sample results were much closer to ALSI
with some deviations  present.   This  is only a  visual
interpretation and does not provide statistical significance.
It does,  however, provide  a visual interpretation that
supports  the  previous statistical results for accuracy,  as
presented above.
NITON XLi (Isotope) Evaluation

Of the 24 sample lots, 8 results are significantly different
based upon the hypothesis test noted above.  Most of the
relative  percent differences are positive which indicates
that the  NITON  XLi  result is generally higher than the
laboratory result. This is indicative of the previously noted
low bias associated with the laboratory data.  There are
some NITON  results that are less  than the laboratory
result; therefore, no overall  NITON  high or  low  bias is
apparent. It appears that NITON data are subject to more
random  variability.

In determining the number of results significantly above or
below the value reported by the referee laboratory, 14 of 24
NITON average results were found to have relative percent
differences less than 30% for sample concentrations above
the estimated PQL. Zero  of 24 NITON  average results
have relative percentdifferencesgreaterthan 100% for this
same group of samples (see Table 6-8).  Interferences
may be  a problem but,  because of the random variability
associated with the data, no interferences are specifically
apparent.
                                                    44

-------
Table 6-8.  Number of Sample Lots Within Each %D Range (NITON XLi)

Positive %D
Negative %D
Total
<30%
12
2
14
>30%. <50%
5
0
5
>50%. <100%
3
2
5
>100%
0
0
0
Total
20
4
24
Only those sample lots with the average result greater than the PQL are tabulated.
In addition to the statistical  summary presented above,
data plots (Figures 6-3 and 6-4) are included in  order to
present a visual  interpretation of the accuracy.  Two
separate plots have been included for the NITON  Isotope
data. These two plots are divided based  upon  sample
concentration  in  order  to  provide  a more  detailed
presentation.  Concentrations of samples  analyzed  by
NITON ranged approximately from 1 to over 1,200 mg/kg.
The previous statistical summary eliminated some of these
data based upon whether concentrations were interpreted
to be in the analytical range of the NITON  Isotope field
instrument.  This graphical presentation presents all data
points.  It shows NITON Isotope data compared to ALSI
data plotted against concentration.  Sample groups are
shown by  connecting  lines.   Breaks between groups
indicate  a  different  set  of  samples  at a  different
concentration. Sample groups were arranged from lowest
to highest concentration.
As can be seen by this presentation, samples analyzed by
NITON below about 100 mg/kg did not match well with the
ALSI  results  with  some  exceptions.    For  higher
concentrations, sample results were much closer to ALSI
with  some  deviations  present.  This is. only a visual
interpretation and does not provide statistical significance.
It does,  however, provide a  visual interpretation  that
supports  the  previous statistical results for accuracy, as
presented above.
                  250
             Figure 6-3.  Data plot for the NITON XLi low concentration sample results.
                                                    45

-------
                 1600
                 1400
             Figure 6-4. Data plot for the NITON XLi high concentration sample results.
Discussion of Interferences
RSDs for the'NITON XLt and XLi instruments are small,
suggesting that precision is good.  (This will be discussed
in more detail in Section 6.1.3)  As noted previously, it
would therefore, appear that interferences may be the
cause of the inaccurate analyses for field samples, but it is
.not apparent as to the  specific interferent causing the
problem.   There is  no apparent significant difference
between reported values and associated sites from which
the samples were collected.  Table 6-9 shows additional,
non-target analyses for each of the collected samples and
associated sampling sites.

Unified  Hypothesis Test

SAIC performed a unified hypothesis test  analysis  to
assess the comparability of analytical results provided by
NITON and those provided by ALSI.  (See appendix B for
a detailed description of this test.)  NITON and ALSI both
supplied multiple assays on replicates derived from a total
of 24  different  sample lots  for  the  NITON XLi field
instrument and 26 different sample lots for the NITON XLt
field instrument, be they field materials or reference
materials. The NITON  and ALSI data from these assays
formed the basis of this assessment.

Results from this analysis  suggest that the two data sets
are not  the  same  for both  the  NITON  XLi and XLt
instruments.  The  null hypothesis tested was that, on
average, NITON and ALSI produce the same results within
a given sample lot.  The null hypothesis is rejected in part
because NITON results tended to exceed those from ALSI.
forthe same sample lot. Even when a bias term is used to
correct this discrepancy, the null hypoth esis is still rejected.
Additional information about this statistical evaluation is
included in Appendix B.
                                                    46

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Table 6-9. Concentration (in mg/kg) of Non-Target Analytes
 iota
             Site
                         TOC   O&G
Aq
                                             As
                                                   Ba
                                                         Cd
                                                                Cr
                                                                      Cu
                                                                             Pb
                                                                                   Se
                                                                                         Sn
                                                                                                Zn
                                                                Hg
1 1 Puget Sound
14 Oak Ridge
17 Manufacturing Site
18 Carson River
19 Manufacturing Site
20 Manufacturing Site
21 Manufacturing Site
22 Oak Ridge
23 Carson River
24 Oak Ridge
25 Puget Sound
26 Oak Ridge
27 Puget Sound
28 Manufacturing Site
29 Manufacturing Site
30 Manufacturing. Site
31 Oak Ridge
32 Manufacturing Site
33 Manufacturing Site
45 SRM CRM 033
46 SRM CRM 032
47 SRM NIST 2710
48 SRM CRM 023
49 SRM CRM 025
50 SRM RTC spec.
51 SRM RTC spec.
52 SRM RTC spec.
53 SRM RTC spec.
54 SRM RTC spec.
62 Spiked Lot 5
63 Spiked Lot 23
64 Spiked Lot 19
65 Spiked Lot 14
66 Spiked MS-SO-08
67 SoikedLot26
3800
7800
2400
1900
630
2000
7800
6600
5700
6600
46000
88000
37000
2000
900
1400
5000
4700
<470
NR
NR
NR
NR
NR
NR
NR
NR
NR
NR
3500
5700
630
7800
NA .
88000
130
180
90
70
60
<50
320
190
100
250
1200
340
1100
50
110
70
80
120
120
NR
NR
NR
NR
.NR
NR
NR
NR
NR
NR
210
100
60
180
NA
340
<0.5 4
0.32 2
<0.5 <2
26 17
<0.5 <2
O.5 <2
1.9 4
1.7 5
37 11
<0.5 5
<0.5 2
9.1 10
<0.5 3
0.86 <2
<0.5 <2
<0.5 <2
0.59 4
<0.5 2
<0.5 <2
0.78 130
81 370
35 630
NR 380 .
130 340
NR NR
NR NR
NR NR
NR NR
NR NR
<0.5 3
37 11
<0.5 <2
0.32 2
NA NA
9.1 10
20
41
180
. 46
410
150
150
120
280
89
46
140
33
160
210
230
120
160
340
220
120
700
76
1800
NR
NR
NR
NR
NR
28
280
410
41
NA
145
<0.5
0.4
<0.5
2
<0.5
<0.5
2.8
<0.5
0.9
<0.5
0.7
1.9
0.7
<0.5
<0.4
<0.5
<0.5
<0.5
<0.5
89
130
22
0.92
370
NR
NR
NR
NR
NR
<0.5
0.9

-------
 or SRM reference values was 14 of 26 different sample
 lots.  The number of NITON XLi average values less than
 30%  different from the referee laboratory results  or SRM
 reference values was  also 14 of 24 different sample lots.
 Both  NITON XLt and XLi results; therefore, often provide a
 reasonable estimate of accuracy for field determination,
 and may be affected by interferences not identified by this
 demonstration.   Because  the  NITON  data compare
 favorably  to  the SRM values,  the differences between
 NITON and the referee laboratory are likely the result of
.matrix interferences for field sample analysis.

 Initially, there were more sample lots tested for both
 instruments,  however, several of the samples were below
 the estimated detection limit. Many samples were not used
 because they were reported as non-detect by NITON. The
 previously estimated detection limit was found to be too low
 for several of the analyses performed. More information on
 detection  limits is provided in Section 6.1.1.

 6.1.3  Precision

 Precision  is usually thought of as repeatability of a specific
 measurement, and it is often reported as RSD. The RSD
 is computed  from a specified number of replicates.  The
 more replications of a measurement, the higher confidence
 associated with  a reported  RSD.   Replication of  a
 measurement may be as few as 3 separate measurem ents
 to 30 or  more  measurements of the same sample,
 depending upon the degree of confidence desired in the
 specified result. Most samples were analyzed seven times
 by both NITON and the referee laboratory. In some cases,
 samples may have been analyzed as few as three times
 and some NITON results were judged invalid and were not
 used. This was often the situation when it was believed
 thatthe chosen sample, or SRM, was likely to be below the
 vendorquantitatiqn limit. The precision goal for the referee
 laboratory, based upon  pre-demonstration  results, is an
 RSD  of  25% or  less.  A descriptive evaluation  for
 differences  between- NITON  RSDs  and  the  referee
 laboratory RSDs was determined. In Tables 6-9 and 6-10,
 the RSD for each separate sample lot is shown for NITON
 compared to the referee laboratory. The average RSD was
 computed for all measurements made by NITON, and this
 value was compared to the average RSDforthe laboratory.

 In addition, the precision of an analytical instrument may
 vary  depending  upon the matrix being  measured, the
 concentration of  -the   analyte,  and   whether  the
 measurement is made for an SRM or a field sample. To
 evaluate precision for clearly different matrices, an overall
 average RSD for the SRMs is calculated and compared to
 the average RSD for the field samples. This comparison
is also included in Tables 6-10 and 6-11  and shown for
both NITON instruments and the referee laboratory.

The  purpose  of this evaluation is to  determine the  field
instrument's   capability to precisely  measure  analyte
concentrations under real-life  conditions.   Instrument
repeatability was measured using samples from each of
four different  sites.  Within each site, there may be two
separate matrices, soil and sediment. Not all sites  have
both soil and sediment matrices, nor are there necessarily
high, medium, and low concentrations for each sample
site. Therefore, spiked samples were included to cover
additional ranges.

Originally, it was anticipated that NITON detection limits
would be lower, based upon information supplied by the
developer.  During the demonstration it was discovered
that  several lower concentration  samples  analyzed  by
NITON were reported as non-detect because the NITON
detection limit was higher than expected. Therefore, there
are fewer sample lots than originally anticipated for the
evaluation because these non-detect samples could not be
included.

Tables 6-10 and 6-11  show results from Oak Ridge, Puget
Sound, Carson River, and the manufacturing site. It was
thought that  because these  four different field   sites
represented different matrices, measures of precision may
vary from site to site.  The average RSD for each site is
shown  in Tables 6-10 and 6-11 and'compared between
NITON and the referee laboratory.  SRM RSDs are not
included in this comparison because SRMs, while grouped
with  different sites for purposes  of ensuring that the
samples remained blind during the demonstration, were not
actually samples from that site,  and were, therefore,
compared separately.

The  RSDs of various concentrations are compared  by
noting the RSD of the individual sample lots. The ranges
of test samples (field,  SRMs, and spikes) were selected to
cover the appropriate analytical  ranges  of  NITON's
instrumentation.  Average referee laboratory values for
sample concentrations are included in the table, along with
SRM values, when appropriate. These are discussed in
detail in Section 6.1.2, and are included here for purposes
of  precision comparison.  Sample concentrations were
separated into approximate ranges: medium and high, as
noted in Tables 6-10, 6-11,  and 6-1.  Sample results
reported by NITON as below their approximated PQLwere
not included in Tables 6-10 and 6-11. There appears to be
no correlation between concentration (medium or high) and
RSD; therefore,  no  other formal  evaluations of this
comparison were performed.
                                                    48

-------
The referee laboratory analyzed replicates of all samples
analyzed by NITON.  This was  used for purposes of
precision comparison to NITON.  RSD for the vendor and

Table 6-10. Evaluation of Precision (NITON XLt)
the laboratory were calculated individually and shown in
Tables 6-10 and 6-11.
Sample Lot No. NITON and
Lab
Avg. Cone, or Reference
SRM Value
RSD

Number of
Samples
w/in 25% RSD Goal?

OAK RIDGE
Lot no. 22
NITON
ALSI
Lot no. 24
NITON
ALSI
Lot no. 26
NITON
ALSI
Lot no. 31
NITON
ALSI
Lot no. 51
NITON
ALSI
Lot no. 65
NITON
ALSI
Lot no. 67
NITON
ALSI
Oak Ridge Avg. RSD
NITON
ALSI
81.6 (medium)


207 (high)


123 (high)


947 (high)


405 (high)


62.9 (medium)


835 (high)






7.9%
. 9.4%

9.5%
48.4%

12.4%
13.5%

3.3%
13.2%

3.9%
13.4%

41.3%
13.5%

4.5%
14.8%

19.6%
20.4% •

3
3

7
7

7
7

3
3

7
7

7
7

7
7




yes
yes

yes
no

yes
yes

yes
yes

yes
yes

no
yes

yes
yes

yes
yes
PUGET SOUND
Lot no. 25
NITON
ALSI
Lot no. 27
NITON
ALSI
Lot no. 48
NITON
ALSI
Lot no. 50
NITON
ALSI
Puget Sound/ Avg. RSD
NITON
ALSI
39.1 (medium)


136 (high)


77.8 (medium)


203 (high)






11.5%
10.7%

13.3%
16.9%

18.9%
32.9%

6.6%
17.7%

13.3%
22.1%

3
3

7
7

4
6

7
7




yes
yes

yes
yes

yes
no

yes
yes

yes
yes
CARSON RIVER
Lot no. 23
NITON
ALSI
Lot no. 53
NITON
ALSI
. Lot no. 54
NITON
ALSI
117 (medium)


910 (high)


1120 (high)



22.2%
5.7%
,\
•\
7.3%
35.5%

4.0%
21.0%

3
3

7
7

7
7

yes
yes

yes
no

yes
yes
                                                   49

-------
Table 6-10. Continued
Sample Lot No. NITON and
Lab
Lot no. 63
NITON
ALSI
Carson River/ Avg. RSD
NITON
ALSI


Avg. Cone, or Reference • ' RSD
SRM Value
169 (high)







9.2%
6.5%

15.7%
6.7%

Number of
Samples

7
7




w/in 25% RSD Goal?


yes
yes

yes .
yes
MANUFACTURING SITE
Lot no. 19
NITON
ALSI
Lot no. 20
NITON
ALSI
Lot no. 28
NITON
ALSI
Lot no. 29
NITON
ALSI
Lot no. 30
NITON
ALSI
Lot no. 32
NITON
ALSI
Lot no. 33
NITON
ALSI
Lot no. 49
NITON
ALSI
Lot no. 52
NITON
ALSI
Lot no. 64
NITON
ALSI .
Lot no. 66
NITON
ALSI
Manufacturing Site/ Avg. RSD
NITON
ALSI

Overall Avg. RSD
NITON
ALSI
Field Samples/ Avg. RSD
NITON
ALSI
SRMs/Avg. RSD
NITON
ALSI
28.7 (medium)


63.9 (medium)


251 (high)


374 (high)


451 (high)


592 (high)


379 (high)


99.8 (medium)


608 (high)


285 (high)


985 (high)
















19.5%
32.2%

19.2%
25.4%

8.2%
15.6%

27.8%
17.4%

13.8%
11.4%

7.8%
12.7%

10.8%
13.3%

20.5%
12.5%

4.7%
21.9%

8.7%
8.9%

3.8%
11.2%

3.8%
11.2%
SUMMARY STATISTICS

13.1%
20.0%

16.9%
17.5%

9.3%
22.5%

4
7

3
7

3
3

3
7

3
3

7
7

6
7

7
7

7
7

7
7

7
7


•











yes
no

yes
yes

. yes
yes

no
yes

no
no

yes
yes

yes
yes

yes
yes

yes
yes

yes
yes

yes
yes

yes
yes


yes
yes

" yes
yes

yes
ves
50

-------
Table 6-11. Evaluation of Precision (NITON XLi)
Sample Lot No. NITON and
Lab
Avg. Cone, or Reference
SRM Value
RSD

Number of
Samoles
w/in 25% RSD Goal?

OAK RIDGE
Lot no. 22
NITON
ALSI
Lot no. 24
NITON
ALSI
Lot no. 26
NITON
ALSI
Lot no. 31
NITON
ALSI
Lot no. 51
NITON
ALSI
Lot no. 65
NITON
ALSI
Lot no. 67
NITON
ALSI
Oak Ridge Avg. RSD
NITON
ALSI
81.6 (medium)


207 (high)


123 (high)


947 (high)


405 (high)


62.9 (medium)


835 (high)






15.8%
9.4%

23.7%
48.4%

15.8%
13.5%

6.4%
13.2%

13.1%
13.4%

33.5%
13.5%

5.0%
14.8%

16.7%
20.4% .

3
3

7
7

7
7

3
3

7
7

7
7

6
7




yes
yes

yes
no

yes
yes

yes
yes

yes
yes

no
yes

yes
yes

yes
yes
PUGET SOUND
Lot no. 27
NITON
ALSI
Lot no. 48
NITON
ALSI
Lot no. 50
NITON
ALSI
Puget Sound/ Avg. RSD
NITON
ALSI

Lot no. 23
NITON
ALSI
Lot no. 53
NITON
ALSI
Lot no. 54
NITON
ALSI
Lot no. 63
NITON
ALSI
Carson River/ Avg. RSD
NITON
ALSI
136 (high)


77.8 (medium)


203 (high)






117 (medium)


910 (high)


11 20 (high)


169 (high)






21.1%
16.9%

25.9%
32.9%

10.0%
17.7%

21.1%
22:1%
CARSON RIVER

11.7%
5.7%

7.0%
35.5%

9.4%
21.0%

11.2%
6.5%

11.4%
6.7%

7
7

4
6

7
7





3
3

7
7

7
7

7
7




yes
yes

no
no

yes
yes

yes
yes


yes
yes

yes
no

yes
yes

yes
yes

yes
yes
                                                      51

-------
Table 6-11. 'Continued
Sample Lot No. NITON and
Lab
Avg. Cone, or Reference RSD
SRM Value
Number of
Samples
w/in 25% RSD Goal?
MANUFACTURING SITE
Lot no. 20
NITON
ALSI
Lot no. 28
NITON
ALSI
Lot no. 29
NITON
ALSI
Lot no. 30
NITON
ALSI
Lot no. 32
NITON
ALSI
Lot no. 33
NITON
ALSI
Lot no. 49
NITON
ALSI
Lot no. 52
NITON
ALSI
Lot no. 64
NITON
ALSI
Lot no. 66
NITON
ALSI
Manufacturing Site/ Avg. RSD
NITON
ALSI
63.9 (medium)


251 (high)


374 (high)


451 (high)


592 (high)


379 (high)


99.8 (medium)


608 (high)


285 (high)


985 (high)






18.3%
25.0%

8.6%
15.6%

16.2%
17.4%

17.5%
11.4%

3.9%
12.7%

9.5%
13.3%

32.8%
12.5%

8.3%
21.9%

7.1%
8.9%

3.6%
11.2%

11.6%
16.3%

3
7

3
3

3
7

3
3

'7
7

6
7

7
7

7
7

7
7

6
7




yes
yes

yes
yes

yes
yes

yes
yes

yes
yes

yes
yes

no
yes

yes
yes

yes
yes

yes
yes

yes
yes
      Overall Avg. RSD

          NITON
           ALSI
                                           SUMMARY STATISTICS
 14.4%
 20.0%
yes
yes
    Field Samples/ Avg. RSD
          NITON
           ALSI

      SRMs/ Avg. RSD
          NITON
   	ALSI	
 13.8%
 17.5%
 15.0%
 22.5%
yes
yes
yes
ves
NITON XLt (X-ray) Evaluation

As noted from Table 6-10, the NITON XLt precision is
better than that of the referee laboratory. The single most
important measure of  precision provided  in Table 6-10,
overall average RSD, is 20.0% for the referee laboratory,
compared to the NITON XLt average RSD  of 16.1%.  The
laboratory and NITON  RSD are both within the predicted
25% RSD objective for precision expected from both
analytical and sampling variance.

In  addition, field sample precision compared to SRM
precision shows that  there  may  be some difference
between these two sample lots; field sample RSD is 17.5%
for ALSI and  16.9% for NITON; SRM RSD is 22.5% for
ALSI and 9.3% for NITON. This is similar to the results for
                                                   52

-------
the accuracy comparison. NITON appears to have better
precision for  the  SRM analyses  compared  to the  field
samples. NITON'S comparison for SRMs was statistically
significant, and for the precision evaluation NITON had a
narrower range for the RSD. Forpurposes ofthis analysis,
spiked samples are considered the same as field samples
because these were similarfield matrices and the resulting
variance was  expected to be equal to field samples.  The
replicate sample RSDs also confirm the pre-demonstration
results, showing that sample homogenization procedures
met their originally stated objectives.

There  appears to be no significant  site  variation  in
precision between Oak Ridge, Puget Sound, Carson River,
and the manufacturing site samples.   (See  Table  6-10
showing average  RSDs for each of these sample  lots.
These  average RSDs are computed using only the results
of  the field   samples  and  not  the  SRMs.)    The
Manufacturing site had a lower average RSD  for both the
vendor and the laboratory but this difference was not
significant in  results from the other NITON instrument or
other data sets and, therefore, may not be significant.

NITON XLi (Isotope) Evaluation

As  noted from Table  6-11, the NITON  XLi  precision is
better than that of the referee laboratory. The single most
important measure of precision provided in Table 6-11,
overall average RSD, is 20.0% for the referee laboratory,
compared to the NITON XLi average RSD of 14.4%.  The
laboratory and NITON  RSD are both within the predicted
25% RSD objective  for precision expected from  both
analytical and sampling variance.  Field sample precision
compared to SRM precision shows no significantdifference
between these two sample lots; field sample RSD is 17.5%
for  ALSI and  13.8% for NITON; SRM RSD is 22.5% for
ALSI and 15.0% for NITON.

There appears to be no significant site variation between
Oak Ridge,  Puget  Sound,  Carson  River, and   the
manufacturing site samples.  (See  Table 6-11 showing
average RSDs for each of these sample lots.   These
average RSDs are computed using only the results of the
field samples  and  not the SRMs.) The Carson River site
had a  lower average RSD for both the vendor and the
laboratory but this  difference was not significant in  results
from the other NITON  instrument or other data sets  and,
therefore, may not be significant.

Precision Summary

The precision  of the NITON XLt and  XLi field instruments
is better than the referee laboratory precision.  The overall
average  RSD  is 20.0%  for  the  referee  laboratory,
compared to the NITON XLt average RSD of 13.1% and
the NITON XLi average RSD of 14.4%. Both the laboratory
and  NITON  precision  goals of 25% overall RSD were
achieved.

6.1.4   Time    Required    for    Mercury
        Measurement
The  700 Series Analyzers  were evaluated over a 3-day
period.  The amount of time that was needed  to setup,
prepare and analyze 197 samples using 2  instruments,
calibrate the analyzers, as well as the time necessary to
demobilize was determined.

Two  technicians performed  all activities including sample
preparation and analysis for four batches  of  mercury-
contaminated soil.  Setup involved taking the analyzers,
test stands, battery packs and battery charger out of the
carrying case, installing a battery pack and connecting the
computers  and keyboard  (optional  equipment)  to  the
electric power source. This took approximately 2 minutes.
Afterturningon the instruments, they were allowedto warm
up for 10 minutes before the instruments were calibrated.
The  technician selected  the Calibrate Detector icon to
recalibrate either instrument. The instrument calibration
screen was displayed until the calibration was complete.
After the calibration finished, the calibration  results were
displayed.  During the demonstration, calibration check
samples were analyzed prior to analysis, in the  middle of
the day, and towards the end operation for the day.  The
check samples were analyzed for 240 seconds, the same
time  used when analyzing samples for the demonstration.

Total setup time including warm-up was about 20 minutes
on the first day of the demonstration.   The XL  Series
Analyzers were calibrated with a 230 mg/kg standard. The
instruments  recorded  concentrations very close  to  the
standard throughout the demonstration.

The time required for mercury measurements started with
sample  setup and  ended when NITON disconnected the
devices and placed them back into the padded carrying
cases.  After setup, sample preparation was carried out.
Soil samples were provided to NITON in 20 mL amber
VOA vials. Priorto  filling the XRFsample cups,the NITON
technicians prepared for the samples by placing a circle of
Mylar film on top of the  sample cup, and securing the film
with  a  collar. The film was smooth and taut.   NITON
performed this step, which took 3 seconds  per sample,
ahead  of time.  (The  observer watched the Mylar film
placed on several sample cups during the demonstration.)
Dry soil was transferred from the VOA vial to the sample
cup using a metal spatula.  A metal spatula was used to
                                                   53

-------
lightly tamp the sample in the cup. A filter paper disc was
then placed on the sample. The rest of the sample cup
was stuffed with polyester filling to prevent the sample from
moving during measurement.  Finally a cap and sample
label were placed on the cup.  Sample preparation took
about two minutes persample. The cup was now ready for
measurement.     Sample  analysis   was  done   in
approximately the top 2-5 mm of the sample.

Some sample batches had free standing water. One batch
was moist and appeared tar-like. Some of these samples
were placed in a toaster oven at 200 ฐFfor 2-3 hours prior
to analysis. Sample preparation and analysis continued
while the moist samples were drying in the toaster oven.

Measurements  taken with the 700  Series  Analyzers
required placing the test platform on  a flat level surface.
The technician then placed the nose cone adapter with the
analyzer's window againstthe test stand's analysis window
and the LCD screen towards the technician.  The prepared
sample was placed in the  pocket on  the test stand. The
technician depressed the test platform lever and pushed
the sample test drawer fully closed.  The technician then
selected  the  desired test procedure.  There  are four
different  methods  of  operation  for  taking  sample
measurements. During the demonstration, the trigger-and
proximity-sensor method was used. With this method, the
measurement window was placed against the sample to be
analyzed to engage the proximity sensor on the frontof the
instrument and  the trigger for sample analysis was then
activated.

Measurement  times  from 30-600  seconds can  be
employed, depending on the data quality  needs of the
project. As the measurement time increases, the detector
collects a larger number of X-rays from the sample. Based
on years of experience and sound engineering practice,
NITON determined the measurement times used during
the demonstration. The measurement time selected was
120 seconds per sample.  The measurement time shown
on the screen was the total time that had elapsed. In some
cases sample measurement times exceeded 120 seconds.
Sample results we're transcribed from the computerscreen
to the Chain-of-Custody  form  and  given to the EPA
representative prior to leaving the site on day one. On days
two and  three,  the  results were  given  to  the EPA
representative shortly after returning to the hotel.  Results
were available on-site, however NITON wanted  some
additional time to look over the data.
Analysis Time Summary

NITON required a total of 17.5 hours (35 man hours) for
mercury measurements of 197 soil samples analyzed using
2 instruments during their 3-day demonstration.  It should
be noted that one technician performed sample preparation
while the other technician simultaneously operated both
analyzers.  Table  6-12  indicates the time required to
complete mercury measurements using  the 700 Series
Analyzers.

Table 6-12. Mercury Measurement Times

 Measurement Activity	Time Required	
 System Setup
 Battery Pack Installation
 Battery Pack Charge
 Analyzer Warm Up
 Analyzer Calibration
 Sample Preparation
 Count Times
 Demobilization	
2 minutes
1 minute
120 minutes
10 minutes
5 minutes
2 minutes per sample
2 minutes per sample
2 minutes	
6.1.5  Cost
Background  information, assumptions used in  the cost
analysis, demonstration results, and a cost estimate are
provided in Chapter 7.

6.2    Secondary Objectives
This  section  discusses the performance results for the
XL-700 Series Analyzers in terms of secondary objectives
described in Section 4.1.  These secondary objectives
were addressed based on observations of the XLi 702 and
XLt 792 and information provided by NITON.

6.2.1  Ease of Use
Documents  the ease of use, as well as the skills and
training required to properly operate the device.
  Based   on  observations  made   during   the
  demonstration, the 700 Series Analyzers are very
  easy to operate, requiring  one field technician
  with a  high school education.  NITON requires
  any user to  attend  a  free-of-charge,  8-hour
  training course priorto operating their analyzers.
  The   instruments   come  equipped   with
  customizable, PC-based reporting software that
  automatically  corrects  for variations in  soil-
  sample chemistry  and density.  Internet-based
  diagnostics and troubleshooting are available.
                                                   54

-------
During the demonstration, one technician prepared most of
the soil samples  while the other technician performed
sample analysis.  However, both technicians did perform
sample preparation and analysis during the three days in
thefield. One technician could easily perform both sample
preparation  and  analysis  for one  instrument.    Two
technicians were used during the demonstration in order to
increase sample throughput during the limited time on-site.
Based on observations and conversations during the field
demonstration, the instrument could be easily operated by
a high school graduate, after attending NITON's  8-hour
training course.
After the analyzer, test stand, computer, keyboard, and
battery charger were unpacked from the carrying case, the
technicians prepared the analyzers for use. The NITON
devices   are  hand-held   portable  X-ray  fluorescence
analyzers. The on/off/escape button on the control panel
was pressed for  about 3 seconds to turn the instrument on.
On start-up, the screen display was replaced by the re-start
screen which  counts down from 29 to 0, in increments of 1
second. When  the restart  was complete, it was replaced
by the logon  screen. The technician selected a  4-digit
security code,  followed by  the  enter  key.   After the
technician  completed the  log-on procedure, the word
"success" appeared on  the  screen.  The technician
checked the  date/time on  the screen.  The NITON 700
Series main menu system allows the technician to take
readings, view and move data with a minimum number of
steps. Menus were  presented as small pictures (Figure
6-5) which allowed the technician to do several things:

1.      Toggle  between two different functions or views,
       such  as turning backlighting on or off.

2.      Present a sub-menu which  allowed access to
       more choices.
3.      Present a screen which allowed the technician to
       view data, edit data or control the instrument.
The standard  soil testing mode was available from the bulk
mode menu. The  standard soil testing menu allowed the
technician to perform tests on soil without adjusting for a
particular  matrix.  The standard soil testing mode uses
Compton  Normalization  to automatically adjust for the
effects of the  matrix. Sample spectra are viewed  on the
screen (Figure 6-6).

The results were displayed throughout the duration of the
reading, and updated every 3 seconds. When the reading
was complete, a final screen on the analyzer displayed the
final  measurements  which have just been  completed.
XL-700 Series downloads include precision data and X-ray
spectra, name of data collector, test location,  sample-
identification, and sample results (Figure 6-7).
Figure 6-5. Main menu screen shot.
 x| a a ปlซ!ปi tfiai*! mai aitr
              E:11.82KeV   HgtLH 11.82
              R:O.77         Br iKa 11.91
                               Tl iLb 12.21
Figure 6-6. Screen shot of sample spectra.
                                                    55

-------
                           y  m
I Index I Ttma
l-Typa
                         |.Duration | Mo
                                                       Pb-
              I ML
                                                                                                 |Hg
                                                                                                          h'Zh
       •2002-OS40 20:50-  5HUT7ER CAtf 50.56'
      •2002-05-1020:55
       200205-1021: tz"
       2002-05-10 21 :'16
       2002-05-1021:23
       2002-05-10 21:28
       2002-05-1021:32
       2pp2-05-.j6 21:35
       2002-05-1021:38
                     BULK
                     BULK.
                     BULK'
                     BULK"-
                     BULK
                     BUUG
               BULK'
               kite:
               BULK
             124.00
             151.32
             190.87
             156.60
             212.91
             123.97:
                                                                                    1-12.40 ฑ 0.00   1 72.52-i 0.00-
                                                                                                                1141.75 ฑ  0.00  I 100.00 ฑ 0.00
                                  20.48 i  12.59
                                  fb.5O.ฑ 10.48
                                  0.54 t  12.74
                                  6.67 ฑ  14.09
                                  20.01 ฑ  10.50
                                  2:08 ฑ  is^es
             160.49
             'I4K43
             208.36
                                  14.13 ฑ  11.42
                                 '77;50'"i  18.5B.1
                                  •10.99  i 11:12
                                                81.08 ฑ  14.54
                                                10:20: ฑ9.52
                                                39.24 ฑ  13.98.
                                                42^55 "ฑ  15.21
                                               ; 84.80'ฑ  UiBZ
                                               ; 35.79 ฑ  20.34
                                                131.13".~ฑr15".i5
5.92  ฑ 4.95
'6.03  ฑ is'.iiZ
.5.64  i .5.25
-1.57 'ฑ 5.37-
6:26.ฑ 3.81
.-2;f4-.ฑ" 6.81
                                                              ,23.17  ฑ 10.03  261.20 ฑ  22.06  296.34 ฑ  21.65  '102.12
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 Figure6-7.  Multi-element data report
6.2.2   Health and Safety Concerns
Documents  potential  health   and  safety  concerns
associated with operating the  device.
   No significant health and safety concerns were
   noted during the  demonstration.   The  XLi  702
   contains radioisotope sources, and should never
   be  pointed at any person  when the  shutter  is
   open.   With  the  safety  shutter(s)  open  while
   testing samples, the  exposure to the  user's hand
   is <.05 mR/hr.  During setup and operation, both
   analyzers  are password protected.
                                                                    Health and  safety concerns,  including chemical hazards,
                                                                    radiation   sources,   electrical   shock,   explosion,   and
                                                                    mechanical hazards were evaluated.
                                                                    Potential exposu re to radiation from  the excitation sources
                                                                    (Cd-109, Am-241,  Fe-55  and. the  X-ray  tube) was  the
                                                                    primary   health   and   safety   concern    during    the
                                                                    demonstration. The XLi 702 used during the demonstration
                                                                    contained a three radioactive source configuration of a 10
                                                                    millicurie (mCi) Cd-109 source, a 14 mCi  Am-241 source
                                                                    and  a 20 mCi Fe-55 source.  The Cd-109 source was the
                                                                    only source used during the demonstration.   The XLi 702
                                                                    instrument is distributed under a specific Massachusetts
                                                                    license and  a general license, and it is  expected that under
                                                                    normal use  an operator would  not accumulate a radiation
                                                                      56

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 dose higher than that from naturally occurring radiation. A
 health  physicist  from the  Tennessee  Department  of
 Environment and Conservation used a gamma-ray detector
 to monitor radiation for half an hour during one day of the
 demonstration.  Background radiation at the site was 5
 microrems per hour (urem/hr).  During sample analysis 20
 urem/hr was obtained on contact with the sample tray, and
 50 prem/hr was obtained  on contact with the window port.
 The sources are sealed and locked in place in a tungsten
 alloy source holder. According to NITON, the sources are
 designed to remain secure even underextreme conditions,
 so that even if the instrument is broken, crushed or burned
 there should be no leakage of radioactive material.

 The cadmium  source used was originally 10 mCi, and has
 a half life of about 15 months. The cadmium source would
 have to be replaced every 15 months and disposed of in
 accordance with Nuclear Regulatory Commission (NRC)
 regulations.   The  replacement of the  source  and its
 disposal would have to be done by the manufacturer or
 their authorized representative.

 During the demonstration, the operators wore nitrile gloves
 and safety glasses  while transferring about 15 grams of
 mercury-contaminated soil per sample from the VOA vials
 into the sample  cups.   SAIC continuously monitored
 ambient air for mercury, using a mercury vapor analyzer.
 Mercury was  not detected (0.000  mg/m3) in the air or
 breathing zones during the course of the demonstration.

 6.2.3  Portability of the Device

 Documents the portability of the device.
   The NITON 700 Series Analyzers are single piece
   units weighing only 0.8 kg (XL! 702) and 1.4 kg
   (XLt 792).   There  are  no cables, no  separate
   processing units. They were easy to set up and
   can  be carried in a  waist  belt  holder.  High
   strength   injection  molding  plastic  housing
   enables them to withstand harsh environments.
   Quick-swap batteries allow up to  6-12  hours of
   continued use. Samples can be analyzed in less
   than five minutes.
 The NITON 700 Series Analyzers are single units that are
 hand-held.  Polyethylene sample cups, Mylar film, filter
 discs, polyester filling and  a  small metal  spatula  are
 required during sample preparation activities. These items
.can be purchased separately from NITON, or directly from
 the manufacturer. One hundred small (approximately 40
 mm) sample  cups,  one roll  of Mylar film, filter discs,
 polyester filling and a small sample tool can fit easily into a
 small box.  The analyzers, test stands and accessories are
 housed in  a padded  carrying case. The XLi 702 weighs
 0.8 kilograms (kg) and is 292 mm by 89 mm  by 76 mm.
 The XLt 792  weighs  1.8 kg and is 248 mm by 273 mm by
 95 mm. The test stand for both units is 278 mm by 63 mm
 by 139 mm.   During the demonstration, a fully charged
 battery pack  lasted for almost 8 hours. The instruments
 can also operate off a 115 volt electric line.
 According to NITON the analyzers willoperate between -7
 and 49 ฐC. In addition, the analyzers can operate  at a
 humidity range of 0-95%  relative  humidity.  During the
 demonstration, relative humidity as high as  98.3%  was
 recorded.

 During the demonstration, NITON  performed  sample
 preparation and  analysis under a tent.  The instruments
 were setup in two  minutes on a six-foot long folding table.
 The small, lightweight battery-operated analyzers could be
'easily  carried by hand to another sample location  and
 operated for about 4-8 hours on one battery pack.

 No solvents or acids were  used for sample preparation.
 The only additional waste generated were the sample cups,
 Mylar film, filter discs and polyester filling which were used
 during analysis of intrusive samples. Finally, even though
 the XLi  contains  radioisotopes,  in most  cases  no
 notification  is  required  if  transporting  within  state
 boundaries. This  may not be the case when entering
 federal properties/The NITON XLi 702 conforms to the
 conditions and limitations specified in 49 CFR 173.421 for
 excepted  radioactive  material.   (Excepted  package
 instruments and  articles,  N.O.S.  UN-2911.)  In  most
 countries,  the analyzers can  be  transported in a  fully
 padded carrying case by plane or car, or shipped as an
 ordinary package. For most courier services, no special
 labels  are  required on the outside of the NITON carrying
 case or on additional packaging. In the U.S., the XLt 792
 can be carried, shipped ortransported in the  carrying case
 without exterior  labeling.

 6.2.4  Instrument Durability

 Evaluates the durability of the  device based on its
 materials of construction and engineering design.
   NITON introduced the first ever hand-held XRF
   analyzer in  1994.  They  are well designed and
   constructed for durability.
                                                    57

-------
The NITON analyzers were designed so that virtually no
measurable  radiation  can escape when the shutter is
closed.  According to NITON,  even  if the instrument is •
broken, crushed or burned there should be no leakage of
radioactive material.

Each  sealed isotope source is  locked in place in a solid
tungsten alloy source holder. The source is secure in its
housing because  the  aperture  at the end of housing is
smaller than  the  source and  completely sealed.   The
source assembly is secured in the instruments case, which
is  fitted with  tamper-proof screws.    Finally, the high
strength   plastic   housing  should    withstand   harsh
environments.   Based  on 'observations   during  the
demonstration,  the analyzers were well constructed and
durable.  During the three days in which the  instruments
were observed, there was no downtime, maintenance, or
repairs. The equipment was not  apparently affected by the
three days of almost continuous  rain, and relative humidity
as high as 98.3%.   The instruments were,  however,
operated under  a tent.

6.2.5 Availability of Vendor Instruments and
       Supplies

Documents  the availability of the  device and spare
parts.
  The NITON 700 Series Analyzers are readily
  available for rental, lease, or purchase. Another
  analyzer if needed, can be received within 2-6
  weeks of order placement. Sample cups, Mylar
  film, spatulas, filter-discs and polyester filling
  are readily available from NITON or several
  supply firms.
During the demonstration, NITON 700  Series Analyzers
and disposable supplies did not have to be replaced. 'If a
replacement analyzer or test stand were required, NITON
claimed it could have been shipped by express courier and
held for pick-up the next day.  There are currently 10 XLi
702  units available  for  rental.   At  the time of  the
demonstration, the NITON XLt Analyzer was  a prototype
and replacement parts may have been difficult to obtain.
NITON now has 3 XLt 792 units available for rental. The
instruments must be held for pick-up at the local express
courier office, and can not be delivered  to any location
because the instruments contain radioisotopes or an X-ray
tube.  The express  courier office  was located  twenty
minutes away from the site. In general, no time would be
lost picking up another unit at a local express courier office
rather than having it delivered  the next day to the site by
10:30 a.m. Many express courier offices are open as early
as 8 a.m.

In  general, the 700 Series Analyzers are available within
2-6 weeks of order placement. The disposable supplies
(sam pie cups, Mylar film, spatulas, filter discs) if needed for
intrusive   analysis   could   be  obtained  from   the
manufacturers, and shipped directly to the site by overnight
courier.  NITON claims the 700 Series Analyzers  never
need site-specific calibrations.
                                                   58

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                                              Chapter 7
                                        Economic Analysis
The purpose of the economic analysis was to estimate the
total cost of mercury measurement at a hypothetical site.
The cost per analysis was estimated; however, because
the cost per analysis would decrease as the number of
samples analyzed increased, the totalcapital costwas also
estimated and reported separately. Because unit analytical
costs are dependent upon the total number of analyses, no
attempt was  made to compare the cost of field analyses
with the NITON 700 Series Analyzers XLi 702 (isotope)and
XLt 792 (X-ray  tube)  to the  costs associated with  the
referee laboratory. "Typical" unit cost results, gathered
from analytical laboratories, were reported to provide a
context in which  to review  NITON XLi/XLt 700 Series
Analyzer  costs.  No attempt was made to  make a direct
comparison  between these  costs for different methods
because  of differences in sample throughput, overhead
factors, total equipment utilization factors, and other issues
that make a head-to-head comparison impractical.

This Chapter describes  the  issues and assumptions
involved  in the  economic analysis,  presents  the costs
associated with field use of the NITON XLi/XLt 700 Series
Analyzers, and presents a cost summary  for  a  "typical"
laboratory perform ing sample analyses using the reference
method.


7.1    Issues and Assumptions

Several factors can affect mercury 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.  NITON offers three options for potential users:
1) purchase of the analyzers, 2)  monthly rental and
3) analyzer leasing depending on  current interest rates
(NITON, 2003a). Because site and user requirements vary
significantly, all three of these options are discussed to
provide each user with the information to make a case-by-
case decision.

A  more detailed cost analysis was performed on the
equipment rental option for three months or less because
this case represents the most frequently encountered field
scenario. The results of that cost analysis are provided in
Section 7.2.

7.1.1  Capital Equipment Cost

The XLi 702 analyzer evaluated during the demonstration
was equipped with  Cd-109, Am-241 and Fe-55 sources.
During the  demonstration, only the Cd-109 source was
used. The  capital  equipment costs are  based on the
analyzer with one source, Cd-109.  The XLt 792 uses a
low-powered, miniature X-ray tube with  a silver target as
the excitation source.  Both analyzers com e equipped with
a test stand, soil grinder, sieve  set and  sample cups. A
keyboard and laptop computer are optional, and may be
supplied by the customer if the user wants to operate the
instrument in the  bench-top mode.

The cost quoted by NITON  includes freight costs to ship
the instrument to the user location when purchasing the
instrument, but does not include the license (radioactive
source) that may be needed to operate the instrument. The
license that is needed to operate the XLi 702 analyzer in
the state of Tennessee cost $900.  A $5,000 dollar fully
refundable security deposit is required for all XLi/XLt 700
Series rentals and leases. An eight-hour training session
is mandatory for anyone renting, leasing  or purchasing an
analyzer  (NITON,  2003a).  NITON offers  over  100
user/radiation training classes free-of-charge throughout
the year..
                                                   59

-------
 7.1.2  Cost of Supplies

 The cost of supplies is minimal, based on the supplies
 required to analyze demonstration samples! Requirements
 vary depending upon whether in-situ or intrusive analysis
 is being performed.  For purposes of this cost estimate,
 only supplies required to analyze soil samples intrusively
 are factored into the cost estimate. Disposable supplies
 are not required for in-situ analysis. The supplies used
 during the demonstration consisted of four consumable
 items which were:

    XRF sample cups (one per sample)
    Mylar film
    Polyester filling  .
    Filter-paper discs

 The purchase prices and supply sources were obtained
 from NITON.  The analyzers are supplied with supplies for
 100 samples.  Because the user cannot return unused or
 remaining  portions  of supplies, no  salvage value was
 included in the cost of supplies. (NITON, 2003a)  PPE
 supplies were assumed  to be  part of the  overall site
 investigation or remediation costs; therefore, no PPE costs
 were included as supplies.

 7.1.3  Support Equipment Cost

 During the demonstration, the XL-Series 700 Analyzers
 were operated  using both AC power  and a lithium ion
 battery pack.  The XLi  instrument operated for almost 5
 hours  using  one battery  pack.   (The  XLi instrument
 observed during the demonstration started at 95% battery
 life). The XLt unit operated for 8 hours using one battery
 pack. Only the battery charger requires AC.

 Because of the large number of samples expected to be
 analyzed during the demonstration, EPA provided support
 equipment, including tables and chairs for the two field
 technician's comfort.  In addition, EPA provided a tent to
 ensure that there were no delays  in  the project due to
 inclement weather. These costs may not be incurred in all
 cases. However, such equipment is frequently needed in
field situations, so these costs were included in the overall
 cost analysis.

 7.1.4  Labor Cost

The labor cost was estimated based on the time required
for setup, sample preparation,  sample analysis, summary
data presentation and instrument packaging at the end of
the day. Setup time covered the time required to take the
analyzers out of their packaging, setup all components,
and ready the devices for operation. Sample preparation
involved transferring samples into the XRF sample cups.
Sample preparation was completed easily, requiring about
one minute per sample.  Sample analysis was the time
required  to  analyze all  samples and  submit  a  data
summary. The data summary was strictly a tabulation of
results in whatever form the vendor chose to provide. In
this case, the  vendor transcribed results from computer
screens to the field chain-of-custody forms. (A printer was
not available in the field.) The time.required to perform all
tasks was rounded to the nearest minute; however, for the
economic analysis,  times were  rounded to the nearest
hour, and 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 two field technicians to
analyze and report results for mercury samples.. Based on
these field observations, a high school graduate with the
eight-hour training specific to the  700-Series Analyzers
would  be  qualified to operate  the analyzers.  For the
economic analysis, an hourly rate of $15 was used for a
field technician. A multiplication factor of 2.5 was applied
to labor costs to accountforoverhead costs. Based on this
hourly rate and multiplication factor, and an 8-hour day, a
daily rate of $300 was used for the  economic analysis.
Monthly labor rates  are based on the assumption of an
average of 21  work days per month.  This assumes 365
days per year, and non work days totaling 113 days per
year (104 weekend days and 9 holidays; vacation days are
discounted assuming vacations will be scheduled around
short-term work  or staff  will be rotated  during  long
projects).  Therefore,  252 total annual work days are
assumed.

7.1.5  Investigation-Derived Waste Disposal
       Cost

NITON  was instructed to segregate its waste into three
categories during the demonstration: 1) general trash; 2)
lightly contaminated PPE and wipes; and  3) contaminated
soil (both analyzed and unanalyzed). General trash was
not included  as  IDW, and  is  not discussed  in  this
document.

Lightly  contaminated wastes consisted primarily of used
nitrile gloves and Kim-wipes. The gloves were discarded
because  they  posed a potential health  and safety risk
(holes  or tears).  The rate of waste generation  was in
excess of what would be expected in a typical application
of these  instruments.  In  addition, the  EPA evaluators
                                                   60

-------
occasionally  contributed  used  gloves  to  this waste
accumulation point. Wipes were used primarily to clean
any spilled soil off  the table and to clean off any moist or
organic material adhering to the spatula which was used to
transfer soil into the sample cups. In cases where cross
contamination is not a major concern (e.g., field screening
orin-situ analysis), lesser amounts of waste would likely be
generated.
Contaminated soil consisted primarily of soil placed in the
XRF sample cups containing a filter paper disc, polyester
filling and  then covered with Mylar film. The sample is not
destroyed during preparation and analysis; therefore it is
possible to send the  samples off-site for confirmatory
analysis, but for purposes of this economic analysis, it was
assumed that they were discarded.

7.1.6  Costs Not Included

Items for which costs were not included in  the economic
analysis are discussed in the following subsections, along
with the rationale for exclusion of each. A free, eight-hour
training course is mandatory in  order  to operate the
analyzers.  The users' time and travel expenses to attend
the course are not included.  Any licensing fees  required
for the radionuclide source were also not included as they
vary from state to state.

Oversight of Sample Analysis Activities.  A typical user
of the 700-Series Analyzers would not be required to pay
for customer   oversight  of  sample analysis.    EPA
representatives observed  and documented all activities
associated with sample analysis during the demonstration.
Costs for this oversight were not included in the economic
analysis because they 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 Technician.  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,  are  site-specific  and,
therefore,   not  included  in   the  economic  analysis.
Furthermore, these activities were not dependent upon the
selected  reference method   or  field  analytical  tool.
Likewise, sample shipping, COC activities, preservation of
samples,  and  distribution  of samples were  specific
requirements of this project that applied to all vendor
technologies and may vary from site to site. None of these
costs were included in the economic analysis.

Items Costing Less than $10. The costs of inexpensive
items, such  as paper towels, were  not included in the
economic analysis.

Documentation Supplies. The costs for digital cameras
used  to  document  field activities were not included  in
project costs.   These were  considered project-specific
costs that would not be needed in all cases.  In addition,
these items  can be  used for multiple projects. Similarly,
the cost of  supplies  (logbooks, copies,  etc.) used  to
document field activities was not  included in the analysis
because they also are project specific.

Health and  Safety Equipment.  Costs for rental of the
mercury  vapor analyzer and  the  purchase  of PPE were
considered site specific and, therefore, were not included
as costs in the economic analysis.  Safety glasses and
disposable gloves were required for sample handlers and
would likely  be required in most cases. However, these
costs are not specific to any one vendor or technology. As
a result,  these costs were not included in the economic
analysis.

Mobilization and Demobilization. Costs for mobilization
and demobilization  were considered site specific, and not
factored  into the economic analysis.   Mobilization and
demobilization costs actually impact laboratory analysis
more  than field analysis. When a  field economic analysis
is  performed,  it may  be possible to  perform  a single
mobilization  and  demobilization.   During  cleanup  or
remediation   activities,   several   mobilizations,
demobilizations, and associated downtime costs may be
necessary when an off-site laboratory is used because of
the wait for analytical results.

7.2     XLi/XLt 700 Series Analyzers Costs

This  subsection  presents information  on the individual
costs  of capital equipment,, supplies, support equipment,
labor, and IDW disposal for the 700 Series Analyzers.

7.2.1 Capital Equipment Cost
During the  demonstration,  each 700  Series  Analyzer
operated for three  days,  and was used to analyze 197
samples.  Figures 7-1 and 7-2 show the relative costs for
the basic capital equipment.  These costs reflect the XLi
equipped with Cd-109, while the XLt used a miniature X-ray
tube as the'excitation source. Table 7-1 summarizes the
                                                    61

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700  Series  Analyzers  capital  costs  for  the  three
procurement  options:  rental, lease,  and purchase.  As
would be expected, Table 7-1 clearly shows that leasing is
the most cost-effective option (in terms of capital costs),
followed  by rental, for short-term projects.  As project
duration  (or use on  multiple projects) approaches two
years,  the  purchase  option becomes the most  cost-
effective. These scenarios cover only capital cost, not the
cost of optional or user-supplied equipment, supplies,
support equipment, labor, and IDW disposal.
                                          Purchase
                                      "Rental
                                  Lease
                     Months
Figure 7-1.  Capital costs for the XLi (isotope).
The  XLi (with Cd-109) sells  for $29,095. The cadmium
source (10 mCi) used  during  the demonstration needs to
be replaced about every 15 months. The cost of replacing
the source is $2,700  and  includes source disposal and
software upgrade.
                                                                                               Purchase
                                                                                            Rental
                                                                                        Lease
                                                                           Months
Figure 7-2.  Capital costs for the XLt (X-ray tube).
The XLt (with miniature X-ray tube) sells for $38,095. As
miniature X-ray tubes are quite new, not enough data has
been  collected to estimate tube lifetime.  The  cost of
replacing the X-ray tube is $5000 and includes a  new
power supply and software upgrade.
Table 7-1. Capital Cost Summary for the XLJ/XLt 700 Series Analyzers







a
b
Item
Purchase XLi 702 (Isotope)
Monthly Rental of XLi 702
Monthly Lease of XLi 702 •
Purchase XLt 792 (X-ray tube)
Monthly Rental of XLt 792
Monthly Lease of XLt 792"
$1,333 per month (24-month
$1 ,745 per month (24-month
Quantity Unit Cost
1
1
1
1
1
1
lease with $1
lease with $1
$29,095
$5,190
$1,333
$38,095
$6,800
$1,745
buyout).
buyout).
1 -Month
$29,095
$5,190
$1,333
$38,095
$6,800
$1,745

Total Cost for Selected Project Duration
3-Month 6-Month 12-Month
$29,095
$15,570
$3,999
$38,095
$20,400
$5,235

$29,095
$31,140
$7,998
$38,095
$40,800
$10,470

$29,095
$62,280
$15,996
$38,095
$81,600
$20,940

24-Month
$29,095
$124,560
$31,992
$38,095
$163,200
$41,880

                                                    62

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 7.2.2  Cost of Supplies

 Supplies used during the demonstration  included XRF
 sample cups, Mylar film, 2.4 cm filters and polyester filling.
 NISI soil SRMs were also used during the demonstration
 and are included with an instrument purchase.

 7.2.3  Support Equipment Cost

 NITON was provided with a 10x10 foot tent for protection
 from inclement weather during the demonstration.  It was
 also provided with one table and two chairs for use during
 sample preparation and analytical activities.  The rental
 cost for the tent (including detachable sides, ropes, poles,
 and pegs)  was $270' per week.   The rental cost for the
 table and two chairs forone week totaled $6. Total support
 equipment  costs  were $276 per week for rental.

 For longer projects, purchase of support equipment should
 be   considered.     Two  folding  chairs  would  cost
 approximately $40. A 10x10 foot tent would cost between
 $260 and $1,000, depending on the construction materials
 and the need for sidewalls and other accessories (e.g.,
 sand stakes, counterweights, storage bag, etc.).  A cost of
 $800 was used for this cost analysis. A folding table would
 cost between $80 and $250, depending on the  supplier.
 For purposes of this cost analysis, $160 was used. Total
 purchase costs for support equipment are estimated at
 $1,000.

 7.2.4 Labor Cost

 Two technicians were utilized for three days (17.5  hours, or
 35 man hours total)during the demonstration to complete
 sample preparation and analysis for both instruments.
 Based on a labor rate of $600 per day, total labor cost for
 application of both 700 Series Analyzers was $1,800 for the
 three-day period.  Laborcosts assume qualified technicians
 are available locally, and that no per diem  costs or travel
 costs are applicable. Table 7-2 summarizes labor costs for
 various operational periods, assuming 21  work  days per
 month  (on  average), 252 work days per year and -one
 technician per job site.  The costs presented do not include
 supervision and quality assurance because these  would be
 associated with use of any analytical instrument and are a
 portion of the overhead multiplier built into the labor rates.

 7.2.5 Investigation-Derived Waste Disposal
       Cost

 NITON generated PPE waste and  soil waste,  including
sample cups, Mylar film, filter discs and polyester filling.
The PPE waste was charged to the overall project due to
site constraints. The minimum waste volume is a5-gallon
container.  Mobilization and container drop-off fees were
$1,040; disposal of a 5-gallon waste soil drum cost $400.
(These costs were based on a listed waste stream with
hazardous waste number U151.)  The total IDW disposal
cost was $1,440. These costs may vary significantly from
site-to-site, depending on whether the waste is classified
as  hazardous  or  nonhazardous and  whether  sample
material  is  generated  that  requires disposal.  Table 7-3'
presents IOW  costs  for  various  operational  periods,
assuming that waste generation rates were similarto those
encountered during the demonstration.
Table 7-2. Labor Costs
    Item
	1	:
Months
 6
12
        24
 Technician  $6,300  $18,900   $37,800  $75,600  $151,200

 Supervisor    NA     NA       NA      NA       NA
Quality
Control
Total
NA
$6,300
NA
$18,900
NA
$37,800
NA
$75,600
NA
$151,200
Table 7-3.  IDW Costs
Item
Drop Fee
Disposal
Total
1
$1,040
$400
$1,440
3
$3,120
$1,200
$4,320
Months
6
$6,240
$2,400
$8,640
12
$12,480
$4,800
$17,280
24
$24,960
$9,600
$34,560
7.2.6  Summary ofXLi/XLt 700 Series Costs

The  total  cost  for  performing  mercury analysis  is
summarized in Tables 7-4 and 7-5.  These tables reflect
costs for projects ranging from 1-24 months.  The rental
option was used for estimating the equipment cost.

Capital  cost  for  equipment  rental exceed  those for
purchase at approximately six months, so rental is not as
cost-effective for projects exceeding this duration.  Finally,
a lease agreement may be a cost-effective alternative  to
either rental or purchase for projects lasting less than 21
months. At that point, equipment purchase may be more
cost-effective; however, the  decision on which purchase
option to utilize should be made on a case-by-case basis.
                                                   63

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Table 7-4. Summary of Rental Costs for the XLi 702 (Isotope)
Item Quantity Unit Unit
Cost
($)
Capital Equipment
Monthly Rental 1 NA $5,190
Support Equipment
Table (optional) - weekly 1 each $5
Chairs (optional) -weekly 2 each $1
Tent (for inclement weather 1 each $270
only) - weekly
To tot SuDDort EouiDrncnt Oost • •• • > • •• >
Labor
Field Technician (person day 1 hour $38
IDW
Container and Drop Fee $1,040
Disposal NA week $400
Trt#^i iniA/ rnate
1 ULOI IL/VV wUOlo ~ — — — — — — — — —
Total Cost
Table 7-5. Summary of Rental Costs for the XLt 792 (X-ray Tube)
Item Quantity Unit Unit
Cost
($)
Capital Equipment
Monthly Rental 1 NA $6,800
Support Equipment
Table (optional) -weekly 1 each $5
Chairs (optional) - weekly 2 each $1
Tent (for inclement weather 1 each $270
only) - weekly
Tots! SuDDort EciuiDmGnt Ooct ป •• >
Labor
Field Technician (person day 1 hour $38
IDW
Container and Drop Fee $ 1 ,040
Disposal ' NA week $400
Tnt-^l in\A/ Pnntt
1 UIQI ILJVV VyUOLO ~~ _™— ป _______
Total Cost
1 -Month

$5,190

$20
$10
$800
$830
$6,300

$1,040
$400
$1,440
$13,760

1 -Month

$6,800

$20
$10
$800
$830
$6,300

$1 ,040
$400
$1 ,440
$15,370
Total Cost for Selected Project Duration
3-Month 6-Month 12-Month

$15,570

$60
$25
$800
$885
$18,900

$3,120
$1,200
$4,320
$39,675


$31,140

$120
$40
$800
$960
$37,800

$6,240
$2,400
$8,640
$78,540


$62,280

$160
$40
$800
$1,000
$75.600

$12,480
$4,800
$17,280
$156,160

Total Cost for Selected Project Duration
3-Month 6-Month 12-Month

$20,400

$60
$25
$800
$885
$18,900

$3,120
$1,200
$4,320
$44,505

$40,800

$120
$40
$800
$960
$37,800

$6,240
$2,400
$8,640
$88,200

$81,600

$160
$40
$800
$1,000
$75,600

$12,480
$4,800
$17,280
$175,480
24-Month

$124,560

$160
$40
$800
$1,000
$151,200

$24,960
$9,600
$34,560
$311,320

24-Month

$163,200

$160
$40
$800
$1,000
$151,200

$24,960
$9,600
$34,560
$349,960
                                                     64

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Tables  7-6  and  7-7  summarize costs  for  the  actual
demonstration. Note that the one-month rental costs of the
XLi/XLt 700  Series units was used for capital costs. 35
hours  were required by both technicians to prepare and
analyze the samples for both instruments over a three-day
period. The labor rate presented in this Chapter assumes
one person performs sample preparation and analysis on
197 samples for one instrument over a two-day period.
Table 7-6.  XLi 702 (Isotope) Costs by Category
Table 7-7. XLt 792 (X-Ray Tube) Costs by Category
Category
Instrument
Supplies
Support
Equipment
Labor
IDW Disposal
Total
Category Cost
$5,190
$280
$276
$600
$1,440
$7,786
Percentage of
Total costs
66.7%
3.6%
3.5%
7.7%
18.5%
100.0%
Note: The percentages in Table 7-6 are rounded to one decimal place;
the total percentage is 100%.

The cost per analysis when renting  the XLi 702, based
upon  197 samples, is $39.52 per sample.  The cost per.
analysis for the 197 samples, excluding instrument rental
cost is $13.18 per sample.

The cost per analysis when renting  the XLt 792, based
upon  197 samples, is $47.69 per sample.  The cost per
analysis for the 197 samples,  instrument rental cost  is
$13.18 persample.
Category
Instrument
Supplies
Support
Equipment
Labor
I DW Disposal
Total
Category Cost
($}
$6,800
$280
$276
$600
$1,440
$9,396
Percentage of
Total costs
72.4%
3.0%
2.9%
6.4%
15.3%
100.0%
Note: The percentages in Table 7-7 are rounded to one decimal place;
the total percentage is 100%.

7.3    Typical Reference Method Costs
This Section presents costs associated with the reference
method used to  analyze the demonstration samples for
mercury. Costs for other project analyses are not covered.
The referee laboratory utilized SW-846 Method 7471B for
all soil and sediment  samples. The referee laboratory
performed 421 analyses over a 21-day time period.

A  typical  mercury analysis cost,  along  with  .percent
moisture for dry-weight calculation, is approximately $35.
This cost covers Sample management and preparation,
analysis, quality assurance, preparation of a data package.
The total cost for 197 samples at $35 would be $6,895.
This is based on a   standard turnaround  time  of 21-
calendar days.   The   sample  turnaround time from  the
laboratory can be reduced to 14, 7, or even fewer calendar
days, with  a cost multiplier between  125% to 300%,
depending upon project needs and laboratory availability.
This results in a cost  range from $6,895 to $20,685. The
laboratory cost  does  not  include sample  packaging,
shipping, or downtime caused to the project while awaiting
sample results.
                                                   65

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                                              Chapters
                            Summary of  Demonstration  Results
As discussed previously in this ITVR, the NITON XLi/XLt
700 Series Analyzers were evaluated by having the vendor
analyze 197  soil  and sediment  samples.   These  197
samples consisted of high-, medium-, and low-concentration
field  samples from four sites, SRMs, and  spiked field
samples. Table 8-1 provides a breakdown of the numbers
of these samples for each sample type and concentration
range or source. Collectively, these samples  provided the
different matrices, concentrations,  and types of mercury
needed to  perform a  comprehensive evaluation of the
XLi/XLt 700 Series Analyzers.

8.1    Primary Objectives
The primary objectives of the demonstration were centered
on evaluation of the field instruments and performance in
relation to sensitivity, accuracy, precision, time for analysis,
and cost. Each of these objectives was discussed in detail
in previous  chapters, and  is summarized in the following
paragraphs. The overall demonstration results suggest that
the experimental design was successfulfor evaluation of the
NITON XLi/XLt 700 Series Analyzers. Quantitative results
were reviewed. NITON results were determined to be more
precise than laboratory analyses and were comparable in
accuracy to SRMs. Differences between laboratory data
and  NITON  field  data were likely the  result  of matrix
interferences.

The two primary sensitivity evaluations performed for this
demonstration  were  the  MDL and  PQL.    Following
procedures established in40CFR Part 136, the MDL for the
NITON XLt (X-ray) instrument is between 13.9 and 69.8
mg/kg. It is likely that the MDL is closer to the  lower end of
this range based upon the results for sample Iot62 (referee
laboratory value = 1.4.6 mg/kg) and sample lot 47 (SRM
value = 32.4 mg/kg) which both had one  of the seven results
reported as below the NITON detection level indicating that
these values are on the edge of the instruments detection
capability.  The lowest calculated MDL for the NITON XLi
instrument is 39.3 mg/kg.  Based upon results presented
in the report for samples analyzed close to this detection
limit, it appears that  the MDL for the NITON XLi field
instrument  is  somewhere close to 32  mg/kg.  The
equivalent calculated  MDL for the referee laboratory is
0.0026 mg/kg.  The calculated MDL is only intended as a
statical estimation  and not a true test of instrument
sensitivity.

The NITON XLt PQL  is somewhere between 62.9 mg/kg
and 99.8 mg/kg. The %D for the 99.8 mg/kg SRM is 8.2%.
The NITON XLi PQL is also somewhere between 62.9
mg/kg and 99.8 mg/kg.  The %D for the average NITON
XLt result for the  99.8 mg/kg SRM is 9.2%. The referee
laboratory PQL confirmed  during the demonstration and
based upon a  lower calibration standard is 0.005mg/kg.
The%Dis<10%.

Accuracy was  evaluated by comparison to SRMs and
comparison to the referee laboratory analysis for field
samples. This included spiked field samples forevaluation
of additional concentrations not otherwise available. The
results from the  XLi/XLt  700  Series  Analyzers  were
compared  to  the 95% prediction interval for  the  SRM
materials and  to  the  referee laboratory results (Method
7471B). NITONXLt data were within SRM 95% prediction
intervals 93%  of the time, which suggests significant
equivalence to  certified standards. NITON XLi data were
within SRM 95% prediction intervals 91% of the time, which
also suggest significant equivalence to certified standards.

The statistical comparison between the  NITON XLt field
data and thereferee laboratory results suggest that the two
data sets are not the  same. The statistical comparison
                                                 •  66

-------
between the NITON XLi field data and the referee laboratory
results also suggest that these two data sets are not the
same. Because the NITON data compare favorably to the
SRM  values, the differences  between NITON  and the
referee laboratory are likely the result of matrix interferences
for field sample  analysis.   The number of  NITON XLt
average values less than 30% different from the referee
laboratory results or SRM reference values; however, was
14 of  26 different sample lots. Only one of 26 NITON XLt
average results have relative percent differences greater
than 100% for this same group of samples. The number of
NITON XLi average values less than 30% different from the
referee laboratory results or SRM reference values was 14
of 24 different sample lots. Zero of 24 NITON XLi average
results have relative percent differences greater than 100%
for this same group of sam pies.  Both NITON XLt and XLi
results therefore, can often provide a reasonable estimate
of accuracy for field determination.

Precision was determined by analysis of replicate samples.
The precision of the NITON XLt and XLi field instruments
is better then the referee laboratory precision.  The overall
average RSD is 20.0% for the  referee laboratory, compared
to the NITON XLt  average RSD of 13.1% and the NITON
XLi average RSD of 14.4%. Both the laboratory and NITON
precision goals are within the predicted 25% RSD objective
for precision; expected from both analytical and sampling
variance.    Precision  was  not   affected  by   sample
concentration  or matrix.
Time measurements were based on the length of time the
operator spent performing all phases of  the analyses,
including setup, calibration, and sample analysis (including
all reanalysis). NITON analyzed 197 samples on a single
instrument in 1,050 minutes (17.5 hours, times 60 minutes,
times  1 analyst per instrument) over  three days, which
averaged to 5.3 minutes per sample result.  Based on this,
an operator could be  expected to analyze 90 samples (8
hours x 60 minutes + 5.3 minutes/sample) in an 8-hour
day.
Cost of  the  NITON  sample analysis included  capital,
supplies, labor, support equipment, and waste disposal.
The cost per sample was calculated both with and without
the cost of the instrument included. This was performed
because the first sample requires the instrument purchase,
and as the sample number increases, the cost per sample
would decrease. A comparison of the field  NITON cost to
off-site laboratory cost was not made.  To compare the
field and laboratory costs correctly, it would be necessary
to include the expense to the  project while waiting for
analyses to return from the laboratory (potentially several
mobilizations and dem obilizations, stand-by fees, and other
aspects  associated  with field  activities).  Table  8-2
summarizes the results of the primary  objectives.

8.2     Secondary Objectives

Table  8-3 summarizes  the  results  of the  secondary
objectives.
Table 8-1.  Distribution of Samples Prepared for NITON and the Referee Laboratory
                                                                   Sample Type
Site
Carson River
(Subtotal = 31)

Puget Sound
(Subtotal = 34)
Oak Ridge
' (Subtotal = 54)
Manufacturing
(Subtotal = 78)
Subtotal
Concentration Range
Low(1-500ppb)
Mid (0.5-50 ppm)
High (50->1,000 ppm)
Low (1 ppb- 10 ppm)
High (10-500 ppm)
Low (0.1-10 ppm)
High (10-800 ppm)
General (5-1,000 ppm)


Soil
0
7
3
3
0
0
13
36

62
	 -r
Sediment
0
0
0
0
10
3
10
0

23
— j i 	
Spiked Soil
0
0
7
0
7
0
14
14

42
SRM
0
0
14
0
14
0
14
28

70
                                                    67

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Table 8-2. Summary of NITON XLi/XLt 700 Series Analyzers Results for the Primary Objectives

                    Evaluation Basis
Demonstration
Objective
Performance Results
NITON XLi/XLt 700 Series
Analyzers	
                                                                                        Reference Method
 Instrument
 Sensitivity
 Accuracy
 Precision
 Time per Analysis
 Cost
                  MDL.   Method from 40 CFR Part 136..
                    PQL.   Low concentration SRMs or
                    samples.
                  Comparison to SRMs, field, and spiked
                  samples covering the entire range of the
                  instrument calibration.
                  Determined by analysis of replicate samples
                  at several concentrations.
                  Timed daily operations for 3 days and
                  divided the total time by the total number of
                  analyses.
                  Costs were provided by NITON and
                  independent suppliers of support equipment
                  and supplies. Labor costs were estimated
                  based on a salary survey. IDW costs were
                  estimated from the actual costs encountered
                  at the Oak Ridge demonstration.
Between 13.9 and 69.8
mg/kg for the NITON XLt.

Approximately 32 mg/kg
for the NITON XLi.

NITON XLt  and NITON
XLi PQL; between 62.9
mg/kg and 99.8 mg/kg.
0.0026 mg/kg
                                                                                      0.005 mg/kg
NITON XLt data were within SRM 95% prediction
intervals 93% of the time; NITON XLi data were within
SRM 95% prediction intervals 91% of the time. NITON
and laboratory data did not statistically compare for all
results but  NITON  results can often provide a
reasonable estimate of accuracy for field determination.

Overall average RSD is 20.0% for the referee laboratory
compared to the NITON XLt average RSD of 13.1% and
the NITON XLi average RSD of 14.4%.

Two technicians performed all setup, calibration checks,
sample preparation and analysis, and equipment
demobilization. Using one technician individual analyses
(excluding sample preparation) took 2 minutes each, but
the total time per analysis averaged approximately 5.3
minutes per sample per instrument.

The cost per analysis based upon 197 samples, when
renting the NITON XLi 702, is $39.52 per sample. The
cost per analysis for the 197 samples, excluding capital
cost, is $13.18 per sample. The total cost for equipment
rental and necessary supplies during the demonstration
is estimated at $7,786. The cost breakout by category is:
capital equipment rental costs, 66.7%; supplies, 3,6%;
support equipment, 3.5%; labor, 7.7%; and IDW, 18.5%.

The cost per analysis, based upon  197 samples, when
renting the NITON XLt 792, is $47.69 per sample. The
cost per analysis for the 197 samples, excluding capital
cost, is $13.18 per sample. The total cost for equipment
rental and necessary supplies during the demonstration
is estimated at $9396. The cost breakout by category is:
capital equipment rental costs, 72.4%; supplies, 3.0%;
support equipment, 2.9%; labor, 6.4%; and IDW, 15.3%.
                                                       68

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Table 8-3. Summary of NITON XLi/XLt 700 Series Analyzers Results for the Secondary Objectives
 Demonstration
 Objective
Evaluation Basis
Performance Results
 Ease of Use
Field observations during the demonstration.
 Health and Safety
 Concerns
 Portability of the
 Device
 Instrument
 Durability
 Availability of
 Vendor
 Instruments and
 Supplies
Observation of equipment, operating
procedures, and equipment certifications
during the demonstration.

Review of device specifications,
measurement of key components, and
observation of equipment setup and tear
down before, during, and after the
demonstration.

Observation of equipment design and
construction, and evaluation of any
necessary repairs or instrument downtime
during the demonstration.
Review of vendor website and telephone
calls to the vendor after the demonstration.
The NITON XLi/XLt 700 Series Analyzers are very easy
to operate, requiring one field technician with a high
school education, and 8-hour training on the NITON
XLi/XLt 700 Series Analyzers.  The analyzers are field
screening tools capable of measuring 25 elements in
seconds. No data manipulation is required.

No significant health and safety concerns were noted
during the demonstration.  The analyzers should never
be pointed at any person when the shutters are open.

The NITON XLi/XLt 700 Series Analyzers are hand-held
portable instruments. They are stand-alone units with no
cables, and are easy to set up.  A sample can be
analyzed in less than five minutes.
The NITON XLi/XLt 700 Series Analyzers were well
designed and constructed for durability. NITON's XRF
analyzers are the product of a decade of continuous
research and development in XRF technology.

In addition, the Cd-109 (10 mCi) source should be
replaced every 15 months, and only by authorized
personnel.

The NITON XLi/XLt 700 Series Analyzers are readily
available for lease or purchase. A rented analyzer can
be received typically within 10-14 days of order
placement. Sample cups, Mylar film, filter discs, spatula,
and polyester filling are the only supplies needed to
analyze samples intrusively and are available from
several supply firms or from NITON.
                                                        69

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                                             Chapter 9
                                           Bibliography
Anchor   Environmental.  2000.  Engineering  Design
  Report, Interim Remedial Action Log Pond Cleanup/
  Habitat  Restoration  Whatcom  Waterway  Site,
  Bellingham, W.A. Prepared for Georgia Pacific West,
  Inc. by Anchor Environmental, L.L.C., Seattle, WA. J uly
  31,2000.

Confidential Manufacturing Site. 2002. Soil Boring Data
  from a Remedial Investigation Conducted in 2000.

NITON.  2002 "NITON  XLi 700  Series  Environmental
  Analyzer User's Manual," Version 3.5

NITON.  2002 "NITON  XLt 700  Series  Environmental
  Analyzer-User's Manual," Version 3.5

EPA.  1998  Field  Portable  X-Ray  Fluorescence
  Spectrometry  for the Determination  of Elemental
  Concentrations in  Soil  and  Sediment.  Revision 0
  January.

Rothchild.E.R., R.R.Turner, S.H. Stow, M.A. Bogle, LK.
  Hyder, O.M. Sealand, H.J. Wyrick. 1984. Investigation
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  Oak Ridge National Laboratory, ORNL/TM-9092.

U.S. Environmental Protection Agency. 1994. Region 9.
  Human  Health  Risk Assessment and Remedial
  Investigation Report - Carson  River Mercury Site
  (Revised Draft).  December 1994.

U.S.  Environmental   Protection  Agency.   1995.
  Contaminants and Remedial Options at Selected
  Metal-Contaminated  Sites. July 1995. Washington
  D.C., EPA/540/R-95/512.
U.S. Environmental  Protection Agency^  1996.  Test
  Methods  for   Evaluating   Solid  Waste,
  Physical/Chemical Methods, SW-846 CD ROM, which
  contains updates for 1986, 1992, 1994,  and 1996.
  Washington D.C.

U.S.  Environmental   Protection   Agency.     1998.
  Unpublished.    Quality  Assurance  Project  Plan
  Requirements for Applied Research Projects,  August
  1998.

U.S. Department of Energy.   1998.  Report  on the
  Remedial Investigation of the  Upper East Fork of
  Poplar Creek Characterization Area at the Oak Ridge
  Y-12 Plant, Oak Ridge, TN.  DOE/OR/01-1641&D2.

U.S. Environmental Protection Agency. 2002a.  Region
  9 Internet Web Site, www.epa.gov/region9/ind ex. htm I.

U.S. .  Environmental  Protection   Agency.   2002b.
  Guidance on  Data Quality Indicators,   EPA G-5i,
  Washington D.C..July2002.

U.S. Environmental  Protection  Agency. 2003. Field
Demonstration Quality Assurance Project Plan - Field
Analysis of Mercury in Soil and Sediment. August 2003.
Washington D.C., EPA/600/R-03/053.

Wilcox,  J.W., Chairman.  1983.  Mercury at Y-12: A
  Summary of the 1983 UCC-ND Task Force Study.
  Report Y/EX-23, November  1983.

www.niton.com,  2003
                                                  70

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                                              Appendix A
                                          NITON Comments
NITON LLC was pleased to participate in this EPA SITE
program  with our new generation of field portable x-ray
fluorescence (FPXRF) analyzers. The instruments used in
this study were the NITON LLC Model XLi 702 radioisotope
excitation spectrometer  and the  Model XLt  792 with
miniature x-ray tube excitation.

Field portable x-ray fluorescence spectrometry has seen
application to  the  determination  of metals  in soil and
sediment for some two decades now (Piorek, 1997). It has
become  a standard  tool  in site  characterization and
remediation  (U.S. EPA, 1996).  The technology is well
known and has been extensively described in the literature
(Spittler,  et.al.,  1985;  Piorek, et.al., 1993; Hewitt, 1994;
Shefsky,  1997).

Results

Figure A-1 shows a comparison of laboratory and  FPXRF
results from the model XLt 792 with  miniature X-ray tube.
The error bars denote 2-sigma variation of the (generally)
seven replicate analyses. We note the consistently worse
precision for the laboratory determinations at the higher
concentration levels, greater than about 200 ppm. W6 note
that the referee laboratory testing was in accordance with
Method  7471A  (Cold  Vapor  Analysis  for Mercury
Determination)  of  SW-846,  a  technique   generally
applicable to a maximum concentration of about  1 ppm.
We suspect the poor precision at the higher levels to  be
due to the substantial  dilutions necessary to apply this
method at these concentrations.

Given these results, samples 32 and 33 should probably be
considered outliers. They are labeled and  appear in the
lower right hand corner of Figure A-1.

We note a slight high bias with respect to laboratory results
for both instruments although in most cases the error bars
overlap the diagonal indicating a one-to-one correlation.
Closer  examination  of the  subset of  samples  with
concentration of about 300 ppm and less (i.e.,  where the
laboratory precision.becomes less of an issue) produces
the following correlation coefficients: Referee laboratory vs.
Tube-excitation, R2~ 0.93; Referee laboratory vs. Isotope-
excitation, R* -0.83.

Approximate   detection  limits  for  a   120  second
measurement time are about 25 ppm for model XLi 702
(radioisotope excitation) and 15 ppm for the model XLt 792
(miniature x-ray tube instrument).  These  LODs are  as
defined by IUPAC (International Union of Pure and Applied
Chemistry) and computed with  reference to the precision
on a blank sample,  i.e., a soil not containing  mercury
(Thomsen,  et.al, 2003, and references therein). They
correspond to what is termed IDL in this ITVR. MDLs are
generally anywhere from two to five times greater than the
IDL, so we can see a correspondence between the LODs
reported above  and those reported in  the ITVR.   Of
perhaps  greater interest are  the  associated  limits  of
quantitation (LOQ, defined as 3.3 times the LOD), which
 This appendix was written solely by NITON. The statements, presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the XLi/XLt-700 Series Analyzers. Publication of this material does not represent EPA's approval
 or endorsement of the statements made in this appendix; performance assessment and economic analysis results for the XLi/XLt-700 Series
 Analyzers are discussed in the body of the ITVR.
                                                    71

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become about 50 ppm for the x-ray tube and 80 ppm for
the isotope excitation instrument. Although action levels for
mercury in soil vary, some preliminary EPA goals, as noted
in this report, are 23 mg/kg (ppm) for residential and 310
mg/kg (ppm) for industrial soil. We can see, therefore, that
the FPXRF instrumentation finds primary applicability in the
latter field, while still finding use as a screening tool in the
former.

Conclusions

The correlation between laboratory and NITON analyzer
.results is quite good. Note that the XRF analysis of soil is
susceptible to  particle size effects, so that sieving to about
250 microns (200 mesh) is recommended. Nevertheless,
the  close correlation reported  here was achieved with
minimal sample preparation. Improved results would be
expected with additional sample preparation. Precisionwas
also very good, with both  analyzers essentially yielding
similar or better precision than the referee laboratory.

We  note  that  lead,  arsenic, and zinc are  potential
interferants, butall three are probably not significantat less
than about 500 ppm. If lead and arsenic are present atthis
level,  then  the  site  has  other  serious contamination
problems. However, zinc may occur naturally in soil and
could well  be  above this level. For questionable  results
(e.g.,  large  reported  measurement  uncertainty)  the
operator/analyst  is  counseled  to examine  the x-ray
spectrum itself.

A clear advantage of field portable x-ray fluorescence is its
non-destructive nature. This allows the same sample to be
sent for confirmatory analysis to eliminate questions or
concerns. However, given the similarity in spread between
laboratory and FPXRF results, this may be a  moot point.

It is also important to point out the multielement nature of
this  analytical  technique as many  elements can  be
analyzed simultaneously. This is certainly an advantage
where multiple contaminants may be involved.
References

Hewitt,  A.D.  1994. "Screening  for  Metals  by X-ray
    Fluorescence   Spectrometry/  Compton  Peak
    Normalization  Analysis."  American  Environmental
    Laboratory, 6, pp. 24-32.

Piorek, S. and Pasmore, J.R. 1993. "Standardless, In Situ
    Analysis  of Metallic Contaminants  in  the  Natural
    Environment  With  a  PC-Based,  High  Resolution
    Portable X-Ray Analyzer." Proceedings  of the Third
    International Symposium on Field Screening Methods
    for Hazardous  Wastes and Toxic Chemicals,  Las
    Vegas, Feb. 24-26, pp.  1152-1161.

Piorek,  S. 1997.  "Field-Portable  X-Ray Fluorescence
    Spectrometry:   Past, Present,  and  Future."  Field
    Analytical Chemistry and Technology  1(6): 317-329.

Shefsky,  S.  1997. "Comparing  Field Portable  X-Ray
    Fluorescence (XRF) to  Laboratory Analysis of Heavy
    Metals  in  Soil."   Presented  at  the  International
    Symposium on Screening  Methods  for Hazardous
    Wastes and  Toxic  Chemicals, Las Vegas, Jan.
    29-31.(Available    online    at   http://
    www.niton.com/shef02.htm I)

Spittler, T., Furst, G.,and Tillinghast, V.  1985. "Screening
    for Metals at  Hazardous  Waste  Sites: A  Rapid,
    Cost-effective Technique using X-ray  Fluorescence."
    Proceedings of the  Sixth National  Conference on
    Management of Uncontrolled Hazardous Waste Sites.

U.S. EPA  Method  6200. 1996. "Field Portable  X-Ray
    Fluorescence Spectrometry for the Determination of
    Elemental Concentrations in Soil and Sediment."

Thomsen,  V., Schatzlein,  D., and Mercuro, D., 2003.
    "Limits of Detection in Spectroscopy."Spectroscopy, In
    print, Nov. 2003. Pre-prints available upon request.
 This appendix was written solely by NITON. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the XLi/XLt-700 Series Analyzers. Publication of this material does not represent EPA's approval
 or endorsement of the statements made in this appendix; performance assessment and economic analysis results for the XLi/XLt-700 Series
 Analyzers are discussed in the body of the ITVR.
                                                     72

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1400-
1200
I 1000
a
a.
*M 8oo-
j2
"5
CO
600
X
400.
200-
0








j.
$P







-T-U-
• FH
• l L









r 7
1 T
	 1










i




— i
r
-i 	
Sample 32

T
i





H



















Sample 33









                       200          400           600          800          1000

                                               Laboratory Results (ppm Hg)
1200
1400
1600
Figure A-1. Comparison of precision, all samples, laboratory and model XLt
 This appendix was written solely by NITON. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the XLi/XLt-700 Series Analyzers. Publication of this material does not represent EPA's approval
 or endorsement of the statements made in this appendix; performance assessment and economic analysis results for the XLi/XLt-700 Series
 Analyzers are discussed in the body of the ITVR.
                                                           73

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                                              Appendix  B
                                         Statistical Analysis
Two separate hypothesis tests were used to compare the
referee laboratory samples to the vendor tested samples.
This appendix details the equations and information for
both of  these  statistical analyses. For purposes of this
appendix, we  have chosen to  call  the test comparing
sample populations using a separate calculation for each
sample  lot  the "hypothesis test,"  and  the  statistical
comparison  of the entire  sample set (all 24  separate
sample  lots for the  NITON XLi instrument  and  all 26
separate sample  lots  for  the  NITON XLt  instrument)
analyzed by the vendor and the laboratory the "unified
hypothesis test," also known as an "aggregate analysis" for
all of the sample lots.

Hypothesis Test

A  hypothesis  test  is used  to determine  if two sample
populations  are significantly different.  The  analysis is
performed based on standard statistical calculations for
hypothesis  testing.   This  incorporates a comparison
between the two sample populations assuming a specified
level of significance. For establishing the hypothesis test,
it  was  assumed  that  both sample  sets  are  equal.
Therefore, if the null  hypothesis is  rejected,  then  the
sample  sets are not considered equal..  This  test was
performed on all sample lots analyzed by both NITON and
the referee laboratory.  H0 and Ha,  null and alternative
hypothesis respectively, were tested with a 0.01 level of
significance (LOS). The concern  related to this test is that,
if two sample populations have highly variable data (poor
precision), then the  null hypothesis  may  be  accepted
because of the test1 s inability to exclude poor precision as
a mitigating  factor.  Highly variable data results in wider
acceptance windows, and therefore, allows for acceptance
of the null hypothesis. Conclusions regarding this analysis
are presented in the main body of the  report.
To  determine  if the two sample sets are significantly
different, the absolute value of the difference between the
laboratory average XL and  the  vendor average  xv  is
compared to a calculated u.  When the absolute value  of
the difference  is  greater than  u,  then the alternate
hypothesis is accepted, and the two sets (laboratory and
vendor) are concluded to be different.

To calculate u, the variances for the.laboratory data set
and the vendor data set are calculated by dividing their
standard deviations bythe number of samples in their data
set. The effective number of degrees of freedom is then
calculated.
                                   — 2
                             V *>
                             V  ฃ
Where:
       f
       VL
       nL

       Vv
       nv
= effective number of degrees of freedom
= variance for the laboratory results
= number of samples for the  laboratory
data set
= variance for the vendor results
= number of sam pies for the vendor data
set.
The  degrees of freedom  (f)  is used  to determine the
appropriate T value and used to calculate p at the 0.01
level of significance using the following:
                                                    74

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Unified Hypothesis Test

For  a specified vendor, let Y,? be  the  measured Hg
concentration for the f1 replicate of the f sample for
/ = 1,2	landy=1.2	J,. Let Xs = log(Yj), where log is the
logarithm to the base 10.  Define xaog to be the average
over all log replicates for the f sample given by:
             jr.
               Jbg
                        -1
log
 7
z
                            Where x2,., is approximately a chi-square random variable
                            with (1-1) degrees of freedom:
                                        -1
                                                              -  X
                                                                               and
Denote the estimate of the variance of the log replicates for
the /""sample to be:
                                                                          1-1
          (  i        y1     /   J,
      *a = Zto-0  b&Z  Z
          U-l       J.     i-1  j-l
Now for the reference laboratory, let Y',;be the measured
Hg concentration for the /" replicate of the fh sample for
/  =1,2 ..... 1' and j  = 1,2,...,J',.   Denote  the  reference
laboratory quantities X'/;, x,', and s'2 defined in a manner
similar to the corresponding quantities for the vendor.
Assumptions: Assume that the vendormeasurements, Yf,
are independent and identically distributed according to a
lognormal distribution with parameters  u, and o2. That is,
X,;= log(Y,?) is distributed according to a  normal distribution
with expected value u, and variance a2. Further, assume
that  the  reference  laboratory measurements, Y',j, are
independent and  identically distributed according to a
lognormal distribution with parameters  u', and o'2.

The null hypothesis to be tested is:

     H0 : ft = fj'j + S, for some Sand i  = !,...,!

against the alternative hypothesis that the equality does hot
hold  for at least one value of /.

The null hypothesis H0 is rejected for large values of:
                 tog -X'^-sf -H (j-1 + J'-1)
                                                I'-l         1-1

                            Critical  values  for  the  hypothesis test are the upper
                            percentile of the chi-square distribution with (1-1) degrees
                            of freedom obtained from a chi-square table.

                            Results of Unified Hypothesis  Test for NITON XLi
                            (Isotope!

                            SAIC performed  a unified hypothesis test analysis  to
                            assess  the comparability of analytical results provided  by
                            NITON  XLi and those provided by ALSI.  NITON XLi and
                            ALSI both supplied multiple assays on replicates derived
                            from a  total  of 24  different  sample  lots,  be  they  field
                            mate rials or reference materials. The NITON XLi and ALSI
                            data from these assays formed  the  basis  of  this
                            assessment.

                            The statistical  analysis  is based on log-transformed
                            (logarithm base 10) data and uses a chi-square test for
                            equality of NITON XLi and ALSI population means for a
                            given sample lot.  Equality of variances is assumed.

                            Initially,  the null hypothesis tested  was that, on average,
                            NITON  XLi and ALSI would produce the  same results
                            within a given sample lot. This  hypothesis is stated as

                               H10: (NITON XLi lot log mean) = (ALSI lot log mean)

                            H10 was rejected in thatthe chi-square statistic was 334.59,
                            which exceeds the upper 99th percentile of the chi-square
                            distribution with 24 degrees of freedom having a value of
                            42.97.

                            The null hypothesis was rejected in part because NITON
                            XLi results tended  to exceed those from ALSI forthesame
                                                    75

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 sample lot. To explore this effect, the null hypothesis was
 revised to included a bias term in the form of

   H20: (NITON XLi lot log mean) = (ALSI lot log mean)
                       +(delta),

 where delta is a single  value that does not change from
 one sample lot to another, unlike the lot log means.  H20
 was rejected strongly in that the chi-square statistic was
 312.60, which exceeded the upper 99th percentile  of the
 chi-square distribution with 23 degrees of freedom  with a
 value of 41.63. In this analysis, delta was estimated to be
 0.0535 in logarithmic (base 10) space, which indicates an
 .average upward  bias for NITON XLi of 10ฐ'0535=1.131 or
 about 13%.

 For both  hypotheses, the large  values of the chi-square
 test statistics summarize the disagreement between the
 NITON XLi and ALSI analytical  results.  Furthermore, a
review of the statistical analysis details indicates that the
overall  discordance  between  NITON  XLi  and  ALSI
analytical results cannot be traced to the disagreement in
results for one or two sample lots.

Summary information on these analyses is provided in
Table  B-1.    The  p-value  can  be considered  as a
significance level.  This is a calculated value and usually
when one sets a p-value (e.g., 95% confidence level which
translates to a p-value of 0.05), this value is used to test
the level of significance for comparison. As noted in Table
B-1 the p-value is calculated from the test statistics and
therefore it can be seen  that because the p-value is so
small  (<  0.000000) the two  sample  populations  are
considered to be non-equivalent and hence the large chi-
square value.
 Table B-1. Unified Hypothesis Test Summary Information for the NITON XLi Instrument

      Hypothesis   Total Sample Lots   Excluded Lot        DF          s2^,          Delta.
                            Chi-square
                                           P-value
H,0 24
H,n 24
None
None
24
23
0.00752
0.00752
0.0000
0.0535
334.59
312.60
0.000000
0.000000
 Results of  Unified  Hypothesis  Test for NITON XLt
 (X-rav)
 SAIC  performed  a  unified hypothesis test analysis to
 assess the comparability of analytical results provided by
 NITON X-ray and those provided by ALSI.  NITON  XLt
 and ALSI  both supplied  multiple assays on  replicates
. derived from a total of 26 different sample lots, be they
 field materials or reference materials.  The NITON  XLt
 and ALSI data from these assays formed the basis of
 this assessment.

 The statistical analysis  is based  on log-transformed
 (logarithm  base 10) data  and  uses a chi-square test for
 equality of NITON XLt and ALSI population means for
 given sample lot.  Equality of variances is assumed.

 Initially, the null hypothesis tested was that, on average,
 NITON XLt and  ALSI would  produce the same results
 within  a given sample lot.  This hypothesis is stated as

   H10: (NITON XLt lot log mean) = (ALSI lot log mean)
H1O was rejected  in  that the chi-square statistic was
266.50, which exceeds the upper 99th percentile of the
chi-square  distribution  with  26  degrees  of  freedom
having a value of 45.64.

The. null hypothesis was rejected in part because NITON
XLt results tended to exceed  those from ALSI for the
same  sample  lot.    To explore this  effect,  the  null
hypothesis  was revised to  included a bias term in the
form of
  H20: (NITON XLt lot log mean) = (ALSI lot log mean)
                      +(delta),

where delta is a single value that does not change from
one sample lot to another, unlike the lot log  means.  H20
was rejected  strongly  in  that the  chi-square  statistic was
249.17, which exceeded the upper 99th percentile of the
chi-square distribution with 25 degrees of freedom with a
value of 44.31. In this analysis, delta was estimated to
be  0.0480  in logarithmic  (base  10)   space,  which
indicates an  average upward  bias  for NITON XLt  of
100048ฐ=1.117orabout12%.
                                                     76

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For both hypotheses, the large values of the chi-square
test statistics summarize the disagreement between the
NITON XLt and ALSI analytical results.  Furthermore,  a
review of the statistical  analysis details indicates that the
overall  discordance between  NITON  XLt and ALSI
analytical results cannot be traced to the disagreement in
results for one or two sample lots.

Summary information  on these, analyses is provided in
Table B-2.    The  p-value  can be considered  as  a
significance level. This is a calculated value and usually
when one  sets  a  p-value  (e.g.,'95%  confidence level
which translates to a p-value of 0.05), this value is used
to test the level of significance for comparison. As noted
in Table B-2  the  p-value  is calculated  from the test
statistics and therefore it can be seen that because  the
p-value  is so  small  (<  0.000000)  the  two  sample
populations are considered to be  non-equivalent and
hence the large chi-square value.
Table B-2. Unified Hypothesis Test Summary Information for the NITON XLt  Instrument
Hypothesis
HIQ
H,n
Total Sam
Lots
26
26
pie
Excluded Lot
None
None
DF
26
25
s pool
0.00887
0.00887
Delta
0.0000
0.0480
Chi-square
266.50
249.17
P-value
0.000000
0.000000
                                                    77

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