United States
         Environmental Protection
         Agency
           Office of
           Research and Development
           Washington, DC 20460
EPA/600/R-04/028
May 2004
&EPA
Innovative Technology
 Verification Report
   Field Measurement Technology for
     Mercury in Soil and Sediment

          MTI Inc.'sPDVGOOO
     Anodic Stripping Voltammetry

-------
                                  EPA/600/R-04/028
                                  May 2004
    Innovative Technology
      Verification Report


      MTI  Inc.'sPDVGOOO
Anodic Stripping Voltammetry
                 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

-------
                                       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
not constitute endorsement or recommendation for use.

-------
                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: MTI Inc.'s Portable Digital Voltammeter (PDV) 6000

COMPANY:    Monitoring Technologies International Pty. Ltd.
ADDRESS:     1/7 Collingwood Street
              Osborne Park, Perth
              West Australia 6017

WEB SITE: www.monitoring-technologies.com.

U.S. CONTACT/TELEPHONE: Felecia Owen, MTI  Inc.
                          1609 Ebb Drive
                          Wilmington, NC  28409
                          (910)392-5714

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 a demonstration  of the Portable Digital Voltammeter (PDV) 6000
developed by Monitoring Technologies International Pty.  Ltd. (MTI).

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 measurement technologies, 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 PDV 6000 and four other field measurement devices for
mercury in soil and sediment. Due to inaccurate results on standards (later determined to be an oilcontaminanton the
disposable beakers that was coating the electrodes), MTI  decided to discontinue the field  measurements.  The
demonstration of their PDV 6 000 instrument was rescheduled and was con ducted in Las Vegas, NV, in June 2003. This
verification statement focuses on the PDV 6000; a similar statement has been prepared for each of the other four
devices. The performance of the PDV 6000 was compared to that of an off-site laboratory using the reference method,

-------
"Test Methods for Evaluating Solid Waste" (SW-846) Method 7471 B (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;
     (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 skills and training required to properly operate the device;
     (2) Documenting potential health and  safety concerns associated with operating the device;
     (3) Documenting the  portability of the  device;
     (4) Evaluating the device durability based on its materials of construction and engineering design; and
     (5) Documenting the  availability of the device and associated spare parts.

The PDV 6000 analyzed 52 field soil samples, 33 field sediment samples, 35 spiked field samples, and 77 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 PDV 6000.  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 — MTI Inc.'s  PDV 6000 Anodic Stripping Voltammetry" (EPA/600/R-04/028).

TECHNOLOGY DESCRIPTION

The principle of analysis used by the MTI PDV 6000 is Anodic Stripping Voltammetry (ASV).  ASVis a simple procedure
in which a reducing potential is applied to a "working electrode." When the potential of this working electrode exceeds
the ionization potential of the particular metal ion solution in solution, it is reduced to the metal.  The metal plates onto
the working electrode surface as follows:
                                              Mn++ ne'^ M

where:  Mn+ = analyte metal ion in solution
        ne" = number of electrons
        M = metal plated onto the electrode

The  longer the  potential is applied, the more metal is reduced and  plated onto the surface  of the electrode.  This
"deposition" or "accumulation" step concentrates the metal. After sufficient metal has  been plated onto the working
electrode, the metal is stripped (oxidized) off the electrode by increasing the potential to that electrode at a constant rate.
For a given electrolyte solution and  electrode, each  metal  has a specific potential in  which  the following oxidation
reaction will occur:
                                              M -> Mn++  ne'

The electrons released by this process form a current that is measured and plotted as a function of the applied potential
to give a "voltammogram." The current at  the oxidation or stripping potential for  the analyte metal is seen  as a peak.
To calculate the sample concentration, the  peak height or area is measured and compared to that of a known standard
or solution under the same conditions.

During the demonstration, each sample was  digested per MTI's  standard operating procedure (SOP).  Sample
preparation consisted of weighing out (in order) 2 grams of sample material, placing that material in a 70-mL digestion
                                                    IV

-------
bottle and then pipetting into that bottle 4.0 ml_ of HNO3, 4.0 ml_ of H2O2, 12 ml_ of deionized (Dl) water, and 20 ml_ of
electrolyte solution.  The prepared samples were then analyzed with the PDV 6000.

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.

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 1 36. The
MDL is between 1 .67 and 3.67 mg/kg.  The equivalent MDL for the referee laboratory is 0.0026 mg/kg. Examples from
analyzed samples, however, suggested that the MTI  MDL may be closerto 0.81 1 mg/kg or lower. Values detected at
these lowerlevels would likely be highly inaccurate and should only be considered as a "positive hit" withoutany implied
accuracy or precision.

Practical Quantitation Lim it - The low standard calculations suggest that a PQL for the MTI field instrument is 4-8 mg/kg.
The percent difference (%D) for the average MTI result for a sample concentration of 4.75 mg/kg, tested as part of the
demonstration, is 46%. The referee laboratory PQL confirmed during the demonstration is 0.005 mg/kg with  a %D
Accuracy: The results from the PDV 6000 were compared to the 95% prediction interval for the SRM materials and
to the referee laboratory results (Method 7471 B). MTI data were within the SRM 95% prediction intervals 53% of the
time.  The comparison between the MTI field data and the referee laboratory results suggestthatthe two data sets are
not different but the similarityfor individual samples is often the result of high variability associated with the MTI reported
values.  The number of MTI average values greater than 50% different from the referee laboratory results or SRM
reference values was only 6 for 21 different sample lots with only 2 of those 6 greater than 1 00% different. These 6 (of
the 21 ) sample lots had results greater than laboratory results, indicating a positive bias. MTI results therefore appear
to provide a rough estimate of mercury concentration for fie Id determination and may be affected by interferences not
identified by this demonstration.  It should be concluded, however, that the  MTI PDV 6000 did not compare well to
laboratory Method 7471 B in terms of obtaining accurate analyses of mercury in soil.

Precision: The precision of the MTI field instrument is not as good as the referee laboratory precision. The overall
average RSD for MTI is 35.1% which is above the 25%  RSD objective set  for the laboratory.  The overall  laboratory
average RSD is 22.3%.

Measurement Time:  From the time of sample receipt,  MTI required  38 hours  to prepare a draft data package
containing mercury results for 1 97 samples. Two persons performed all setup, calibration checks, sample preparation
and analysis, and equipment demobilization. Each  individual analysis, on  average, took 7.5 minutes (from the time the
sample was digested until results were displayed), butthe total time per analysis averaged approximately 1 1 .6 minutes
when all sample preparation, sample analysis, and data package preparation were included in the calculation.

-------
Measurement Costs:  The cost per analysis, based on measurement of 197 samples, when incurring a minimum
1-month rental fee for the PDV 6000, was determined to be $43.74 per sample.  Excluding the instrument rental cost,
the cost  for analyzing  the  197 samples  was  determined to be $32.57 per sample.   Based  on the 3-day field
demonstration, the total cost for equipment rental and necessary supplies was estimated at $8,600. The cost breakout
by category is: capital costs, 25.5%; supplies, 32.5%; support equipment, 3.2%; labor, 17.4%; and IDW, 21.4%.

Key demonstration findings are summarized below for the secondary objectives.

Ease of Use: Based upon observations made during the demonstration, the PDV 6000 is relatively easy to operate,
requiring one fie Id technician with a basic knowledge of chemistry acquired on the job or in a university, basic computer
skills, and training on the PDV 6000.  A 1-day training course on instrument operation is offered at additional cost; this
training should be considered for most potential users having  no previous laboratory experience.

Potential Health  and  Safety Concerns: No significant  health  and safety  concerns  were  noted during  the
demonstration; however, during the demonstration, fumes following the addition of acidic solution, during digestion of
certain samples, was observed. The digestion procedure involves the use of potentially reactive oraggressive reagents
and ultimately there is a potential for vigorous reactions to occur.

Portability.  The main components of the PDV 6000 consist of a handheld control unitand a cell assembly. The control
unit, cell assembly, and other accessories are easily portable due to their size, weight, and method by which they are
packed and transported. The  handheld control unit, cell assembly, and other pertinent accessories are transported in
a hard  pelican style case (approximately 36 cm by 25 cm by 15 cm). The portable control unit weighs approximately
700 grams and measures 10 cm by 18 cm by 4 cm.  The unit was easy to setup, and it can be taken anywhere by foot.
It operates on 110 or 220 volt AC current and also on a rechargeable NiMH battery power supply.

Durability:  The PDV 6000 was well designed and constructed  of durable plastic.  According to MTI, a conformal
coating on the instrument's electronics allows for unlimited  humidity range; however,  the laptop used to run the
voltammetric analysis system (VAS) software  should be kept dry. The cell assembly is also constructed of durable
plastic, and the cell assembly stand is constructed of metal.

Availability of the Device:  Per MTI, a stock of instrumentation will be available in the U.S. through the new MTI U.S.
operations.  Instruments will be available for purchase, rent, or lease and can be delivered within one week of order
placement. Spare parts and consumable supplies can be added to the original PDV  6000 order. Supplies not typically
provided by MTI (pipetters and a scale) are readily available from laboratory supply firms.

PERFORMANCE SUMMARY

In summary, during the demonstration, the PDV 6000 exhibited the following desirable characteristics of afield mercury
measurement device: (1) field  acceptable accuracy, (2) good precision, (3) good sensitivity compared to the PRGs, (4)
high sample throughput, (5) measurement costs comparable to laboratory analytical costs, (6) exceptional portability,
and (7) relative ease of use.  During the demonstration the PDV 6000 was found to have the following  limitations: (1)
sample digestion requiring nitric acid and hydrogen peroxide  and (2) generation of a secondary waste stream from
sample digestion.
  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

-------
                                              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 at a 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

-------
                                               Abstract


Mil's PDV 6000 was demonstrated under the U.S. Environmental Protection Agency Superfund Innovative Technology
Evaluation Program in June 2003 in Las Vegas, NV. The purpose of the demonstration was to collect reliable performance
and cost data for the PDV 6000. Four other field measurement devices for mercury in soil and sediment were evaluated
in May 2003 at the  Oak Ridge National Laboratory in Oak Ridge, TN.   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 (POL); 2) determine analytical accuracy associated with vendor field measurements; 3) evaluate the
precision of vendor field measurements using field samples and standard reference materials (SRMs); 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 fora 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 7471 B.

The sensitivity, accuracy, and  precision measurements were successfully completed. Results of these measurement
evaluations suggest that the MTI field instrument does not perform as well as the laboratory analytical method but does
provide a rough estimate of mercury concentrations in soils  and sediments  often suitable for field analysis. During the
demonstration, MTI required 38 hours for analysis of 197 samples.  The cost peranalysis, based  on measurement of 197
samples, when  incurring a minimum 1-month rental fee for the PDV 6000,  was determined to be $43.74  per sample.
Excluding the instrument rental cost, the cost for analyzing the 197 samples was determined to be $32.57  per sample.
Based on the 3-day field demonstration, the  total cost for equipment  rental and necessary supplies was estimated at
$8,600.

The PDV 6000 exhibited good ease of use and durability, as well as no major  health and safety concerns. However, there
is the potential for gas-producing reactions to occur during the digestion procedure used to prepare the samples.  MTI sells
kits, containing  extraction reagents and disposable supplies, for the analyses of samples. When  conducting a  large
number of analyses, purchase of bulk reagents and disposable supplies should be considered to reduce costs.
                                                   VIM

-------
                                               Contents
Notice	  ii
Verification Statement  	iii
Foreword  	  vii
Abstract  	viii
Contents	ix
Tables	  xii
Figures 	xiii
Abbreviations, Acronyms, and Symbols	xiv
Acknowledgments  	xvi

Chapter                                                                                               Page

1      Introduction 	  1
       1.1     Description ofthe 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 Chemistry  	  3
               1.3.2   Mercury Analysis	4

2      Technology Description	6
       2.1     Description of Anodic Stripping Voltammetry	6
       2.2     Description ofthe MTI PDV 6000	  7
       2.3     Developer Contact Information  	  8

3      Field  Sample Collection Locations and the 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
       3.3     Confidential Manufacturing Site	  11
               3.3.1   Site Description	  11
                                                     IX

-------
                                      Contents (Continued)
Chapter
              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

       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

       Assessment of Laboratory Quality Control  Measurements	  30
       5.1    Laboratory QA Summary	  30
       5.2    Data Quality Indicators for Mercury Analysis  	  30
       5.3    Conclusions and  Data Quality Limitations  	  31
       5.4    Audit Findings	  33

       Performance of the PDV 6000  	  34
       6.1    Primary Objectives	  35
              6.1.1    Sensitivity  	  35
              6.1.2    Accuracy	  37
              6.1.3    Precision 	44
              6.1.4    Time Required for Mercury Measurement 	48
              6.1.5    Cost	  50
       6.2    Secondary Objectives  	  50
              6.2.1    Ease of Use	  50
              6.2.2    Health and Safety Concerns	  53
              6.2.3    Portability of the Device	  53
              6.2.4    Instrument Durability	  54
              6.2.5    Availability of Vendor Instruments and Supplies	  54

       Economic Analysis  	  56
       7.1    Issues and  Assumptions  	  56
              7.1.1    Capital Equipment Cost	  56
              7.1.2    Cost of Supplies  	  57

-------
                                     Contents (Continued)
Chapter                                                                                          Page

              7.1.3   Support Equipment Cost	 57
              7.1.4   Labor Cost	 57
              7.1.5   Investigation-Derived Waste Disposal Cost 	 58
              7.1.6   Costs Not Included  	 59
       7.2     PDV 6000 Costs	 59
              7.2.1   Capital  Equipment	 59
              7.2.2   Cost of Supplies 	60
              7.2.3   Support Equipment	61
              7.2.4   Labor Cost	 62
              7.2.5   Investigation-Derived Waste Disposal Cost 	 62
              7.2.6   Summary of PDV 6000 Costs	62
       7.3     Typical Reference Method Costs	 64

8      Summary of Demonstration Results	65
       8.1     Primary Objectives	 65
       8.2     Secondary Objectives  	66

9      Bibliography	 69

Appendix A -   MTI Comments	 70
Appendix B -   Statistical Analysis 	 75
                                                  XI

-------
                                               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
2-1     Power Supply Options for the PDV 6000  	 8
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	 31
5-2     LCS Summary	 31
5-3     Precision Sum mary	 32
5-4     Low Check Standards	 32
6-1     Distribution of Samples Prepared for MTI and the Referee Laboratory  	 34
6-2     MTI SRM Comparison	 38
6-3     ALSI SRM Comparison	 38
6-4     Accuracy Evaluation by Hypothesis Testing 	 39
6-5     Number of Sample Lots Within Each %D Range  	42
6-6     Concentration of Non-Target Analytes 	42
6-7     Evaluation of Precision 	45
6-8     Time Measurements for MTI	49
7-1     Capital Cost Summary for the PDV 6000 	 60
7-2     Supplies Cost Summary, Using Preparation Kits  	61
7-3     Supplies Cost Summary, Preparing Reagents  	61
7-4     Labor Costs	 62
7-5     IDW Costs	 62
7-6     Summary of Purchase Costs for the PDV 6000 	63
7-7     PDV 6000  Costs by Category 	 64
8-1     Distribution of Samples Prepared for MTI and the Referee Laboratory  	 66
8-2     Summary of PDV 6000 Results for the Primary Objectives  	 67
8-3     Summary of PDV 6000 Results for the Secondary Objectives	68
A-1     Calibration Standard and Analysis  Information	 71
B-1     Unified Hypothesis Test Summary Information	 77
                                                   XII

-------
                                               Figures
2-1     PDV 6000 cell assembly	  7
2-2     Photograph of the PDV 6000 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 low concentration sample results	43
6-2     Data plot for medium concentration sample results  	43
6-3     Data plot for high concentration sample results  	44
6-4     PDV 6000 sample run log with open data windows  	  51
6-5     PDV 6000 sample graph screen	  52
6-6     PDV 6000 mercury graph for sample analyzed by method of standard additions  	  52
7-1     Capital equipment costs  	  60
                                                   XIII

-------
                         Abbreviations, Acronyms,  and Symbols
%             Percent
%D           Percent difference
°C            Degrees Celsius
|jg/kg         Microgram per kilogram
g/L           Gram per liter
AC           Alternating current
AAS          Atomic absorption spectroscopy
ALSI          Analytical Laboratory Services, Inc.
ASV          Anodic Stripping Voltammetry
bgs           Below ground surface
cm           Centimeter
CFR          Code of Federal Regulations
Cl            Confidence Interval
COC          Chain of Custody
DC           Direct current
Dl            Deionized (water)
DOE          Department of Energy
EPA          United States Environmental Protection Agency
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
MS/MSD       Matrix spike/matrix spike duplicate
MMT          Monitoring and Measurement Technology
MTI           Monitoring Technologies International
NERL         National Exposure Research Laboratory
                                                 XIV

-------
                 Abbreviations, Acronyms, and Symbols (Continued)
NiMH          Nickel metal halide
nm            Nanometer
ORD          Office of Research and Development
ORR          Oak Ridge Reservation
ORNL         Oak Ridge National Laboratory
OSWER       Office of Solid Waste and Emergency Response
PDV          Portable Digital Voltammeter
PPE          Personal protective equipment
ppb           Parts per billion
ppm          Parts per million
ppt            Parts per trillion
POL          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
VAS          Voltammetric analysis system
V             Volt
                                                 xv

-------
                                       Acknowledgments
The U.S. Environmental Protection Agency (EPA) Superfund 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 EnergyOak Ridge National Laboratory (ORNL); Stephen Chi Ids, 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; Felecia Owen and Colin Green of MTI, Inc.; 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

-------
                                              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 MTI's Portable Digital Voltammeter (PDV) 6000 anodic
stripping voltammetry instrument.  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) Program.
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 underwell-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 Officeof Solid Waste and Emergency
Response (OSWER)  and ORD  under the Superfund
Amendments and  Reauthorization Act of 1986.

The  overall goal  of  the  SITE Program is  to conduct
performance verification  studies and  to  promote  the
acceptance of innovative technologies that may be used to
achieve  long-term protection of human health and  the
environment. The program is designed to meetthree 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

-------
    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
    demonstrations 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), and 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 com panies 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 10 companies
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 demonstration, data
analysis, data interpretation, and preparation of the ITVRs.

-------
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 forthe 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.

    Selecta 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 asoil preparation laboratory
forhomogenization. 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 forachieving 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 by adding 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 forthe demonstration
is detailed in Chapter 4.

1.3    Mercury Chemistry and Analysis

1.3.1 Mercury Chemistry
Elemental mercury is  the only metal thatoccurs 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.

-------
 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 "C

-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+), elemental form (Hg°),
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 biotic 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 Cl'and
CO32".  Mercury (II) also forms complexes with inorganic
ligands such as fluoride (F~),  bromide (Br~),  iodide (I"),
sulfate (SO42"),  sulfide (S2~), and phosphate (PO43~) and
forms  strong complexes with  organic ligands, such as
sulfhydryl groups, amino acids, and humic and fulvicacids.
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.

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

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   0.5-100ppt
                      organo-mercury
                                    inorganic mercury
                                    organo-mercury
                                         0.5 - 200 ppt
                      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

-------
                                               Chapter 2
                                     Technology Description
This chapter provides a detailed description of 1) anodic
stripping voltammetry  (ASV),  which  is  the   type  of
technology on which Mil's instrument is based, and 2) a
detailed  description  of  the  actual  MTI  PDV  6000
instrument.

2.1     Description    of  Anodic    Stripping
        Voltammetry
The  principle of analysis  used by the MTI PDV 6000 is
ASV. ASV is a sensitive method that can be used for the
analysis of trace  concentrations  of metals in  solution,
including digestion solutions from metal-contaminated soils
and sediments. The method involves initially plating metals
onto an electrode  by applying a negative  voltage, then
stripping the metals back into solution  by applying a
positive voltage to the  electrode.  The ramping of  the
positive voltage generates a small but measurable current
(MTI, 2002).

The  ASV technique was first discovered in the  1920s by
Jaroslav Heyrovsky, who won the Nobel prize in 195 9 (MTI,
2002).   The technique  was  originally developed with a
hanging Hg drop electrode. However, to limit the quantity
of Hg needed, thin  Hg films can be pre-deposited onto an
electrode such as  glassy carbon, or co-deposited with the
analyte metal ions. With such films, sensitivities  in the low
part-per-billion (ppb) range can be achieved. A negative
potential is applied to the glassy carbon working electrode.
When  the  electrode potential  exceeds  the  ionization
potential of the analyte metal ion in solution (Mn+), it is
reduced to  the metal,  which  plates onto  the  working
electrode surface as follows:
                                    where: Mn+ = analyte metal ion in solution
                                           ne" = number of electrons
                                           M = metal plated onto the electrode

                                    The  first  step  of the process  is  referred  to as  the
                                    "deposition" or "accumulation" step.  This step involves
                                    concentrating the metal on the electrode. The longer the
                                    potential is applied, the more metal is reduced and plated
                                    onto  the surface of the electrode. The deposition time is
                                    predetermined.  When sufficient metal has  been plated
                                    onto  the working electrode, the metal is stripped (oxidized)
                                    off the electrode by applying, at a constant rate, a positive
                                    potential applied  to the working electrode.  For a  given
                                    electrolyte  solution and   electrode,  each metal  has a
                                    specific potential at which the following oxidation reaction
                                    will occur:
                                                       M
                        Mn++ ne'
Mn++
                               M
The electrons released by this process form a current. The
current is measured and may be plotted as a function of
the applied  potential  to give a "voltammogram."  The
currentat the oxidation orstripping potentialforthe analyte
metal is  seen  as a  peak.   To  calculate  the  sample
concentration, the peak height or area is measured and
compared to that of a  known standard solution under the
same conditions. As a metal is identified by the potential
at which oxidation occurs, a number of metals may often
be  determined   simultaneously  due to  their differing
oxidation potentials.

The  plating  step makes it  possible to  detect very  low
concentrations of metal in  the sample, and  laboratory
versions of an ASV device can measure concentrations in
the parts  per trillion (ppt) range.  The length of the plating
step can be varied to suit the analyte concentration of the
sample. For example, analysis of a 10-ppb solution of Pb

-------
may require a  3-5  minute  accumulation  step, while a
solution in the parts per million range would require less
than 1 minute.
2.2    Description of the MTI PDV 6000

The PDV 6000 Portable Analyzer is an instrument thatcan
be used for field screening or laboratory analysis of heavy
metal  ions  such as  silver,  arsenic,  gold,  cadmium,
chromium, copper, iron, mercury, manganese, nickel, lead,
tin, and zinc. The instrument  can be used for metal ion
detection in a wide variety of matrixes, including  chemicals,
materials, food,  beverages, water, industrial effluent, and
Pharmaceuticals.  The PDV 6000 consists of two major
components: 1) the main instrument control unit and 2) the
cell assembly. Figure 2-1  is a  schematic of the top of the
cell assembly. Within  the cell assembly, there are  three
separate  electrodes surrounding a stirrer motor.  The
reference electrode, found in the cell's assembly with the
other electrodes, is a critical component of the  PDV 6000.
                 CELL TOP
                                 Cell Connector
                                 to PDV 6000
Figure 2-1.  PDV 6000 eel I assembly.


Applications and Specifications - The  MTI PDV 6000
can be operated as a stand-alone instrument or attached
to  a laptop or desktop computer to run  accompanying
voltammetric analysis system (VAS) software.  The VAS
software incorporates features such as standard addition
calibration, simultaneous  multi-element analysis,  and
storage of data.  For stand-alone use,  the control unit is
programmed to analyze 10 metals in  the concentration
range of 10 ppb to 30 ppm.   According to MTI, the
stand-alone  unit  should  only  be  used for screening
purposes  (i.e., determining whether a  sample may be
above or below a particular threshold).

According to  MTI, the VAS software  allows for better
detection limits and  more accurate analysis.  A specific
electrolyte and electrode combination are used to optimize
results for specific metals.  This is essential for detection
limits in the low mg/kg range. Where the detection range
is in the g/kg range, it is possible to analyze a larger range
of metals per scan,  but the  reproducibility will be around
10%, as opposed to  the 3%  typically seen when optimum
conditions are used.   High silver concentrations  can
interfere with mercury determinations.

Operation - The PDV 6000 control unit is a hand-held
portable device, weighing approximately 700 g, and has a
dimension of 10 cm by 18 cm by 4 cm.  When used in the
field (Figure 2-2),  the PDV 6000 should only be used to
indicate the approximate concentration range of the metal
of interest.  This  is true for all field analysis  since many
factors can reduce  the accuracy  and precision of any
analysis.  (When used in the laboratory, the vendor reports
the  PDV 6000 can  provide accurate  and reproducible
data).  According to  MTI, it is realistic to expect the PDV
6000 to obtain data from the field that is within 20% of the
true value. For this reason, it is best to use the PDV 6000
to classify samples as "above a threshold concentration" or
"below a threshold concentration."
Figure 2-2. Photograph of the PDV 6000 during the field
demonstration.

-------
Certain  field  conditions may affect  the  accuracy and
precision of results.  These include the following:

    Sample homogeneity
    Sampling handling errors
    Pipetting errors
    Unpredictable matrix effects
    Sample and cell contamination

Essential Components and Supplies- Fortypical use as
a field instrument, the PDV 6000 is shipped with a carrying
case, the handheld  control unit, cell  assembly and cell
stand,  Ag/AgCI  reference electrode,  platinum counter
electrode, glassy carbon working electrode, cable to link
the analytical cell to the control unit, a  DB9 serial cable to
link the control unit to a computer, a reference electrode
plating accessory, a  main-powered  12 volt  (V)  direct
current (DC) supply, a nickel  metal halide (NiMH) battery
pack and battery pack charger, the PDV 6000 operation
manual, and VAS software installation disks and the VAS
User's Guide.

For solids analysis,  ancillary supplies  are  required  to
conduct extractions.  These  include a portable scale for
measuring the correct sample mass to extract; a set of air
displacement pipetters (50-500 uL,  100-1000 uL, and
200-1000 uL);  a repeating  pipetter  (0.5-50  ml_);  and
extraction reagents.   It is recommended that  kits  be
purchased  to  supply  the  extraction  reagents  and
disposable supplies (e.g., bottles) necessary to extract and
analyze the samples. To "digest" the solids, a slightly
modified  Method 3050B is used from EPA's Test Methods
for Evaluating Solid  Waste;  Physical/Chemical Methods
(SW-846).

Power Supply - The PDV 6000 can operate using either
a 110 V alternating current (AC) source or direct current
battery.   The  specific power  supply options for the PDV
6000, as presented in Table 2-1, affect the  number  of
analyses that may be performed on a daily basis.

 Table 2-1.  Power Supply Options for the PDV 6000
 Power Source	No. of Analyses	
 9VPP3                    10-20
 Rechargeable Battery Pack   50
 9V main power supply a	Continuous	
a      Main  power supply also  recharges the battery pack  and
       powers the reference electrode plating accessory.

Instrument Calibration - The standard  curve method
compares the sample response with that of one or more
known standards. Voltage  readings can allow calibration
curves of between  1-10 standards to be constructed and
then compared  with  up to  15  samples.   Generally,
calibration is based on a single pointcomparison, whereby
the voltage generated by the standard is compared to the
voltage generated  by the sample.  The response  for a
particular analyte is proportional to its concentration in the
analytical cell; therefore,  dilution  by electrolyte or  other
reagents  must  be  taken into consideration.   For  best
results, the sample concentration in the cell should be
close to the cell concentration of the standard with which it
is being compared. Standard addition calibration involves
analyzing a sample and then "spiking" the same sample
solution with a small volume of standard before reanalyzing
that solution.  The same sample can be  spiked  and
reanalyzed once or several  times, as necessary.   The
spiking enables the result to be calculated by the method
of standard additions.  The results from the sample and
spiked sample runs are then  plotted, and  a line of
regression  is fitted and  used to calculate  the sample
concentration.

VAS Software - The use of the  supplied VAS software
allows more flexible and accurate analyses, even in the
field. This software incorporates features such as multiple
point calibration curves or standard  addition calibration,
simultaneous  multi-element  analysis,  easy parameter
optimization and   manual baseline,  and  peak center
adjustment.  It also stores data, and allows comments to
be added about the sample location and a description of
the sample.  The VAS software requires a computer that
has a minimum specification of a  300 Mhz 586 processor
(Pentium or equivalent), 64 MB RAM, 10 MB of free hard
disk space, and runs Windows 98, ME, NT, 2000, or XP.

2.3   Developer Contact Information

Additionalinformation aboutthe PDV6000can be obtained
from the following source:

International Contact
Monitoring Technologies International Pty. Ltd.
1/7 Collingwood Street
Osborne Park, Perth
West Australia 6017
Internet email: support@mti.com.au
Web address: www.monitoring-technologies.com.

U.S. Contact
Felicia Owen, MTI Inc.
1609 Ebb Drive
Wilmington, NC 28409
Telephone:(910)392-5714   Fax:(910)392-4320
email: fowen@owenscientific.com

-------
                                              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 preparedfrom 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.

-------
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 -9m bgs
1.5-1.8 m 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
10 ppb - 50 ppm
10 ppb- 1,000 ppm
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 presentat the former gold and
silvermining  mill sites; waterways adjacentto the millsites;
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 presentat, 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, local terrain,
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

-------
sealable 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) adjacent to the city of
Oak  Ridge, TN.  Built in 1 943 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, as partof 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 sealable 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

-------
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
Geoprobe® 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 mixing. 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 0.15 m along the site perimeter to 3 m 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.
                                                    12

-------
    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 percentsediment 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
materialwere  collected in a similarmanner. 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 36°N,
the longitude 35°W, 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

-------
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

-------
                                                  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  and in  Las Vegas in
June 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  in  order  that  potential
                                  technology users have  adequate information needed  to
                                  make   sound  judgements   regarding  an   innovative
                                  technology's applicability to a specific site and to be able 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 vendorfield 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

-------
Critical data support primary objectives and non critical data
support  secondary objectives. With the exception of the
cost information, primary objectives required the use of
quantitative  results to  draw conclusions regarding the
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
Objectives
Addressing  Primary
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 vendorand 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 Chapter 6.

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 (IDL), a method detection
limit  (MDL),  and as a practical quantitation limit  (PQL).
MDL is not a measure of sensitivity in the same respect as
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 at which an individualfield 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 a 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_1?099) =
                                                                 MDL = Vi.o.Q9)s
                                                   99  percentile 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

-------
concentration  samples or  SRMs.   The evaluation  of
vendor-reported   results   for  the  PQL   included  a
determination of the percent difference (%D) between their
calculated  value  and  true  value.  The true value  is
considered the value defined by the referee laboratory for
field samples or spiked field samples,  or, in the  case of
SRMs, the certified value reported  by the supplier.  The
equation used for the %D calculation is:
%D =!.
                         ' calculated
                                 x100
                        'true
where: Ctri
        'calculated "
        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  MTI field instrument.
Samples representing  all  three  standard  types were
prepared at the SAIC GeoMechanics Laboratory.  In order
to preventcross contamination, 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 usedforcomparison 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 the demonstration, the referee
laboratory analyzed  SRMs  as  an ongoing  check for
laboratory bias.

Evaluation ofvendorand 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:
                                                           l(n-1.0.975)
                                                                     .3
                                         where: t(n_..
                                                 '(n-1,0.975)
                      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 that shows the percentage of vendor-
                                         reported measurements thatare within a specified window
                                         of the reference value.  For example, a distribution within
                                         a 30% window of a reported concentration, within a 50%
                                                    17

-------
window,  and  outside  a 50%  window  of a  reported
concentration.  This distribution aspect could be reported
as average concentrations of replicate results  from the
vendorfora 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 for this 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 ofvariable 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 test was 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 orconcentration were made in order to
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 as RSD.
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 otherattributes such as cost or ease of use
that  defined  specific  attributes  of  their technology).
Because of this fact, not all vendors analyzed the same
samples.

During  the demonstration, the vendor's instrument 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 laboratory measured replicates of all samples.
The results were used for  precision  comparisons to the
individual  vendor.  The  RSD for the vendor and the
laboratory was calculated  individually, using the following
equation:

                       $
               %RSD = -x100
                                                    18

-------
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 com parisons
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
sedimentsamples 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 lists for purchasing, renting, or leasing each field
    measurement device.  If the device was purchased,
   the capital  cost estimate did not  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 or other 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 supplycosts 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

-------
    solvent, glassware,  pipettes, spatulas, agitators, and
    similar materials.  The type and quantity of all supplies
    broughtto 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 increased, the initial capital  costs and certain
other costs were distributed across a greater number of
samples. Therefore, the per unit cost decreased. For this
reason, two costs were reported: 1) the initial capital costs
and 2) the operating costs per analysis. No com parison 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 demonstration. 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 met 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
observerwas assigned to independently evaluate onlythe
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
, , . . Secondary Objective # 1
Information Ease of Use
- Vendor Name - No. of Operators
- Observer Name - Operator Names/Titles
- Instrument Type - Operator Training
- Instrument Name - Training References
- Model No. - Instrument Setup Time
- Serial No. - 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

-------
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 weightof 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 Prepara tion

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
Project Plan (SAIC, August 2003,  EPA/600/R-03/053).
Figure 4-1 summarizes the homogenization steps of the
SOP, beginning with sample mixing. This procedure was
                                                    21

-------
used   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
hinderhomogenization. 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
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.
Table 4-3.  Field Samples Collected from the Four Sites

                     No. of Samples / Matrices
 Field Site             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
12 L each for sediment
12 L each for sediment
4 L each for soil
4 L each
1 2 L each
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. A subsample 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 slurryas 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  waterfrom 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

-------
      1
 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)
                                                \             /
                   Transfer cut
                    sections to
                   20 mL vials
                                              TEFLON SURFACE
I                                                             Elongated
                                                           octangular pile
                                                           (from 6* split)
                                                   Sample aliquots made
                                                     by transverse cuts
                                                    across sample piles
                  1
                                  Samples shipped @ 4 °C to
                                   referee lab and Oak Ridge
                                       (Container numbers will vary)
Figure 4-1. Test sample preparation at the SAIC GeoMecharries Laboratory.
                                           23

-------
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 Chapter 6.

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  a known concentration  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 a  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 manner 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 accuracyof 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  °C.   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 aliquots for 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 for analysis, the sample size sent to
all participants was a 20-mL  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,  and
        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

-------
measurement ranges for mercury detection, not all vendors
received  samples  from  the same field material.   All
samples were stored in an ice cooler prior to 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
it 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 forsamples 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 forthe 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 the above considerations, itwas determined that
SW-846  Method  7471B [analysis of mercury in  solid
samples by  cold-vapor 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.
These laboratories received and analyzed blind samples
                                                   25

-------
and SRMs 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 the SAIC
QA Manager at the remaining two candidate laboratories.
Results of the SRM samples were compared for the two
laboratories. Each laboratory analyzed each sample (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% Cl 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 ug/kg, but it was uncertain at the time if this limit
was actually a PQLora detection limit). Therefore, it was
determined that,  if necessary, the laboratory  actually
should be able to achieve even alowerPQL than 10 ug/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 partof 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.

Other QC-related  issues  examined  during  the audits
included 1) analyses of otherSRM samples not previously
examined, 2) laboratory control charts, and 3) precision
                                                    26

-------
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 aliquot sizes 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 ug/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
proceduresforsubsampling, 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 7471 B,
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
positioned in the light path of the AA spectrophotometer.
Absorbance (peak height) is measured  as a function  of
mercury concentration.  Potassium permanganate is added
                                                    27

-------
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 had 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 °C 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 °C.  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   for   Non-Critical
        Measurements.

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
constituency of 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
EPA 2540G
n-Hexane
extraction,
Gravimetric
analysis
Carbonaceous
analyzer
Gravimetric
4.5
Deviations
Plan
from  the  Demonstration
Three deviations to the demonstration plan occurred. The
first was that the demonstration was to be conducted in
Oak Ridge, TN, on May 5-8, 2003. On the morning of May
6,  MTI was able to confirm,  through  the  analyses of
standards,  that the obtained results  were erroneous.
While several  possibilities existed as to why erroneous
results were being generated, the exact reason could not
be determined  and corrected  in time to complete  the
analyses  during the scheduled demonstration.   Several
discussions ensued  between  the  EPA  TOM,  SAIC
personnel on-site, and MTI personnel.  These discussions
resulted in an agreement that if the cause of the erroneous
results could be identified and a new location and date
could  be  arranged, then MTI would be given a second
attempt at the demonstration.

During the following weeks, MTI traced the source of the
problem to  disposable beakers that  were  used in  the
analyses.   The  beakers had  an  oil film  in them that
gradually coated  the electrodes,  preventing  accurate
readings. In order to correct the problem, MTI disposed of
the beakers in stock, and added to the operating procedure
a sodium hydroxide rinse between samples that prevented
the buildup  of residues on the electrodes.

While in Oak Ridge, MTI only received samples from the
Oak Ridge sampling site. None of the results from this first
demonstration are presented ordiscussed in this ITVR. All
samples were collected from MTI and returned to the SAIC
GeoMechanics Laboratoryforstorage purposes.  Samples
                                                    28

-------
that were opened by MTI were replaced with unopened
sample bottles held in reserve by SAIC, when available.

The second demonstration for MTI was held in Las Vegas,
NV, June 14-17, 2003.

A second and third deviation occurred in the distribution of
the samples (second deviation) and an unforeseen and
unrelated emergency (third deviation).  The intent in the
demonstration plan was to give the samples from one
sampling site to the vendors  and, when that sample set
was completed, the next sample set would be given to the
vendor.  This process was repeated until all four  sample
sets were completed by the vendor.  MTI's two personnel
on-site divided the workload into two parts.  The first
individual extracted the samples and  the second individual
analyzed the samples with the PDV  6000.   When  the
extraction of the first set of samples was completed, the
second set of samples was given to MTI for extraction.
The extraction was faster than the analysis; therefore, the
first individual completed all of the extractions in two days.
The second individual completed the analyses  in three
days.  This  was complicated by an unrelated emergency,
which prevented any work from being performed on the
third day at the site; therefore, no sample preparation or
analyses were performed on June 16. All samples were
prepared June 14-15.  Sample  analyses were completed
June 14, 15, and  17.   MTI  personnel are unsure as to
whether the one  day  delay would  have any effect  on
results; however,  it is  common practice to  analyze  low
concentration mercury  samples as soon as possible upon
preparation.
                                                   29

-------
                                             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:

          (Maximum Value - Minimum Value)
         (Maximum Value -(-Minimum Value)/2

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=
                          C
                              x100
where,

       Css    =      Analyte concentration  in spiked
                     sample
       Cus    =      Analyte concentration in unspiked
                     sample
       Csa    =      Analyte concentration  added to
                     sample

Laboratory control  samples (LCSs)  were used as  an
additional measure of accuracy in the event of significant
                                                   30

-------
matrix interference. To determine the percent recovery of
LCS analyses, the equation below was used:
         „,,_.   Measured Concentration   .__
         %R =	xi 00
              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
aliquoting 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 lotanalysis 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    and   Data     Quality
        Limitations
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 fa II within specifications. The
MS/MSD 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 accuracywas 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
                                                    31

-------
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/MS D RPD Range
Number of Duplicate Pairs
Average MS/MSD RPD
No. of Pairs Outside QC
Specifications
RPD<
0.0%
23
5.7%
2
20%
to 25%



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, comparabilityand 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 were achieved 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.  Veryfew
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 for every 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 appropriatelyand dry weights
reported  when  required.  All of  these QC checks met
                                                     32

-------
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
The SAIC 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 con ducted 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.
                                                     33

-------
                                              Chapter 6
                                 Performance of the PDV 6000
MTI analyzed samples on May 5-6, 2003 in Oak Ridge, TN.
As discussed in Section 4.5, on the morning of May 6, MTI
determined through  the  analyses of standards  that the
results they were  obtaining were erroneous.  A second
demonstration was performed in Las Vegas from June 14-
17, 2003, and  it proved successful in accomplishing the
specified objectives.  The observations conducted as part
of this second attempt at the demonstration were reviewed,
and the primary and secondary objectives were completed.
The  results of the  primary and secondary objectives,
identified in Chapter  1, are discussed in Sections 6.1 and
6.2, respectively.

Due  to an  unrelated  emergency during  the  second
demonstration, analysis  activities  were  not able  to be
performed  on June 16.  For this reason, samples that were
analyzed on June  17 had been extracted on June 15, and
stored  in plastic  bottles.  This may have resulted in a
reduced mercury concentration in the extract, especially for
                                  low concentration  samples.  The extracts that remained
                                  for  analysis on June  17 were from  low concentration
                                  samples.   There was,  however, no additional  study
                                  performed to determine if time elapsed between extraction
                                  and analysis influenced mercury concentrations, and it is
                                  believed that this short time  period was not significant in
                                  the overall evaluation of results.

                                  The distribution of the samples prepared for MTI and the
                                  referee laboratory is presented  in Table 6-1. From the four
                                  sites, MTI received samples at 36 different concentrations
                                  for a total of 197 samples. These 197 samples consisted
                                  of 22 concentrations in replicates of 7,13 concentrations in
                                  replicates  of 3, and  1  concentration in a replicate  of 4.
                                  Although all these samples were analyzed by MTI, a few
                                  samples were  not used as part of the  evaluation. Some
                                  sample results were judged invalid by MTI field personnel
                                  and some were found to be below MTI's detection limit, as
                                  explained in more detail in the following sections.
Table 6-1. Distribution of Samples Prepared for MTI and the Referee Laboratory
       Site
Concentration Range
                                              Soil
       Sample Type
Sediment       Spiked Soil
                                                                          SRM
Carson River
(Subtotal = 48)
Puget Sound
(Subtotal = 51)
Oak Ridge
(Subtotal = 54)
Manufacturing
(Subtotal = 44)
Subtotal
(Total = 197)
Low(1-500ppb)
Mid (0.5-50 ppm)
Hiqh(50->1,000ppm)
Low (1 ppb - 10 ppm)
Hiqh (10-500 ppm)
Low (0.1 -10 ppm)
Hiqh (10-800 ppm)
General (5-1,000 ppm)

3
0
0
13
0
0
13
23
52
10
0
0
0
10
3
10
0
33
7
0
7
7
7
0
0
7
35
0
7
14
3
11
14
14
14
77
                                                   34

-------
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 measurements are explained in the paragraphs
below,  along with a comparison to the referee laboratory.
These determinations setthe standard forthe evaluation of
accuracy and precision for the MTI field instrument.  Any
sample analyzed by MTI and subsequently reported as
below their level of detection  was not used as part of any
additional evaluations.   This was done because of the
expectation that values below the  lower limit of instrument
sensitivity would not reflect the true instrument accuracy
and precision.

The sensitivity measurements of  MDL and  PQL are  both
dependent upon the matrix and method. Hence, the  MDL
and PQL will vary, depending  upon whetherthe 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 they 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
accuracyand precision. This is often defined by the lowest
point on the calibration curve. Our approach was to let the
vendor provide the lower limit of quantitation as determined
by their particular standard operating procedure, and then
test this limit by comparing  results of samples analyzed at
this low concentration to the referee laboratory results,  or
comparing the results to a  standard reference material, if
available.   Comparison of  these data are,  therefore,
presented for the lowest concentration 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, the sample(s) 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 forseven 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 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 determined or implied.

Several blind standards and field samples were provided to
MTI at their estimated lower limit of sensitivity.  The MTI
lower limit of sensitivity was  previously estimated at 0.100
mg/kg. Because  there a re several different SRM sand fie Id
samples at concentrations close to the MDL, evaluation of
the MDL  was  performed  using  more  than  a  single
concentration. Samples chosen forcalculation 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 MTI 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.

Seven replicates were analyzed by MTI of a sample for
which the laboratory reported an average concentration of
0.734 mg/kg.  (Sample lot 57 from the Puget Sound site.)
The average concentration reported  by MTI forth is sample
was  1.58  mg/kg, and the standard deviation  was  1.17
mg/kg.  An SRM with a  reference  value  of 0.62  mg/kg
(sample lot 38) was analyzed seven times by MTI, with a
reported  average concentration  of 2.71  mg/kg  and a
standard deviation  of 0.632 mg/kg.  Calculations of the
respective MDLs based upon each of these standards are
3.67  and 1.99 mg/kg.

As a further check of the  MDL, both MTI  and the referee
laboratory analyzed sample lot 56 from the Carson River
samples.  The  referee laboratory  reported  an average
concentration of 0.231  mg/kg, and MTI  reported "non-
detect" for 6 of 7 replicates analyzed.  This confirms that
the MTI  field  instrument sensitivity  is above this sample
concentration.   The  referee   laboratory  reported  a
concentration of  0.811 mg/kg for  sample  lot  11 (from the
Puget Sound samples), while  MTI  reported an average
concentration of  3.15 mg/kg for three replicate analyses,
with  a standard  deviation of 1.96 mg/kg.  Therefore, it
appears that the method detection limit for this instrument
                                                    35

-------
is between 0.231 and 0.811 mg/kg. Also, based on results
from sample lots 57 and 38 (noted  above in  the  MDL
calculation), there is  additional  evidence that sample
concentrations in this  range can be detected but not
accurately quantitated by the MTI field instrument.  The
referee laboratory reported an average value of 0.06 mg/kg
for sample  lot 2 from the Puget Sound site, while the MTI
average value for seven separate results was 1.61 mg/kg,
with  a standard deviation of 0.534 mg/kg. While this is 2
orders of magnitude above the  value reported by the
referee laboratory, it does indicate that, for this sample,
MTI was able to  detect a much lower concentration than
indicated by the MDL calculations noted above. Therefore,
MTI  instrumentation is sometimes  able  to detect lower
concentrations  of mercury,  but this  appears to  be
inconsistent based on the results for sample lot 56 (referee
laboratory measured value of 0.231 mg/kg) that resulted
primarily in reported data as  "non-detects."  This apparent
difference in the  MDL is probably attributable to the fact
that, when analyzing  samples on  the PDV 6000, the
operator selects a concentration, based upon the expected
sample  set concentration  range, and   prepares and
analyzes a  standard at the selected concentration.

The  MDL  is  between  1.67 and  3.67  mg/kg.   This
calculation,  however,   did  not  prove   accurate  for
instrument/method sensitivity.  As noted  by  the results
above,  the  MTI  field  instrument  was  able  to detect
concentrations well below this calculated value.  It should
be noted, however, that in one  sample   MTI  detected
mercury  at 0.06  mg/kg (as  determined  by the referee
laboratory result), but in  another sample it was  unable to
detect mercury at 0.231 mg/kg.   The  reason for this
discrepancy is unknown. It should be concluded, however,
that values  below 0.811 mg/kg may or may not be detected
by the MTI field instrument and that these  values,  if
detected, would likely be  highly inaccurate and should only
be considered  as a "positive hit"  and  do  not represent a
value that is close to the true concentration.

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 PQL
estimation, however, is method- and matrix- dependent. In
order to determine the PQL, several low  standards  were
provided to MTI and subsequent %Ds were calculated.

The  lower  limit of sensitivity previously provided by the
vendor (0.10 mg/kg) appears to be an inaccurate estimate
of instrument sensitivity, but, as noted above, sometimes
the MTI field instrument may be able to detect values close
to this lower concentration.   If one considers  the  MDL
around 0.8 mg/kg, then the PQL could be between 4 and
8 mg/kg.   This,  however, is only an estimate.  The
relationship between sensitivity and precision is  such that
the  lower the  concentration, the higher the  variation in
reported sample results. The PQL should have a precision
and accuracy that match the instrument capabilities within
a certain operating range of analysis.

Values in the range between 4 and 8 mg/kg were chosen
for estimating  the PQL and associated  %D  between the
MTI 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.  In  addition, values below the
estimated value of 4 mg/kg are included to determine if the
instrument capabilities can provide an even lower PQL.

Sample lot 14  (Oak  Ridge site) has an  average value of
4.75 mg/kg reported  by the  referee laboratory,  with  a
standard  deviation of  1.31 mg/kg.  The 95% Cl for this
sample is 3.38 to 6.12 mg/kg. The MTI average value is
6.95 mg/kg, which is just outside the range of the 95% Cl.
The %D  between this value and that obtained  from the
referee laboratory is 46.3%.

Sample  lot 57 (Puget Sound) has an average value of
0.734 mg/kg reported  by the  referee laboratory, with   a
standard  deviation of 0.119 mg/kg. The 95% Cl for this
sample is 0.624 to 0.844 mg/kg.  The MTI average value
is 1.58 mg/kg,  which is outside the range of the 95% Cl.
The  %D   between  this value and that of  the referee
laboratory is 115%.

These results  suggest that the  instrument  PQL is 4-8
mg/kg.  Given the information associated with  the  MDL
determination,  the PQL is probably above the MDL range
noted previously as between 1.67 and 3.67 mg/kg.

Sensitivity Summary

The low standard calculations suggest that a PQL for the
MTI field  instrument is 4-8 mg/kg.  The referee laboratory
PQL confirmed during the demonstration is 0.005 mg/kg.
The  %D  for  the average  MTI  result for  the sample
concentration of 4.75 mg/kg is 46%.  The range for the
calculated MDL is between 1.67 and 3.67 mg/kg,  based on
the results of seven replicate analyses for low standards.
The equivalent MDL for the referee laboratory is  0.0026
mg/kg.   The  MDL  determination, however,  is  only a
statistical  calculation that has been used  in the past by
EPA and  is currently not considered a "true" MDL by
                                                    36

-------
SW-846  methodology.    SW-846  is  suggesting  that
performance-based methods be used and that PQLs be
determined using low standard calculations.

More  definitive information for the  PQL is unavailable
because additional standards in the calculated range of the
PQL are  not available. Vendor estimations of the PQL
were  actually  much  lower  than determined  during the
demonstration; therefore, several lower standards below
Mil's PQL were provided for analysis (see accuracy tables
below) and subsequently, additional standards orsamples
in the actual PQL range were not tested.

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 concentration 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 different SRMs analyzed by both the vendorand the
laboratory, for a total of 53 data points by the vendor and
63 data points by the laboratory. One SRM (sample lot 44)
was not included because 6 of 7 analyses performed by the
vendor were judged to be invalid, and  this would  not
provide a sufficient number of analyses for comparison.

The second accuracy determination used a comparison of
vendor results of field samples and SRMs to the referee
laboratory results for these same sam pies. Field samples
were used to ensure that "real-world" samples were tested
for  each  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 about this statistical comparison is included in
Appendix B.)

It should be noted that a laboratory bias is evident. 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 32 sample lots.  (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 in
the same manner as the other field  samples. Spikes were
prepared to cover additional concentrations 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
order to ensure that a competent laboratory would be used
for the demonstration.  The pre-demonstration laboratory
qualification  showed  that the  laboratory  was  within
                                                    37

-------
prediction intervals for all SRMs analyzed.  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).

Evaluation of vendor and laboratory analysis of SRMs is
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 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 for the 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.    The
percentage of total results within the prediction interval for
the vendor and laboratory are reported in Tables 6-2 and
6-3, respectively.
Table 6-2.  MTI SRM Comparison
Sample
No.
Lot SRM Value/
95% Cl
MTI Avg./95%CI
Cl Overlap
(yes/no)
No. of 95% Prediction
Samples Interval
Analyzed












a
b
37
35
48
50
38
53
54
49
52



0.158/0.132-0.184
0.017/0.010-0.024
77.8/71.5-84.0
203 / 183-223"
0.62/0.61 -0.63b
910/821 -999b
1120/1009- 1231 b
99.8/81.9- 118
608 / 490- 726 b
Total Samples
% of samples w/in
prediction interval
2.12/0.767-3.47
1.11/0-2.87
62.6/20.9-104
188 / 121 -255
2.71 / 2.05 -3.37
323 / 253 - 393
733/511 -955
123/90.8- 155
390/270-510



Prediction interval is estimated based upon n=30. A 95% Cl

Cl is estimated based upon n=30.
A 95% prediction interval
no
yes
yes
yes
no
no
no
ves
ves



was provided
was provided
6
3
3
7
6
7
7
7
7
53


by the SRM
by the SRM
0
0
45.6
97.4
0.54
437
582
31.3
292



- 0.357
-0.0358s
-110
-308
-0.70
- 1380
- 1701
- 168
-924



MTI No. w/in
Prediction
Interval
0
1
2
7
0
1
5
7
5
28
53%

supplier but no prediction interval was given.
supplier but no
Cl was given.

Table 6-3.  ALSI SRM Comparison
Sample
No.












a
b
37
35
48
50
38
53
54
49
52



Lot SRM Value/
95% Cl
0.158/0.132-0.184
0.017/0.010-0.024
77.8/71.5-84.0
203/183-223b
0.62/0.61 -0.636
910/821 -999b
1120/ 1009- 1231 b
99.8/81.9- 118
608 / 490 - 726 b
Total Samples
% of samples w/in
prediction interval
ALSI Avg./ 95% Cl
0.139/0.093-0.185
Cl No. of 95% Prediction
Overlap Samples Interval
(ves/no) Analyzed
yes
0.00874/0.00782-0.00966 no
82.9/56.7- 109
167 / 140- 194
0.533 / 0.502 - 0.564
484 / 325 - 643
71 1 / 552 - 870
84.2/74.5-93.9
424/338-510



Prediction interval is estimated based upon n=30. A 95% Cl

Cl is estimated based upon n=30.
A 95% prediction interval
yes
yes
no
no
no
ves
ves



was provided
was provided
7
7
7
7
7
7
7
7
7
63


by the SRM
by the SRM
0-0.357
0 - 0.0358 "
45.6- 110
97.4 - 308
0.54 - 0.70
437 - 1380
582 - 1701
31.3- 168
292 - 924



supplier but no prediction
ALSI No. w/in
Prediction
Interval
7
7
5
7
7
4
5
7
7
56
89%

interval was given.
supplier but no Cl was given.
                                                     38

-------
The single most importantnumberfrom these tables is the
percentage of samples within the 95% prediction interval.
As noted for the MTI data, this percentage is only 53% with
n = 53.  As seen from  the tabulated data, average results
for MTI  fall evenly both  above and  below the reference
value. (Four results are above and five results are below.)
This  would suggest that  there is no particular high  or low
bias.

SRM values  of  0.017,  0.158,  and  0.62  mg/kg show a
percent difference between  the  MTI  result  and  the
reference value  greater than  300%, indicating  that MTI
results in  this range  are not accurate.   The sensitivity
evaluation  suggested  that  the  MTI   PQL  may   be
somewhere between 4 and  8 mg/kg. If these results are
not included in the  accuracy evaluation,  27 of 38, or 71%,
of the   MTI results are within  the prediction  interval.
(Considerably greater  than the 53%  noted for all results.)
Also, 25 of these 38 samples, or 66%, are within 50% of
the SRM reference value, and 16 of these 38 samples or

Table 6-4. Accuracy Evaluation by Hypothesis Testing
42% are within 30% of the SRM value. Therefore, there is
a correlation with accuracy and concentration, at least for
the very low concentrations.

The  percentage of samples  within the 95%  prediction
interval for the laboratory data  is 89% with n = 63. For 8 of
the 9 different SRMs, ALSI average results are below the
reference value. This would suggest that the ALSI data are
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 (63) 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 6-4), 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.
Sample Lot No./ Site
14/ Oak Ridge
MTI
ALSI
21/ Oak Ridge
MTI
ALSI
221 Oak Ridge
MTI
ALSI
241 Oak Ridge
MTI
ALSI
261 Oak Ridge
MTI
ALSI
31/Oak Ridge
MTI
ALSI
37/Oak Ridge
MTI
ALSI
67/Oak Ridge
MTI
ALSI
02/Puget Sound
MTI
ALSI
05/Puget Sound
MTI
ALSI
11/Puget Sound
MTI
ALSI
Avg. Cone.
mg/kg
6.95
4.75
38.3
11.2
65.9
81.6
212
221
147
77.0
1211
947
2.12
0.14
1203
835
1.61
0.06
1.87
0.21
3.15
0.81
RSD or CV
37.5%
27.5%
118%
23.8%
31.1%
9.44%
22.7%
44.8%
56.4%
13.2%
12.9%
13.2%
60.8%
36.4%
5.1%
14.8%
33.2%
23.6%
9.8%
33.3%
62.3%
32.7%
Number of
Measurements
3
7
3
3
3
3
7
7
7
7
3
3
6
7
6
7
7
4
3
2
3
7
Significantly Different at
Alpha = 0.01
no

no

no

no

no

no

no

no

yes

yes

no

Relative Percent
Difference (MTI to
ALSI)
38.7%

109 %

-21.2%

-4.2%

62.8%

24.5%

175%

36.1%

174%

160%

118%

                                                     39

-------
Table 6-4.  Continued
Sample Lot No./ Site
25/Puget Sound
MTI
ALSI
27/Puget Sound
MTI
ALSI
35/Puget Sound
MTI
ALSI
48/Puget Sound
MTI
ALSI
50/Puget Sound
MTI
ALSI
57/Puget Sound
MTI
ALSI
62/Puget Sound
MTI
ALSI
04/Carson River
MTI
ALSI
38/Carson River
MTI
ALSI
53/Carson River
MTI
ALSI
54/Carson River
MTI
ALSI
63/Carson River
MTI
ALSI
1 //Manufacturing Site
MTI
ALSI
20/Manufacturing Site
MTI
ALSI
32/Manufacturing Site
MTI
ALSI
33/Manufacturing Site
MTI
ALSI
49/Manufacturing Site
MTI
ALSI
52/Manufacturing Site
MTI
ALSI
66/Manufacturing Site
MTI
ALSI
Avg. Cone.
mg/kg
56.6
16.6
76.7
45.7
1.61
0.009
62.6
82.9
188
167
1.58
0.73
27.6
14.6

0.29
0.11
2.71
0.53

323
484

733
711

230
169
13.4
10.5
53.2
63.9
876
592
1048
1204
123
84.2
390
424
949
892
RSD or CV
70.9%
12.3%
25.5%
22.2%
1 1 .4%
6.3%
26.8%
34.2%
38.2%
17.7%
74.1%
16.2%
21.1%
28.3%

56.0%
9.1%
23.5%
6.2%

23.5%
35.5%

32.7%
21.0%

34.8%
6.6%
16.9%
14.6%
20.9%
25.3%
40.2%
12.7%
36.6%
13.3%
28.2%
12.5%
33.1%
21.9%
26.6%
11.2%
Number of
Measurements
3
3
7
7
3
7
3
7
7
7
6
7
7
7

3
7
6
7

7
7

7
7

7
7
2
7
7
7
7
7
6
7
7
7
7
7
6
7
Significantly Different at
Alpha = 0.01
no

yes

yes

no

no

no

yes

no


yes

no


no


no


no

no

no

no

no

no

no

Relative Percent
Difference (MTI to
ALSI)
109%

50.6%

198%

-27.9%

73.3%

73.6%

61 .6%

90%


134%

-39.9%


3.0%


30.6%


24.3%

-18.3%

38.7%

-13.8%

37.5%

-8.4%

6.2%

CV = Coefficient of variance
                                                         40

-------
Hypothesis Testing

Sample results from field and spiked field samples for the
vendor com pared to sim ilar 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 were compared  to  laboratory results to
determine  if  sample  populations   are  the  same  or
significantly different. This was performed for each sample
lotseparately. Because this comparison doesnotseparate
precision from bias, if MTI's or ALSI's computed standard
deviation was  large  due  to  a  highly variable result
(indication of poor  precision), the two CIs could overlap.
Therefore, the fact that  there was no significant difference
between the  two results could be  due to  high  sample
variability. Accordingly, associated RSDs have also been
reported in Table 6-4, along with results of the hypothesis
testing for each sample lot.

Of the 31 sample lots (including results below 8 mg/kg), 6
results  are  significantly  different,  based  upon   the
hypothesis test noted above.  Of these six results, four are
at concentrations of 0.5 mg/kg, or less. This is due to the
inability of the MTI field  instrument to accurately measure
results  in this   low range,  as  was noted  previously.
Therefore, only two results  within the range  of the MTI
analysis  capability  are significantly different than  the
laboratory results. This suggests that there is no difference
between these two data sets.

The most striking feature of the information in Table 6-4 is
the high variability in reported RSDs for the MTI data.  This
high variability  is a major reason that  the  comparison
between vendor and referee laboratory data are not found
to be different. Discounting the results that are too low to
accurately  quantitate,  there  appears  to  be very  little
difference between MTI and  referee laboratory data. It is
not, however, a  result  of the MTI instrument accurately
determining sample concentrations. As was  noted in the
discussion of SRMs, the MTI  field analysis was successful
at measuring accurate  concentrations of mercury  only
about 50%  of the  time.  The  increased similarity noted
between MTI and the laboratory is a result of the inability of
the hypothesis test to note a difference between the two
results when sample variability is high.

Most of the relative percent differences are positive, which
indicates that the MTI 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 MTI results that are less than the laboratory result;
therefore, no overall MTI high or low bias is apparent.  It
appears  that  MTI  data are  subject to  more  random
variability.

In determining the number of results significantly above  or
below the  value reported by the referee laboratory, only 6
of 21  MTI  average results  were found to have relative
percent  differences  greater  than  50%  for  sample
concentrations above the estimated PQLof 8 mg/kg.  Only
2  of  21  MTI  average  results have relative  percent
differences greater than 100% for this same  group  of
samples (see Table 6-5). Interferences may be a problem
but, because of the random  variability associated with the
data, no interferences are specifically apparent from the
data collected.  Table 6-6 shows the results of additional
data collected for these same  samples.

In  addition to the statistical summary presented above,
data plots (Figures 6-1, 6-2,  and 6-3) are included in order
to  present a visual interpretation of the accuracy. Three
separate plots have been includedforthe MTI data. These
three plots are divided based  upon sample concentration
in   order  to   provide  a  more  detailed  presentation.
Concentrations of  samples  analyzed by  MTI ranged
approximately from  0.01 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  MTI field instrument.  This
graphical presentation presents all data points.  It shows
MTI 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
MTI below about 50 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, ltdoes, however,
provide a visual interpretation that  supports the previous
statistical results for accuracy, as presented above.
                                                     41

-------
Table 6-5.  Number of Sample Lots Within Each %D Range
                        <30%           >30%, <50%
>50%, <100%
>100%
                                      Total
Positive %D
Negative %D
Total
4
6
10

4
1
5
4
0
4
2
0
2


14
7
21

Only those sample lots with the average result greater than the PQL are tabulated.
Table 6-6. Concentration (in mg/kg) of Non-Target Analytes
Lot # Site
1 Carson River
2 Puget Sound
4 Carson River
5 Puget Sound
6 Carson River
11 Puget Sound
13 Manufacturing Site
14 Oak Ridge
17 Manufacturing Site
20 Manufacturing Site
21 Oak Ridge
22 Oak Ridge
24 Oak Ridge
25 Puget Sound
26 Oak Ridge
27 Puget Sound
31 Oak Ridge
32 Manufacturing Site
33 Manufacturing Site
35 SRM Can met SO-3
37 SRMCRM-016
38 SRM NWRI TH-2
44 SRM CRM 021
46 SRM CRM 032
48 SRM CRM 023
49 SRM CRM 025
50 SRM RTC spec.
52 SRM RTC spec.
53 SRM RTC spec.
54 SRM RTC spec.
56 Spiked Lot 1
57 Spiked PS- X1.X4
62 Spiked Lot 5
63 Spiked Lot 23
66 Spiked MS-SO-08
67 Spiked Lot 26
TOC O&G
870 190
3500 290
2400 200
3500 210
7200 200
3800 130
3200 100
7800 180
2400 90
2000 <50
7800 320
6600 190
6600 250
46000 1200
88000 340
37000 1100
5000 80
4700 120
<470 120
NR NR
NR NR
NR NR
NR NR
NR NR
NR NR
NR NR
NR NR
NR NR
NR NR
NR NR
870 190
3500 290
3500 210
5700 100
NA NA
88000 340
Aa
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
0.32
<0.5
<0.5
1.9
1.7
<0.5
<0.5
9.1
<0.5
0.59
<0.5
<0.5
NR
0.7
5.8
6.5
81
NR
130
NR
NR
NR
NR
<0.5
<0.5
<0.5
37
NA
9.1
As
9
3
8
3
4
4
2
2
<2
<2
4
5
5
2
10
3
4
2
<2
NR
7.8
8.7
25
370
380
340
NR
NR
NR
NR
9
3
3
11
NA
10
Ba
210
23
240
28
32
20
110
41
180
150
150
120
89
46
140
33
120
160
340
300
79
570
590
120
76
1800
NR
NR
NR
NR
210
23
28
280
NA
145
Cd
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
0.4
<0.5
<0.5
2.8
<0.5
<0.5
0.7
1.9
0.7
<0.5
<0.5
<0.5
NR
0.47
5.2
1.2
130
0.92
370
NR
NR
NR
NR
<0.5
<0.5
<0.5
0.9
NA
1.9
Cr
19
16
17
18
16
18
42
16
48
35
22
44
6.3
35
47
39
41
190
9.7
26
14
120
11
15
31
440
NR
NR
NR
NR
19
16
18
25
NA
47
Cu
13
10
32
11
9
8
51
9
20
52
40
36
7
33
73
29
32
47
31
17
16
120
4800
590
8.9
7.8
NR
NR
NR
NR
13
10
11
170
NA
73
Pb
3
1
12
3
1
1
7
11
15
5
23
23
10
31
82
31
16
6
8
14
14
190
6500
4600
210
1450
NR
NR
NR
NR
3
1
3
140
NA
82
Se
<2
<2
<2
<2
<2
<2
<2
<2
<2
2
<2
<2
<2
<2
<2
<2
<2
<2
<2
NR
1
0.83
NR
170
120
520
NR
NR
NR
NR
<2
<2
<2
<2
NA
<2
Sn
<5
<5
<5
<5
<5
<5
<5
<4
<5
<5
<4
<5
<5
6
5
5
<5
<5
<5
NR
NR
NR
300
1300
NR
NR
NR
NR
NR
NR
<5
<5
<5
<5
NA
5
Zn
60
24
66
28
24
24
61
74
120
68
340
160
31
98
250
110
96
78
110
52
70
900
550
2600
94
52
NR
NR
NR
NR
60
24
28
170
NA
250
Ha
0.19
0.04
0.10
0.16
0.23
0.63
5.5
78
10
83
14
88
220
35
100
120
870
650
1300
0.02
0.16
0.62
4.7
21
78
100
200
600
900
1100
0.20
0.61
23
270
980
740
CRM = Canadian Reference Material
RTC = Resource Technology
NA = Not Analyzed
Corporation























NR = Not Reported by Standard Supplier
                                                   42

-------
    15
                                                          r*
Figure 6-1. Data plot for low concentration sample results.
 Figure 6-2. Data plot for medium concentration sample results.

-------
                iooo
                1300
            Figure 6-3. Data plot for high concentration sample results.
Unified Hypothesis Test

SAIC performed a  unified hypothesis test  analysis to
assess the comparability of analytical results  provided by
MTI and those provided by ALSI.  (See appendix B for a
detailed description of this test.)  MTI and ALSI both
supplied multiple assays on replicates derived from a total
of 31 different sample lots, consisting of fie Id materials and
reference  materials.  The MTI 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.  The null hypothesis tested was that, on
average, MTI and ALSI produce the same results within a
given sample lot.  The null hypothesis is rejected in  part
because MTI results tended to exceed those from ALSI for
the same  sample lot. Even when a bias term is used to
correctthis discrepancy, the null hypothesis is still rejected.
Additional information about this statistical evaluation is
included in Appendix B.

Accuracy Summary

In summary,  MTI  data  were  only within  SRM  95%
prediction  intervals about 50% of the time, which suggests
significant  non-equivalence.     ALSI  data, however,
compared favorably to SRM values  and were within the
95%  prediction  interval  89%  of  the time,  indicating
statistical parity found to be biased low.

The comparison between the MTI field data and the ALSI
results suggest that the  two data sets are not different, but
this similarity between individual samples is often the re suit
of high variability associated with the MTI reported values.
When a unified hypothesis test is performed, the results
suggest that the two data sets are in fact not the same.
MTI data was found to  be both above and below referee
laboratory  concentrations;   however, the  sample  lot
distribution shown in Table 6-5 implies a positive bias when
compared  to  the low  bias  previously  noted  for  the
laboratory reported results.  The number of  MTI  average
values greater than  50%  different from  the  referee
laboratory results or SRM reference values, however, was
only 6 of 21 different sample lots and those  greater than
100% different were only 2 of 21 different sample lots. MTI
results therefore appear to  provide a rough estimate of
accuracy for field  determination and may be affected  by
interferences not identified by this demonstration.

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
                                                    44

-------
more replications of a measurement, the higher confidence
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,
depending upon the degree of confidence desired in the
specified result. Most samples were analyzed seven times
by both MTI  and the referee laboratory.  In some cases,
samples may have been analyzed  as few as three times
and some  MTI results were judged invalid and were not
used.   This was often  the situation when  it was believed
that the chosen sample, or SRM, was likely to be below the
vendorquantitation limit. The precision goal forthe referee
laboratory, based  upon pre-demonstration results,  is  an
RSD of 25% or less.   A descriptive  evaluation  for the
differences between  MTI RSDs and the referee laboratory
RSDs was determined. In Table 6-7, the  RSD for each
separate sample lot is shown for  MTI compared to the
referee laboratory. The average RSD was then computed
for all measurements  made  by MTI, and this value was
compared to the average RSD for the 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  Table 6-7 and shown for both MTI 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

Table 6-7. Evaluation of Precision
site.  Therefore, spiked samples were included to cover
additional ranges.

Table 6-7 shows 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
Table 6-7 and compared between  MTI  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  MTI'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 describing the accuracy evaluation
and  are  included  here  for purposes  of  precision
comparison. Sample concentrations were separated into
approximate ranges: low, medium, and high, as noted in
Table 6-7 and Table 6-1.  Samples reported by  MTI as
below their approximated MDL  were not included in Table
6-7.  Also not included in  this table are samples where a
high  number of results  were reported as invalid by MTI.
Other than the low concentrations previously noted, there
appears to be no correlation between concentration (low,
medium, or  high) and  RSD; therefore,  no other formal
evaluations of this comparison  were performed.

The referee  laboratory analyzed replicates of all samples
analyzed by MTI. This was used for purposes of precision
comparison to MTI. RSD for the vendor and the laboratory
were calculated  individually and shown in Table 6-7.
Sample
Lot No. MTI and Lab
Avg. Cone, or Reference
SRM value
RSD
Number of
Samples
w/in 25% RSD Goal?
OAK RIDGE









Lot no. 14
MTI
ALSI
Lot no. 21
MTI
ALSI
Lot no. 22
MTI
ALSI
4.75 (medium)


1 1.2 (medium)


81. 6 (high)



37.5%
27.5%

118%
23.8%

31.1%
9.4%

3
7

3
3

3
3

no
yes

no
yes

no
yes
                                                    45

-------
Table 6-7.  Continued
Sample Lot No. MTI and Lab

Lot no. 24
MTI
ALSI
Lot no. 26
MTI
ALSI
Lot no. 31
MTI
ALSI
Lot no. 37
MTI
ALSI
Lot no. 67
MTI
ALSI
Oak Ridge Avg. RSD
MTI
ALSI
Avg. Cone, or Reference
SRM value
221 (high)


77.0 (high)


947 (high)


0.11 (low)


835 (high)





RSD


22.7%
44.8%

56.4%
13.2%

12.9%
13.2%

60.8%
36.4%

5.0%
14.8%

40.6%
20.9%
Number of
Samples

7
7

7
7

3
3

6
7

6
7



w/in 25% RSD Goal?


yes
no

no
yes

yes
yes

no
no

yes
yes

no
yes
PUGET SOUND
Lot no. 05
MTI
ALSI
Lot no. 1 1
MTI
ALSI
Lot no. 25
MTI
ALSI
Lot no. 27
MTI
ALSI
Lot no. 35
MTI
ALSI
Lot no. 48
MTI
ALSI
Lot no. 50
MTI
ALSI
Lot no. 57
MTI
ALSI
Lot no. 62
MTI
ALSI
Puget Sound/ Avg. RSD
MTI
ALSI
0.21 (low)


0.81 (low)


16.6 (medium)


45.7 (medium)

0.11 (low)
0.017(lo


77.78 (high)


200 (high)


0.73 (low)


14.6 (medium)






9.8%
33.3%

62.3%
32.7%

70.9%
12.3%

25.5%
22.2%

1 1 .4%
6.3%

26.8%
34.2%

38.2%
17.7%

74.1%
16.2%

21.1%
28.5%

44.0%
24.1%

3
2

3
7

3
3

7
7

3
7

3
7

7
7

6
7

7
7




yes
no

no
no

no
yes

no
yes

yes
yes

no
no

no
yes

no
yes

yes
no

no
yes
CARSON RIVER
Lot no. 04
MTI
ALSI
Lot no. 38
MTI
ALSI
0.11 (low)


0.62 (high)



56.0%
9.1%

23.3%
6.2%

3
7

6
7

no
yes

yes
ves
                                                          46

-------
Table 6-7.  Continued
Sample Lot No. MTI and Lab
Lot no. 53
MTI
ALSI
Lot no. 54
MTI
ALSI
Lot no. 63
MTI
ALSI
Carson River/ Avg. RSD
MTI
ALSI
Avg. Cone, or Reference RSD
SRM value
900 (high)
1100 (high)
169 (high)


23.5%
35.5%
32.6%
21.0%
34.8%
6.6%
49.3%
16.3%
Number of
Samples
7
7
7
7
7
7

w/in 25% RSD Goal?
yes
no
no
yes
no
yes
no
yes
MANUFACTURING SITE
Lot no. 17
MTI
ALSI
Lot no. 20
MTI
ALSI
Lot no. 32
MTI
ALSI
Lot no. 33
MTI
ALSI
Lot no. 49
MTI
ALSI
Lot no. 52
MTI
ALSI
Lot no. 66
MTI
ALSI
Manufacturing Site/ Avg. RSD
MTI
ALSI
10.5 (medium)
63.9 (high)
592 (high)
1204 (high)
99.8 (high)
600 (high)
892 (high)


16.9%
14.6%
20.9%
25.4%
40.2%
12.7%
36.6%
13.3%
28.2%
12.5%
33.1%
21.9%
26.6%
11.2%
28.2%
15.4%
2
7
7
7
7
7
6
7
7
7
7
7
6
7

yes
yes
yes
yes
no
yes
no
yes
no
yes
no
yes
no
yes
no
yes
SUMMARY STATISTICS
Overall Avg. RSD
MTI
ALSI
Field Samples/ Avg. RSD
MTI
ALSI
SRMs/Avg. RSD
MTI
ALSI








35.1%
22.3%
39.4%
19.4%
30.9%
25.1%








no
yes
no
yes
no
yes
                                                         47

-------
As noted from Table  6-7, MTI precision  is often more
variable than the referee laboratory.  The single  most
important measure of precision provided  in Table  6-7,
overall average RSD, is 22.3% for the referee laboratory,
compared  to the MTI average RSD of 35.1%.  Only the
laboratory RSD is 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 19.4%
for ALSIand 39.4% for MTI; SRM RSD is 25.1% for ALSI
and 30.9% for MTI), but that this difference is likely not
significant. For purposes of this analysis, spiked samples
are considered the same as field samples because these
were similar field  matrices, and the resulting variance was
expected to  be  equal to field samples.  The replicate
sample  RSDs confirm  the  pre-demonstration  results,
showing thatsample homogenization procedures mettheir
originally stated objectives.

There appears to be no significant site variation between
Oak  Ridge,  Puget  Sound, and the Carson  River sites.
(See Table 6-7 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 different vendors and,  therefore,
may not be significant.

Precision Summary

The precision ofthe MTI field instrument is notas good as
the measured laboratory precision.  The overall RSD for
MTI is 35.1%, which is above the 25% RSD objective set
for the laboratory. The overall laboratory RSD  is 22.3%.
Because MTI precision shows a wider variance  in sample
results, MTI data did not prove to be significantly different
from the ALSI data when performing a hypothesis test
procedure for data comparison.
6.1.4   Time   Required
        Measurement
for   Mercury
During the demonstration,  the time required for mercury
measurement activities was measured.   The following
specific activities were timed: instrument setup, sample
preparation,sample analysis, and instrumentdisassembly.
Two  MTI technical  representatives performed  these
operations  during  the  demonstration;  one  individual
performed sample preparation (i.e., acid digestion of the
soil and  sediment samples)  and  the  other  individual
conducted instrument setup/disassembly and all sample
analyses with the PDV 6000.

Setup  and disassembly  times  were  measured  once.
Sample preparation and analytical time were measured
separately each day. Combined, sample preparation and
sample  analysis  comprised   the  operational   time.
Recording of sample preparation time began when the first
aliquot of sample material was weighed out on a portable
scale  and  continued  until the last  digestion bottle  was
completed at the end of the day.  Recording  of analytical
time began with preparation and initial analysis  of the
mercury standard and  continued until the  last sample
analysis was completed at the end of the day.

To acquire the total operational time for all three days, the
sum of the total sample  preparation time and total sample
analysis time was divided  by the total number of analyses
performed  over the  3-day  demonstration.   For  this
calculation, analyses of blanks and calibration standards
and reanalyses  of samples were not included in the total
number of samples. Anydowntime (i.e., lunch  breaks)was
noted and subtracted from the total daily operational time.

Setup time for the PDV  6000 consisted  of 1)  transporting
the PDV 6000  carrying  case,  preparation  kits,  laptop
computer,  and  other ancillary equipment from a  rental
vehicle to  the  measurement  site;  2)  unpacking  and
spreading the items out on a on a level working surface; 3)
connecting the cell assembly to the PDV 6000 control unit
and connecting otherperipheral devices, such as the serial
cable  used to link the PDV 6000 to the laptop computer;
and 4) securing  all power connections.

It should  be noted that the VAS software was already
installed on MTI's laptop  computer.  If  this were not the
case for  potential users, then the  software  installation
would add to the setup time.

The main components of the PDV 6000 were contained
within a hard shell, pelican-style carrying case.   These
components included the main PDV 6000 control unit, the
cell assembly with  stirrer, the  cell stand,  a Ag/AgCI
reference electrode, a platinum counter electrode, a  glassy
carbon working  electrode, a connecting cable to link the
analytical cell to  the control unit, a DB9 male/female serial
cable  link for connecting the PDV 6000 to a computer, a
reference electrode plating accessory, a main powered 12
VDCsupply(plug pack),  a NiMH rechargeable  battery pack
and battery pack charger, the PDV6000 operation manual,
VAS software installation disks, and a printed  VAS  User's
Guide and warranty card.
                                                    48

-------
Of these components, the reference  electrode plating
accessory, the NiMH  battery pack, and the charger were
not used during the demonstration.   (The  pre-plating
procedure is  not required for mercury analysis and the
instrument was powered by line electricity.)

In addition to the main instrument components, there was
ancillary equipment that was unpacked as part of setup.
Most of this equipment related directly to sample digestion
procedures.  These included the following items:

    Portable scale

    Air displacement pipettes (5-50 uL, 100-1000 uL, and
    200-1000 uL)

    Repeating pipetter (0.5 - 50 ml_)

    Sample processing  kits

    Incidentals (i.e., paper wipes, felt labeling pens, etc.)

These  items,  along with other supplies, were transported
in  a cardboard  box.  Setup  of  all  of  the  necessary
equipment and supplies took approximately 15 minutes.

It should be noted that, although MTI utilized two people
during the demonstration, one person could perform both
the sample preparations and sample analyses. According
to MTI, the number of individuals required for  conducting
full analyses should be based on the number of sam pies to
be analyzed.  For instance, if there are 15 samples or less
per day to be analyzed, MTI would advise that one person
would  be sufficient; if there  were to  be more  than  15
samples analyzed daily, the user may decide  to use two
people. In the case of the demonstration, where over 50
samples were analyzed daily, two people were  deemed
necessary by MTI to efficiently process the samples.

Individual  sample  analysis  times  were  not  measured
during the demonstration. Analysis  time was estimated by
recording start and stop times each day and accounting for
any instrument downtime due to operator breaks or device
failure and maintenance activities. Therefore, the total time
foranalyses included preparing a mercury standard and an
electrolyte standard solution each  day, analyzing blanks
and the calibration standards, and conducting  reanalyses
on certain samples; however, the total numberof analyses
performed includes only  demonstration  samples (i.e.,
samples, spikes, and  SRMs). The sample total  does not
include blanks, calibration standards, or reanalyses. Table
6-8 presents the time measurements recorded for each of
the three days of PDV 6000 operation.
Table 6-8.  Time Measurements for MTI (minutes)3.
Day 1 Day 2 Day 3
Activity
Instrument Setup
Sample Preparation
Sample Analysis
Operation Time b
Disassembly
a Times are rounded
b Operation Time =
Analysis Time.
15
370
370
740
-
to nearest
Sample
-
430 0
560 550
990 550
10
15 minutes.
Preparation Time
3-Day
Totals
15
800
1,480
2,280
10
+ Sample
Disassembly of the instrumentand ancillary equipmentwas
measured from the completion  time of the last  sample
analyses  until  the   instrument   components  were
disassembled and  placed back into the original shipping
container. Disassembly of the PDV 6000 involved turning
off the power, disconnecting the electrical power  source,
the  serial cable link between the control unit  and laptop
computer, and removal of the cable link connecting the
analytical cell to the control unit. This complete process
took about 15 minutes (earlier stated 15-minute rounding).
Packaging  for  shipping  is  not included  in the time
measurement; however,  the PDV  6000 carrying case
appears durable enough to ship  as is or in a box, without
the  need for reinforced corners  and buffer spaces. The
pipettes, scale, and any unused supplies would also need
to be  packaged for shipment.   It is estimated that this
complete  process  would  take  approximately  1  hour,
including the time to ship any returnable items to suppliers.
Analysis Time Summary
In   total,  MTI   analyzed  197  samples  during  the
demonstration.  Sample preparation took a total  of 800
minutes (roughly 4 minutes per sample)  and  sample
analysis took 1,480 minutes (7.5 minutes per analysis).
Using the total operational time reported in  Table 6-8
(2,280 minutes), 11.6  minutes is the estimated time per
complete sample analysis  for the  demonstration.   As
previously noted, the number of analyses does  not include
blanks, standards, and reanalyzed samples.
It is realized that actual times will vary from  site  to site
depending on project goals.  For example, if the  results
can be reported as  "greater than" or "less than" a  specific
target concentration, then  the time  per sample analysis
could  be significantly reduced. On the other hand, if high
                                                    49

-------
concentration samples require one or more dilutions,  or
heterogeneous samples  require duplicate analysis, the
sample time per analysis may increase.  If project goals
require all  samples  to  be quantified,  the  number  of
reanalyses and blanks required could be higher, thus also
increasing  the  time  per  analysis.     During  the
demonstration, no "greater than values" were reported;
however, some "less than values" were reported.

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
PDV 6000 in terms of the secondary objectives described
in  Section  4.1.    These  secondary  objectives  were
addressed based on observations of the PDV 6000  made
during the demonstration and information provided by MTI
during and after the demonstration.

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 and review  of the  PDV 6000
  operation manual, the instrument appears to be
  easy  to  operate as  a stand-alone  unit  or in
  conjunction with the VAS software. Training on
  the unit and software would be recommended for
  first-time users. A  laboratory or field technician
  with a basic knowledge of chemistry and basic
  computer   knowledge   could   operate   the
  equipment after a 1-day training course.
The vendor provides a SOP that summarizes the sample
preparation and sample analysis procedures for the PDV
6000.  Also provided with  the  unit is  the  PDV 6000
Operations Manual, version 2.2 (47 pages in length), and
the VAS User's Guide, version 2.1 (50 pages  in length).
This SOP was evaluated during the demonstration and the
step-by-step procedures were easy to understand.
The analysis portion  of the  MTI  mercury measurement
process  may  require  analytical  experience to gain
efficiency in the field.  Familiarity with calibrating analytical
instruments, running blanks before processing samples,
running calibration standards, and overall familiarity with
sample peaks, would be an advantage for a prospective
user. The VAS User's Guide does provide some examples
of sample peaks in  the  chapter titled "Analyzing Data."
There is also some discussion of peak measurement with in
the  PDV   6000  Operations   Manual  in  Chapter  3
(Introduction to Voltammetry).

In addition to  providing  the  written instructions,  MTI
provides a 1 -day training course on the PDV 6000 for up to
eight individuals (at the purchaser's cost). Currently, there
is no specific training course for the VAS software.  The
combination of instrument training, the field SOP, the PDV
6000  Operations Manual,  and the VAS User's Guide
should provide a user with adequate direction on basic use
of the PDV 6000. Once in the field, MTI does supply some
ongoing support. MTI has a phone number for domestic
support  (910-617-8367)  and an Internet email  support
address with support provided from Australia. Chapters of
the PDV6000 Operations Manual does include information
on troubleshooting.  Neither the training course nor email
support was evaluated during the demonstration.

MTI  chose to  operate  the  PDV  6000  with two  MTI
representatives during the demonstration. One individual
who  conducted the sample preparation held B.S. degrees
in biology and chemistry. The other individual conducting
the analysis held a  degree in chemistry/pharmacology.
The two MTI representatives were able to perform sample
preparation and analysis on a somewhat continuous basis,
although sample preparation was more routine and, thus,
a quicker operation. The sample digestion procedure kept
far enough ahead of the sample  analysis  that all 197
samples were prepared for analysis more than a day
ahead of completing all  the analyses. The separation of
sample extraction and analysis is not recommended by
MTI; however, it was performed by MTI as a  means of
completing the 197 samples over the  3-day time frame.

Sample preparation took approximately four minutes  per
sample. Sam pie preparation consisted of weighing out a
specific mass of sample  material, placing the material into
a 70-mL digestion bottle, and then pipetting the following
into the bottle.

•    4mLofHNO3
    4 ml_ of H2O2 (1 ml_ at a time)
    12 ml_ of Dl  water
    20 ml_ of electrolyte  solution

This  procedure  was easy to understand, and could be
performed  by a trained technician.   The two  main
                                                   50

-------
peripheral items  used  during  the sample  preparation
procedure are a portable analytical scale and one or more
pipettes.
MTI typically would not  supply the analytical balance and
pipettes, although the company indicates that these items
could be purchased as part of an accessory kit; however,
MTI does supply disposable pipette tips within the sample
preparation kits.  The reader should note that brands and
models of the balance and pipettes, otherthan those used
for the demonstration, may be adequate for use.
Sample  analysis  on  average took  approximately 10-12
minutes per sample.  Because  sample analysis  was  a
separate  procedure  and  involved   running   blanks,
calibration standards, and some reanalysis, the procedure
lagged  behind sample preparation.  If a single individual
                                    were to perform both preparation and analysis, it would be
                                    advantageous to prepare several samples in advance  of
                                    conducting analyses.
                                    The sample analysis process is more involved than the
                                    sample preparation procedure and should be performed by
                                    a technician trained in using the PDV 6000 with the VAS
                                    software. As sam pies are analyzed, VAS software screens
                                    do  allow the  analyst to track the  stage at which the
                                    analytical   process  is  progressing,  which  would  be
                                    especially beneficial to the novice user.  Figure  6-4 is an
                                    example of the PDV 6000 run log screen with open data
                                    windows.  Figure 6-5 shows the sample graph screen for
                                    a mercury analysis and Figure 6-6 has a sample graph and
                                    data  for a  sample  analyzed  by  the  method of  standard
                                    additions.
  E0 Sample
  0 Sample
  0 Sample
 ^ 15377
  ^j Sample
  £| Standard Addit
  g Results
   13447
  £3 Blank
  ^j Standard
  ^j Sample
 L|£j Results
Q 10148
  ^ Standard
  ^] Sample
  3 Results
Q 11373
    ] Blank
    j Sample
    j Standard Addit
 LH Results
   19444
  j^l Sample
   17445
  [72! Sample
  |5?j Standard Addit
   17148
  0 Blank
  0 Standard
                           22:43:57
                          .22:46:28
                           22:48:16
                           22:54:27
                      Initiate Run
              17Jun2003
              17Jun2003
              17Jun2003
              17Jun2003
Sample-file:  SOppbstd
 . Comment; 'I
                                                                              Start
                                                                             Cancel
                           Using::    flun-Configuration...  |

                         Run Type—
                         ^ Cample    f*1 Standard Addition
                         r Standard   f Blank
                                                                              Help
                       - Concentrations -
                          Standards-Set >
                         f Hg - 20 pprn

                          .Save;.,    Standards .-libtaij.,.
                           Acid-
                                   Edit...
                                            Delete
                             --Volumes—
                                   SafflpleVolurne [mLJ.1: |.1

                               lotal Standard Volume (ml);: [05

                                  Electrolyte Volume (ml): f20~
                                                      Delect Peaks
Detection Limit |%): [75

      hing.m: |75
                                                                     DK
                                                                                           Cancel
                                                                                            Help
                                  .Blank Subtraction
                                  Artificial Blank Subtraction

                                  Generate For Entire F3e     l~ Retain Hand Modified Peaks
       Figure 6-4. PDV 6000 sample run log with open data windows.
                                                         51

-------
                               Jj.!sDl&i<
                                               JHelp
[¥.9J
                                 WW" IEPA H° ""' LV 2-11334. Sample
                                                                          260mV   280* 300mV
                                                         ]1x1 Zoom-   [Anode  |1338mV    |98.8 .j4
Put Helit,.prs&n                               I Instrument: PDV3000
Figure 6-5.  PDV 6000 sample graph screen.
                                                                          lEOHt I   RiFI
                             plvst: [iBLisy ^etutJ W«i
                            jJil§|B|g|ileJ
                 TOW  150 M/  200 mV  250W/  300 mV  350*'  4001*  450*  500 iW  550 nnV  'BflOmV
        Figure 6-6.  PDV 6000 mercury graph for sample analyzed by
        method of standard additions.
                                           52

-------
6.2.2  Health and Safety Concerns

Documents potential  health  and  safety  concerns
associated with operating the device.
  The main health and safety concern observed
  during the demonstration was potentialexposure
  to  fumes  resulting  from  vigorous  reactions
  during sample  preparation.   This occurrence
  necessitates the use of appropriate PPE  when
  conducting acid digestions.
Health and safety concerns, including chemical hazards,
radiation   sources,  electrical  shock,   explosion,   and
mechanical hazards were evaluated.

Chemicals were used in the preparation or processing of
samples. These included the following:

    Nitric acid (HNO3) (concentrated)
    Hydrogen peroxide (H2O2) (1 00%)
    An electrolyte  solution  containing  sodium  acetate,
    acetic acid, and trace metals
    Potassium chloride (KCI)
    Mercury standard

Of these chemicals, the two posing the greatest exposure
risk are HNO3  (a strong oxidizer) and H2O2 (a strong
oxidant).  MTI does include Material  Safety Data Sheets
(MSDS) for HNO3, H2O2, the electrolyte solution, and the
mercury standard.

The main  potential health and safety concern regarding
MTI's process is, therefore,  potential exposure to spilled
chemicals  or  fumes  caused  by  reactions of  these
chemicals with  one another or with unknown sample
constituents.  Ampules of these chemicals were handled
with gloves, and  the operator wore safety glasses with side
shields at all times.  Such standard laboratory precautions
mitigate the potential for dermal exposure. In addition, the
MTI  representative conducting the sample  preparation
wore a long-sleeved laboratory coat.

During  the  demonstration, a  few  samples  reacted
vigorously, releasing pungent reddish-yellow fumes from
the digestion bottles, following the addition of H2O2 to the
solution.   In  some instances,  an effervescing  solution
frothed over the top of the digestion  bottle and onto the
table.
It should also be noted that the demonstration samples
may pose a mercury inhalation hazard. During the original
demonstration  in Oak Ridge, TN, in May 2003,  vapor
measurements were recorded for the same samples that
were  analyzed  by  MTI  in  Las Vegas in June.   The
measurements were collected with a Jerome 431-x gold
film mercury vapor analyzer, manufactured by Arizona
Instruments Corporation.  The instrument has a rangefrom
0.000 to 0.999 mg/m3. In all cases, readings were 0.000
mg/m  in the breathing zone of the operator, indicating no
inhalation hazard.

In  evaluating electrical shock potential, two factors were
evaluated: 1) obvious areas  where electrical wires are
exposed and 2) safety certifications.  No exposed wires
were  noted during  the demonstration.  All connections
between equipment were made using standard electrical
lines,  interface cables, and 8-pin cords.  The power cord
was grounded with  a ground fault interrupter.

No obvious explosion hazards were noted. The PDV 6000
has a CE electrical certification, which is  the European
equivalent of the Underwriters Laboratory  (UL) electrical
certification in the  United States.  The unit also  has a
N4266 electrical certification (Australia's equivalent to UL),
but it does not have UL certification.

No serious mechanical hazards were noted during the
demonstration.   All  equipment edges  were  smooth,
minimizing any chance of cuts or scrapes.  If an electrical
cord is used to provide power to  the PDV 6000, it needs to
be installed in a manner designed  to prevent trip hazard
(e.g.,  taped down).

6.2.3 Portability of the Device

Documents the portability of the  device.
  The  PDV 6000  is  a handheld  device that is
  transported in a carrying case along with its main
  components. Due to its packaging and compact
  size and weight, the unit can be taken anywhere
  that is accessible by foot and can be operated on
  a small-level surface.
The PDV 6000 display unit measured approximately 20 cm
(L) by 10 cm (W) by 4 cm  (H) when lying flat. The weight
of the control unit was estimated at less than 1 kg. Also
included as  standard with the PDV 6000 were the cell
assembly, stand for the cell assembly with integral stirrer,
a set of electrodes, connecting cables, a NiMH batteryand
                                                    53

-------
battery charger,  and the accompanying VAS software
installation disk.

All of these accessories are lightweightand easily portable,
and fit into a pelican-style case measuring approximately
35 cm (L) by 25 cm  (W) by 15 cm high.  As a result, the
PDV6000 is practical for field applications, including use in
remote areas accessible only by foot.

The  sample digestion   required  a  flat,  stable surface,
which would also be suitable for  a laptop computer. A
table was supplied during the demonstration for preparing
and  staging samples.   The majority of materials  and
supplies required forconducting sample preparation come
in a kit that is the approximate size of a shoe box. Each kit
comes with enough supplies to  prepare 10  samples.
Additionally, a small portable scale and pipettes  are
needed to properly prepare samples for analysis. These
additional items, along with the kits, could be  transported
in a heavy duty bag or cardboard box.

The  PDV 6000  is  equipped  with  a NiMH  battery  for
operation in the absence of electrical power.  The battery
powers the  unit for  about 4 hours  and would allow for
analyzing 10-20 samples. Line operation of the instrument
requires a standard electrical source of 110 volts.

For the  demonstration,  the vendor was supplied with a
folding table, two  chairs, and a tent to provide shelter from
inclement weather.  In  addition, two  1-gallon containers
were provided for waste soil and  for decontamination
residual extract  waste.  A 2-gallon  zip-lock  bag was
furnished for disposal of used gloves, wipes, and other
wastes which were contaminated during the demonstration.
Finally, a large trash  bag was supplied for disposal of non-
contaminated wastes.

6.2.4  Instrument Durability

Evaluates  the durability of the device based on  its
materials of construction and engineering design.
  The PDV 6000 is well designed and constructed
  for  durability.  A  conformal   coating  on  the
  device's electronics allows for  use in humid
  climates.
However, the outer shell  of the instrument display  unit
appears to be  well designed and constructed, indicating
that  the  device should  be  durable  under most field
conditions.  No  evaluation could be made regarding the
long-term durability of the cell assembly, or display circuitry.
Visual inspection did not indicate that any problems were
likely.

MTI  indicated  that a conformal coating on the device
electronics allows for operation in an unlimited humidity
range (i.e., other than the  unit being submersed in water,
no damage should result due to moisture). The PDV 6000
was  observed  in  both wet and  dry  conditions  (the
instrument was operated at both the Oak Ridge, TN,  and
Las Vegas, NV, demonstration locations.

6.2.5  Availability of Vendor Instruments and
       Supplies

Documents  the availability of the device and  spare
parts.
  The MTI PDV 6000 units are stocked and
  available for purchase,  rent, or lease. They are
  available within one week of order placement
  through the new MTI US operations.  Spare
  parts and consumable supplies can be added
  to the original PDV 6000 order. Supplies not
  typically provided by MTI (pipetters and a scale)
  are readily available from laboratory supply
  firms.
The  outside of the  PDV  6000 is constructed  of sturdy
plastic.  The main  display unit was  secured  with four
screws. No environmental (e.g., corrosion) or mechanical
(e.g.,  shear stress  or impact)  tests were performed.
EPA  representatives  contacted  MTI   regarding  the
availability of the PDV 6000 and supplies.  MTI indicated
thatapproximately 90% of its currentbusiness is purchase,
but that units are stocked and available for purchase, rent,
or lease. According to  MTI, such systems  are available
within one week of order placement through the new MTI
U.S. operations.

The instrument comes standard with the following items:

    PDV 6000 handheld control unit
    Analytical cell assembly
    Analytical cell stand
    Ag/AgCI reference electrode
    Platinum counter electrode
    Glassy carbon working electrode
    Cable to link analytical cell to control unit
                                                    54

-------
    DB9 serial cable to link PDV 6000 to a computer
    Reference electrode plating accessory
    Main powered 12 VDC supply (plug pack)
    NiMH rechargeable battery pack
    NiMH battery pack charger
    PDV 6000 operation manual
    VAS software installation disks
    Printed VAS User's Guide
    Warranty and contact sheet

Consumable  supplies that  are  required  for  sample
preparation are provided by MTI as kits and can be ordered
with  the  PDV 6000  equipment.  The  kits contain  the
following items:

    Digestion bottles  (10)
    Electrolyte medium (one 500-mL bottle)
    Electrolyte ingredients
    Hydrogen peroxide (two 30-mL bottles)
    Deionized water (one 250-mL bottle)
    Mercury standard (one 30-mL bottle)
    Waste container (one 500-mL bottle with kitty litter)
    Analysis cups (15)
    PVC gloves (2 pair)
    5-ml soil grabber samplers (10)
    10-100 uL pipette tips (14)
    100-1,000 uL pipette tips (15)
    5,000 uL pipette tips (14)
    Part I -  Electrode polishing kit - dry cloth
    Part II - Electrode polish mixture

Common laboratory equipment also needed for sample
preparation include air displacement pipettes, a repeating
pipette, and a portable balance. This equipment can be
purchased from MTI as part of an accessory kit but also is
readily available from laboratory supply companies.
                                                    55

-------
                                              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  increased,  the  total capital  cost  was  also
estimated and reported. Because unit analytical costs are
dependent upon the total number of analyses, no attempt
was made to compare the cost of field analysis using the
PDV 6000  to the analytical  costs associated with  the
referee laboratory.  "Typical" unit cost  results, gathered
from  analytical laboratories, were reported  to provide a
context in which to review the PDV 6000 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 PDV 6000, and presents a
cost summary for a  "typical" laboratory performing 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. MTI offers purchase, rental, and lease options for
potential  PDV 6000  users.   Rentals  have a 1-month
minimum and MTI  has a variation of  the rental option
which allows a 50% credit for rental fees toward 50% of the
instrument purchase  price.   Lease agreements  are for
three  months, in which the  3-month lease equals  the
purchase price.  Because site and user requirements vary
significantly, each of these three options is discussed to
provide each user with the information to make a case-by-
case decision.

A  more detailed cost analysis was performed on  the
instrument purchase option because MTI has indicated that
instrument  purchase  comprises approximately  90%  of
company orders.  The results of that cost analysis are
provided in Section 7.2.

7.1.1  Capital Equipment Cost
The PDV 6000 (the analytical instrument) is marketed as
a standard package that includes all necessary equipment
needed to operate the PDV 6000. The instrument and its
accessories are regarded as capital equipment since they
represent a relatively significant capital expenditure that
typically is depreciated. Other equipment is required for
sample  preparation; however,  these  are typically  non-
depreciable items of lower cost and are better categorized
as supplies (see Section 7.1.2).

It should be noted upfront that the PDV 6000 can be used
as a stand-alone unit  (without the  VAS  software).   For
stand-alone  use, the controller  unit is  programmed  to
analyze 10 metals in the concentration range of 1 0 ppb to
30 ppm.  According to MTI, the stand-alone unit is more
appropriately used  for field screening, and  it does not
provide  the  accuracy  of  laboratory analysis.  MTI has
indicated that the stand-alone unit should only be used for
determining whether a sample may be above or below a
particular threshold.

During the demonstration, MTI utilized the VAS software in
conjunction with  the PDV 6000. Because this software
incorporates features such as standard addition calibration,
simultaneous multi-element analysis, and storage of data,
                                                   56

-------
it allows for more flexible and accurate analysis. The cost
of the software adds less than 3% to the total cost of the
PDV 6000 unit (i.e.,  the PDV 6000 costs  $7,900 as  a
stand-alone unit and $8,100 with the VAS software).  For
this reason, an assumption was made that the user will
utilize the  VAS software with the PDV 6000  unit, whether
purchased or rented.  Costing the unit with  the software
reflects the instrumentation configuration used during the
demonstration.

The  VAS  software requires  a computer that  has  a
minimum specification of 300 Mhz586 processor(Pentium
or equivalent), 64 MB RAM,  10MB of free hard disk space,
and runs on Windows 98, ME, NT, 2000, orXP. The cost
of a computer is not included. For this economic analysis,
an assumption was made thatthe userwill supply a laptop
computer that meets those  specifications.

The instrument cost quoted by MTI does not include any
packaging orfreightcosts to ship the instrument to the user
location. For rental and lease agreements, the first month
rental or lease cost is  required up front.  A user manual  is
provided with the unit  at no cost.   An  8-hour training
session is available  for up to  eight  individuals,  at an
additional fee of $950.

7.1.2 Cost of Supplies

The cost of supplies was estimated based on the supplies
required  to  analyze  demonstration  samples and  on
discussions with MTI.  For purposes  of this cost estimate,
the supplies  required to analyze solid  samples were
factored into the cost estimate.  Supplies utilized  by MTI
during the demonstration consisted  of both consumable
and non-consumable items. The consumable supplies
were  contained  within "sample processing kits" and
consisted of the following items:
   Digestion bottles
   Electrolyte medium
   Electrolyte ingredients
   Nitric acid ampules
   Hydrogen peroxide
   Deionized water
   Mercury standard
   Waste electrolyte jar
- Analysis cups
- PVC gloves
- 5-mL soil samplers
- 10-100 uL pipetter tips
- 100-1000 uL pipetter tips
- 5000 uL pipetter tips
- Electrode polishing kit
- Electrode polish mixture
These consumable items contained in the kits are readily
available from MTI.   Because the user cannot  return
unused  portions of the kit contents, no salvage value is
included  in the cost of  supplies.  Personal protective
equipment (PPE) supplies are assumed to be part of the
overall site investigation or remediation costs; therefore, no
PPE costs are included as supplies.

Non-consumable supplies  utilized by MTI  consisted of
reusable items that were not included  in the kits. These
items were necessary to conduct the sample digestion
procedure. These items included a portable laboratory
scale required to measure out the correct mass of sample
to digest; a set ofairdisplacement pipetters (5-50 uL, 100-
1,000 uL, and 200-1,000 uL); and a repeating pipetter (0.5
-50 ml_).   It should be noted that this  type of equipment
may or may not be already owned by a potential PDV 6000
user; however, for this economic analysis, an assumption
was made that the user does not possess these items.

7.1.3  Support Equipment Cost

During the demonstration, the PDV 6000, control unit, cell
assembly, and laptop computer that ran the VAS software
were operated using AC power. The costs associated with
providing the power supply and electrical energy were not
included in the economic analysis; the demonstration site
provided  AC  power  at  no cost.   None  of  the  items
mentioned above can operate on DC power; however, the
PDV 6000 can run on a NiMH rechargeable battery. The
laptop computer can also run on a rechargeable battery.

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  PDV 6000 and sample preparation equipment setup,
sample  preparation,  summary  data  preparation, and
instrument packaging at  the end of the day. Setup time
covered the time required to unpack the instrument, set up
all  components,  and ready  the  device  for  operation.
Sample preparation is somewhat labor intensive, albeit a
routine operation.    Sample   preparation  involved  the
following steps:

1.   2.0 grams of sample  is weighed out and placed into a
    digestion bottle,

2.   4.0 mL of HNO3 is pipetted into the bottle,
                                                    57

-------
3.  4.0 mL of H2O2 is pipetted into the bottle, 1 ml_ at a
    time.

4.  12 mL of deionized (Dl) water is added to quench the
    sample, and

5.  20 mL of electrolyte medium is added to  the  bottle
    (thus, a total 40 mL solution is created).

Due to the large number of samples to be prepared and
analyzed, MTI had decided to utilize two individuals, one to
conduct  sample preparation  and the other to conduct
sample  analysis.  Sample preparation  was the faster
component of the entire procedure.  As  a result, sample
digestion of all 197 demonstration samples was completed
near the end of the second day of operation.  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  MTI analyst  electronically
transferred the  results of all  197 samples  from  the
computer database at the end of the demonstration.

The time required to perform all tasks was rounded to the
nearest 5 minutes; 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 1) conducting the field sample
preparation and 2) to analyze the samples with the PDV
6000 utilizing the VAS software and report the results for
mercury samples.  Based on these field  observations, a
field technician with basic chemistry skills acquired on the
job or in  a university setting was considered qualified to
conduct  the  sample  preparation  procedure.   If this
individual  also  possessed  basic computer skills and
completed a  1-day training course specific to  the PDV
6000, and for the VAS software, that individual was also
considered qualified to operate the instrument.

Analysis with the PDV 6000 can be performed with either
one or two operators,  depending upon  the number of
samples expected to be analyzed on a  daily basis.  For
analyzing 15 or fewer samples per day, MTI  advises that
1 person would be sufficient. For analyzing more than 15
samples  per day MTI advises using 2 people.  One also
has to consider that in remote areas, where the instrument
could be used, a minimum  of two field staff are typically
required as a health and safety precaution. (In the case of
the demonstration, where over 50 samples were analyzed
daily,  2  people  were  deemed  necessary by  MTI  to
efficiently process the samples.)

The use of two individuals may increase costs if travel and
per diem were  required; however,  these  cost  are  not
considered,  as  explained  in Section 7.1.6.   For this
economic analysis, an  assumption was  made that one
technician will be able to conduct both sample preparation
and sample analysis, with the understanding that there are
ongoing activities at the site, allowing the technician to be
in constant communication with other individuals.

An hourly rate of $15 was used for the field technician. A
multiplication factor of 2.5 was applied to labor costs to
account for overhead 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
MTI was instructed to segregate its waste into  three
categories during the demonstration:  1) general trash;
2)  lightly contaminated PPE and  wipes; and 3) excess
contaminated soil (both analyzed and unanalyzed) and
other highly  contaminated wastes such as  the digestion
liquid.  General  trash was not included as investigation-
derived waste (IDW) and is not discussed in this document.
A  separate  container  was  provided for  each  waste
category.

Lightly contaminated wastes consisted primarily  of used
surgical gloves  and wipes.   The surgical gloves  were
discarded for one of three reasons: 1) they posed a risk of
cross contamination (noticeably soiled), 2) they posed a
potential health and safety risk (holes or tears), or 3) the
operator needed to leave the analysis area  to perform
other tasks (e.g.,  using a cell phone, etc.).  The rate of
waste PPE generation was  in excess of what would be
expected in  a typical application of this instrument  since
EPA evaluators  occasionally contributed  used gloves to
this waste accumulation point.

The  specific wastes  that  were  generated  by  MTI's
measurement process consisted of the following:
                                                    58

-------
    Empty HNO3 ampules

    Waste PPE (nitrile gloves) and wipes

    Spent 70-mL digestion bottles containing a mixture of
    residual contaminated soil, HNO3, and H2O2
    Empty analysis cups

    Spent  electrolyte  solution,  containing  a
    concentration of mercury and other metals
small
The empty HNO3 ampules were considered general trash,
the PPE and wipes were considered lightly contaminated
material,  and  the  remaining  items were considered
hazardous wastes for purposes of this cost analysis.

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.

Oversight of Sample Analysis Activities. A typical user
of the PDV 6000 would not be required to payfor 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 referee 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, were 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 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, 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     PDV 6000 Costs
This section presents information on the individual costs of
capital equipment, supplies, support equipment, labor, and
IDW disposal for the PDV 6000.

7.2.1  Capital Equipment
The PDV 6000 sells for $7,900 as a stand-alone unit, and
for $8,100 with the VAS software. Whether purchased or
rented, the unit comes with the following components and
items:
          • Handheld control unit
          • Analytical cell assembly
          • Analytical cell stand
          • Reference electrode
          • Counter electrode
          • Working electrode
          • Cable to link unit/cell
          • Cable to link unit/laptop
                           - Plating accessory
                           - 12 VDC supply
                           - NiMH battery
                           - NiMH battery charger
                           - Operation manual
                           - VAS installation discs
                           - VAS User's Guide
                           - Warranty/contact sheet
                                                    59

-------
During the demonstration, the PDV 6000 was operated for
approximately 3  days and  was  used  to  analyze  197
samples. Table 7-1 summarizes the PDVGOOOcapitalcost
for four procurement options: purchase, rental, lease, and
                          rental with an option to purchase. These scenarios cover
                          only capital cost, not the cost of optional or user-supplied
                          equipment, supplies, support equipment, labor, and IDW
                          disposal.
Table 7-1.  Capital Cost Summary for the PDV 6000
            Item
Quantity   Unit Cost ($)              Total Cost for Selected Project Duration

                       1-Month  3-Month    6-Month     12-Month     24-Month
Purchase PDV6000/VAS 1
Monthly Rental of PDV 6000 a 1
Lease PDV 6000/VAS 1
Rental with purchase option b 1
$8,100
$2,200
$2,700
$2,200
$8,100
$2,200
$2,700
$2,200
$8,100
$6,600
$8,100
$6,600
$8,100
$13,200
$8,100
$12,850°
$8,100
$26,400
$8,100
$12,850°
$8,100
$52,800
$8,100
$12,850°
        The standard rental period is generally a minimum of 1-month; however, the PDV 6000 can be rented for a 1-week period for $600 (with
        pipettes) or $800 (without pipettes).
b       50% of monthly rental fee is credited to 50% of the purchase price.
c       After 4 months of renting the unit, $8,800 of rentals fees are incurred. Up to $4,050 can be credited toward purchase.
        Therefore, a balance of $4,050 would be owed to purchase the instrument and the total cost would be $12,850.
Figure 7-1  shows the relative costs for the basic capital
equipment  for the purchase, rental, and rental/purchase
option (PO) scenarios.   The lease arrangement is  not
shown since it is very similar to direct purchase for the time
scales presented. These costs reflect the basic PDV 6000
unit and accessories (with VAS software included).  No
options (e.g., laboratory scale or multi-volume dispensing
pipetters) and no supply or shipping costs are included.
                                        Purchase
                                     Rental
                                 Rental/PO
                    Months
Figure 7-1. Capital equipment costs.
                          As would be expected, this chart shows that purchase is
                          the most cost-effective option (in terms of capital costs) for
                          long-term use, and the rental with a purchase option may
                          be desirable for product trial.  Rental is shown  to  be  a
                          logical choice only  for short-term projects  (i.e., three
                          months or less).

                          MTI's policy of applying a portion  of rental costs toward
                          instrument purchase would be a consideration in instances
                          where the project duration is unknown, or when the user's
                          acceptability and reliance on the instrument increase with
                          usage. As noted in Table 7-1, after4 months of renting the
                          PDV 6000, $4,050 of the $8,800 expended for rental fees
                          can be credited toward instrument  purchase.  Therefore,
                          a  balance of  $4,050 would be owed to purchase the
                          instrument,  and  the total  cost of the rent-to-own option
                          would be $12,850.

                          7.2.2  Cost of Supplies
                          During the demonstration, there were two types of supplies
                          used  by  MTI. The first type was consumable items that
                          were  contained within "sample preparation kits."  One kit
                          contained enough supplies for 10 sample measurements,
                          which correlated to approximately $10 per analysis. Based
                          on the assumed 10-hourworkday and 21-day work month
                          (estimated  in   Section  7.1.4),  and   MTI's  sample
                          measurement rate of roughly 50  samples  per  day (as
                          calculated  in  Section  6.1.4),  a   total  of  5  "sample
                          preparation  kits" would be required per day.  MTI prices
                                                     60

-------
these kits at $99 each and offers a 15% discount on orders
of 20 kits or more.  Therefore, using a discounted price of
$84 per kit cost, a 21-day (i.e., 1 month) supply would total
approximately $8,800.

In addition  to the consumable items  contained within the
sample  preparation  kits,  there  was reusable  sample
preparation equipment used  during  the demonstration.
These items included a portable laboratory scale used to
measure out the proper mass of sample and  a set of
variable-sized pipetters  used to  dispense  accurate and
precise volumes of reagents and standards.

The scale used by MTI was an Aculab portable scale. A
compact electronic scale manufactured by Ohaus is priced
at  about  $110   (www.Fishersci.com,  2003).     This
comparable scale would be sufficient for the sample mass
measurements in the field.

MTI   was  equipped  with   four  pipetters  during  the
demonstration.    Three  of the  instruments were  air
displacement pipetters  with  a  50-1000  uL dispensing
capacity, and one of the instruments  was a repeating
pipetter with  a  0.5-50  ml_  dispensing capacity.  The
disposable  pipetter tips used for the demonstration were
provided in the kits which prevented cross contamination
between samples.

The microliter range air displacement pipetters are priced
at $230 each  (www.Fishersci.com, 2003); therefore, a set
of three air displacement pipetters would cost $690.  For
dispensing  set amounts of larger liquid volume, MTI used
a 0.5-50 ml_ HandyStep repeating pipetter.  This type of
pipetter prices at $320 (www.Fishersci.com, 2003).  The
lifetime of these pipetters could vary significantly, but it is
assumed that the pipetters would  last several years. The
total annual costs for these  supplies  (i.e., kits, scale, and
pipetters) would total roughly $10,000.

Table 7-2 summarizes the costs for the supplies, assuming
that the same number of samples are run per day during
each 3-month period.  As indicated, for continuous  daily
measurements the sample  preparation kits dominate the
cost of supplies. For 1 month of continuous sampling, the
kits comprise about 89%  of total supply costs.   This
percentage escalates with duration until  the kits comprise
nearly the  entire supply cost percentage.  Table  7-3
indicates the costs associated with analysis when the user
prepares their reagents and purchases disposable supplies
as opposed to purchasing preparation kits.  The  1-month
column is indicated as not applicable (NA) because it is not
advantageous to prepare reagents for  short periods of
time.  In addition to the chemical and supply costs, $1,000
per month  amount  is added to the cost to account for
preparation time and reagent  analysis.   Based on  this
observation,  the  instrument  supplies  (i.e.,  scale  and
pipetters)should be considered negligible costs, especially
after the first few months of daily measurements.

Table 7-2. Supplies Cost Summary, Using Preparation Kits
Item

Prep. Kits
Scale
ML Pipetters
mL Pipetter
Total Cost

1
$8,800
$110
$690
$320
$9,900
a Cost values are
b MTI can arrang<

3
$26,000
$110
$690
$320
$27,000
Months a'b
6
$53,000
$110
$690
$320
$54,000

12
$110,000
$110
$690
$320
$110,000
rounded to two significant digits.
3 to make bulk kits available with

24
$210,000
$110
$690
$320
$210,000
electrolyte
       and water in 25 L reusable drums, the standard as the small
       20-mL vials, the acid and peroxide in reusable 5 L containers
       with accurate  dispenser and plasticware in a big bag (no
       packaging)  for $4,000 for 1,000 samples, subject  to a
       minimum of order of $12,000.  The 24-month cost for bulk
       supplies would be $96,000.
Table 7-3. Supplies Cost Summary, Preparing Reagents
    Item                     Monthsa

Reagents b
Scale
uL Pipetters
mL Pipetter
Total Cost
1
NA
NA
NA
NA
NA
3
$8,900
$110
$690
$320
$10,000
6
$16,000
$110
$690
$320
$17,000
12
$31,000
$110
$690
$320
$32,000
24
$62,000
$110
$690
$320
$63,000
a Cost values are rounded to two significant digits.
b The "reagents" cost includes disposable supplies and
preparation labor.
7.2.3   Support Equipment
MTI was provided with a 10x10 foottentfor 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 for one week totaled $6.  Total support
equipment costs were $276 per week for rental.
                                                     61

-------
For longer projects, purchase of support equipmentshou Id
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
MTI utilized two people to analyze 197 samples; a sample
preparation person  spent  almost two days performing
sample digestions and an instrument analyst spent three
days analyzing and reporting data results. Combined, the
total operational  time was 2,280 minutes.  Including
instrument setup  and  disassembly,  the total  labor time
expended during  the demonstration was roughly 3,000
minutes.  This time correlates to 50 hours, or five 10-hour
days for one individual. Based on a labor rate of $300 per
day, total  labor cost for  using the PDV 6000 during the
demonstration was $1,500.

Labor  costs for the hypothetical site  assume qualified
technicians are available locally  (i.e., no lodging or per
diem costs are apply).  Table 7-4 summarizes labor costs
for various operational periods, assuming 21 workdays per
month  (on average) and 252  work days per year.  The
costs presented do not separate  supervision and quality
control because these would be associated with use of any
analytical  instrument and are  a portion of the overhead
multiplier built into the labor rate.
Table 7-4.  Labor Costs
Item
1 3
Months
6
12
24
 Technician       $6,300   $18,900 $37,800  $75,600 $151,200
 Supervisor        NA      NA     NA      NA      NA
 Quality Control     NA      NA     NA      NA      NA
 Total	$6,300   $18,900 $37,800  $75,600 $151,200
NA = Not applicable.

7.2.5 Investigation-Derived Waste Disposal
       Cost
MTI generated PPE waste, digestate solution with excess
soil waste, and waste electrolyte solution. The PPE  waste
was  charged  to the  overall  project due  to  project
constraints.  The minimum waste volume is a  5-gallon
container. Mobilization and container drop-off fees were
$1,040; a 5-gallon  soil waste drum was  $400, and  a
5-gallon liquid waste drum was $400. (These costs were
based  on a listed waste stream with hazardous waste
number U151.)

The total demonstration IDW  disposal cost was $1,840.
These  costs may vary significantly from site  to  site,
depending on whetherthe waste is classified as hazardous
or nonhazardous and whether excess sample material  is
generated that requires disposal. Table 7-5 presents IDW
costs for various operational periods,  assuming that waste
generation rates were similar to those encountered during
the demonstration.

It should be  noted that when a large  amount of digestion
samples are conducted for using the PDV 6000, the waste
digestion liquid would be poured out of each digestion
bottle and into a liquid waste container (as opposed to just
discarding the 70 ml_ digestion bottle  containing the liquid,
as was done  during  the  demonstration).  The empty
digestion bottles could  then  be thrown away  as  non-
hazardous waste. Since there is 40 ml_ of digestion liquid
generated   per  sample  analyzed,   there  would  be
approximately 42 liters, or 11  gallons, of digestion liquid
generated per month (40 ml_ x 50 samples x 21 days).
Table 7-5.  IDW Costs

   Item

             1       3
Months

  6        12
                                              24
 Drop Fee    $1,040   $3,120    $6,240   $12,480  $24,960

 Disposal"    $1,400  $2,000    $3,400    $6,000   $10,000
                                                        Total
           $2,440   $5,120    $9,640   $18,480  $34,960
        Disposal costs are estimated  at $1,400 for a 20-gallon
        container and  $2,000 for 55-gallon drum.   The most
        economical combination of containers is used for disposal cost
        estimates.
7.2.6  Summary of PD V 6000 Costs
The   total  cost  for  performing  mercury  analysis  is
summarized in Table  7-6.  This table reflects costs for
project durations of  from  1 to 24 months.  The purchase
option was used for estimating the equipment cost.  For the
first month of use, the total cost is primarily the  instrument
purchase and labor.  As  time progresses, supplies and
labor  become dominant cost  categories,  the  sample
                                                    62

-------
preparation kits being the dominant supplies cost. When
operating the PDV 6000 for periods in excess of three
months,  it may  be  more  economical to  prepare  the

Table 7-6. Summary of Purchase Costs for the PDV 6000
           Item
Quantity    Unit   Unit Cost
                    ($)
                              reagents and purchase the disposable items, as opposed
                              to purchasing the sample extraction kits.
Total Cost for Selected Project Duration
                                                        1-Month   3-Month
                                                  6-Month
                        12-Month    24-Month
Capital Equipment3
Purchase

1

NA

$8,100

$8,100

$8,100

$8,100

$8,100

$8,100
Supplies b
Reagents and Disposable
Micro Pipetters (set of 3)
Repeating Pipetter
Portable Scale
Total Supply Cost
Support Equipment a c
Table (optional) - weekly
Chairs (optional) - weekly
Tent (for inclement
Total Support Equip. Cost
Labor
Field Technician
IDW
Drop Fee
Disposal
Total IDW Costs
Total Cost d
a Costs are rounded to a
b The number of sample
1
1
1
1
-

1
2
1
1

NA
NA
each
set
each
each
	

each
each
each

hour


week

$84
$690
$320
$110
	

$5
$1
$270

$38

$1,040
$400

maximum of three significant digits.
preparation kits (or reagents) provides
$8,800
$690
$320
$110
$9,900

$20
$10
$800
$6,300

$1,040
$1,400
$2,440
$28,000
sufficient
$8,900
$690
$320
$110
$10,000

$60
$25
$800
$18,900

$3,120
$2,000
$5,120
$43,000
supplies to analyze
$16,000
$690
$320
$110
$17,000

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

$6,240
$3,400
$9,640
$74,000
50 samples
$31,000
$690
$320
$110
$32,000

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

$12,480
$6,000
$18,480
$136,000
$62,000
$690
$320
$100
$63,000

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

$24,960
$10,000
$34,960
$260,000
per day. Significant cost savings
        are achieved if reagents are purchased in bulk. The 1-month cost uses sample preparation kits, all other months are based upon preparing
        reagents and purchasing disposable supplies (e.g., beakers, pipette tips).
c       Rental costs were used through the 3-month period for chairs and the 6-month period for the table. Purchase costs were used for longer
        periods. Purchase costs for the tent were used for all periods.
d       Totals are rounded to two significant digits.
From these data, it is apparent that the cost to purchase
the PDV 6000 instrument and accompanying  software
becomes relatively insignificant after 6 months of continual
use. This may imply that the instrument purchase option
is the most cost-effective in many instances; however, the
decision on which procurement option to utilize should be
made on a case-by-case basis.
                              An alternative to the vendor-supplied kits may be desirable
                              due to the relatively high cost of the kits when used over an
                              extended period of time.   MTI  will  supply  the  reagent
                              concentrations to anyone interested is preparing their own
                              extraction reagents.

                              Table 7-7 summarizes costs for the actual demonstration.
                              Note that the 1-month rental cost of the  PDV 6000 was
                              used for capital costs.
                                                       63

-------
The cost per analysis based on 197 samples when renting
the PDV6000 is $43.74 per sample. Thecostperanalysis
for the 197 samples, excluding instrument cost, is $32.57
per sample.

Table 7-7.  PDV 6000 Costs by Category
Category
Instrument
Supplies b
Support
Equipment
Labor
IDW Disposal
Total
Category Cost
$2,200
$2,800
$276
$1,500
$1,840
$8,616
Percentage of
Total Costs a
25.5%
32.5%
3.2%
17.4%
21.4%
100.0%
       The percentages are rounded to one decimal place; the total
       percentage is 100%.
       Includes 20 sample preparation kits, a portable scale, 3-uL
       capacity pipetters, and a milliliter capacity pipetter.
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 7471 B for
all soil and sediment samples.  The referee  laboratory
performed 421 analysis 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, and preparation  of a data
package.  The total cost for  197 samples at $35 would be
approximately $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 an approximate
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.
                                                    64

-------
                                              Chapter 8
                             Summary of Demonstration Results
As discussed previously in this ITVR,  the MTI PDV 6000
was evaluated by having the vendor analyze 197 soil and
sediment samples.  These  197 samples included  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  different  matrices,
concentrations, and types of mercury needed to perform a
comprehensive evaluation of the PDV 6000.

8.1    Primary Objectives
The primary objectives of the demonstration were centered
on evaluation of the field instrument 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 suggestthat
the experimental design was successfulforevaluation of the
MTI PDV 6000. Quantitative results were reviewed. The
results from   this  instrument  were  found  not to   be
comparable  to standard  analyses   performed  by  the
laboratory in  terms  of  precision and  accuracy,  and  the
collected  data provide evidence to support this statement.

The two primary sensitivity evaluations performed for this
demonstration  were the  MDL and   PQL.   Following
procedures established in 40  CFR Part 136, the MDL is
between 1.67 and 3.67 mg/kg.  The equivalent MDL for the
referee  laboratory  is  0.0026  mg/kg.   Examples from
analyzed samples, however, suggestthatthe MTI MDL may
be closer to 0.811 mg/kg or lower. Values detected at these
lowerlevels;  however, would likely be highly inaccurate and
should only be considered as  a "positive hit" without any
implied accuracy or precision.  The  calculated MDL is only
intended  as  a  statical estimation and not a true test of
instrument sensitivity.

The low standard calculations suggest that a PQL for the
MTI field instrument is 4-8 mg/kg. The %D for the average
MTI result for  a sample concentration of 4.75 mg/kg is
46%. The referee laboratory PQL confirmed during the
demonstration  is 0.005 mg/kg with a %D of 10% or less,
based upon  a  lower calibration standard. Both the MDL
and PQL  were  determined for soils and sediments.

Accuracy was  evaluated  by  comparison to SRMs and
comparison  to the referee laboratory analysis  for field
samples.  This included spiked fie Id samples for evaluation
of additional concentrations not  otherwise available.  In
summary, MTI  data were within the SRM 95% prediction
intervals about 50% of the time.  ALSI data compared to
SRM values were within the 95% prediction interval 89% of
the time.  The comparison  between the MTI field data and
the ALSI  results suggests that the two data sets are not
different,  but the similarity for individual samples is often
the result of high variability associated with the MTI
reported values.

In determining  the number of results significantly above or
below the value  reported  by the  referee laboratory, the
number of MTI average values greater than 50%  different
from the  referee  laboratory  results  or  SRM reference
values was only 6 for 21 different sample lots and those
greater than 100% different were only 2 for 21  different
sample lots.  MTI  results,  therefore, appear to provide a
rough estimate of accuracy forfield determination,  and may
be  affected   by  interferences   not   identified  by this
demonstration. It should be concluded, however, thatthe
MTI PDV 6000 did not compare well to laboratory Method
7471B in  terms of obtaining accurate analyses of mercury
in soil.
                                                   65

-------
Precision was determined by analysis of replicate samples.
The precision of the MTI field instrument did not compare
well to the measured laboratory precision. The overall RSD
for MTI is 35.1% which is above the 25% RSD objective set
for the laboratory.  The overall laboratory RSD is 22.3%.

Time measurements were based on the length of time the
operator  spent performing  all   phases of the  analyses,
including setup, calibration, and sample analyses (including
all reanalyses).   MTI  analyzed 197  samples in 2,280
minutes over three days, which  averaged  to 11.6 minutes
per sample  result.  Based  on this, an operator could be
expected to  analyze 41 samples (8 hours x 60  minutes •*•
11.6 minutes/sample) in an 8-hour day.

Cost of the MTI sample analyses 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 that the instrument is either purchased or
                                   rented, and as the sample number increases, the cost per
                                   sample would decrease.  A comparison of the field MTI
                                   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 incurred to the project
                                   due to waiting  for analysis  results  to  return from  the
                                   laboratory  (potentially  several   mobilizations   and
                                   demobilizations,  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 MTI and the Referee Laboratory
       Site
Concentration Range
                                               Soil
                                         Sediment
                                                                    Sample Type
Spiked Soil
SRM
Carson River
(Subtotal = 48)

Puget Sound
(Subtotal = 51)
Oak Ridge
(Subtotal = 54)
Manufacturing
(Subtotal = 44)
Subtotal
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)


3
0
0
13
0
0
13
23

52
10
0
0
0
10
3
10
0

33
7
0
7
7
7
0
0
7

35
0
7
14
3
11
14
14
14

77
                                                    66

-------
Table 8-2. Summary of PDV 6000 Results for the Primary Objectives
Demonstration Performance Results
Objective Evaluation Basis PDV 6000
Instrument
Sensitivity
MDL. Method from 40 CFR Part 1 36 Between 1 .67 and 3.67
mg/kg
Reference Method
0.0026 mg/kg
Accuracy
Precision
PQL.   Low concentration SRMs and
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.
                                                             Approximately 4-8 mg/kg    0.005 mg/kg
Mil's PDV 6000  is not within expected accuracy for
laboratory analyses. Mil's field instrument was only
within the SRM 95% prediction  intervals about 50% of the
time. The comparison between the MTI field data and the
ALSI results suggests that the two data sets are not
different but similarity for individual samples is often the
result of high variability associated with the MTI reported
values.  The MTI  PDV does,  however, appear to provide
a rough estimate  of mercury  concentrations in soil  and
sediment.

Overall RSD for the MTI PDV 6000 was computed  to be
35.1% compared to the referee laboratory RSD of 22.3%.
This is a combined measure  of precision which includes
sampling and aliquoting variations.
Time per Analysis
Cost
Timed daily operations for 3 days and
divided the total time by the total number of
analyses.
Costs were provided by MTI 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.
Two MTI representatives performed all setup, calibration
checks, sample preparation, sample analysis, and
equipment disassembly. Individual analyses took 7.5
minutes each, but the total time for preparation and
analysis averaged approximately 11.6 minutes per
sample.

The cost per analysis, based on measurement of 197
samples, when incurring a minimum 1-month rental fee
for the PDV 6000, is $43.74 per sample. Excluding the
instrument rental cost, the  cost for analyzing the 197
samples is $32.57 per sample. The total cost for
equipment rental and  necessary supplies during the
demonstration is  estimated at $8,600. The cost breakout
for the demonstration  by category is: capital costs,
25.5%; supplies,  32.5%; support equipment, 3.2%; labor,
17.4%; and IDW disposal,  21.4%.
                                                      67

-------
Table 8-3. Summary of PDV 6000 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
Observation of the equipment, operating
procedures, and any 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 the equipment design and
construction, and evaluation of any
necessary repairs or instrument downtime
during the demonstration.
The instrument appears to be easy to operate as a
stand-alone unit or in conjunction with the VAS software.
Training on the unit and the VAS software would be
recommended for first-time users. A laboratory or field
technician with a basic knowledge of chemistry and basic
computer skills could operate the equipment after a 1-day
training course.

No significant health and safety concerns were noted for
the PDV 6000. The main potential health and safety
concern observed during the demonstration was potential
exposure to fumes resulting from the reactions that
occurred during sample preparation. This observation
emphasizes the need for PPE such as safety glasses,
gloves, and possibly a  laboratory apron when conducting
acid digestions.

The PDV 6000 was easily portable due to its compact
size and weight, and by the method by which it is
transported (i.e., the unit and  instrument accessories  are
transported within a briefcase size carrying case. The
unit was easily set up by MTI  and was easily carried while
walking. The  instrument can be characterized as truly
field portable.

The PDV 6000 control  unit is well designed and
constructed for durability. The hard shell carrying case
used to transport the unit and ancillary equipment
provides adequate protection  of electrodes and  other
sensitive components.
 Availability of the
 Vendor
 Instruments and
 Supplies
Review of vendor website and telephone
calls to the vendor after the demonstration.
Per MTI, the PDV 6000 units are stocked in the U.S. and
available for purchase, rent, or lease within one week of
order placement through the new MTI U.S. operations.
Spare parts and consumable supplies can be added to
the original PDV 6000 order. Supplies not typically
provided by MTI (pipetters and laboratory  scale) are
readily available from laboratory supply firms.
                                                        68

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

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

Monitoring Technologies International Pty.  Ltd.  2002a.
  PDV   6000  -  Portable  Heavy  Metals  Analyzer,
  Operation Manual, version 2.2.

Monitoring Technologies International Pty.  Ltd.  2002b.
  Voltammetric Analysis System  - VAS User's Guide,
  version 2.1.

Rothchild, E.R., R.R. Turner, S.H. Stow, M.A. Bogle, L.K.
  Hyder, O.M. Sealand, H.J. Wyrick. 1984. Investigation
  of Subsurface Mercury at the Oak Ridge Y-12 Plant.
  Oak Ridge National Laboratory, TN. 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 1 994.

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 DC.

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/index. html.

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

U.S. Environmental Protection  Agency. 2003.  Field
  Demonstration and Quality Assurance Project Plan -
  Field Analysis  of Mercury in  Soil and  Sediment.
  August 2003. Washington D.C., EPA/600/R-05/053.

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.Fishersci.com, 2003.

www.monitoring-technologies.com, 2003.

www.mti.com.au, 2003.
                                                  69

-------
                                              Appendix A
                                            MTI  Comments
Site Demonstration Comments

The ITVR demonstration showed that the PDV 6000 can
produce data in the field that can confidently be used to
effectively manage on site investigations and remediation
projects.   MTI  is  a  small  company  and  values the
opportunity to compare its method to a fully validated
reference method. MTI would like to thank  the teams at
SAIC and the EPA for setting up the program and looking
after the vendors in such a professional way.

MTI completed all 197 samples in a 3-day working period,
2 days using 2 technicians and the third day using just 1.
This time would have been significantly reduced had the
PDV 6000 method been used to classify soil samples into
set concentration bands as against a  more quantitative
analysis.

The PDV 6000 when  used in  the  field is designed to
provide screening  data and is not expected to generate
laboratory quality data over a wide concentration  range.
The instrumentis calibrated using a single pointcalibration,
either by the method of curve  comparison or standard
addition. The concentration selected to  calibrate the PDV
6000 is equivalent to the pollutant action level for that site.
This concentration is  simply achieved by varying the
volume of standard added to the analysis cup. The amount
of sam pie extract analysed can also be varied to reflect the
expected concentration range in the soil. This approach
has two benefits:

1.      It is very easy to change the calibration range to
        reflect changing pollutant  concentrations  in the
        soil.
2.      It gives the best accuracy around the important
        action concentration without the need to generate
        multipoint calibration curves and therefore  allows
        for  significantly faster sample throughput.

The PDV 6000 field analysis procedure has been designed
to give the best accuracy around the site specific pollutant
concentration that drives the investigation or remediation.
For example, if the threshold for contamination is 5  mg/kg
the standard  concentration and analysis procedure sets
5mg/kg  as the midpoint of the  calibration. This will provide
accurate results within a 1-10 mg/kg range (x10 range) for
the samples analysed. The PDV calibration curve is linear
over 2 orders of magnitude and therefore a  single point
calibration is sufficient to cover 1 order of magnitude.

Table A-1  shows  the volumes and  analysis methods
recommended   for   the   commonly   encountered
contamination ranges.
 This appendix was written solely by MTI. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the PDV 6000. 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 PDV 6000 are discussed in the body of
 the ITVR.

                                                     70

-------
Table A-1. Calibration Standard and Analysis Information
Target Soil
Concentration (mg/kg)
0.5-5
2-20
10- 100
100-1000
Volume of sample
extract (ml) to add to
analysis cup
5
2
1
0.1
Volume of Hg
Electrolyte (ml) to add
to analysis cup
15
20
20
20
Deposit time
(seconds)
200
100
60
30-60
Hg calibration
concentration
(mg/ml)
0.025-0.075
0.01 -0.1
0.025-0.25
0.025-0.25
The above procedure could not be adopted for this ITVR
evaluation, as a quantitative result was wanted across a
very wide  concentration range. The concentration ranges
encountered were:

Carson River: low x500 (0.001 - 0.5 ppm), mid x100 (0.5
- 50 ppm), high x200 (50 - >1000 ppm)
Puget Sound: low x10,000 (0.001 -10 ppm, highxSO (10 -
500 ppm)
Manufacturing Site: x200 (5 - 1000 ppm)
Oak Ridge: low x100 0.1 -  10 ppm), high x80 (10 - 800
ppm)

This meant that the procedure used to analyze the sample
deviated from the standard operating  procedure for the
PDV 6000. The data generated however clearly shows that
the PDV 6000 method has similar precision and accuracy
to the laboratory method when the calibration  is close to
the actual concentration of  mercury in the sample. This
makes the PDV 6000 perfectly acceptable for managing
site investigations and remediations.

It should also be noted  that in this evaluation, all of the
samples had been carefully  prepared to ensure they were
virtually identical for all the vendors. In the field, the issue
of sample homogenization  is critical.  The  PDV 6000
procedure uses a 2 g  sample that can be prepared on site
using  a very quick mixing procedure from an initial 500 -
1000g sample. Two grams are considered  to  be  the
minimum  amount of  sample that can  be used  to get a
representative field analysis for soil types that include,
clays, chalks and  large particles of other porous stones.
The relevance of any field or laboratory analysis data will
only be good if the sampling is statistically meaningful and
sample size is an important  factor in this. The smaller the
sample analyzed on site, the more samples that must  be
analyzed to provide meaningful data.
Comments   on   SRM   Precision   and   Accuracy
Interpretation

As discussed above, quantifying over wide concentration
ranges is not ideal for the PDV as a single calibration point
cannot cover the entire range. The PDV operators in this
situation therefore selected the mid point of the expected
sample  concentration  range to  set the calibration  to,
knowing that it would be less  accurate at either end of the
range. It was hoped to initially screen the samples and
those that fell out of the calibration range could be  re-
analyzed  during  the  course  of the  evaluation.  The
emergencies unfortunately prevented this from being done
for all of these samples.  The data generated was still
submitted and MTI accepted that this would compromise
the statistical analysis of the results at either end of the
range.

Of  the  SRM  sets   analyzed,  57%   of  the   target
concentrations were at the  extreme limit of the sample set
and therefore out of the effective calibration range of the
PDV. Where the SRMs were within the calibration range of
the PDV, good agreement with the expected concentration
was achieved, together with reasonable precision. (lot# 48
%RSD 26.8, lot#49  %RSD 28.2, lot# 50  %RSD 38.2, lot#
62 %RSD 21.1, lot# 63 %RSD 34.8 and lot# 66  %RSD
26.6), which compares to  an average 25% RSD  for the
laboratory analysis. Not shown in the report is the data for
SRM lot# 46 (%RSD 20), which on extraction evolved large
amounts of Bromine. The targetvalue was 21 ppm and the
PDV method averaged 18  ppm over 5 samples analyzed
using the 10 to 100 ppm calibration range with a %  RSD of
15.3. Sample lot# 44 also evolved bromine, but these were
reported as below detection  limits using  the 1-10 ppm
calibration range, even though the expected concentration
was 4.7 ppm. For this sample lot 5 ml_ of sample  extract
were added to the electrolyte, compared to 1  ml_  for lot#
 This appendix was written solely by MTI. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the PDV 6000.  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 PDV 6000 are discussed in the body of
 the ITVR.

                                                    71

-------
46. The extra Bromine in the analysis cup could  have
allowed the formation of the relatively insoluble HgBr2. It is
suggested  that the evolution of bromine on  site  would
indicate that there was a serious problem  with the soil in
the area and further  investigation  of the site would  be
needed. The laboratory was unable to accurately detect
mercury in either of these brominated SRMs.

Lot# 52 was within the calibration  range,  but both the
laboratory and the PDV method reported significantly lower
concentrations than expected.

The low concentration  SRM results from the initial analysis
using a 1-10 ppm calibration  range did  not detect any
Mercury and only a trace for those samples with 0.6 ppm
and higher. The exception was samples from lot#38 that
showed good peaks. The analysis was then repeated using
the very low level  method. The  mercury  concentrations
using the low level method were typically reported as up to
5 times the expected  concentration.  For  these samples
(Lot#35, 37 and 57)  10  ml_ of  sample  and  10 ml_  of
electrolyte were used with a 120-180 second deposit time.
These  samples were  run  sequentially, using the same
batch of electrolyte. The initial matrix blank indicated  no
mercury. The sample analysis  however  all  showed a
significant  peak at the Mercury position. This shows
mercury was in the analysis cup. The results for lot# 2 and
35 which are below the detection limits of the PDV indicate
approximately 40 parts per billion of mercury was in the
analysis cup. This is equivalentto 1.6 ppm in the soil. All of
these samples stood  in the extraction bottle for over 24
hours before analysis, which is not in the usual SO P, where
analysis is required within a few hours of the extraction.

The better variability in %RSD between the SRMs and the
field  samples could be due  to the  chemical form of the
mercury in  the sample. The field samples have been in
contact with the Mercury for several decades and as such
the mercury can form tighter associations with the matrix.
SRMs  due  to their method of production are often highly
processed with very small particle sizes and rarely contain
elemental   Hg  or  Hg in  amalgams. The  PDV  6000
extraction procedure is less effective for these forms of Hg
which were present in  the field samples. Variability within
the field sample matrix, even though some processing had
occurred would also vary the extraction efficiency.
The results obtained from the SRMs shows that the PDV
6000 field method gives acceptable precision and accuracy
when  used  in accordance with  its designed  operating
parameters.

Comments   on   the   Precision   and  Accuracy
Interpretation of Field samples

The  PDV 6000  field  extraction is the  main  cause of
variability between the  results within each sample lot. This
extraction method is not time or temperature controlled and
cannot be expected to give absolutely consistent or 100%
extraction efficiency. It is expected that approximately 85%-
100% of the Mercury will be extracted during the initial acid
digest and peroxide addition, where temperatures  will
reach 80 °C. The  addition of water and electrolyte does not
completely  neutralize  the solution, as residual acidity is
needed to keep  any mercury extracted in solution. This
means further extraction may occur  over time. It was
however decided to keep the soil in the extraction solution
before analysis and not to decant sample to a separate
container in  order to reduce the waste generated in the
field   and   reduce  cross  contamination of  the  low
concentration range samples.

In some cases the samples were re-analyzed at the end of
the day using the correct calibration range, which means
thatthe sample remained in the extraction solution for over
5 hours. The combination of a more accurate calibration
and longer extraction time will have given the  much wider
%RSD observed for many of the sample  batches as the
statistics will include results from both sets of analysis.

For example, lot# 13 from the Manufacturing Site gives an
average of  15  ppm  for  5 samples when  the actual
concentration  is  5.5 ppm.  However, 2 of those samples
were re-analyzed using the lower concentration calibration
range and gave an average of 5.15 ppm with a %RSD of
17.8.  Sample lot#  32, also  from  the manufacturing site,
gives  an average concentration from 5 samples of 875.5
ppm with  a %RSD  of 40. If the one high value reported is
removed from  this set  of results, the average value is 700
ppm with a %RSD of 3. The expected result was 650 ppm.
It is likely thatthe high sample result was genuine because
the laboratory also  found one sample in  this batch with
more  than twice the concentration of the other samples.
 This appendix was written solely by MTI. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the PDV 6000. 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 PDV 6000 are discussed in the body of
 the ITVR.

                                                     72

-------
Forsoilsamples above 1,000ppm, the extraction efficiency
will be lower depending on the competing effects of other
compounds  in the matrix neutralizing the acid  and the
physical form  of  the  Mercury.  Elemental Mercury and
amalgams are the most difficult to dissolve.

In practice  however, soils containing over 310 ppm are
usually considered highly contaminated and the PDV and
laboratory methods both gave similar results for samples
in this range.

The field samples that theoretically should have had less
than 1 ppm in (Lot# 2,5,11) were detected as more than
1 ppm by the PDV 6000 method. In every case the raw data
shows a significant peak at the mercury position. These
samples were again exposed to the extraction liquid for 24
hours and were also analyzed  using the very low level
method. Lot#1 was only analyzed at  the 1-10 ppm range
and  showed no  mercury  present.  Sample  lot#4 was
analyzed as part of a separate batch of sam pies, and gave
an average concentration of 0.28 ppm compared to the
laboratory 0.11 ppm  average.  Sample lot#6 out of 5
samples were analyzed  in the  same batch as lot#4 and
showed less than 0.5 ppm  in the sample. The raw data
gives an average of 0.46 for 4 samples  for the values
above 0.25 ppm estimated and  the  laboratory estimated
0.23 ppm. The other 3 samples from  the set gave  an
average concentration of 0.19 ppm. These results were not
submitted in the data set as the standard run with these
samples was accidentally deleted while calculating the
results.  The estimated concentrations  are  based on a
comparison  with a standard run using different  analysis
times.

The results from sample lots# 1, 4 and 6 indicate that the
values obtained for the other low concentration samples
may be  contamination   in  the reagents, possibly the
electrolyte used to dilute the initial extract.

Comments on the Calculated MDL and PQL

The lowest quantifiable concentration of mercury detected
by the PDV 6000 is 2.5 micrograms per liter. The dilution
effect of the soil extraction procedure and the volume of
the extract added to the analysis cup  would mean 2.5 ppb
is equivalent to 0.1  mg/kg in  the  soil. At this  level of
sensitivity,  sample  or  reagent  contamination  during
extraction or handling may cause an erroneous result.

The very low concentration samples were analyzed using
different calibration ranges. The reported results are from
the 0.1-1 ppm calibration range. The initial results at the
1-10  ppm  range did  not  detect Mercury  above 1ppm,
indicating all samples were below 1 ppm. The subsequent
analysis for samples on lot# 2,5, 11, 35, 37 and 57 using
the same batch of extraction reagents gave results greater
than  1 ppm. Unfortunately, no blank was analyzed for the
extraction reagent and contamination from this part of the
procedure cannot be ruled outdue to the close proximity of
samples and extraction reagents in  this trial.

All of the low level sam pies showed Mercury peaks that are
significantly  higher than  the  2.5  ppb  peak. This  does
indicate that Mercury was present in the analysis solution,
but the source is not clear. The end result is that in this trial
the true MDL could not be  determined from the data set.
The PQL estimated in the report is also slightly high.

The  sample lots analyzed  in the low level range  have
concentrations that jump from 0.6 ppm to 4.75 ppm. This
large jump  makes it difficult to calculate a PQL from the
data  at anything less than  4 ppm.  If  the  estimated
contribution by contamination is removed from the results
obtained and the results from sam pie lots# 4 and 6, a PQL
of around 1 ppm is obtained. This is in line with  MTI's
reported field PQL of between 0.5 and 1 ppm.

Comments on the Economic Analysis

When evaluating the costs of an instrument it should also
be taken into consideration any other analyses that can be
carried out with it. The PDV 6000 can be used to analyze
soil and  water samples  for  many toxic  heavy metals,
including As, Cd, Cr, Cu, Hg, Ni,  Pb, Sb, Sn, Tl, Te and Zn
with low part per billion detection limits. In most cases the
extraction procedure is the same forall metals. This means
only  a  few  extra reagents such as standards would  be
required in order to analyze a much wider suite of metals.
For sites where several metals a re present, the per sam pie
cost of the PDV would be considerably reduced.
 This appendix was written solely by MTI. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the PDV 6000.  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 PDV 6000 are discussed in the body of
 the ITVR.

                                                    73

-------
Method Improvements that Have Been Implemented

The  evaluation  gave  MTI  a wonderful  opportunity  to
compare its method against a fully approved method on
samples that are genuine field samples. This information
has highlighted some improvements that have now been
incorporated  into the product and analysis procedure.

The PDV instrument has had a software modification that
allows greater sensitivity to  be  achieved. This gives an
improved  signal to noise ratio  and will  generate better
peaks for  quantification. This will improve the instrument
repeatability.
For the very low detection limits, the longer analysis times
will allow any  Mercury  coming  from contamination  to
contribute to the total mercury result to a  significantly
greater extent.  Due  to  the volumes of extract used,
electrolyte blanks can only performed once  on the  bulk
electrolyte  and not  for  each  sample. The  analysis
procedure has been modified to run bulk electrolyte blanks
more frequently to exclude contamination in this reagent as
a source of error.

The  VAS software has  been  modified to automatically
calculate the soil concentration  directly. This removes the
need to transfer data to another program for the final data
generation and saves several hours of labor.
 This appendix was written solely by MTI. The statements presented in this appendix represent the developer's point of view and summarize
 the claims made by the developer regarding the PDV 6000. 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 PDV 6000 are discussed in the body of
 the ITVR.

                                                      74

-------
                                              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 32  separate
sample lots) 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  MTI 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 test'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 by the number of samples in their data
set. The effective number of degrees of freedom is then
calculated.
Where:

       f       = effective number of degrees of freedom
       VL      = variance for the laboratory results
       nL      = number of samples for the laboratory
               data set
       Vv      = variance for the vendor results
       nv      = 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 u at the 0.01
level of significance using the following:
                                                     75

-------
Unified Hypothesis Test
For a  specified vendor,  let Y,j be  the measured  Hg
concentration for the f  replicate  of  the ith sample  for
/=1,2,...,l and)= 1,2,...,Ji. LetX^= log(Y^), where log is the
logarithm to the  base 10.  Define x,log  to be the average
over all log replicates for the Ith sample given by:
                                                        Where x M is approximately a chi-square random variable
                                                        with (1-1) degrees of freedom:
5  =  7
                                                                    -'
                                                                      tog
                          z'log
                                                                                                 ilog
                    -J
                          '
                           log
                                                                                 and
Denote the estimate of the variance of the log replicates for
the Ith sample to be:
                      -1
Now for the reference laboratory, let Y',y be the measured
Hg concentration for the/1 replicate of the ith sample for
/  =1,2,...,!' and  j  =  1,2,. ...J',.   Denote the  reference
laboratory quantities X',j, x/, and s'2 defined in  a manner
similar to the corresponding quantities for the vendor.

Assumptions: Assume that the vendormeasurements, Y,y,
are independent and identically distributed according to a
lognormal distribution with  parameters u,and o2. That is,
X,y= log(Y,y) is distributed according to a normal distribution
with expected value u,and variance o2.  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:

     HQ : /jj = fj'j + 5, for some S and i = I,..., I

against the alternative hypothesis that the equality does not
hold for at least one value of /.

The null hypothesis H0 is rejected for large values of:
     Zi-i =
                                                                            i-i
            i-1
                          1 pool
                                                        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  MTI

                                                        SAIC performed  a unified hypothesis test analysis  to
                                                        assess the comparability of analytical results provided by
                                                        MTI  and those  provided by ALSI.   MTI  and ALSI both
                                                        supplied multiple assays on replicates derived from a total
                                                        of 31 different  sample  lots,  be they field materials  or
                                                        reference materials.  The MTI 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 MTI  and ALSI population  means  for given
                                                        sample  lot. Equality of variances is assumed.

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

                                                             H10:  (MTI Lot log mean)  = (ALSI Lot  log mean)

                                                        H10 was strongly  rejected in  that the chi-square  statistic
                                                        was 941.12, which exceeds the upper 99th percentile of the
                                                        chi-square distribution with 31 degrees of freedom having
                                                        a value of 52.19.

                                                        The  null hypothesis  was  rejected  in part because  MTI
                                                        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
                                                     76

-------
H20: (MTI Lot log mean) = (ALSI Lot log mean) +(delta),
where delta is a single value that does not change from
one sample lotto another, unlike the lot log means.  H20
was rejected strongly in that the chi-square statistic  was
699.19, which exceeded the upper 99th percentile of the
chi-square  distribution with 30 degrees of freedom with a
value of 50.89.  In this analysis, delta was estimated to be
0.355 in logarithmic (base 10) space, which indicates an
average upward bias for MTI of 100355=12.265  or about
127%.

For both hypotheses, the large  values of the chi-square
test statistics summarize the disagreement between the
MTI and ALSI analytical results.  Furthermore, a review of
the statistical analysis details indicates that the overall
Table B-1. Unified Hypothesis Test Summary Information

  Hypothesis    Tota! SamP|e   Excluded Lot       DF
                                     discordance between MTI  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 com parison. 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.
                                                             pool
                                                     Delta
                                                    Chi-square
                                                    P-value
     H,,
31
31
None
None
31
30
0.02645
0.02645
0.0000
0.3546
941.12
699.19
0.000000
0.000000
                                                     77

-------