Hazard Ranking System Issue Analysis:
    Laboratory Limits of Detection
                MITRE

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Hazard  Ranking System Issue  Analysis:
     Laboratory Limits  of  Detection
                   Jerry M. Fitzgerald
                       July 1986
                      MTR-86W77
                        SPONSOR:
                 U.S. Environmental Protection Agency
                      CONTRACT NO.:
                       EPA-68-01-7054
                   The MITRE Corporation
                       Metrek Division
                      7525 Colshire Drive
                   McLean, Virginia 22102-3481

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  Department Approval:,
MITRE Project Approval:.

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                              ABSTRACT
     The U.S. Environmental Protection Agency (EPA) uses the Hazard
Ranking System (HRS) to estimate the effects of the release or
potential release of hazardous substances; this estimate is required
by the Comprehensive Environmental Response, Compensation,  and
Liability Act of 1980 (CERCIA).  Scoring a site for release or
potential release requires the detection of hazardous substances by
chemical analysis.  The Limit of Detection (LOD) for analytical
methods is thus of concern to EPA because a lower value of  LOD will
increase the number of different substances reported present at a
site.  This technical review addresses two concerns regarding LODs
and their impact on the HRS.

     The first concern is:  what is the likelihood, in the near
term, that LODs for chemicals which are frequently reported at
National Priorities List (NPL) sites will reach significantly
smaller concentrations?  A number of sources were consulted to
arrive at the conclusion that LODs will be reduced only slightly, if
at all, in the near term.  Around 1 ppb or so, most methods have so
much inherent imprecision that the number of repetitive analyses
required to measure a given lower concentration is prohibitively
large.  Unless there is a special need for data below around 1 ppb,
then an LOD barrier has been reached in essence.

     The second concern is:  radioactive elements can be measured
either by radiochemical counting or else by methods currently in use
for environmental analysis of metals.  There could be a substantial
difference in LOD between the two techniques and hence a method-
dependent bias in reporting the presence or absence of radioactive
elements.

     Five radioactive elements, of importance in the HRS program,
were selected for a comparative study.  For those radioactive
elements with half-lives of around a billion years, the radio-
chemical LOD values are about the same as those obtained by
spectroscopic methods.  But, if the element in question has a
half-life of only a few thousand years, the radiochemical LOD is
around a million times smaller than the spectroscopic LOD.   There-
fore, a bias for radiochemical detection exists if radioactive
elements with short half-lives are in a sample from an NPL site.
                                 iii

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                         TABLE OF CONTENTS

                                                                 Page

LIST OF TABLES                                                    vi

1.0  INTRODUCTION                                                  1

1.1  Background                                                    1
1.2.  Limits of Detection (LOD) and Estimation
     of Hazard                                                     3
1.3  Objectives                                                    4
1.4  Scope and Approach                                            5
1.5  Organization of the Paper                                     6

2.0  ORIGIN AND DEFINITIONS OF LOD                                 9

2.1  Origin of the LOD Concept                                     9
2.2  Description of the LOD                                       10
2.3  Calculation of the LOD                                       11

3.0  REGULATORY SPECIFICATION OF LODs                             13

4.0  POTENTIAL FOR IMPROVEMENTS IN LABORATORY LOD VALUES           19

4.1  Past Improvements in the LOD                                 19
4.2  LOD Limits from Interlaboratory Data                         21
4.3  LOD Limits from Proficiency Testing Data                     23

5.0  EQUIVALENCE OF LODs FOR RADIOCHEMICAL COUNTING
     COMPARED TO SPECTROSCOPIC METHODS                            25

5.1  Selection of Elements to be Considered                       25
5.2  Quantitative Principles for Radionuclides                    26
5.3  Inorganic LODs for Comparison Purposes                       27
5.4  LOD Values for Radioactive Elements in
     Environmental Samples                                        27

6.0  CONCLUSIONS                                                  31

6.1  Anticipated Changes in Operational LODs                      31
6.2  LOD Comparisons Between Radiochemical and
     Spectroscope Techniques                                      33

REFERENCES                                                        35

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                           LIST OF TABLES

Table Number                                                     Page

     1            Limits of Detection Required By Two
                  EPA Programs for Substances Found at
                  NPL Sites                                       15

     2            Limits of Detection for Radioactive
                  Substances Found at NPL Sites                   30
                                 vi

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1.0  INTRODUCTION




1.1  Background



     The Comprehensive Environmental Response, Compensation, and




Liability Act of 1980 (CERCIA) (PL 96-510) requires the President to




identify national priorities for remedial action among releases or




threatened releases of hazardous substances.  These releases are to




be identified based on criteria promulgated in the National




Contingency Plan (NCP).  On July 16, 1982, EPA promulgated the




Hazard Ranking System (HRS) as Appendix A to the NCP (40 CFR 300;



47 FR 31180).  The HRS comprises the criteria required under CERCLA




and is used by EPA to estimate the relative potential hazard posed




by releases or threatened releases of hazardous substances:




     The HRS is a means for applying uniform technical judgment




regarding the potential hazards presented by a release relative to




other releases.  The HRS is used in identifying releases as national




priorities for further investigation and possible remedial action by




assigning numerical values (according to prescribed guidelines) to




factors that characterize the potential of any given release to




cause harm.  The values are manipulated mathematically to yield a




single score that is designed to indicate the potential hazard posed




by each release relative to other releases.  This score is one of




the criteria used by EPA in determining whether the release should



be placed on the National Priorities List (NPL).

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     During the original NCP rulemaking process and the subsequent

application of the HRS to specific releases,  a number of technical

issues have been raised regarding the HRS.   These issues concern the

desire for modifications to the HRS to further improve its

capability to estimate the relative potential hazard of releases.

The issues include:

     •  Review of other existing ranking systems suitable for
        ranking hazardous waste sites for the NFL

     •  Feasibility of considering ground water flow direction and
        distance, as well as defining "aquifer of concern," in
        determining potentially affected targets

     •  Development of a human food chain exposure evaluation
        methodology

     •  Development of a potential for air release factor category
        in the HRS air pathway

     •  Review of the adequacy of the target distance specified in
        the air pathway

     •  Feasibility of considering the accumulation of hazardous
        substances in indoor environments

     •  Feasibility of developing factors to account for
        environmental attenuation of hazardous substances in ground
        and surface water

     •  Feasibility of developing a more discriminating toxicity
        factor

     •  Refinement of the definition of "significance" as it relates
        to observed releases

     •  Suitability of the current HRS default value for an unknown
        waste quantity

     •  Feasibility of determining and using hazardous substance
        concentration data

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     •  Feasibility of evaluating waste quantity on a hazardous
        constituent basis

     •  Review of the adequacy of the target distance specified in
        the surface water pathway

     •  Development of a sensitive environment evaluation methodology

     •  Feasibility of revising the containment factors to increase
        discrimination among facilities

     •  Review of the potential for future changes in laboratory
        detection limits to affect the types of sites considered for
        the NPL

     Each technical issue is the subject of one or more separate but

related reports.  These reports, although providing background,

analysis,  conclusions, and recommendations regarding the technical

issue, will not directly affect the HRS.  Rather, these reports will

be used by an EPA working group that will assess and integrate the

results and prepare recommendations to EPA management regarding

future changes to the HRS.  Any changes will then be proposed in

Federal notice and comment rulemaking as formal changes to the NCP.

The following section describes the specific issue that is the

subject of this report.

1.2- Limits of Detection (LOP) and Estimation of Hazard

     The EPA uses the HRS to estimate the relative potential hazard

posed by releases or threatened releases of hazardous substances.

When the HRS was originally developed, the laboratory limits of

detection (LOD) for substances likely to be found at release sites

were typically in the range of parts-per-billion (ppb) to

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parts-per-million (ppm).  For purposes of the HRS,  EPA considers




hazardous substances detected at these concentrations to pose a




potential for concern.  Several of the rating factors used in the




HRS (e.g., observed releases and toxicity) can be affected by the




LOD because these factors rely on a determination that hazardous



substances are identified at sampling locations.




     EPA is concerned that if analytical laboratory detection limits




for hazardous substances were to decrease significantly during the




next few years,  then substances could be detected at release sites




at levels where they may not pose a potential for concern.  If such




a lowering of analytical detection limits was to occur, then it




could be necessary to specify minimum concentrations below which the




hazardous substances could not be used for HRS estimates.




1.3  Objectives




     There are two objectives for this report.  Both objectives are




united by a concern with the analytical LCDs for chemical substances




frequently found at hazardous sites.




     The first objective is to identify the current LOD values for




substances which occur frequently at hazardous waste sites and to




estimate whether the LODs for some or all of these  substances will



improve (be lowered) over the next few years.




     The second objective is to identify whether substantial




differences might exist in LODs for different methods of quantifying




certain radioactive elements.  Large differences in LODs will result

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in a bias for detection of some radioactive elements when measured

in different ways.  This can affect the HRS score.

1.4  Scope and Approach

     Examination of the question of improvements in LCDs for

hazardous substance determination is restricted to those kinds of

procedures currently used in environmental analysis, since it is

these procedures that are commonly used in the site evaluation phase

of the Hazardous Substance Response Plan (40 CFR 300.66).  The

presentation begins by tracing the concept of LOD from early use in

the laboratory, and on to more sophisticated scientific treatments.

The interplay of technical ability and regulatory needs are

demonstrated by using LOD criteria from the EPA Contract Laboratory

Program (CLP) and the guidelines under the Clean Water Act.

     Finally, the likelihood of major improvements in LODs for the

substances involved in the HRS is discussed.  The likelihood of

improvement is based on three considerations.

     •  How the LODs for current environmental procedures can be
        improved

     •  Compilations of data from interlaboratory analyses which
        show an exponential worsening of precision (repeatability of
        data) as concentration is decreased

     •  Proficiency test data for many analyte concentrations which
        show degradations of precision as concentrations are lowered

     The approach used for all three factors above is to look for

any general trends that could lead to improved LOD values for the

kinds of environmental methods considered in this review.

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     The consideration of LOD values for radiochemical counting




compared to the more usual analytical chemistry procedures used to




analyze environmental samples for quantification of inorganic




substances will be limited to five elements.   These elements are




used as models for the more general case.  These five were selected



because they have also been reported at NPL sites.   LOD values



obtained from two independent sources are compared  against each




other.  Comparisons between LODs of different elements is made in




order to identify any trends in sensitivities.




1.5  Organization of the Paper




     This report first describes the scientific origins of the LOD




concept and then addresses the formal definition of LOD by




scientific organizations.  Methods of calculating LOD are summarized




and the results compared.  Current regulatory limits of detection




for two EPA programs for hazardous substances are then tabulated and




discussed.  The substances listed are those likely  to be present at




release sites, based on reported findings.  Following this, an




assessment is made as to whether the operational LODs for hazardous




substances are likely to be lowered significantly in the near term




(within the next five years).  Data from two programs (the




Association of Official Analytical Chemists and the New York State




Department of Health), where many laboratories analyzed the same




samples, are summarized.  Evidence is presented for a general

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barrier to LODs in the low-ppb concentrations.   Available evidence




is assessed as showing little or no near-term LOD improvement.



     LOD for radiochemical measurement of nuclides reported at




release sites are tabulated.  Calculated LODs and values obtained in



a commercial laboratory are compared to each other.   LODs for the




more usual methods of chemical analysis are compared with LOD values




for counting methods.

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2.0  ORIGIN AND DEFINITIONS OF LOD




2.1  Origin of the LOD Concept




     Historically, the concept of the chemical LOD as a




specification for an analytical chemistry procedure was first




developed in the 19th century.  The intended use of laboratory LODs




was to indicate that a certain analytical method could measure the




amount of a given chemical within a specified concentration range.




The early analytical methods had LODs in the concentration range of




a tenth of a percent (ppt) to parts-per-million (ppm), expressed




usually on a weight-to-weight or volume-to-volume basis.  Then, in




the 20th century, analytical research development lowered the




then-attainable LOD values down to the parts-per-billion (pp,b) and




even parts-per-trillion (ppt) levels.  This decrease was largely due




to the introduction of new technologies into the analytical




laboratory.




     Scientific interest in improvement and refinement of




expressions of LOD continues up to the present time.  A recent




symposium, held as part of the 191st National Meeting of the




American Chemical Society (ACS) in April 1986, examined both




scientific and regulatory/legal aspects of the specification of




LODs.  In this two-day symposium, over half the papers dealt with




legal or regulatory LOD concerns.     Lowering of LODs, more




reliable specifications for LOD, and consequences of using two




procedures to measure one substance, which then yields two different

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LODs are among topics addressed in the symposium papers.   What is

new about this meeting is that the analytical chemists are

addressing both scientific and legal utilization of LOD data.

2.2  Description of the LOD

     The LOD has always been an important numerical expression in

the field of chemical analysis because it is a way to communicate,

from one analyst to another, the lowest concentration of a specified

chemical which can be measured using a given analytical method.   The

ACS's 1980 definition of LOD states that "the limit of detection is

the lowest concentration of an analyte that an analytical process
                    ..(2)
can reliably detect."

     LOD is an operational parameter, not an invariant physical

constant, for any analytical procedure or for any substance.   (The

molecular weight of a chemical is, for example, a physical

constant.)  LOD is an operational parameter because it depends on a

variety of factors which vary slightly every time the analytical

procedure is performed on a group of samples.

     The usual way of carrying out a trace chemical analysis

consists of two distinct unit operations:

     •  A sample-workup operation, in which the chemical to be
        quantified is extracted from most of the other substances in
        the sample matrix.  Usually some concentration and "cleanup"
        of the extract are also performed to enhance the analytical
        signal of the chemical above the matrix background noise.

     •  An instrumental-analysis operation, in which the chemical in
        the "cleaned-up" extract is quantified by an instrument
        containing a detector.  The instrument typically converts
                                 10

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        the quantity of chemical present in the detector at any time
        to a proportionate electrical signal, which is, in turn,
        manipulated by on-board microprocessors to yield the best
        signal (measurement) possible.  Background interference
        caused by the sample matrix can decrease the net measurable
        signal from the chemical, and thereby raise the LOD.

The operational LOD obtained is thus affected by each of the above

operations.  One can improve or degrade the LOD by varying the

quality of either the sample-workup or instrumental-analysis steps.

Day-to-day LOD variation depends on such variables as solvent

quality and instrument stability.  This means that even though the

whole procedure may have a fairly constant LOD on the average, the

daily LOD for the procedure will vary somewhat.  The size of.this

variation depends on the individual procedure.  Application of one

procedure to two different sample matrices usually leads to
                                                 i
different LOD values for each matrix.

2.3  Calculation of the LOD

     A further cause of an apparent variation in LOD values is that

there is more than one acceptable way to calculate an operational
                                                 i

LOD from one single set of experimental data using one of several

acceptable calculation techniques.  The variation in LOD which can

result from different methods of calculation is illustrated by the

                             (3)
work of Long and Winefordner.     These investigators calculated

three LOD results for calcium using one set of experimental data

(from measurements of calcium concentrations in water using plasma

              (3)
spectroscopy).     Each of the three mathematical equations uses
                                 11

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different pieces of information taken from the same instrumental

calibration line to yield different LODs.  Following are three of

the methods used for the calculations:

     •  A mathematical statement of the International Union of Pure
        and Applied Chemistry (IUPAC) definition of LOD.

     •  A graphical definition which takes into consideration the
        standard deviation of the slope of the calibration line.

     •  A procedure that includes the errors in both the intercept
        and the slope of the straight-line calibration plot.

Using the same spectroscopic data to construct one calibration line,

Long and Winefordner arrived at three different LODs for calcium by

following three different algorithms.  The values are 0.002, 0.003,

and 0.05 ppm.  The different values result from different mathe-

matical equations used to express the LOD.  The results vary by over

an order of magnitude even though portions of the same experimental

data were used in all three calculations.
                                 12

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3.0  REGULATORY SPECIFICATION OF LODs

     Regulatory LODs can be used to specify how well an analytical

method (or more correctly, a laboratory using that method)  must

perform to be acceptable for use in a particular regulatory

        (4)
program.      Therefore, laboratory LODs should always be lower in

concentration than regulatory LODs.  Table 1 lists the LOD  data

specified in two EPA programs for a variety of substances.   The

substances listed in Table 1 are those most frequently reported at

nearly 900 sites listed or proposed for inclusion on the National

Priorities List (NPL).  The LOD specifications are taken from the

EPA Contract Lab Program (CLP)^ ' )7' and also from the Clean

                     (8)
Water Act regulations   .  The respective LOD requirement from

each program is paired with the frequently occurring substances from

the NPL sites, where such regulatory LOD data currently exist.

     Some observations can be made about the data collected in

Table 1:

     •  For some hazardous substances frequently found at NPL sites,
        there are no LOD specifications listed for either EPA pro-
        gram (e.g., ethylbenzene, PCBs, benzo(j,k)fluorene, uranium).

     •  The LOD criteria set by the two programs for the same
        substance are frequently different (e.g., trichloroethylene,
        chloroform, and 1,1-dichloroethane).

     •  The LOD specifications for the Clean Water Act program are
        variable, whereas the CLP numerical limits tend to be more
        uniform.  LOD values of 5, 10, and 330 ppb can be seen
        regularly in columns 3 and 4 (CLP program).  LOD data for
        CLP have clearly been collected for a variety of chemicals
        and then this array of data has been "rounded off"  to a
        smaller number of expected LOD values.
                                 13

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                                 TABLE 1

  LIMITS  OF  DETECTION REQUIRED  BY TWO  EPA PROGRAMS  FOR SUBSTANCES  FOUND
AT NPL SITES (SUBSTANCES ARE LISTED BY FREQUENCY OF REPORTED OCCURRENCE)
Substance Name


Trichloroethylene (TCE)
Lead (Pb)
Toluene
Chromium and Compounds,
NOSe (Cr)
Benzene
Chloroform
Polychlorinated Biphenyls,
NOS (PCBs)
1, 1, 1-Trichloroethane
1, 1, 2,2-Tetrachloroethene
Zinc and Compounds, NOS (Zn)
Cadmium (Cd)
Arsenic
Phenol
Xylenes - Total
Ethylbenzene
Copper and Compounds, NOS (Cu)
1, 2-Trans-Dichloroethene
Methylene Chloride
1 , 1-D ichloroethane
1,1-Dichloroethylene
Mercury (Hg) NOS
Cyanides (Soluble Salts), NOS
Vinylchloride
Nickel and Compounds, NOS (Ni)
Chlorobenzene
1, 2-Dichloroethane
Carbon Tetrachloride
Pentachlorophenol (PCP)
Naphthalene
Methyl Ethyl Ketone
Trichloroethane, NOS
Site
Frequency3


311
286
243

220
208
179
159

151
149
142
141
141
121
113
111
106
104
91
85
79
78
73
70
65
64
64
61
53
48
42
38
Required
Limits of Detection
CLPb
^gfr
5
5
5

10
5
5
—

—
—
20
5
10
10
5
—
25
—
5
5
5
0.2
10
10
40
5
5
5
50
10
10
5
CLPC
^JTkg
5
—
5

—
5
5
—

—
—
—
—
—
330
5
—
—
—
5
5
5
—
—
10
—
5
5
5
1600
330
10
5
CWAd
ug/L
0.12
—
—

—
—
0.05
—

0.03
0.03
—
—
—
—
—
—
—
0.10
0.25
0.07
0.13
—
—
0.18
—
0.25
0.03
0.12
—
—
—
0.03
                                   14

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                         TABLE 1 (Continued)
Substance Name
   Site
Frequency3
                                                        Required
                                                  Limits of Detection
                                             CLPb
                                                          CLPC
                                  CWAd
Iron and Compounds, NOS (Fe)          33
Barium (Ba)                           32
Manganese and Compounds, NOS (Mn)     31
Acetone                               30
Phenanthrene                          28
Benzo[a]Pyrene                        27
1,1,2-Trichloroethane                 25
Anthracene                            22
Styrene                               22
DDT                                   22
Tetrachloroethane, NOS                21
Lindane                               21
Bis(2-Ethylhexyl)phthalate            21
Selenium                              20
Sulfuric Acid                         20
Pyrene                                19
Aluminum and Compounds, NOS (Al)      18
Fluorene                              17
Benzo(j,k)Fluorene                    17
Ethyl Chloride                        16
Radium and Compounds, NOS (Ra)        168
Dichloroethane, NOS                   15
Trichloroflouromethane                15
Acenaphthene                          14
Uranium and Compounds, NOS (U)        148
cis-l,2-Dichloroethylene              14
Trinitrotoluene (TNT)                 13
Asbestos                              13
Antimony and Compounds, NOS (Sb)      13
Chlordane                             13
Dichlorobenzene, NOS                  12
Radon, NOS (Rn)                       128
Hexachlorobenzene                     12
Tribromomethane       ,                12
Ammonia, NOS                          11
               60
                0.5
100
200
15-
10
10
10
5
10
0.1
5
0.05
10
5
10
200
10
10
5
10
—
—
—
10
330
330
5
330
16
5
8
330
—
330
—
330
10
5
330
                                                                 0.02
                                                         80
                                                                 0.52

                                                                 0.03
                                                                 0.20
                                 15

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TABLE 1 (Continued)
Site
Substance Name Frequency3


Chloromethane
Di-n-Butylphthalate
Tetrahydrof uran( I)
Thorium and Compounds, NOS (Th)
DDE
Dioxin
Dibromochloromethane
Methyl Isobutyl Ketone
(4 methyl-2-pentanone)
Chrysene
Dieldrin
1,4-Dichlorobenzene
2,4-Dinitrotoluene
Hexachlorocyclopentadiene (C56)
Cresols
Beryllium and Compounds, NOS (Be)
Nitrates, NOS
Endrin
2, 6-Dinitrotoluene
Ethyl Ether
1, 2-Dichlorobenzene
Diethylphthalate
Bromomethane
Fluoride (ion), NOS
Diethylphthalate
Cyclonite (RDX)
Aldrin
Boron and Compounds, NOS (B)
Heptachlor
Hexachloro butadiene (C46)
1, 2-Dichloropropane
Endrin
Silver, NOS
1,2,3-Trichloropropane
Chlorodifluoromethane
Chloride (ion) NOS


11
11
11
108
10
10
10

10
10
9
9
9
9
9
8
8
8
8
8
8
8
8
8
8
8
7
7
7
7
7
7
6
6
6
6
Required
Limits of Detection
CLPb
ug/L
10
10
—
—
0.1
— f
5

10
10
0.1
10
10
—
—
5
—
0.1
10
—
10
10
10
—
10
—
0.05
—
0.05
10
5
0.01
10
—
—
—
CLPC
ugTkg
10
330
—
—
16
	 f
5

10
330
16
330
330
—
—
--
—
16
330
—
330
330
10
—
330
—
8
—
8
330
5
16
—
—
—
—
CWAd
iiZL
0.08
—
—
—
—
—
0.09

—
—
—
0.24
—
—
—
—
—
—
—
—
0.15
—
1.18
—
— -
—
—
—
—
—
0.04
—
—
—
1.81
—
        16

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                            TABLE 1 (Concluded)
Site Required
Substance Name Frequency3 Limits of Detection


ODD
Dibenzofuran
Cobalt and Compounds, NOS (Co)
Sulfate (ion), NOS
Methane
Acenaphthylene
Hexachlorocyclohexane, NOS
1,2,4-Trichlorobenzene
Trimethyl Benzene
Benzo [a Janthracene
2-Chlorophenol
2, 4-Dimethylphenol
Hydrogen Sulfide
Methanol


6
6
5
5
5
5
5
5
5
5
5
5
5
5
CLPb
ug7L
0.1
10
50
—

10
—
10
—
10
10
—
—
"
CLPC
ujTkg
16
330
—
—
—
330
—
330
—
330
330
—

"
CWAd
ug/L
—
—
—
—
—
—
—
—
—
—
—
—
—
"
aNumber of sites at which a chemical has been identified through NPL
Update 5 (888 sites).

bContract Required Detection Limits (CRDL) for water:  U.S. EPA Contract
 Laboratory Program, Statement of Work for Organics Analysis, Revised
 January 1985; and Inorganic Analysis, July 1984.

CCRDL for soils and sediment:  U.S. EPA Statement of Work for Organics
 Analysis, op.cit.

^Method Detection Limits in water:  taken from Federal Register/Vol. 49,
 No. 2091, Friday, October 26, 1984; 40 CFR Part 136, Guidelines
 Establishing Test Procedures for the Analysis of Pollutants Under the
 Clean Water Act, Table 1, p. 43265.

eNOS = Not otherwise specified as to isomers, oxidation state, counter
 ions.

^Performance criteria for the GC/MS method for Dioxin (TCDD) described in
 the Statement of Work, Dioxin Analysis, U.S. EPA Contract Laboratory
 Program, September 1983.

SRadioactive element.  See Table 2 for LOD data.
                                    17

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     The above observations reflect the somewhat subjective




procedures that the two programs use in setting the regulatory LOD




values shown in Table 1.  The programs have different objectives




and, consequently, the value of the LOD required for a given




chemical in a given program may be different.
                                    18

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4.0  POTENTIAL FOR IMPROVEMENTS IN LABORATORY LOD VALUES

     This section develops a forecast of near-term (next five years)

major improvements in LOD values for the chemical analysis of

environmental samples.  This forecast is based first on an exami-

nation of past times when LODs were improved dramatically and then,

on an identification of the causes of that improvement.  A second

basis for forecasting LOD improvements is an evaluation of current

barriers which are seen as preventing substantial LOD improvement at

the present time.  A conclusion is drawn that LODs in environmental

laboratory procedure will not improve significantly over the near

term.

4.1  Past Improvements in the LOD

     In the past, improvements in the best obtainable LODs have come

about in one of two ways:

     •  Through gradual improvements in the quality of reagents
        employed or in the more stable operation of instruments,
        which have led to incremental improvements in LOD values

     •  Through dramatic improvement in reagent quality or as a
        result of invention of a new instrument or detector which
        has led to sudden decreases in LOD (over several orders of
        magnitude)

The time period when the most dramatic improvements occurred in

analytical chemical LODs was the period 1945-1970.  During this time

frame, an abundance of new electronic technology and equipment de-

rived from World War II programs became available.  Also, personnel

trained during the war in the use of these electronic components
                                 19

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began to work in analytical chemistry research laboratories.   The


combination of new technology and trained people resulted in new,


sensitive, chemical instrumentation such as:  atomic absorption


spectroscopy, mass spectrometry, gas chromatography, the electron


capture detector, and the ubiquitous application of high-speed,


digital mini-computers in chromatography.  Detection limits,  in


general, decreased to ppt levels or lower during this period.


     However, two sources of error became important when detection


limits reached the ppt level:  (l) adsorption on laboratory


apparatus; and (2) trace impurities in reagents and solvents.  At


this level, adsorption to sites in the field sample containers and


laboratory glassware, as well as in the instruments, resulted in


losses of significant fractions of substances originally present in

                                                             (9)
the sample, thus making detection in the ppt range difficult.


For example, the losses of a chemical during the sample-workup


resulted in extracts containing a lower amount of chemical than the


original sample from which the extracts were derived.  Also,  traces


of impurities in solvents and reagents became detectable by the


instruments when they were operated in the ppt range.  Signals from


these impurities sometimes obscured the signal caused by the sample,


resulting in an LOD at only high ppt levels.  These phenomena


(chemical adsorption and reagent impurity) have created an impasse.


Ways to easily overcome adsorption losses, such as coating

                               (9)
glassware, have not been found;    and substantially higher purity
                                 20

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reagents and solvents have not been developed (by distillation,



etc.) despite attempts to do both.  Strides in instrumentation have


                                        (9)
not been able to overcome these effects.



4.2  LOP Limits from Interlaboratory Data



     Recent evidence has been published which indicates that poor



precision has been encountered for a variety of analytical methods



at concentrations below 10 ppb.      Generally, a loss of



precision makes measurements at low concentrations more difficult,



and the LOD reaches a limit.  Based on a statistical study of



precision data from 18 separate Association of Official Analytical



Chemists (AOAC) interlaboratory studies, precision seriously



deteriorates below 10 ppb.  In an interlaboratory study, all



laboratories conduct an analysis of the same samples using the



identical analytical procedure.  Each laboratory submits its answer



to the AOAC for statistical analysis.  For each of the 18 studies, a



different analytical procedure was used and a different substance



was measured.



     The numerical value used to measure precision in the analysis



of the 18 studies was the among-laboratories relative standard



deviation, RSD .  The RSD  is calculated by first computing the
              X          X


standard deviation for all* the results submitted by the



laboratories.  This standard deviation is then divided by the mean
*Statistical outliers are removed first.
                                 21

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of results submitted by all laboratories and multiplied by 100 to



yield RSDx, in units of percent.   A large numerical value of



precision means there is poor agreement among participants,  and a



small value of RSD  means there is close agreement in results
                  A


among laboratories.



     The among-laboratories RSD ,  as a function of sample



concentration, C, was found (for all procedures used in all 18



studies) to increase with decreasing C according to the following


        (9)
equation   :




                       RSDX = 2^  ~ °'5 lQS  C)



This means that the RSD  increases exponentially as the
                       X


concentration being measured decreases.  In only 3 of 18 studies


                                                         (9)
reviewed was there any deviation from the above equation.     The



deviation from the equation in the three studies was found to be



caused by the inability of the instrument used to respond to



chemical concentrations less than 100 ppm.



     Even for methods which gave a good instrument signal down to



1 ppb, the same relentless decay in precision was encountered as



sample concentrations decreased.   The descriptive equation that



gives the relative error as a function of concentration, and the



comparative laboratory data themselves, show that the RSD  is
                                                         


usually about +12 percent at sample concentrations of 10 ppm and



that RSD  more than doubles to +30 percent at a concentration of



10 ppb.      Because the RSD  is an exponential function of
                                 22

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sample concentration, it will increase in magnitude rapidly for



measurements of concentrations below the 1 ppb level.



     The precision versus concentration studies assembled to date


              (9)
from AOAC data    are extensive, but not exhaustive.   The evidence



demonstrates that operational LODs at sample concentrations below



1 ppb are not imminent due to the exponential increase in random



error at such low concentrations.  Without some revolutionary



breakthrough in technology that provides a practical means of



improving attainable precision at low concentrations,  the LODs will



not improve substantially.



4.3  LOP Limits From Proficiency Testing Data



     Further evidence that current LODs may not decrease



dramatically in the near term comes from studies conducted by the



New York State Department of Health, which conducts a quarterly



proficiency testing activity as part of their laboratory



certification program.      In proficiency testing, separate



portions of one master sample are sent to participating laboratories



and all the portions are analyzed at about the same time.



     Ninety chemistry laboratories participated in recent New York



State proficiency testing, and the results are in accord with the


                          (9)
previously described study    of collaborative analyses.  Seventy



different test solutions of chemicals were analyzed by the parti-



cipating laboratories.  The best reported precision was +8 percent



(two relative standard deviation units).  This was obtained with the
                                 23

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highest concentration sample,  a 1.51 ppm solution of copper.




Conversely, the worst precision, +69 percent,  was reported for the




lowest concentration sample in the program.   This sample was  a 0.14



ppb solution of the pesticide Silvex.




     Once again, precision is seen to deteriorate as the sample




concentration was lowered, making it increasingly difficult to




detect the substance of interest with any certainty.  Data for the




test results for other chemicals used in the New York State




Proficiency Testing Program also support the observed decrease of




precision with decreased concentration for all methods.




     LODs will not improve appreciably until the exponential




increase in uncertainties in analytical measurements at  concen-




trations less than 1 ppb can be overcome by new technology.
                                 24

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5.0  EQUIVALENCE OF LCDs FOR RADIOCHEMICAL COUNTING COMPARED TO
     SPECTROSCOPIC METHODS.

5.1  Selection of Elements to be Considered

     For radioactive elements there is additional concern that

current radiochemical detection limits may be significantly smaller

than those for more conventional techniques.   If so, it is con-

ceivable that radioactive substances identified in environmental

samples by radiochemical means might not have been detected if other

methods of chemical analysis were used.  Since the HRS ranking

factor for toxicity is based on chemical hazard, not radiation

hazard, radiochemical detection could bias the relative ranking of

sites containing radioactive elements.  In this section, typical LOD

values for radiochemical techniques are compared with LODs for the

spectroscopic methods used for CLP procedures.  The CLP methods use

inductively coupled plasma emission spectroscopy and atomic absorp-

tion spectroscopy to determine the inorganic elements included in

the program.

     There are four radioactive elements listed in Table 1:  Radium,

Uranium, Radon, and Thorium.  The LOD values for these will be

considered here.  A fifth nuclide, Plutonium, has been included in

the present discussion because of special interest in detecting

small amounts of this element.  This section addresses the question

of what the LODs would be, in the same units as used in Table 1, if

radiochemical counting methods were used to quantify these five

radioactive elements found at hazardous substance release sites.
                                 25

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5.2  Quantitative Principles for Radionuclides




     In order to quantify a nuclide by radiochemical counting,  two




things are required.  The first is an instrument capable of




detecting and counting the radiation given off by the nuclide of




interest; and the second is a sample nuclide with a reasonable



half-life.  A reasonable half-life may be defined as one short




enough to give adequate count rates, and yet long enough so that the



concentration of the isotope does not change significantly during




the time frame of the measurement.




     Radiochemical methods have the potential for low LODs because




it takes only one atom to give one particle emission, which in turn




can give one count at the instrument.  The one-atom, one-count




relationship is inherently very sensitive, given the large number of




atoms present even at trace concentrations.  However, just as for




other instrumental methods of analysis, one or more factors




affecting steps in the procedure can degrade the operational LOD




dramatically.  For example, the counter detector can be less than




100 percent effective at counting the emitted radiation.  This loss




of efficiency can be due to counting geometry, detector or




electronic overload.      Absorption of emissions by any matrix




material, or by changes in geometry between sample and detector, can




occur.  Such matrix effects lower the observed count rates for a




given level of radioactivity, and thus the effects degrade the




operational LOD for that sample or mixture.
                                 26

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     If the radiochemical analysis method consists of unit




operations of sample workup and instrument measurement (such as




described earlier), then either or both operations can affect the




LOD obtained on any given day.  Therefore, radiochemical analysis




then becomes similar to other instrumental methods of analysis,



except that the instrument signal is triggered by radiation from the




isotope being measured.  Thus, any loss of the nuclide in the sample




workup operation will unfavorably affect the LOD of a radiochemical




method.




5.3  Inorganic LODs for Comparison Purposes




     In order to compare radiochemical measurements with other




techniques, some reference point data are needed.  A set of LOD data




for metals in environmental samples has been established as part of




the CLP.     The LODs for 24 metals in water range from 0.2 to




5000 ug/L, as measured by inductively coupled plasma emission or




atomic absorption spectroscopy.  Eighteen of the 24 LODs are




specified to be 100 ug/L or less.  So, for a range of comparison,




0. 5 to 100 ug/L would be reasonably representative of the CLP




expected performance of spectroscopic methods used to measure




18 different metals.  This range will be used for comparisons with




radiochemical LOD ranges, because radioactive element LODs are not




specified in the CLP program at this time.




5.4  LOD Values for Radioactive Elements in Environmental Samples




     A search proved unsuccessful in providing literature which




addressed the exact environmental problem under consideration.




                                 27

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Alternative sources of LOD data were located and contacted.   Two



independent means of establishing LOD values were identified and




used.  First, an EPA research scientist in the Office of Radiation




Programs calculated LODs from properties of the radionuclides



                                         (13)
selected and current counting technology.      Independently, the




director of a commercial environmental testing laboratory




(specializing in radioactive tests) provided the operating LOD



                                          (14)
values currently in use at their facility.      Neither of the two




sources of data were aware of the other.




     Table 2 summarizes both calculated and operational LODs for the




five radioactive elements of interest.   '     Half-life data are




also tabulated.  For the first two radionuclides, Uranium and




Thorium, both the calculated and experimental LODs are around 1 ug/L




(approximately 1 ppb) .  These LOD values are in the range of the




spectroscopic LODs for many nonradioactive metals in CLP samples, as




presented in Section 5.3.




     In contrast, the LODs for radiochemical quantification  of both


                                           —7      —fi
Radium and Plutonium are on the order of 10   to 10   ppb and




are therefore a million-fold smaller than any LOD in the current CLP
        / f \

listing.     The relatively short half-lives of Ra    and



  239
Pu    (1,600 and 24,390 years, respectively) cause high counting




rates and therefore low LOD values.




     One single value of the LOD for Radon gas cannot be listed in




Table 2 because the methods of trapping and collecting the Rn gas
                                 28

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from the rest of the sample matrix are important determinants of the




LOD finally achieved.



     For radiochemical LODs, therefore, both counting instrument




sensitivity and isotope half-life play an important role in



determining how low a concentration can be detected.   In general,




the LOD can be expected to decrease for isotopes with shorter




half-lives, as listed in Table 2.
                                 29

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                               TABLE  2

                       LIMITS  OF  DETECTION  FOR
              RADIOACTIVE SUBSTANCES  FOUND  AT NPL SITES
Element, Isotope3
Th, 232
U,238
Pu,239
Ra,226
Rn,222
Isotope
Half-Life
1. 4lxl010year
4.51xl09year
24, 390year
1, 600year
3. 82day
Limits of
Calculated13
1.0 ug/L
0.3 ug/L
1. 5xlO~6ug/L
lxlO~7ug/L
(gas)d
Detection
Experimental0
5.4 ug/L
1.8 ug/L
0. lxlO~6ug/L
0. 6xlO~6ug/L
(gas)e
a For each element a minimum instrument count rate is required  to
  measure the isotope.  The instrument limit assumed for calculation of
  LODs is 0.1 pCi/L.  The experimental count limit is given as  0.6  pCi/L
  for LOD measurements.   A Curie (Ci)  is 3.7 x 10^0 disintegrations
  per second.
  Personal communication, Dr.  Paul Hahn,  EPA Office of Radiation
  Programs, Las Vega
  for Rn gas in air.
Programs, Las Vegas,  NV.   Units are for ground  water  matrix,  except
c Personal communication, James Mueller,  Controls for Environmental
  Pollution, Inc., Santa Fe, NM.  Units are for ground water matrix,
  except Rn'gas.

** LOD for Radon depends on method used to collect (and thus
  concentrate) gas.

e Operational detection limit given as 0.1 pCi/m3 based on 400 m3
  of air collected, d^)
                                    30

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6.0  CONCLUSIONS




6.1  Anticipated Changes in Operational LODs




     The numerical value of an operational laboratory LOD obtained




experimentally will depend on the combination of equipment and




reagents involved, the sample throughput rate and the sample




concentration, and the calculation algorithm.  The operational LOD




obtained in the laboratory on a day-to-day basis further depends on




the care expended in doing each step as well as the skill and



experience of the analyst doing the work.  At the present time,




there is no apparent prospect that dramatic improvements in current




sample processing and instrument technologies will be able to




improve the LODs, much beyond those values listed in Tables 1 and 2,




within the next five years.  The different values of LOD specified




by different regulatory programs for the same compound, as given in




Table 1, show that some programs may require something less than the




state-of-the-art LODs to achieve a regulatory goal.  It is not clear




that future improvements in laboratory LODs would necessarily lead




to corresponding changes in regulatory LOD values, because the




present values may well be adequate to accomplish the regulatory




objective.




     Additionally, any new technology must do two things before




being integrated into current environmental laboratory operations.



First, the new technology must demonstrate its ability to provide




reliable, low LOD values in the matrices of the common environmental
                                 31

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samples.  Second, the new technology must meet the requirements of




standardized environmental laboratory programs such as the CLP.




These requirements Include the use of proven, standard methods, and




the availability of affordable equipment, supplies and repair ser-




vices.  A new technology offering a lower LOD without also meeting



these other requirements will not be sufficient.  It is necessary to




demonstrate that the technology is workable by providing substantial




LOD improvement in the work environment of a for-profit testing and




production laboratory.




     The most direct way to obtain a short-term, immediate




improvement in an LOD is to decrease the size of the statistical




variability (i.e., improve precision) in the analytical data for a




given chemical.  This improvement can result from incremental



improvements in the quality of the instrumental and/or the sample




extraction and concentration steps.  It can also be improved by




increasing the number of replicate analyses run on the same sample.




Both steps to improve method precision and thus decrease the LOD




always increa'se cost-per-sample-analyzed substantially, and are




therefore not in general use in environmental analytical




laboratories.



     In summary, a major "breakthrough" in the lowering of LODs will




only occur if a completely new instrument (capable of analyzing




components in environmental samples) is introduced or if a new




sample workup technique should be developed.  The last few years
                                 32

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have not produced major breakthroughs in either environmental




instrumentation or methodology.  Improvement of LODs for existing




methodologies (such as used in the CLP program) over the next




five years should therefore be gradual, if at all.



6.2  LOP Comparisons Between Radiochemical and Spectroscopic Techniques




     Radioactive metals, reported present at a few NPL sites, do not




have LOD values established as part of the CLP program at the




present time.  For purposes of comparison, an estimate of LODs which




might be expected for metals can be obtained by examination of CLP




limits for metals determined by atomic spectroscopy.  The current




CLP program sets limits between 0.2 and 100 ug/L for 18 of the




24 nonradioactive elements measured by atomic spectroscopy.  This




range of values was compared with the LODs for five naturally




radioactive elements measured by radiochemical counting.




     LOD specifications using radiochemical counting techniques




depend on the radiochemical decay rate of the isotope being




measured.  The observed decay rate of a given isotope is a function




of the half-life which is a physical constant, and is invariant for




the particular nuclide being measured.  In general, the shorter the




half-life of an isotope, the smaller will be the LOD of that




element.  Therefore, based on Table 2, for elements with longer




half-lifes (e.g. Thorium, Uranium), LODs for radiochemical and




spectroscopic methods are generally comparable.  LODs for




radiochemical counting are much lower for those elements with




shorter half-lifes (e.g., Radium and Plutonium).




                                 33

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                             REFERENCES
1.   Abstracts of the 191st National Meeting of the American
     Chemical Society, New York, N.Y., April 13-18, 1986.  Division
     of Analytical Chemistry, Abstracts 54-58, 71-77, 91-96, and
     108-111.

2.   L.H. Keith, et al., "Principles of Environmental Analysis,"
     Anal. Chem., 55, pp.2210-2218, 1983.

3.   G.L. Long and J.D. Winefordner, "Limit of Detection, A Closer
    , Look at the IUPAC Definition," Anal. Chem., 55, pp. 712A-724A,
     1983.                                       ~

4.   L.B. Rogers, et al., Eds., "Recommendations for" Improving the
     Reliability and Acceptability of Analytical Chemistry Data Used
     for Public Purposes," C&E News, j>0, (23)44, pp.44-48, 1982.

5.   U.S. EPA Superfund Contract Laboratory Program Statement of
     Work for Organics Analysis," Exhibit C, Revised January 1985.

6.   U.S. EPA Superfund Contract Laboratory Program Statement of
     Work for Inorganic Analysis, SOW No. 784, Exhibit C, July 1984.

7.   U.S. EPA Statement of Work, Dioxin Analysis Soil/Sediment
     Matrix Multi-Concentration, September 15, 1983.

8.   Fed. Reg. 49, No. 2091, 40CFR, Part 136, "Guidelines
     Establishing Test Procedures for Analysis of Pollutants Under
     the Clean Water Act," Table 1, p.43265ff, Fri., Oct. 26, 1984.

9.   L.B. Rogers, "Problems with Interlaboratory Measurements at
     Trace Levels" Abstracts of 191st National Meeting, American
     Chemical Society, Abstract ANYL 55, April 1986.

10.  K.W. Boyer, W. Horwitz, and R. Albert, "Interlaboratory
     Variability in Trace Element Analysis," Anal. Chem., 57,
     pp.454-459, 1985.

11.  J.C. Daly and K.E. Asmus, "Laboratory Performance in
     Proficiency Testing," Environ. Sci. Technol., 19, pp.8-13, 1985.

12.  H.H. Willard, L.L. Merritt, and J.A. Dean, "Instrumental
     Methods of Analysis," Chap. 11, Radiochemical Methods, pp.
     302-327, 5th ed., 1965.
                                 35

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                       REFERENCES (Concluded)


13.  Personal Communication:  Dr. Paul Hahn, EPA Office of Radiation
     Programs, Las Vegas, NV, July 1985.

14.  Personal Communication:  James Mueller, Pres., Controls for
     Environmental Pollution, Inc., Santa Fe, N.M., March 1986.
                                 36

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