Hazard Ranking System Issue Analysis: Laboratory Limits of Detection MITRE ------- 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 ------- Department Approval:, MITRE Project Approval:. ------- 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 ------- 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 ------- 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 ------- 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). ------- 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 ------- • 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 ------- 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 ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- |