PROTOCOL FOR APPROVAL OF ALTERNATE TEST PROCEDURES
FOR INORGANIC AND ORGANIC ANALYTES IN NATIONAL POLLUTANT
        DISCHARGE ELIMINATION SYSTEM MONITORING
                      Revision 1.3

                      January,  1996
          U.S. Environmental Protection Agency
           Office of Research and Development
          National  Exposure Research Laboratory
                 Cincinnati,  Ohio  45268

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      PROTOCOL FOR APPROVAL OF ALTERNATE  TEST  PROCEDURES FOR
       INORGANIC AND ORGANIC ANALYTES  IN  NATIONAL POLLUTANT
              DISCHARGE  ELIMINATION"' SYSTEM MONITORING

 INTRODUCTION

      An alternate test  procedure  (ATP) is one that  differs from a
 method previously approved by the.U. S.  Environmental  Protection
 Agency (USEPA) for determining  the  constituent of interest  in
 National Pollutant Discharge Elimination System (NPDES) monitoring.
 Any person may apply for  approval of  the use  of  an  alternate  test
 procedure for a specific  constituent  in  NPDES monitoring.

      Before submitting  an ATP application, however,  the applicant
 is  responsible  for  performing  an  in-depth comparison  of  the
 description  of the  proposed method with the description of  the
 appropriate approved NPDES method(s), listed  in  Tables  IB,  1C,  or
 ID of section 136 of Title 40 of the Code of Federal Regulations
 (CFR) .   In this  comparison each of  the  topics,  outlined in  the
 Method Description Requirements  (pp.  2-4),  must be  considered  in
 detail.  If  this  comparison reveals that there are  absolutely  no
 differences in the technical  details  of  the proposed and approved
 methods,  the methods   are  considered  identical  and   an  ATP
 application  is not  required.    If  the   proposed  method  differs
 slightly in any of the technical details,  the  applicant  may choose
 to:  (1) modify the method  so that  it is identical  to one of  the
 previously  approved methods,    (2)  submit  a  simple   2-column
 comparison  (see   the text on  p.  4  in  the  Method Description
 Requirements)   for  NERL-Cincinnati   determination   of    the
 comparability  of   the proposed  method   or  the  need for  an ATP
 application, or (3)  submit  an application for approval  of  an ATP.

     Every ATP application  shall  be made  by letter  in triplicate.
An application for  nationwide   (NW)  approval of a proposed ATP
 should be  forwarded  to the Acting Director,  Ecological Exposure
 Research   Division  -   Cincinnati     (NERL-Cincinnati),   U.S.
 Environmental  Protection  Agency,  Cincinnati,  Ohio  45268.    An
 application for approval  of the  limited-use  (LU) of an ATP by  a
 regional  EPA  laboratory  should be  forwarded  directly  to  the
 appropriate  Regional Administrator.  An application for approval  of
 the limited-use of an ATP  by a State or commercial laboratory or  an
 individual discharger or  permittee  shall  be forwarded directly  to
 the Director  of  the  State Agency issuing NPDES  permits in that
 State if that  State has  primacy  (i.e., the state permit  program  is
USEPA-approved) .    If the  State  does  not have primacy, then the
application by a  State  or  commercial   laboratory  or   individual
discharger or permittee

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should  be forwarded  directly  to the  appropriate USEPA  Regional
Administrator.    The State  Agency  Director  and  USEPA  Regional
Administrator will forward applications as required.

APPLICATION REQUIREMENTS

     The  general  requirements  for an ATP application  include  the
name and address of the  applicant and/or authorized representative;
if applicable/  the applicant's NPDES permit number; the pollutant
or constituent for which the ATP is proposed; the  type  of  approval
desired  (NW or  LU);  justification for the proposed ATP;  the  full
title of  the method, company  identification number  and date  of
preparation of  the proposed method; a  complete description  of  the
proposed method and of the approved method if used in a  comparison;
and  the  comparability  data.   All  information  provided to  the
Government  is  subject  to  the  requirements  of  the  Freedom  of
Information Act.   Any  proprietary  information' in  the  proposed
method should be marked  as "Confidential".   USEPA  staff  will  handle
all  proprietary  information  according  to  the  regulations   in
subparts A and  B of  Part 2 of Title 40 CFR.

     Initially  an applicant should forward the above information,
except the comparability data, to NERL-Cincinnati.   Upon receipt  of
the  application,  the NERL-Cincinnati  ATP staff  will  assign  the
application an  identification number, which should be  used  in  all
future communications.  The NERL-Cincinnati ATP staff will perform
an initial evaluation of the submitted information and advise  the
applicant  of the  specific  comparability data  requirements,   if
applicable.

Method Description Requirements

     Each  method description must include  the following topics,
listed  in  the  recently  formulated  Environmental  Monitoring
Management Council (EMMC) method format:

1.0  Scope and  Application

     Include  analyte identification;  CAS  number;  sample  type;
     method  sensitivity,  expressed  as mass;  and,  concentration
     range.

     The concentration range  of the proposed method should be equal
     to or  greater than that of the approved method.   If  the range
     is smaller than  that  of  the approved method  (particularly,  if
     the  detection  limit  is higher), EMSL  may  advise   that  the
     method is inapplicable or the method may require a declaration
     of method  limitations.

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2.0  Summary of the Method

     Describe  the scientific  basis,  e.g.,  chemical principles,
     reactions, kinetics.

3.0  Definitions

4.0  Interferences

     As a  separate document,  include data observed by  appliccr.t
     (during method development) using typical wastewater samples
     containing a specific quantity of an  interfering substance.

5.0  Safety

     Refer to good laboratory practice, appropriate material safety
     data  sheets,  and  use  of  hood,  goggles,  and/or protective
     clothing.  Emphasize any  special procedure.

6.0  Equipment and Supplies

     As a separate document, include any applicable manuals.

7.0  Reagents and Standards

     Describe  reagent  formulations  and  shelf  life  of  packaged
     materials.

8.0  Sample Collection, Preservation, Shipment, and Storage

     The guidance in Table  II  of  Part 136.3 of  Title  40  of  CFR
     takes  precedence  over  the  information  published  in  the
     approved methods'.

9.0  Quality Control

     Indicate need for a formal  laboratory quality control program;
     initial and periodic demonstration of performance by analyzing
     reagent blanks,  check  standards, and/or fortified samples;  and
     maintenance of records,  QC charts, etc.  The periodic checking
     of performance should  preferably  occur at a minimum frequency
     of 10% of the total samples.

10.0 Calibration and Standardization

     This section should include the calibration steps that are not
     performed  daily.   Include the daily calibration step(s)  in
     the procedural section.

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 11.0  Procedure

      Include  in  the method write 'up the.procedural steps  and  the
      daily   calibration steps.   As a separate document  include  a
      typical  calibration   graph  or  curve.

 12.0  Data Analysis  and  Calculations

 13.0 Method Performance

      Indicate the percent  recovery,  precision,  and  bias of  the
     method  for  typical wastewater samples, fortified with  known
      amount(s) of the analyte. Include the method detection limits
      (MDL),  derived as  outlined in  Appendix B of section 136 of
      Title  40 of CFR,   and expressed  in  weight/  volume.    The
      calculated  MDL should be  confirmed by analyzing a  sample at
      the calculated MDL  concentration.  Note that  the MDL  should be
      equal to or smaller than that of the approved method.  If  the
     MDL is higher,  EMSL may advise  that the method is  inapplicable
      or  the  method may  require a  declaration  of  the  method's
      limited  range  of performance.

 14.0  Pollution Prevention

      Cite good laboratory practices for pollution prevention.

 15.0 Waste Management

     Cite how waste and samples  are to be disposed.

 16.0 References

      Include  reference  to documents and publications.

 17.0 Tables,   Diagrams,  Flowcharts,  and Validation-Data

   •  Any proprietary information in the proposed method  should be
marked "Confidential".   USEPA staff will  handle  all proprietary
 information according to  the regulations in subparts A  and B of
 Part 2 of Title  40 of CFR.

     If the  proposed method is  very similar to  an approved and
promulgated method,  the applicant  should simply prepare a two-
 column comparison of the  approved and  proposed methods.    (The
 combined width  of the  two  columns  shall not exceed  17   inches.)
This document should include  the title and identification  number of
each  method,  the date of the proposed method and all the topics
 listed in  the previous outline.  The applicant should highlight any

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 differences in the proposed method.   If  the method is an automation
 of  a previously approved manual method,  any differences in kinetics
 and interferences should be presented and a comparison of the final
 ratios  of the concentrations of the reactants in the proposed and
 approved methods should be included.  This  information should then
 be  forwarded  to  NERL-Cincinnatii  for  review and  recommendation
 regarding the comparability of the  proposed method or need for an
 ATP application.

 Comparability Data  Requirements

     A  method comparability study will be required for each new or
 significantly revised method  submitted for  nationwide  approval.
 Guidance  for  the  comparability study is provided in the following
 text.  Applicants are encouraged to  have a brief  consultation with
 the EMSL ATP staff  regarding specific comparability  study plans
 which may include the  number of analyses,   concentration  levels,
 quality control  activities, performance evaluation  samples,  etc.
 If  a  major area differs,  such as the concentration range  of the
 proposed  method differs  from  that of  the  approved method,  the
 applicant must  consult  with the  NERL-Cincinnati ATP  staff  to
 determine  the appropriate modification  of the comparability study
 design.

     The comparability data shall include observations  of effluent
 samples,  quality control  samples in reagent  water  and  performance
 evaluation samples  in reagent  water.   Initially, each  collected
 effluent will be analyzed  once  by the approved method to  determine
 the concentration of  the  constituent of interest and the need for
 sample   dilution  and/or  fortifying  to   achieve  a  baseline
 concentration equal  to  5  times the  method  detection  limit  as
 detailed  in the  Subsample Preparation  Requirements  (pp. 7-8).
 After appropriate preparation,  the subsamples of  each effluent are
 to be analyzed by both the approved and proposed methods.

     The .  quality   control  samples  (QC)    and   the   performance
 evaluation  samples  (PE)  are to  be  prepared in reagent  water  and
 used to determine if the laboratory is in  control.   PE  samples
 containing  known  analytes, but  of  concentrations unknown  to  the
 analyst, will be  provided  by EMSL along  with  instructions for use.
 The analyst is responsible for preparing the final QC and PE sample
 solutions  for analyses.   The QC and PE solutions must  be  spaced
 every tenth sample among the  effluent samples  which  are to  be
 analyzed by both methods.

     As general guidance,  the minimum number of  analyses required
 are summarized in the following table.  However,  depending  on  the
particulars of the method  under  review,  the number of analyses may

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 change.  We strongly suggest consultation  with the EMSL ATP staff
 prior  to analyses.


 Type of                Initial     Lowest
 Approval  Applicant    Screening  Cone.*  Fortified   QC/PE    Total
 ^ •• ™»^ ^^ ^^ ^^ ^ ••^^••^^^^••^^^^^^^^^^ ^ ^ ^OM^^^^^^^^^^^^^^^B^^^^ ^
 Nationwide    Any        10       60      120-!-180  •  18-24   208-274


 Limited Use  USEPA        5       30      60-90      9-12   104-137
             Regional,
             State  or
             commercial

 Limited  Use  Individual   5       20         40        6       71

 * It is highly desirable  to use effluents which have a low level (5
 x MDL) of the  analyte(s)  of interest.   When this is not possible,
 the effluent must be diluted to a low  level so that the fortified
 concentration  is detectable and quantifible.


 Effluent Sampling Requirements

     For each  constituent of interest,  the applicant must collect
 a specified number  of samples from a  specified number of companies
 from a specified number of industry types, the latter identified by
 their  individual 1987  standard  Industrial Classification  (SIC)
 codes.  The general  requirements are  summarized in the table below
 Consultation with the EMSL ATP .staff may result in changes to the
 general  requirements based upon specific conditions of the method
 under review.

                                           No.  effluent
Approval          No.  SIC   No.  companies  samples per   Total no.
  type  Applicant codes      per SIC  code    company     of samples


   NW   Any         52              1            10

   LU   USEPA       51              15
        regional,
        state,  or
        commercial
        lab

   LU   Individual  1             1              55
        discharger

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      The NERL-Cincinnati ATP  staff will provide  the appropriate
 constituent  or analyte  code(s) 'and  1987  SIC  Codes  and  code
 descriptions to an applicant for either of the first two types of
 approval  (listed above).   If the applicant has difficulty locating
 appropriate sample sources  (for these two types of applications),
 he  may  obtain  (for  a  fee)  a list  of major companies,  their
 addresses/   contact   persons,   telephone  numbers,   and   recent
 constituent  measurements  by  directing a  Freedom of Information
 (FOI)  request to  Jeralene  B.  Green,  FOI Officer,  MS-A101,  401 M
 Street, S.W., Washington,  DC  20460, telephone:  202-260-4048.  The
 requestor must designate  the Permit  Compliance System as the source
 of  the information and specify the  constituent or analyte code and
 name,  the  SIC  codes, .  and geographical   locations  of  interest
 (nationwide,  regional, and/or  state).   Note that  the individual
 discharger LU  applicant must  collect  five  samples  of his  own
 effluent,   representing  only  one  SIC  code.    Occasionally,  an
 individual discharger may have  two or more different effluents.  In
 this  case he should consult with  the NERL-Cincinnati ATP  staff
 concerning  the  sampling requirements.

     An applicant  is required to diligently  select  a source and/or
 time of collection that will afford  a  constituent concentration as
 close  as  possible  to 5 x MDL.   (if  the MDL is  unpublished,
 determine as  directed in  Section 13, Method Performance  on p. 4.)
 This  selection will  enable  the  preparation  of  the   required
 subsamples  by  either dilution  or  fortifying  with a minimum  of
 alteration  of sample matrix.

     All  samples   should  be   collected using  the  containers,
 preservation techniques, and holding times outlined in Table II of
 section 136 of  the aforementioned CFR.

 Subsample Preparation Requirements

     The  bias,  precision and  percent  recovery of the proposed
 method will be compared to the bias, precision and percent recovery
 of  the approved method. Several  levels of concentrations covering
 the performance range of the proposed method will  be  used  in the
 study.  Ideally, the range of concentration for the proposed method
 will  be  the  same  as  the approved method.   This  issue must  be
 addressed with  the EMSL ATP staff prior  to  analyses.

     The study design initially  requires  a single analysis  of each
of  the collected samples  by the approved method to determine the
concentration of  the  constituents  of interest.   If the  initial
concentration of the constituents  in  any collected sample  differ
 from the 5  x  MDL  level,  the sample must then be either  carefully
diluted or fortified to achieve  the  5 x MDL  level.   Dilutions must
be  done using reagent water, as defined in the approved method.
Sample fortifying  must be  accor.;.lished using  a substance  whose
character reflects the nature of the analyte in the effluents

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                                 8

and/or  the calibration  standards.    For example,  in an ATP  for
mercury the  fortifying  substance must  consist  of a mixture  of
inorganic and organic mercury compounds.   Sample adjustment to the
baseline  or  5  x  MDL  concentration must  be  performed  before
splitting  the  sample into  subsamples  otherwise,  the  analytical
error of each analysis may also  include the error of any individual
adjustment  of the  subsamples  to the 5  x  MDL level.  Record  and
report  all  sample dilutions and/or fortifying  required  to adjust
each sample concentration to the 5 x  MDL level.

     The fortifying of each subsample  must  also  be achieved before
aliquoting  for analysis.   Otherwise, the analytical error  will
include individual fortifying errors and  the analytical data may be
inappropriate.  Record and report the  amount of the substance added
to each fortified subsample and  the theoretical total concentration
in each subsample.  The latter  is calculated  for each subsample by
adding  the mean of  the replicate analyses  of the subsample by the
approved method to the amount of substance added to that subsample.
The  evaluation of  the  comparability of  the proposed method  is
dependent upon  subsamples with  very similiar concentrations.

Laboratory Requirements

     It is highly desirable to have one laboratory analyze all  the
samples required in the  study  design.   This is  to  eliminate  the
effects of multiple laboratories on the comparision of data between
methods. Analyses by an additional laboratory should be included as
a  check but  these  data  are   in  addition  to   the  required  ATP
comparative analyses by the primary laboratory.  This option should'
be  discussed with  the ATP  staff  prior  to  generating data.   In
nationwide applications,  the laboratory should be independent,  that
is, without a vested interest in the company.   NERL-Cincinnati will
judge on the  appropriateness of the suggested laboratory.

Approved Method Selection Requirements

     Since the approval of an ATP depends upon the comparability of
the proposed method to that of an approved  method,  the applicant's
analyses by the approved  method  must also be  examined to  determine
their   acceptability  as  a  basis   in  the  comparison.    This
acceptability will  be determined by comparing the  applicant's
analyses of QC and  PE Samples by both the  approved method and the
proposed method.

     The  criteria  used  in  the  evaluation will  be derived  from
available regulations,  text of the approved method,  and/or various
interlaboratory validation and/or performance evaluation studies.
USEPA  may,  consequently,  limit the applicant's  choice  of  an
approved method  to  insure  that' the approved  method used in  a
comparability study is one which  has been evaluated with sufficient
frequency in  the  interlaboratory studies to  afford an appropriate

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data  base  with  which  to  determine  the  acceptability  of  the
applicant's analyses by  the approved method.

Effluent Subsample Analysis Requirements

     Applicants  for  nationwide  approval  and  individual  USEPA
Regional, State/ or. commercial laboratory applicants  for  limited-
use approval of an ATP  must perform six analyses of each subsample,
three by the approved method  and three by the proposed  method.
Individual  dischargers  applying for  limited-use  approval must
perform four analyses of  each subsample/ two by the approved method
and two  by the proposed method.  The effluent sample,  effluent
subsample/ and analysis  requirements  (without  screening analyses)
are summarized in the  following  table:
                                                No. of
                                                replicate
                            No. of              analyses
                            sub-       Total    per sub-
                            samples   No. sub-  sample       Total
                   No. of   per       samples   per each      No.
                 collected  collected    for     of two       of
Appvl. Applicant  samples   sample    analysis  methods  analyses
NW
LU
Any
USEPA
10
5
3-4
3-4
30-40
15-20
3
3
180-240
90-120
          regional,
          State, or
          commercial
          lab

 LU       Individual   53         15        2            60
          discharger
     The aforementioned quality control analyses must be performed
at a 10% frequency among the analyses of the effluent samples and
subsamples (See Comparability Data Requirements, pp.5-6).

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 Data Reporting Requirements

      Initial single observations of  the  collected samples by the
 approved method,  dilutions and/or  fortifying of  each collected
 sample/  the quantity of substance added to each subsample, and the
 total theoretical concentration of each  subsample,  the replicate
 observations of all subsamples by both methods, and quality control
 observations must be forwarded to USEPA.

      A suggested  format for reporting the  observations of each set
 of  subsamples  is attached.   The quality  assurance  observations
 associated with each set  of subsample observations should also be
 tabulated and identified.   An evaluation of  the ATP application can
 be  accomplished more quickly by the  NERL-Cincinnati  ATP staff if
 the  information  is  also  forwarded  on one  or more  floppy  discs
 compatible with an IBM-PC computer.  The text on the disc should be
 presented in the latest version of WordPerfect  (currently, 6.0)  and
 the  data may be presented in WordPerfect  or in ASCII.

 DATA REVIEW AND METHOD RECOMMENDATION

      Upon receipt of an the applicant's data sets,  NERL-Cincinnati
 staff  will  initiate   its  technical  and   statistical  reviews.
 Appropriate criteria, derived either  from  published regulations or
 from  interlaboratory  studies,  will  be- used to'  determine  the
 acceptability  of  the  approved method data as  a basis in  the
 evaluation  of  the  analyses  by  the  proposed  method.   If  this
 evaluation is favorable,  the evaluation of the comparability of  the
 proposed method will follow.

      Since the sampling and analytical requirements  for each  ATP
 application are based on a factorial experimental design with  three
 factors,   namely,   method,   sample   matrix,   and   constituent
 concentration,  each comparability review will be conducted over  the
 range of. these three factors.   Descriptive statistics,  such as  the
 mean,   standard  deviation,  coefficient  of  variation  (relative
 standard deviation),  and percent recovery of each set of replicates
 will  be calculated.  The  precision of the proposed method will be
 compared with   that   of   the   approved  method  by   means  of  a
 nonparametric  statistical procedure  attributable to  Scheffe.   An
 analysis of variance (ANOVA) will be  used to compare  the accuracy
 of the  proposed method with that of the approved method.

     Upon  completion  of  the technical and statistical  reviews,
NERL-Cincinnati      will   prepare    its   recommendation    for
 approval/disapproval,  notify the applicant  of  its  recommendation,
and   forward  the  recommendation  to the   appropriate  approval
authority.    An ATP  recommended for   nationwide  approval will  be
 forwarded to  the 304(h)  Committee, which has been delegated  the
responsibility of proposing the s-.TP in the  Federal Register.

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                                11

After  a three-month  public comment period,  this committee  will
review  any submitted  comments and prepare  the  final  nationwide
approval/disapproval  decision  and notice  in  the Federal Register.
A recommendation for approval/disapproval of a limited-use ATP will
be   forwarded  •initially  to   the  appropriate  EPA   Regional
Administrator  and,  subsequently,  to the appropriate  State Agency
Director, who are responsible for  the final decision  and notice to
the applicant.

     If  you  have  any   questions regarding   the  requirements,
especially  the  comparability  study  design  and  the  subsample
fortifying,  please contact the ENERL-CincinnatiCincinnati ATP staff
at 513-569-7307.

REFERENCES

1.   Villa, 0.  and L. Reed, Co-Chairs,  EMMC Methods  Integration
     Panel.  Final Version of Approved EMMC  Format (Memorandum to
     Members of EMMC Steering Committee, Methods Integration Panel,
     and Work Group, Tri-Chairs).  U. S. Environmental  Protection
     Agency, February 14, 1992, pp. 1-2.

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                                                      12
                        Application No:
                (USEPA Assigned)'
                                        NPDES COMPARABILITY STUDY DATA

                Source or Discharger Identity:	

                SIC  Code:
                Constituent  Identity:
                Concentration Units  (weight/volume):   	

                Initial Sample Constituent  Cone.  (Before  Adjustment)
                Initial Sample Adjustment
                 by Dilution	
                                (specify  )
or by Fortifying
                  (specify weight/volume)

Sub-
samp
1
2
3
4
Theoretica Cone. Approved Method Observations Proposed Method Observation*
Amount
Added*
0



Total^
Cone




Replicate
1




Replicate
2




Replicate
3




Replicate
1




Replicate
2




Replicate
3




* Identify the applicant or source of data ONLY by the USEPA-assigned application number.
+ See pp. 7-8 of the protocol for a discussion of how these concentrations are derived.

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