JlBaneiie
                                                 Arlington Otnce
                                                 2101 Wilson Boulevard. Suite 800
                                                 \rlmgton V-\ :220l-Uir)H
                                                 Iflecopiur irtl'il ~,5-~,Mn
 February 17,  1989
Ms.  Mary Frankenberry
U.S.  Environmental Protection Agency
Office  of Toxic Substances
401  M Street,  SW
Washington,  DC   20460

Dear Mary:

                      Contract No. 68-02-4294

Enclosed is  a  copy of the Draft Final Report, for Task 2-22,
"Quality Control Guidance,"  prepared under the above contract
number.

If you  have  any questions, please call me at (703) 875-2963 or
Bertram Price  at (202)  457-9007.

Sincerely,
Barbara Leczynski
Project Manager
Applied Statistics and
  Computer Applications  Section

BL:bs

Enclosures

cc: S. Dillman
    J. Glatz
    C. Stroup
    P. Cross, EED Contract  Monitor
    E. Sterrett
    L. Farmer (Itr only)

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                                   February  16,  1989

            DRAFT FINAL REPORT
                   for
                Task 2-22
         QUALITY CONTROL GUIDANCE
                    by

              Bertram Price
            Anne Morris Price

             Price Associates
           1825 K Street, N.W.
         Washington, D.C.  20006
            Barbara Leczynski
               Task Leader

                 BATTELLE
Columbus Division - Washington Operations
           2101 Wilson Boulvard
                Suite 800
        Arlington, Virginia   22201
         Contract No. 68-02-4294
      Susan Dillman,  Co-Task Manager
        Jay Glatz,  Co-Task Manager
    Mary Frankenberry,  Project Officer
      Design and Development Branch
       Exposure  Evaluation  Division
        Office of Toxic  Substances
Office of Pesticides and Toxic Substances
   U.S.  Environmental  Protection  Agency
         Washington, D.C.  20460

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                          OTS DISCLAIMER
           This  report  was  prepared  under contract to an  agency of
 the   United  States  Government.    Neither  the  United   States
 Government nor  any  of  its  employees, contractors, subcontractors
 or  their employees makes  any  warranty,  expressed or implied, or
 assumes  any  legal  liability  or   responsibility  for  any third
 part's  use of  or  the  results of  such  use  of  any information,
 apparatus,  product,  or  process disclosed  in  this  report,  or
 represents  that its use  by such third party would not infringe on
 privately  owned rights.                                     y

           Publication  of  the  data in  this  document  does  not
 signify  that   the  contents  necessarily  reflect  the   joint  or
 separate views  and policies of  each  sponsoring  agency.   Mention
 of  trade  names  or  commercials products does  not  constitute
 endorsement or  recommendation  for use.


                       BATTELLE DISCLAIMER

          This  is  a report of  research  performed  for  the United
 States  Government  by  Battelle.    Because of the  uncertainties
 inherent in experimental  or  research  work,  Battelle  assumes  no
 responsibility  or  liability for any consequences  of use, misuse.
 inability  to  use,  or  reliance upon  the  information  contained
 herein, beyond  any  express obligations  embodied  in the governinq
written  agreement   between  Battelle  and   the   United  States
Government.
                               11

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                       TABLE OF CONTENTS


TABLE OF CONTENTS	    iii

EXECUTIVE SUMMARY	     v

1. 0  INTRODUCTION	     1

2 . 0  CONCLUSIONS	     5

3.0  INSTRUMENT RESPONSE MODEL AND ESTIMATION METHOD	    10
     3.1  The Calibration Step	    13
     3.2  Estimating Concentrations of Target Compounds..    15
     3 .3  Quality Control Samples	    18

4 . 0  THE QC PROGRAM	    22
     4 .1  Description	    22
          4.1.1  Routine Calibration Check	    25
          4.1.2  Recovery	    26
          4.1.3  Post Analysis Review of QC Data	    27
     4.2  Discussion of QC Program Elements	    30
          4.2.1  Real Time QC	    31
                 4.2.1.1  Routine Calibration Check
                          Sample (RCC) 	    31
                 4.2.1.2  Recovery	    33
          4.2.2  Post Analysis Summary of Data Quality...    34

5. 0  SIMULATION ANALYSIS	    36
     5.1  Introduction	    36
     5.2  Description of Analysis and Parameter Values	    38
     5. 3  Results	    45

REFERENCES	    52
                               111

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                  TABLE OF CONTENTS  (continued)
                         LIST OF TABLES
 Table  E-l



 Table  E-2


 Table  4-1




 Table  5-1



 Table  5-2



 Table  5-3



Table  5-4
 Probabilities  of  Detecting  Calibration  and
 Recovery  Shifts	   viii
TCDD  Simulation Model  Parameter Values:
"In Control" Case	
QC  Procedures and Criteria  for Analysis of
Human Adipose Tissue Samples  for PCDDs
and PCDFs	

TCDD Simulation Model Parameter Values:
"In Control" Case	
TCDD Simulation Model Parameter Values:
RRF Shift	

TCDD Simulation Model Parameter Values:
Recovery Shift	
Probabilities of Detecting Calibration and
Recovery Shifts	
ix
23
                                              41
43
44
                                                             46
                        LIST OF FIGURES
Figure 5-1
QC Tests, Decisions, and Corrective
Actions	
                                                             40
                               IV

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                                                           DRAFT

 EXECUTIVE  SUMMARY
 The U.S. Environmental  Protection Agency  (EPA) analyzes adipose
 tissue  samples collected  in the National  Human Adipose Tissue
 Survey  (NHATS) to estimate and monitor exposure to
 environmentally persistent toxic compounds.  In 1982 the
 program was expanded to include analysis  methods for
 determining concentrations of polychlorinated dibenzo-p-dioxins
 (PCDDs) and dibenzofurans  (PCDFs).  The quality assurance
 project plan  (QAPP) for the analysis of the 1987 samples
 specifies  various types of quality control  (QC) activities
 intended to assure and  document data quality.  Since QC costs
 can be  significant, a study was initiated to investigate the
 effectiveness and costs of the current QC program as well as
 other QC programs that  may be considered  for the analysis of
 NHATS samples in future years.

 To advance the investigation,  a computer simulation model of
 the laboratory process  for adipose tissue analysis has been
 developed.   The model simulates events in their sequence of
 occurrence in the laboratory.   It distinguishes batches,  days
 required to complete a  batch,  and the following QC activities:
 initial calibration; routine calibration check at the beginning
and at the end of each day; a  test of absolute recovery of the
 internal quantitation standard (IQS)  in every sample; and a
                                v

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                                                          DRAFT

test of method recovery  (MR) following the completion of each
batch.

The simulation model may be applied to analyze effectiveness
and costs for a variety of QC programs and data quality
objectives including the QC program used for the 1987 samples.
To demonstrate the analysis approach, the model has been used
to address three questions concerning the current QC program
for NHATS samples.  A more comprehensive analysis,  based on the
simulation model, will be necessary to thoroughly evaluate
costs and efficiency for NHATS QC program alternatives.

The three questions are:

     1.   What are the false positive error rates associated
          with the routine calibration check,  the test of
          absolute recovery of the internal quantitation
          standard,  and the method recovery test?

     2.   What are the probabilities that these three
          components of the QC program will detect  a change in
          the calibration coefficient (usually referred  to as
          the relative response factor -  RRF)?
                               VI

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                                                           DRAFT

      3.    What  are  the  probabilities  that these three
           components  of the  QC  program will detect  a '
           degradation in method recovery?

 Simulation results  have been developed that provide answers  to
 the  three  questions.  Results for TCDD are summarized  in Table
 E-l  and  discussed below.   (TCDD is  used as an example
 throughout the  study  wherever specificity enhances  the
 presentation.)   Briefly, the analysis indicates that:

      o     the routine calibration test is effective;

      o     the absolute  IQS recovery test as currently
           formulated  may cause  positive bias in concentration
           estimates;  and

      o     the relationship between tests of IQS recovery and
           method recovery needs better coordination with data
           quality objectives.

  When the analytical process is "in control," (the first
column of Table E-l, based on the parameter values  in Table E-
2),  the probability of detecting a calibration failure is less
than 0.01  (i.e., the  false positive error rate is small).   The
column labeled "RRF Shift" in Table E-l refers to an increase
                               vii

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                                                                   DRAFT
      Table E-l.  Probabilities of Detecting Calibration and
                  Recovery Shifts
                                       Status of Analytical Process
      PC Test                 In Control   RFF Shift    Recovery Shift
                              	Probability of Detection	
      Routine Calibration       <0.01         >0.99           <0.01
      Check (RCC)*
      Internal Quantitation      0.39          0.45      •      0.14
      Standard (IQS)2
      Method Recovery (MR)3      0.09          0.10
0.69
Notes:
    1 - probability of detecting at least one RCC failure (i.e, two
    consecutive RCC sample failures) per batch

    2 - probability of detecting at least one IQS failure per batch

    3 - probability of detecting an MR failure per batch
                                       viii

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                                                                    DRAFT

     Table  E-2.  TCDD  Simulation  Model  Parameter Values:   "In  Control"  Case
  Analysis
  Operation
GC Resp. Parameter     Recovery
  Intercept  Slope    TCDD
                                              IS
                   Standard Deviation
                Batch   Sample  Analysis
    Calibration
       Std/IS
       IS/RS
0.00
0.00
0.80
1.73
1.000
1.000
                             1.000
                             1.000
                               0.00
                               0.00
                                0.0000
                                0.0000
                                0.0500
                                0.0800
    Field Samples
       U/IS
       IS/RS
0.00
0.00
0.80
1.73
0.595
1.000
                      0.521
                      0.521
                         0.15
                         0.15
                       0.1250
                       0.0525
                                                      0.1000
                                                      0.1575
    QC Samples
       Std/IS
       IS/RS
0.00
0.00
0.80
1.73
0.595
1.000
                      0.521
                      0.521
                         0.15
                         0.15
                       0.0150
                       0.0525
                                                      0.0450
                                                      0.1575
Notes:

The symbols */* in the left hand column refer to ratios of areas that represent
instrument responses.  The numbers in each row are the parameter values used
in the equation to generate an instrument response for the ratio indicated in
the first column.  For example, U/IS refers to the equation used to produce the
ratio of areas corresponding to the concentration of TCDD in a primary sample
and the concentration of the internal quantitation standard.

Std - a sample spiked with a known amount of TCDD
RS -  recovery standard sample
                                         ix

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                                                           DRAFT





 in the RRF of  37.5 percent immediately  following the  initial



 calibration.   The detection probability of the routine



 calibration test in this situation is greater than 0.99.   The



 routine calibration test, therefore, is extremely effective for



 detecting a change of this magnitude.







 When the analytical process is "in control" the internal



 quantitation standard (IQS) test has a  probability of 0.39 for



 detecting failures, a large value for a false positive error



 rate.  IQS absolute recovery test failures have two



 consequences.  First, the batch must be reextracted and



 analyzed resulting in additional cost.  Second, the test favors



 larger recovery values.   Estimated concentrations of TCDD  in



 primary tissue samples,  therefore, will be biased toward larger



 values.  These findings suggest that the IQS recovery test,



 which currently requires IQS recovery to be in the fixed



 interval between 0.40 and 1.50, should  be based on a



 statistical interval with boundaries determined from the mean



 and standard deviation of the recovery  estimate.







The column labeled "Recovery Shift" reflects a change from the



 "in control" case in both IQS absolute  recovery and method



recovery.   IQS recovery has been increased from 0.521 for the



 "in control" case to 0.600 and method recovery from 1.142 to



1.500.   The IQS detection probability drops from 0.39 to 0.14

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                                                          DRAFT

because  the  true  IQS recovery value is closer to the center of
the allowable range than it was  in the other two cases.  The
detection probability for the method recovery test has
increased from 0.09 to 0.69 because the hypothetical true MR
value of 1.500 is also the upper boundary of the MR test
interval.  (Note that the range of values defining the IQS test
and the  MR test are the same.)  The apparent inconsistency
between  the  detection probabilities of the two recovery tests
is, in part, a consequence of the fixed interval approach to
defining the recovery tests.  These tests should reflect DQO's
associated with applications of the data and, as indicated
above, should be based on statistical characteristics of the
recovery estimates.

The results discussed above reflect two sets of assumptions.
The first assumptions,  which are implicit in the QC program,
form the basis for detecting and correcting recovery problems.
These assumptions are:

     1.    when absolute recovery of the target compound in a
          primary sample declines as a result of sample
          processing,  absolute recovery of the internal
          quantitation  standard in the same sample also
          declines;  and
                               XI

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                                                           DRAFT

      2.    when absolute recovery of  the  target  compound in a
           primary sample declines as a result of  sample
           processing,  absolute  recovery  of  that target  compound
           in a QC sample also declines.

 Under these  assumptions:  (i) absolute recovery  of the internal
 quantitation standard  acts  as a recovery adjustment  applied to
 estimates  of target  compound concentrations; and  (ii) method
 recovery computed from QC samples is representative  of  method
 recovery in  primary  tissue  samples.   Neither assumption is
 easily verified and  if either assumption were violated,
 portions of  the QC program  may  be ineffective.  It is notable
 that  under these  assumptions a  change in the value of absolute
 recovery of  the internal  quantitation standard  does  not signal
 a change in  method recovery.

 The second set of assumptions concerns parameter values
 selected for the  simulation that  characterize recovery,
 variability, and the calibration  curve of the analytical
 method.  Most of the values used  for the cases  represented  in
 Table  E-l  were derived  from data  generated in a method
 validation study  (USEPA,  1986).    A few of the values, which
 could  not  be derived from the method validation data were based
purely on  judgement.   Additional values  for the parameters,
determined either subjectively or from more recent data, are
                               xii

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                                                          DRAFT

needed to conduct a sensitivity analysis of the results in
Table E-l and any subsequent findings regarding alternative QC
proposals.

The results presented in this report serve as one example of
the type of analysis that can be conducted with the simulation
model.  Additional analyses using the model are needed to
evaluate alternative QC programs and alternative data quality
objectives.  First, however, QC alternatives must be refined to
ensure they are practical with respect to laboratory operating
constraints and additional PCDD (PCDF)  measurement data, if
available, need to be analyzed to improve,  if possible,
estimates of model parameters.
                              Xlll

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                                                           DRAFT





 1.0  INTRODUCTION



 The U.S.  Environmental  Protection  Agency  (EPA) analyzes  adipose



 tissue  samples collected  in  the  National  Human Adipose Tissue



 Survey  (NHATS)  to estimate and monitor  exposure to



 environmentally persistent toxic compounds.  NHATS  is a



 statistically  designed  program intended to represent the



 general U.S. adult population.   In 1982 the program was



 expanded  to  include  analysis methods  for  determining



 concentrations of polychlorinated  dibenzo-p-dioxins (PCDDs)  and



 dibenzofurans  (PCDFs).  A detailed quality assurance project



 plan  (QAPP) was developed for the  analysis of the 1987 samples



 (MRI, 1988).   The QAPP  specifies various  types of quality



 control (QC) activities.  These  activities, which include



 analysis  of QC  samples, are  intended  to assure data quality  and



 provide information  that documents  data quality.  Since  QC



 activities can  add significant cost to  an analytical program,



 the effectiveness and cost of alternative QC programs for the



 NHATS analysis  is being investigated.   To further that



 investigation,  a  model has been developed to analyze the



 effectiveness and cost of alternative QC programs.  This report



 describes the model  and its  application for analyzing the QC



 program specified "in the QAPP for PCDD's  (PCDF's).







The analysis of tissue samples collected in 1987 involved 5



batches, each batch containing 12-15 composite samples.   The



analytical method  is high resolution gas chromatography/high

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                                                          DRAFT





resolution mass  spectrometry  (HRGC/HRMS).  The QAPP specifies



analysis  of QC samples including calibration checks, controls,



and spikes.  The purpose of QC samples,  in general, is to



monitor and document the quality of data being produced.  Since



the unit  cost of a QC sample analysis is equal to the unit cost



for analyzing a  primary sample, efficient allocation of QC



resources in terms of types and numbers of samples is



essential.  Each QC sample must contribute in a measurable way



to the quality of data used for estimating PCDD (PCDF)



concentrations in primary samples.







To evaluate alternative QC plans from a cost-effectiveness



perspective, quantitative data quality objectives (DQO's) are



needed.  DQO's should be associated with particular



applications of  the primary data.  The types and numbers of QC



samples necessary to achieve a DQO, then, can be assessed.







For example, the PCDD (PCDF)  estimates obtained by analyzing



human adipose samples may be used:








     (i)        to determine if the 1987 levels of PCDD (PCDF)



               are above or below an established standard



               (e.g.,  a standard based on health



               considerations); or

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                                                          DRAFT

      (ii)      to determine  if there is a trend in PCDD  (PCDF)
               levels  (e.g., compare 1987 results with past
               results).

The DQO  in both of these examples may be specified as a pair of
values for the Type I and Type II statistical error rates
(e.g., a Type I error rate of 0.15 and a Type II error rate of
0.20) associated with statistical tests of the implied
hypotheses .  This approach  to data quality, which focuses on
error rates associated with  statistical decisions based on
monitoring data, is consistent with recent guidance on the
development of DQO's prepared by the EPA/ORD Quality Assurance
Management Staff.

The magnitudes of statistical test error rates are affected by
recovery of the analytical measurement method, variability of
the method, and replication.  Information about recovery and
variability is obtained through analyses of QC samples.  An
analytical response model,  introduced in Section 3,  is used to
describe the concentration estimates produced by the HRGC/HRMS
method.   The model includes explicit parameters that
characterize calibration,  recovery,  and variability.   The
analysis of QC program effectiveness is based on the model and
these parameters.   Measurement characteristics of TCDD, one of

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                                                          DRAFT





the PCDD congeners, are used throughout this report as a



specific example to'enhance exposition.







The remainder of this report is presented in four sections.



Conclusions are summarized in Section 2.  Section 3 contains a



description of the analytical response model and a discussion



of the method employed for estimating concentrations of target



compounds in adipose tissue.  The current QC program is



described in Section 4 and results of computer simulation



analysis are presented in Section 5.

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                                                           DRAFT

 2.0   CONCLUSIONS
 A  computer  simulation model of the  laboratory process for
 adipose  tissue  analysis of NHATS samples has been developed.
 The model simulates  events in their sequence of occurrence  in
 the laboratory.   It  distinguishes batches, days required to
 complete a  batch, and the following QC activities: initial
 calibration; routine calibration check at the beginning and at
 the end  of  each day; a test of absolute recovery of the
 internal quantitation standard (IQS) in every sample; and a
 test  of  method recovery (MR) following the completion of each
 batch.   With parameter values selected to represent a
 particular  set of laboratory characteristics, the model may be
 used  to  evaluate the effectiveness  of alternative QC programs
 for detecting laboratory circumstances that are considered "out
 of control."

 The model also provides information for comparing costs of QC
 programs.   Costs depend on the total number of samples,
 including both primary and QC samples,  that must be analyzed to
 complete a  particular analytical program.   The number of
 samples  that must be analyzed may be greater than the minimum
number specified in an analytical program plan for two reasons.
First, false positive QC test results may require calibration
to be repeated or primary samples to be reanalyzed.   Second, an
"out of control" situation that is not  immediately detected by
                                5

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                                                           DRAFT





 QC  tests  could necessitate the  reanalysis of many primary



 samples.   Costs of alternative  QC programs, therefore, can be



 compared  by  comparing the total number of sample analyses  that



 must be conducted to complete the analytical program and



 achieve specified data quality  objectives.







 At  present,  the simulation model has been used to address  three



 questions concerning the current QC program.







     1.    What are the false positive error rates associated



           with the routine calibration check, the test of



           absolute recovery of the internal quantitation



           standard, and the method recovery test?







     2.    What are the probabilities that these three



           components of the QC program will detect a change in



           the  calibration coefficient (usually referred to as



           the  relative response factor - RRF)?







     3.    What  are the probabilities that these three



           components of the QC program will detect a



           degradation in method recovery?







One set of results has been developed that provides answers to



the three  questions.   Briefly,  the analysis indicates that:



                                6

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                                                           DRAFT
      o    the routine calibration test is  effective;

      o    the absolute IQS  recovery  test as  currently
           formulated  may cause positive bias in  concentration
           estimates;  and

      o    the relationship  between tests of  IQS  recovery  and
           method  recovery needs better coordination with  data
           quality objectives.

A discussion  of each  result follows.

The RCC test  is extremely effective.   The  false  positive  error
rate  is less  than 0.01.   The probability of  detecting changes
of 40  percent or  larger  in  the  RRF is  greater than 0.99.

The false  positive error  rate  for  the  IQS  absolute recovery QC
test  is approximately  0.40  when  IQS recovery is  slightly
greater than  0.5  and method recovery is approximately 1.1.  IQS
recovery test  failures have two  consequences.  First, when a
failure is detected, the  batch must be reextracted and analyzed
resulting  in additional cost.  Second,  since method recovery
and absolute recovery are correlated, method recovery in the
batches that pass the test  will  reflect the characteristics of
                                 7

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                                                          DRAFT

 the  IQS  samples that pass.  This test favors larger recovery
 values.  Estimated concentrations of target analyte in primary
 tissue samples, therefore, will be biased toward larger values.
 These findings suggest that the IQS recovery test, which
 currently requires IQS recovery to be in the fixed interval
 between  0.40 and  1.50, should be based on a statistical
 interval with boundaries determined from the mean and standard
 deviation of the  recovery estimate.

 When IQS recovery is larger (e.g., 0.6) and method recovery is
 1.5, the IQS detection probability drops to 0.14 because the
 IQS recovery value is closer to the center of the allowable
 range defining the test.  The detection probability for the
 method recovery test in this case is 0.69 because the
 hypothetical MR value of 1.5 is also the upper boundary of the
 test interval.  The apparent inconsistency between the
 detection probabilities of the two recovery tests is,  in part,
 a consequence of the fixed interval approach to defining the
 recovery tests.  These tests should reflect DQO's associated
with applications of the data and, as indicated above, should
be based on statistical characteristics of the recovery
estimates.

The results presented in this report serve as one example of
the type of analysis that can be conducted with the simulation
                                8

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                                                          DRAFT
model.  Additional analyses using the model are needed to
evaluate alternative QC programs and alternative data quality
objectives.  First, however, QC alternatives must be refined to
ensure they are practical with respect to laboratory operating
constraints and additional PCDD (PCDF) measurement data, if
available, need to be analyzed to improve, if possible,
estimates of model parameters.

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                                                           DRAFT
 3.0  INSTRUMENT RESPONSE MODEL AND ESTIMATION METHOD
 The procedure for estimating PCDD (PCDF).  concentrations in
 human adipose tissue involves the analysis of calibration
 samples,  quality control samples,  and primary human adipose
 tissue samples.   Each sample is fortified (spiked)  with two
 internal  standards prior to analysis:  an  internal  quantitation
 standard;  and a  recovery standard.   The internal quantitation
 standards  are chemically almost identical to  the target
 compounds.   (For TCDD,  the  internal  quantitation standard is  a
 13C12  labeled version of the same  analyte - 13C12-2,3,7,8-TCDD.
 The recovery  standard is 13C12-l,2/3,4-TCDD.)

 The analytical instrument responses  associated with these
 samples are areas that  are  proportional to the analyte
 concentrations.   The  areas  are  summarized as  two ratios:  (i)
 the target compound area divided by  the internal quantitation
 standard area; and  (ii)  the  internal quantitation standard  area
 divided by the recovery  standard area.  These ratios may  be
 described mathematically as:
     A/A* = K0 + K1*(C/CI) + Za[K0 + K1*(C/c')]     (Equation
1)
where
                                10

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                                                           DRAFT

           A is the instrument response  (an  area)  to
           concentration C ;  -

           A  is the instrument response  to  concentration C1;

           Kg and KI are the  intercept and slope respectively  of
           the straight  line  relationship;

           a is the coefficient of variation of the  response
           ratio;  and

           Z is a  random deviate with distribution N(0,l).

The term,  Za[K0 +  K1*(C/c')],  represents a  random error
contribution to the  instrument response which, in general,
consists of three  components.   These are: (i) a batch
component;  (ii) a  sample  component; and  (iii) an analytical
replication component.  The error term takes the general  form:

    random  error =  (ZBaB  + zsas + Zrar)*[K0 + K1*(C/C1)]
                                                (Equation 2)

where
          aB represents batch variability;
          as represents sample variability;
                                11

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                                                          DRAFT

          ar represents analytical replication variability; and
          ZB' zs» zr are standard normal variates.

There also is an instrument response relationship similar to
Equations 1 and 2 for the ratio of the internal quantitation
standard to the recovery standard.  These response equations
are discussed in more detail later.

Estimates of PCDD (PCDF) concentrations are obtained as
follows:

     1.    Establish an instrument calibration curve (i.e.,
          obtain estimates of K0 and K±) .
     2.    Spike an adipose tissue sample with a known
          concentration of the internal quantitation standard;

     3.    Prepare (extract)  the sample;

     4.    Add a known concentration of the recovery standard to
          the extract;

     5.    Analyze the sample and compute estimates.
                               12

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                                                           DRAFT

Specification  of these steps and subsequent details regarding
the analytical method are based on the presentation in MRI,
1988.

3.1  THE CALIBRATION STEP
Calibration solutions are prepared with known concentrations of
the target compound, the internal quant itat ion standard, and
the recovery standard.  Eight samples, each with different
concentrations of the target compound, are used.
Concentrations of the two internal standards are constant
across the calibration samples.  The calibration relationship
for the target compound is:
              = K0 + K1*(CSTD(i)/CIS)
                      + (Zsi^s + Zri°r)*[K0 + K1*(CSTD(i)/CIS)]
                                                   (Equation 3)
where

     ASTD(i)   is tne instrument response (area) corresponding
               to concentration CSTD(i) of the target compound;

     AIS       i-s the instrument response corresponding to
               concentration CIS of the internal quantitation
               standard;
                                13

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                                                           DRAFT

      K0,  K!    calibration  parameters  to  be  estimated;  and

      a's,  Z's   previously defined  in Equation  2.

 aB  does not enter  Equation  3  since the calibration  step does
 not involve batches.

 The calibration relationship  for the internal  quantitation
 standard  relative  to the recovery  standard is:

 (AIS(i)/ARS) =  L0  + L1*(CIS(i)/CRS)
                      +  (Zsias + Zriar)*[L0  +  L1*(CIS(i)/CRS)]
                                                    (Equation 4)

 CRS  and ARS  are  tne concentration  and  instrument response
 respectively for the recovery standard.   Further discussion of
 this relationship  is found with the discussion of recovery in
 Section 3.2.

 Estimated values of K0 and Kx in Equation 3  are used to
 calculate target compound concentrations  from analyses of
 primary samples.  Typically, K0 is assumed to be zero (i.e.,
the calibration  curve goes through the origin)  and K± is
 referred to  as the relative response factor  (RRF).  K^ may be
estimated by the method of least squares.   The approach used in
                                14

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                                                           DRAFT

 MRI,  1988  is  a  slight  variation  of  the  standard  least squares
 approach.  • An RRF  is calculated  for each  calibration sample.
 That  is:

           RRF(i) = (ASTD(i)/AIS)-r(CSTD(i)/CIS)      (Equation  5)

 If the  relative standard  deviation  (RSD)  of the  RRF's is  less
 than  0.20  (or 0.30 depending  on  the target compound),  i.e., if

      ({2[RRF(i)-ave{RRF(i) }]V(n-l)}* -=- ave{RRF(i)»  <  .20,

 then  RRF is set equal  to  ave{RRF(i)}.  This value of RRF  is,  in
 fact, the  weighted least  squares estimate of Kx  when K0 is  zero
 and the weights are [CsTDfiJ/Cjs]-1.  Throughout the ensuing
 discussion, the operating calibration relationship will be

                    (A/A1) = RRF*(C/C')            (Equation 6)

 based on RRF  as defined above.

 3.2  ESTIMATING CONCENTRATIONS OF TARGET COMPOUNDS
The procedure for  estimating concentrations of the target
compounds  in  tissue samples involves steps 2, 3, 4,   and 5
listed in Section  3.0.   Denote the unknown concentration of the
target compound and the concentration of the internal
                               15

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                                                           DRAFT

 quantitation standard by Cy and CIS respectively.   The internal
 quantitation standard is added to the sample before extraction.
 Denote  by P^Cy and 02cis tne concentration of these two
 compounds in the final extract.   /?]_ and /32 represent recovery
 proportions.   Both values are expected to be between zero and
 one.  The estimate of the unknown concentration is:

           est(Cu)  = (Au/AIS)*(CIS/RRF)              (Equation 7)

 where AU  is  the  instrument response for the target compound of
 unknown concentration and RRF is the relative response factor
 determined in  the  calibration step.   This estimate is
 potentially  biased for a number  of reasons,  but most
 specifically because  AU and AIS  are instrument responses  to
 concentrations of  ^Cu and 02CIS respectively rather than GU
 and CIS.   Using  Equation 6 to substitute for AU/AIS  in Equation
 7 demonstrates that

           est(Cu)  =  (j9i//?2)-Cu.                    (Equation 8)

The factor,  (/3i//32) i  is  method recovery  (MR).   /3X  represents
recovery of the  target  compound.   f32  represents recovery  of the
internal quantitation  standard.   If f32 = PI,  then  MR = 1  and
the estimate of  GU would  be unbiased.  The  estimation method of
Equation 7, therefore,  implicitly  utilizes  the  analytical
                                16

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                                                           DRAFT

 response for the internal quantitation standard as a recovery
 adjustment for estimating Cjj.

 02  may be estimated from data  generated for the internal
 quantitation standard and the  recovery standard.   Equation 4
 represents the calibration relationship between instrument
 response and concentration for these compounds.  When L0 is
 zero,  the weighted least squares estimate of Llf  which is the
 relative response factor for the internal quantitation standard
 (RRFIS),  is

           RRFIS  =  ave{AIS/ARS)-5-(CIS/CRS) }         (Equation 9)

 with the average  taken over all  calibration  samples.   The
 operating calibration relationship  for the  internal
 quantitation  standard relative to the recovery standard,
 therefore,  is
                (AIS/ARS)=RRFIS*(C/CRS).            (Equation 10)

An estimate of  /?2  is

     est(02)  =  (Ais/ARS)-(CRS/CIS)-HRRFIs.          (Equation 11)

Substituting  the right hand  side of Equation  10 with  C replaced
by &2CIS' which is the concentration  of the internal
                                17

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                                                           DRAFT

 quantitation  standard  in  the  extract,  into  Equation 11  confirms
 the  estimating  formula for  02

 est(/32)  =  RRFIS()32CIS/CRS)'(CRS/CIS)H-RRFIS = 02   (Equation 12)

 Note that the value  of 02 alone  does not  constitute sufficient
 information to  assess  the degree of bias  in estimates of  GU,
 the  unknown concentration of  the target compound.   Assuming,
 however,  that p: = 02  implies that estimates of GU  are
 unbiased.   Information about  p-^  and method  recovery
 (i.e., MR = /?i//32) may be obtained from QC  samples  as discussed
 below
     •

 3.3  QUALITY  CONTROL SAMPLES
 For  purposes  of this discussion,  the term QC samples refers to
 samples of  adipose tissue that originally contain,  at most,  the
 background  concentration, C0, of the target  compounds.  (Other
 types of  samples are used for QC purposes also.  These  samples
 - calibration samples  and routine calibration check samples -
 are  discussed in Section 4.1.)   These QC samples, then, are
 spiked with known concentrations  of the target compounds.
Unspiked  samples (i.e., a spiking concentration of  zero)  also
are  included  in this definition.  The unspiked samples  of
adipose tissue are referred to as "controls."
                                18

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                                                           DRAFT

 3.3.1  Method Recovery
 Spiked QC  samples  may  be  used  to  estimate  analytical  method
 recovery.   A  QC  sample is analyzed by  following  the same
 procedure  used for primary adipose tissue  samples.  The
 internal quantitation  standard is added to the spiked sample
 prior to extraction and the recovery standard is added to  the
 final extract prior to analysis.  The  concentration of the
 target compound  in a QC sample will be CSTD, the spiking
 concentration, plus C0/ the background concentration.  Denoting
 the concentrations of  the target  compound  and the internal
 quantitation  standard  in  the final extract by 0' ^» (CSTD+C0) and
 ^ 2*CIS respectively,  and applying the estimation method
 embodied in Equation 7, yields

      est(CSTD) = est(CSTD+C0)  - est(C0)
               = (P* i/(3'2) *CSTD-                  (Equation 13)
Since CSTD is a known quantity, an estimate of the method
recovery factor is:

     est(MR) = est(CSTD)/CSTD.                    (Equation 14)

Estimates of the concentration of the target compounds in
primary tissue samples may be adjusted in an attempt to remove
recovery bias.  That is,
                                19

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                                                           DRAFT
      adj (Cjj)  = est(Cu)/(est(MR) .           (Equation 15)

Using the  results  of  Equations  8  and  13  in Equation 15 yields

      adj(Cu)  = C(j8i//9I1) + (jS2//Sl2)]-Cu             (Equation 16)

The adjusted  estimate is unbiased if  the recovery proportions
of the target compound in  primary samples and QC  samples are
equal  (i.e.,  p* ^ = p^  and the  recovery  proportions of the
internal quantitation standard  in primary samples and  QC
samples are equal  (i.e., p ' 2 =  /32) , or if method  recovery is
the same in both types of  samples (i.e.,  P\/P* 2  =
The potential differences among values of  the /?'s  result  from
differences in the effects of sample processing  (i.e.,
extraction) on target compounds recently spiked  into  samples  of
adipose tissue and target compounds that were part of the
sample at the time it was taken from its donor.  In fact,  the
values of p\, p2, and 0*2 may be closer to each other than to
the value of P1.  Determining if p± and P2 have different
values than p\ and /? ' 2 cannot be resolved without extensive,
complex experimentation.  Even if P2 = /?'2, which  is  likely and
can be determined from QC data, the possibility that  p\  and  p-^
                                20

-------
                                                          DRAFT

may differ has implications for the allocation of QC resources
and the use of QC analysis results.
                               21

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                                                           DRAFT

 4.0  THE QC PROGRAM
 4.1  DESCRIPTION
 The 1987 NHATS  samples  were  analyzed  in  five  batches  consisting
 of  12 to 15 samples per batch.   For purposes  of  the analysis
 undertaken  in this  report, there will be five batches each
 consisting  of 12 primary samples plus QC samples.  A  batch
 requires two days to complete -  six primary samples per day
 plus  QC  samples.

 The complete set of QC  procedures and criteria for taking
 corrective  action are summarized in Table 4-15 of the QAPP
 (MRI,  19-88)  which is reproduced  in this  report for reference
 purposes as  Table 4-1.   The  current analysis  of  QC
 effectiveness focuses on a subset of the QC procedures
 described in the table.   These are: (i) the routine calibration
 check; (ii)  absolute recovery of the internal  quantitation
 standard in  primary samples; (iii)  absolute recovery  of the
 internal  quantitation standard in QC samples;  (iv) method
 recovery  determined  from  QC  samples; and  (v) post analysis
 review of all QC data to  evaluate method precision, constancy
 of  recovery  across  batches,  and  constancy of recovery with
 respect to concentration  level of the target compound.  Recall
 that the term "QC sample" in this report is used to describe:
unspiked samples of human adipose tissue with  naturally
occurring background  levels of PCDD (PCDF) which are
                               22

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               Table  4-1
                                          IdLle 4 IS   (JL l-Mnedmes -1 LOU-, ,d lu, Analysis of ll,.jn Adipuse I ,ssue
     And I vs is event
                                                                                                                               fo, PI IVIs dnd ICM »«
  Cdllbrdl ion


•  PUin/PC»  dnd lysis
U)
    (oluon perloradiiie
    lalibrdlion standards

    •  lnili.il tdlibrdl ion
    •  Nouline calibration
    Ir id« dne  blank
   Sd«nleS/QL s a«|iles

   •  Analysis
      Pel lurndiue evdliidl tun
      u dap Its
                                Daily
                                I  n si event ol
                                diiulysit Udy
                                        red I
 Pieiedes  in it id I
 SJ*ple  dndlysis  It
 routine idl ibrdtian
 does not MCI outing
 i dl ibrdtian erf lend.

 Precedes staple
 dnjlysis on ddily
 bat is.  Also oust
dMonslrdle idlibrdlion
ds  IdSl  injection or
edch dndlyses ddy.
                              A,  VuLallKJ  IH sample
                              bdUh   i u I  I iii-
                           »uil  Jvauislrdle diiuidlc Bd^i  cdlibidllun uilnj
                                             (PU).   »inl  dtlivily  ol
                                   ltdy

                           IKinij If K  lunv  to d  ainiauB  resolution ol  10 .000
                           (liH  n.ilU-r) dml up! i«dl  m|«me  dnd |ivdk ihd|w
                           •/< JUI    Adjuil  Bdyiiviic  field  lo pdii •/< JUU  dl
                           .-lc'rjtii>j volldije    Introduce PU Ihrouqh
                           ilireil  inlel dnd diquire dueler dl my volldyv
                           tidns tnm BUUU  lo 4UUU V using  IIKOS lid Id SyM»
                           loa«dss (•// Jtll) idrnlided in PIK tpuclru* used
                           lo uutldte.   Mass Cdlibrdtion ranges I rat JUI to
                           S9] d*u.
                                                         Must  dnonstrdte isowr specificity for
                                                         7.J./.B ILOU before proceeding with
                                                         of  Cdlibrdliun sldnddid
                                                         •   bO-« UD-b (.oluin.  /S» resolul ion
                                                        Analysis of si. concenlrdtion Cdlibrdtion
                                                        Sldiiddrds.  1 K>0 of KM for MM KHf (or all
                                                        standards tJOI for PUID/PIU . l2M tor IUJO/
                                                        ICtt.
                                                   Measured HW values fur solution Cb / oust be
                                                   within tJUX for FCUI/Plllf  and i.'Ul for IIDU/ICU .

                         Ikicuaenl  resuons.  of  internal  recovery  sldnddid(s)
                         diid  Cuajidi e  lo  ddily  CdliLuliuii  tidiiddiil
                         Inleiiidl  retovmy  slaiiddiil rn|unsn auM be
                         Milhin bill of response noted for  cdlibrdlion
                         slmdard  used lo verify KM values.  ^a*pln
                         iuuiitlrd as blinds lo Hi analyst.

                         lh«k solutions provided by QTT for •easurmml of
                         aiturdiy.  10 I JUI   Uu nut piucecd »ilh Sdaple
                         diulysis  until nul it led of dLitptdble prrlw«diH.e
                         by the QLL.
                                                                                                              H«.dlibidliuii    II iiileridnul dLlneved.
                                                                                                              du nul |Hotn.-a Mllh dlidlyill
                                                                                                                                                               Netponiibilily
                                                      dlldly*!
  Meier  lu  luninu, and .uss talibi al ion uruiedure   Mb analyst
  II crilfi ta Ldnnul be mlneved.  imtruaifil Bay
  re<|uiie Bdlnl i-noiicc
                                                                               Adjust CO loan luiu,|n (~U I •)  and lediu
                                                                               ly*e perforunce •i.tmt.    II
                                                                               insldll  d nex HRLC toluvi dinj
 Prepare  fresh concentration calibration
 standard.
                                                                                                             Meanalyie solution CS-/ or repeal  the inilidl
                                                                                                             idlibration sequence.   If  calibration criteria
                                                                                                             are nul  *el at the end of  the day  all saapln
                                                                                                             are subject lo reanalysis  by tMGC/IIIMs..
                                                                                                             *nd/or  •nje.non  l.ner.
 II  internal recovery sUnddrd noted lu be
  001 ul idlibml lun sldiiddrd. iedndly
-------
to
.£>.
        Table  4-1  continued

                                                                       l-ible 4 IS ((.oiil mued)
                             I •«•!»«".»              If niurid                     	        .."      - -    -  -               .          _       	
                                                                                              Cm ic>. I ivv  di. limit                          „      .  ,
                                                                                                                                      "—	Ibl Illy
        Udld mler|ircldl ion    lullo»inj dndlyus of
                            bdUh
        InltTiidl (1)1 Sd^ilfs)                       /V.Curdi  (Kihi.1 r


                                                 -""«iLT'il^n'u,1^! "LTrd..'^«.d btlowr'  0,1,"""!1,!,,!'  l^f1 '^T""' '•l*l'""d      »
                                                 vilhin 40 IbW                                "  rediidinii.  tdiple bdli.li  is &ubj«.l  lu


                                                                                               uu „/- «.u u  ...~   /... ,.•	           ..       IBBHII k-djer
          lor the dfidlysu ul Ml (JO dnd HHUf drc Idr^etcO lo Mel
                                                                      „ „,, ,„„, ,or

-------
                                                           DRAFT

 called controls;  and  two  other  samples  of adipose tissue  that
 have  been spiked  with PCDD  (PCDF),  one  at a low concentration
 level and the  other at a  high concentration level.   (For  TCDD,
 the spiking  concentrations were 0  for the control, 10 pg/g,  and
 50 pg/g.)  These  three QC samples  were  analyzed, unidentified
 to the analyst and interspersed randomly among the primary
 samples,  with  each batch  (Heath,  1988).

 4.1.1  Routine Calibration Check
 A routine  calibration check  (RCC)  is the first and last sample
 analyzed  each  day.  RCC is identical to a calibration sample
 with  the  target compound  concentration  at one of the lowest
 calibration  concentrations (2.5  pg/nl for TCDD).  An estimate
 of the  relative response  factors for the target compound  and
 for the internal  quantitation standard  (i.e.,  RRF and RRFIS)
 are determined  for this sample  and compared to the current
 operating values  of these response factors (i.e.,  the RRF's
 determined from the most  recent calibration).   At the beginning
 of the day,  if either RRF or RRFIS differs from the current
 operating calibration values by ±20% for TCDD (±30% for other
 compounds),  a new RCC sample must be prepared and analyzed
before proceeding.  If the second RCC fails,  the initial
calibration must be repeated.  If the RCC at the end of the  day
 fails twice,  the  initial calibration must be repeated and all
                                25

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                                                           DRAFT

 primary samples analyzed that day are subject to reanalysis
 (MRI,  1988;  Table 4-1).

 4.1.2   Recovery
 Absolute recovery of  the internal quantitation standard is
 monitored in every primary sample.   This  recovery factor,
 denoted as /32  previously in this  report,  is  calculated using
 the  formula:

     est(02)  = (AIS/ARS) • (CRS/CIS)-rRRFIS           (Equation 17)

 The  QAPP requires that 0.40 < est(/32)  < 1.50.   If this QC
 criterion is  satisfied,  the analysis program proceeds  to the
 next sample.   If  the  QC  criterion is not  satisfied,  the sample
 is reanalyzed  and a new  estimate  of  /32 is tested.  If  the  QC
 criterion is not  satisfied  on this second attempt, the initial
 calibration must  be repeated  (i.e.,  new values  of RRF  and  RRFIS
 must be  estimated).

 Absolute  recovery  of  the internal quantitation  standard also is
 monitored  in all QC samples.   Method  recovery  is  checked using
 the QC samples with nonzero spiking  levels.  The  method
 recovery  tests are conducted  after all samples  in  a batch  have
been analyzed.  Method recovery is determined  from:
                                26

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                                                           DRAFT





           est(MR)  = est(CSTD)/CSTD                (Equation 18)







 where est(CSTD)  is defined in Equation 13.







 The QAPP specifies that both estimates must  fall  between 0.40



 and 1.50 for the analysis program  to  continue.  If  the



 estimates of either /32  or MR are outside  the specified  range,



 the QC sample must be reanalyzed and  tested  again.   A second



 failure means the  initial calibration must be repeated.   If



 upon reanalysis  the QC  test fails,  all primary  samples  in the



 batch are subject  to reextraction  and analysis.







 4.1.3  Post  Analysis Review of QC  Data



 Upon completion  of the  analytical  program, data will  have been



 collected on 15  QC samples,  three  samples from each  of the five



 batches.   The  three samples from each batch  are:  a control



 sample  of adipose  tissue  (i.e., unspiked); a  low  concentration



 spiked  sample  of adipose  tissue (10 pg/g  for  TCDD); and  a high



 concentration  spiked sample of adipose  tissue (50 pg/g for



 TCDD).  These  data  may  be used in a variety of ways to



 characterize the quality  of data obtained from the primary



 samples.   Following Heath,  1988,  these data are used  to:  (i)



 obtain a  working estimate of overall method recovery; (ii) test



 for method recovery differences among batches; (iii)  test  for



method recovery dependence  on concentration level; and (iv)



                               27

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                                                          DRAFT

estimate method precision  (i.e., estimate the total standard
deviation of concentrations of target compounds measured  in
primary samples) .  These results are obtained using regression
analysis applied to the estimated and true concentrations from
QC samples.

In the basic regression model:

       est(CSTD(i)) = a0 + a^Cs-roti) + Z^a,       (Equation 18)
the ordinary least squares estimate of a^ is an approximation
of method recovery assuming method recovery is independent of
batch and concentration.  Dependence of method recovery on
batch is modeled by adding Er j 'Bji'CSTD(i) to the right side of
Equation 18.  B j ^ is defined to be 1 if the ith QC sample came
from the jtn batch and 0 otherwise.  With this addition to
Equation 18, method recovery in the jtn batch is equal to c^ +
TJ.  Dependence of method recovery on concentration is modeled
by adding £6k'Cki'CSTD(i) to the right side of Equation 18.
Cki is defined to be 1 if the itn QC sample has the kth spiking
concentration and 0 otherwise.  In this expanded equation,
method recovery for a QC sample analyzed in batch j and having
a true concentration equal to spiking level k would be a^ + T
                                28

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                                                          DRAFT

Based on the  full model  (i.e., Equation 18 with the terms
described above added to the right side), method recovery would
be independent of concentration if the 6's were all equal to 0.
This can be tested as a statistical hypothesis by combining
appropriate sums of squares from the expanded model and from a
"restricted"  model with all fi's set equal to zero to form an F
ratio with 2  and 7 degrees of freedom (Chatterjee, 1977) .
Method recovery would be independent of batch if the r's were
all equal to  0.  This hypothesis can be tested by combining the
appropriate sums of squares and using an F ratio with 4 and 7
degrees of freedom.

The root mean square error calculated from the expanded model
may be used as an estimate of overall method precision.
                               29

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                                                           DRAFT

 4.2   DISCUSSION OF PC PROGRAM ELEMENTS
 The  QC program described  above consists two general components:
 (i)  a component based on  samples  that may be evaluated  in  real
 time to identify and  correct  analytical problems when they
 occur;  and  (ii)  a component that  provides information about
 data quality  only after all samples have been analyzed.  The
 former component,  as  represented  in the QAPP, is intended  to
 control recovery throughout the analytical program.  The latter
 component provides information on recovery, factors that affect
 recovery, and precision (Heath, 1988).

 Ideally, each QC activity has  a clearly defined purpose and a
 measurable contribution to data quality objectives.  The
 purpose of each  QC activity in the NHATS program is apparent,
 however the relationship of these activities to a DQO that
 reflects an application of the data has not been developed.
 The  acceptance bounds  in Table 4-1 for RRF's, absolute
 recovery, and method  recovery,  have not been identified with a
 DQO  for a specific  application of the data,  but are treated in
 the  QAPP as the  DQO's.  Therefore, the only measurable
 contribution to  data quality that can be analyzed for this QC
 program is the contribution each  QC activity makes to holding
 the  RRF and recovery within the bounds specified.  Whether
those bounds are adequate for  any specific application of the
data is  an open question.
                                30

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                                                           DRAFT
 4.2.1   Re»T Time OC
 4.2.1.1 Routine Calibration Check Sample  (RCC)
 The  RCC is employed at the beginning and end of each day to
 determine if the calibration relationship has changed.  This is
 accomplished by comparing estimates of RRF and RRFIS based on
 each RCC sample to the current operational RRF and RRFIS
 derived previously from a calibration experiment involving
 eight samples at eight different concentrations.  The
 effectiveness of this element of the QC program should be
 measured by the Type I and Type II statistical error rates for
 testing a hypothesis of no change in the RRF (i.e., the
 likelihood that the RCC test will indicate a significant shift
 in the  calibration factor, RRF, when in fact no change has
 taken place; and the likelihood that no change will be detected
 when in fact a significant shift in the calibration factor has
 occurred).

 Both types of errors have implications for the effectiveness of
 the QC  program.   Type I errors cause calibration experiments to
be repeated unnecessarily which adds cost and time to the
analysis program.   Type II errors are at least as damaging.   If
a change in RRF to a larger value is undetected,  concentration
estimates of the target compound in primary samples will be
inflated.  Estimates of method recovery obtained from QC
                               31

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                                                          DRAFT





samples will be larger than before the undetected shift



occurred.  If a change in RRF to a smaller value is undetected,



concentrations in primary samples will be underestimated and



method recovery estimates derived from QC samples also will be



smaller.  The Type I error rate may be reduced by expanding the



allowable difference between the RRF value obtained from the



RCC sample and the value of the operating RRF.  The Type II



error rate may be reduced by increasing the number of



independent RCC samples used to compare RRF's.  The number of



samples required depends also on the magnitude of change in RRF



that is important to detect.  This quantity, which should be



reflected in the DQO's for specific applications of the data,



is not addressed in the QAPP.







The effectiveness of the QC program for detecting RRF shifts of



approximately 40 percent has been quantified using simulation



analysis.  These results are presented in Section 5.  Note that



RRF shifts,  as indicated above,  may be detected not only



through RCC samples,  but also through QC sample estimates of



method recovery.   In fact,  when the method recovery test fails,



the first corrective action recommended is to repeat the



initial calibration (Table 4-1).
                               32

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                                                           DRAFT

4.2.1.2  Recovery
The NHATS QC program includes two forms of recovery: absolute
recovery of the  internal quantitation standard, which can  be
estimated from each primary and QC sample; and method recovery,
which can be estimated only from QC samples.  Absolute recovery
(/32 in the discussion found in Section 3.3) is checked in  every
sample to test for a shift in its value.  A test for a change
in method recovery is conducted with every QC sample that  has a
non-zero spiking level (i.e., two samples per batch, 10 samples
overall).  The method recovery tests are conducted at the
completion of a batch.  A failure that is not corrected by re-
calibration requires each sample in the batch to be reextracted
and analyzed (Table 4-1).

The effectiveness of both tests for uncovering calibration or
recovery problems depends,  in part,  on the following
assumptions:

     1.    when absolute recovery,  p^,  of the target compound in
          a primary sample  declines  as a result of sample
          processing,  absolute recovery,  02,  of the internal
          quantitation standard in the same sample also
          declines;  and
                               33

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                                                           DRAFT

      2.    when  absolute  recovery,  /?]_,  of  the  target  compound in
           a  primary  sample  declines  as a  result  of sample
           processing,  absolute  recovery,  (3\,  of that  target
           compound in  a  QC  sample  also declines.

 (The  mathematical notation  employed  above is  the same  notation
 defined  and  used in  Section 3.3.)

 The QC program  is predicated on both assumptions.  Under these
 assumptions:  (i) absolute recovery of  the internal quantitation
 standard,  /?2, acts as  an implicit  recovery adjustment  applied
 to estimates of target compound concentrations;  and  (iii)
 method recovery computed from QC samples  is representative of
 method recovery in primary  tissue  samples.  If either
 assumption were violated, portions of  the  QC  program would
 produce misleading results.   It is notable, however, that under
 these assumptions a  change  in the  value of /?2 does not signal a
 change in method recovery.

 4.2.2  Post Analysis Summary of Data Quality
The statistical analysis described in  Section 4.1.3 of all QC
samples following completion  of the analytical program leads
to: (i)  a working estimate of overall method recovery; (ii) a
test for method recovery differences among batches;  (iii) a
test for method recovery dependence on concentration level; and
                                34

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                                                           DRAFT





 (iv)  an estimate  of  method  precision  (i.e.,  an estimate  of the



 total standard  deviation  of concentrations of target  compounds



 measured in  primary  samples).  The validity  of these  results



 depends on the  same  assumptions underlying the validity  of the



 real  time applications  of QC program  elements.







 Since these  statistical results are not available until  after



 all samples  have  been analyzed, if a  problem is indicated  there



 is little opportunity to  correct the  analytical process  and



 reanalyze samples.   A problem, such as a shift in recovery



 across  batches  that  was not  identified and corrected  in  real



 time, becomes a permanent characteristic of  the data.  This and



 other characteristics may, however, be used  effectively  in



 applications of the  data.  In the example cited (i.e., a shift



 in method recovery across batches) an estimate of method



 recovery  for each batch could be used to adjust estimated



 concentrations  from  each  primary sample prior to comparing



 these data to similar data from other years.   Summary



 statistics derived from QC samples, therefore,  should be



 retained as statements of data quality with the data from



 individual samples.  The  adequacy of the current QC program to



supply this data quality  information can be analyzed using the



computer simulation approach described in Section 5.
                               35

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                                                           DRAFT
 5.0  SIMULATION ANALYSIS
 5.1  INTRODUCTION
 A computer  program has  been developed  that  simulates the
 laboratory  process described  in MRI, 1988 for analyzing the
 1987  NHATS  adipose tissue  samples.   (This computer program is
 referred to as  the simulation model  or simply as "the model" in
 the ensuing discussion.)   The model  simulates events in their
 sequence of occurrence  in  the laboratory.   The model
 distinguishes batches,  days required to complete a batch,  and
 the following QC activities:  initial calibration; routine
 calibration check at the beginning and at the end of each  day;
 test  of absolute recovery  of the internal quantitation standard
 in  every sample;  and test  of method recovery following the
 completion  of each batch.

 Laboratory  measurements are generated  using Equations 1 and 2
 of  Section  3.  These equations represent the analytical
 instrument  response, a ratio of areas,   which is translated into
 an  estimate  of concentration using Equation 8 (Section 3.2).
 Different choices  of parameter values  in Equations 1 and 2 are
 used to generate measurements for the different types of
 samples addressed  in the model (i.e., calibration samples,
 calibration check  samples,  primary adipose tissue samples; and
QC samples).
                                36

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                                                           DRAFT
 After the parameter values  are  selected  to  represent  a



 particular set of laboratory  characteristics, the model  is  used



 to evaluate the effectiveness of  alternative QC programs for



 detecting laboratory circumstances  that  are considered "out of



 control."  For example,  the parameters in the model may  be



 adjusted  to incorporate  a systematic shift  over time  in  the RRF



 value.  Simulation results, then, would  lead to an estimate of



 the probability of detecting  the  shift.  The magnitude of the



 shift could be varied to estimate the relationship between  the



 detection probability and the magnitude  of  change in  the RRF.



 A  similar analysis could be conducted for recovery.   The model



 also may  be run for a laboratory that is "in control" (i.e., no



 systematic shifts  in  the values of  parameters that affect data



 guality)  to estimate  false  positive rates associated  with the



 QC  activities.   In general, the model can be used to  evaluate



 the  effectiveness  of  any QC program that has well-defined QC



 activities,  QC test decision  rules, and corrective actions.







 In addition  to QC  effectiveness, the model provides information



 for  comparing  costs of QC programs.  Costs depend on the total



number of  samples,  including both primary and QC samples, that



must be analyzed to complete a particular analytical program.



The number of  samples that must be analyzed may be greater than



the minimum number specified in an analytical program plan for



two reasons.   First,  false positive QC test results may require



                                37

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                                                          DRAFT

calibration to be repeated or primary samples to be reanalyzed.
Second, an "out of control" situation that is not immediately
detected by QC tests could necessitate the reanalysis of many
primary samples.  Costs of alternative QC programs, therefore,
can be compared by comparing the total number of sample
analyses that must be conducted to complete the analytical
program and achieve specified data quality objectives.

5.2  DESCRIPTION OF ANALYSIS AND PARAMETER VALUES
To date the simulation model has been used to investigate three
questions concerning the QC program for analysis of adipose
tissue to determine levels of TCDD.

     1.   What are the false positive error rates associated
          with the routine calibration check,  the absolute
          recovery test of the internal quantitation standard,
          and the method recovery test?

     2.   What are the probabilities that these three
          components of the QC program will detect an increase
          in the RRF?

     3.   What are the probabilities that these three
          components of the QC program will detect a
          degradation in recovery?
                               38

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                                                           DRAFT
 The  simulation  model  incorporates the QC  tests, decision  rules,
 and  actions  described in  Figure  5-1.   (These  are based on Table
 4-1  and MRI,  1988).   Analytical  measurements  representing each
 type of sample  are generated using Equations  1 and 2  (Section
 3) with the  parameters appearing in those equations replaced by
 appropriate  values.   (Parameter  values for TCDD were used.
 TCDD is used as an example throughout the study wherever
 specificity  enhances  the  presentation.)

 The  parameter values  used to address question 1 are displayed
 in Table 5-1.  The parameter values for this case are constant
 throughout the analysis of all samples in the batch.  The model
 is used to simulate analysis of  500 batches.  For each QC test,
 data are collected from each batch regarding the number of
 tests conducted and the number of tests resulting in failures.
 The  ratio of the number of failures to the number of tests,
 averaged over the 500 replicate batches,  is an estimate of the
probability of detecting a QC failure,   since the analytical
process remains "in control" in this first case (i.e., there
are no changes in the parameter values defining the process),  a
                               39

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                                                           DRAFT

 Figure 5-1.   QC Tests,  Decisions,  and Corrective Actions
 A:  INITIAL CALIBRATION AND INITIAL CALIBRATION TEST
 PASS  -  Begin analysis
 FAIL  -  Repeat calibration


 B:  ROUTINE CALIBRATION CHECK  (RCC)  AT BEGINNING OF DAY
 PASS  -  Begin analysis
 FAIL  -  Reanalyze  solution
      PASS  - Begin analysis
      FAIL  - Go to A


 C:  ROUTINE CALIBRATION CHECK  (RCC)  AT END  OF  DAY
 PASS  -  Prepare for next day
 FAIL  -  Reanalyze  solution
      PASS  - Prepare for next  day
      FAIL  - Go to A and reanalyze  all samples from that  day


 D:  IQS  ABSOLUTE RECOVERY (ALL SAMPLES)
 PASS  -  Continue with next  sample
 FAIL  -  Reanalyze  solution
      PASS  - Continue with  next sample
      FAIL  - Analyze an RCC sample
           PASS  -  Reextract batch and  analyze
           FAIL -  Go to A.  Repeat  initial  calibration  and
                  reanalyze all samples from that day


E: METHOD  RECOVERY  (estimated concentration in  spiked  QC sample
minus estimated concentration in QC control divided by QC
spiking concentration)
PASS  - Record average  method  recovery and  continue with  next
       batch
FAIL  - Record  failure  and  average method recovery  for  the batch
                                40

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                                                                  DRAFT

    Table  5-1.   TCDD  Simulation Model  Parameter Values:   "In Control"  Case
  Analysis
  Operation
GC Resp. Parameter
  Intercept  Slope
                Recovery
               TCDD    IS
                                  Standard Deviation
                               Batch   Sample  Analysis
    Calibration
       Std/IS
       IS/RS
0.00  0.80
0.00  1.73
                      1.000  1.000
                      1.000  1.000
                               0.00   0.0000   0.0500
                               0.00   0.0000   0.0800
    Field Samples
       U/IS
       IS/RS
0.00  0.80
0.00  1.73
               0.595  0.521
               1.000  0.521
                                      0.15   0.1250   0.1000
                                      0.15   0.0525   0.1575
    QC Samples
       Std/IS
       IS/RS
0.00  0.80
0.00  1.73
               0.595  0.521
               1.000  0.521
                                      0.15    0.0150   0.0450
                                      0.15    0.0525   0.1575
Notes:

The symbols */* in the left hand column refer to ratios of areas that represent
instrument responses.  The numbers in each row are the parameter values used
in the equation to generate an instrument response for the ratio indicated in
the first column.  For example, U/IS refers to the equation used to produce the
ratio of areas corresponding to the concentration of TCDD in a primary sample
and the concentration of the internal quantitation standard.

Std - a sample spiked with a known amount of TCDD
RS -  recovery standard sample
                                        41

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                                                           DRAFT

QC test  failure means that a  false positive has occurred and
the probability estimated is  the false positive error rate for
the QC test in question.

The parameter values used to  address question 2 are displayed
in Table 5-2.  In this case,  the RRF undergoes a change after
the initial calibration.  This is accomplished by using a  value
of K! equal to 0.80 in Equation 1 (Section 3) for the
calibration step and a value  of K! equal to 1.10 when
generating data for all other samples.  The model is used  to
simulate 500 batches and probabilities of detecting the change
in the RRF are estimated using ratios as described above.  In
this case,  since a shift in the RRF has taken place, the ratios
estimate probabilities of correctly detecting a QC failure.

The parameter values used to address question 3 are displayed
in Table 5-3.   A change in method recovery from 1.142 to 1.500
has been imposed by changing values of the /J's as indicated in
the table.
                               42

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                                                                 DRAFT
     Table  5-2.   TCDD Simulation Model  Parameter Values:   RRF Shift
   Analysis
   Operation

     Initial
     Calibration
        Std/IS
        IS/RS
GC Resp. Parameter
  Intercept  Slope
       0.00
       0.00
0.80
1.73
          Recovery
         TCDD
1.000
1.000
        IS
1.000
1.000
            Standard Deviation
                 Sample  Analysis
O.OQ
0.00
0.0000
0.0000
0.0500
0.0800
     Routine  Calibration
     Check Samples
       Std/IS           o.OO   1.10
       IS/RS           0.00   1.73
                      1.000
                      1.000
                1.000
                1.000
                0.00
                0.00
                0.0000
                0.0000
                0.0500
                0.0800
    Subsequent
    Calibration
       Std/IS
       IS/RS
       0.00
       0.00
1.10
1.73
1.000
1.000
1.000
1.000
0.00
0.00
0.0000
0.0000
0.0500
0.0800
    Field Samples
       U/IS
       IS/RS
       0.00
       0.00
1.10
1.73
0.595
1.000
0.521
0.521
0.15
0.15
0.1250
0.0525
0.1000
0.1575
    QC Samples
       Std/IS
       IS/RS
       0.00
       0.00
1.10
1.73
0.595
1.000
0.521
0.521
0.15
0.15
0.0150
0.0525
0.0450
0.1575
Notes:

The symbols */* in the left hand column refer to ratios of areas that represent
instrument responses.  The numbers in each row are the parameter values used
in the equation to generate an instrument response for the ratio indicated  in
the first column.  For example, U/IS refers to the equation used to produce the
ratio of areas corresponding to the concentration of TCDD in a primary sample
and the concentration of the internal quantitation standard.

Std - a sample spiked with a known amount of TCDD
RS -  recovery standard sample
                                         43

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                                                           DRAFT
     Table 5-3.   TCDD Simulation Model Parameter Values:   Recovery Shift
   Analysis
   Operation
GC Resp. Parameter
  Intercept  Slope
          Recovery
         TCDD    IS
                	Standard Deviation
                Batch   Sample  Analysis
     Calibration
       Std/IS
       IS/RS
       0.00
       0.00
0.80
1.73
1.000
1.000
1.000
1.000
0.00
0.00
0.0000
0.0000
0.0500
0.0800
    Field Samples
       U/IS
       IS/RS
       0.00
       0.00
0.80
1.73
0.900
1.000
0.600
0.600
0.15
0.15
0.1250
0.0525
0.1000
0.1575
    QC Samples
       Std/IS
       IS/RS
       0.00  0.80
       0.00  1.73
         0.900
         1.000
       0.600
       0.600
         0.15
         0.15
       0.0150
       0.0525
         0.0450
         0.1575
Notes:

The symbols */* in the left hand column refer to ratios of areas that represent
instrument responses.  The numbers in each row are the parameter values used
in the equation to generate an instrument response for the ratio indicated in
the first column.  For example, U/IS refers to the equation used to produce the
ratio of areas corresponding to the concentration of TCDD in a primary sample
and the concentration of the internal quantitation standard.

Std - a sample spiked with a known amount of TCDD
RS -  recovery standard sample
                                        44

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                                                           DRAFT
 5.3  RESULTS
 Results that provide answers to the three questions introduced
 in Section 5.2 are summarized in Table 5-4.

 When the analytical process is "in control,"  (i.e.,  the process
 is characterized by the parameter values  in Table 5-1),  the
 probability of detecting a calibration failure  is less  than
 0.01 and the probability of a method recovery failure  is
 approximately 0.09.   The test of absolute recovery of the
 internal quantitation standard has a detection  probability
 equal  to 0.39.

 The  absolute IQS  recovery failures have two consequences.
 First,  the  batch  must be reextracted and  analyzed resulting in
 additional  cost.   Second,  since  method recovery and  absolute
 recovery are correlated,  method  recovery  in the batches  that
 pass will reflect the characteristics of  the  IQS  tests that
 pass.   These tests  favor larger  recovery  values.   Estimated
 concentrations of TCDD in  primary  tissue  samples,  therefore,
will be  biased toward  larger values.  For example, MR for  these
parameter values  is 1.142  (i.e., 0.595*0.521  or p^ divided  by
/?2 according to Equation 8  in Section 3.2).   An analysis result
for a sample with a below  average  random contribution (see
Equation 4 in Section  3.2) would be likely to fail the IQS
recovery test since the underlying value of f32  is near the
                                45

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                                                                 DRAFT
      Table 5-4.  Probabilities of Detecting Calibration and
                  Recovery Shifts
                                       Status of Analytical Process
      QC Test                 In Control   RFF Shift    Recovery Shift
                              	Probability of Detection	
      Routine Calibration       <0.01         >0.99           <0.01
      Check (RCC)1
      Internal Quantitation      0.39          0.45            0.14
      Standard (IQS)2
      Method Recovery (MR)3      0.09          0.10
0.69
Notes:
    1 - probability of detecting at least one RCC failure (i.e,  two
    consecutive RCC sample failures)  per batch

    2 - probability of detecting at least one IQS failure per batch

    3 - probability of detecting an MR failure per batch
                                        46

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                                                           DRAFT

 lower boundary  (0.40)  of  the  test  interval.  This below  average
 random contribution  affects recovery  (see Equation  3  in  Section
 3.2)  also,  causing it  to  be below  average.  Since the IQS  test
 is  likely to  result  in a  failure,  the batch will be reextracted
 and analyzed  again.  The  new  set of results will be retained  if
 the estimate  of /?2 is  larger  than  0.40, which is assured when
 the random  contribution is above average.  An above average
 random contribution  also  ensures an above average method
 recovery ratio.  The IQS  test when (32 is near the lower
 boundary of the test interval, therefore, acts as a filter,
 eliminating analyses of primary samples with below  average
 recovery ratios and  retaining analyses with above average
 recovery ratios.

 The effect  of the IQS  recovery test described above also is
 observed in simulation output that summarizes recovery for all
 primary samples processed by  the model.  When method  recovery
 is  set, as  above, at 1.142 and (32  is 0.521, average method
 recovery estimated by the model is 1.210.  The value  should be
 1.142.  The discrepancy is due to  the filtering effect of  the
 IQS recovery test.

These  findings suggest that the IQS recovery test,  which
currently requires IQS recovery to be in the fixed  interval
between 0.40 and 1.50,  should be based on a statistical
                               47

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                                                          DRAFT





 interval with boundaries determined from the mean and standard



 deviation of the recovery estimate.







 The second and third columns of Table 5-4 display probabilities



 that QC tests correctly detect changes in the operating



 characteristics of the analytical procedure.  The column



 labeled "RRF Shift" refers to an increase in the RRF of 37.5



 percent, which occurs immediately following the initial



 calibration.  The RCC test is extremely effective for detecting



 a change of the stated magnitude.  The detection probability is



 greater than 0.99.  The probabilities for the IQS test and the



 MR test are both false positive error rates since the recovery



 values have not been altered from the values used for the "in



 control" case.  The interpretation of these probabilities,



 therefore, is the same as that in the former case.







 The column labeled "Recovery Shift" reflects a change from the



 "in control" case in both IQS absolute recovery and method



 recovery.   IQS recovery has been increased from 0.521 to 0.600



 and method recovery from 1.142 to 1.500.   The RCC test



probability for this situation is less than 0.01 as expected



since it is a false positive error rate.   The IQS detection



probability drops to 0.14 because the IQS recovery value is



closer to the center of the allowable range than it was in the



other two cases.   The detection probability for the method



                               48

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                                                          DRAFT

recovery test has increased to 0.69 because the hypothetical MR
value of 1.500 is equal to the upper boundary of the test
interval.   (Note that the range of values defining the IQS test
and the MR test are the same.)  The apparent inconsistency
between the detection probabilities of the two recovery tests
is, in part, a consequence of the fixed interval approach to
defining the recovery tests.  These tests should reflect DQO's
associated with applications of the data and, as indicated
above, should be based on statistical characteristics of the
recovery estimates.

The results discussed above reflect two sets of assumptions.
The first assumptions, which are implicit in the QC program,
form the basis for detecting and correcting recovery problems.
These assumptions are:

     1.    when absolute recovery of the target compound in a
          primary sample declines as a result of sample
          processing,  absolute recovery of the internal
          quantitation standard in the same sample also
          declines;  and

     2.    when absolute recovery of the target compound in a
          primary sample declines as a result of sample
                               49

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                                                           DRAFT





           processing, absolute  recovery of that target compound



           in  a  QC  sample  also declines.







Under  these assumptions:  (i) absolute recovery of the internal



quantitation  standard acts as a recovery adjustment applied to



estimates  of  target compound concentrations; and  (ii) method



recovery computed  from QC samples  is representative of method



recovery in primary tissue samples.  Neither assumption is



easily verified and if either assumption were violated,



portions of the QC program may be  ineffective.  It is notable,



however, that under these assumptions a change in the value of



absolute recovery of the  internal  quantitation standard does



not signal a change in method recovery.







The second set  of assumptions concerns values selected for



parameters that characterize recovery, variability, and the



calibration curve of the  analytical method.  Most of the values



used for the case represented in Table 5-4 were derived from



data generated  in the method validation study of the analytical



method for measuring PCDDs (PCDFs) in adipose tissue referred



to previously (USEPA,  1986).   A few of the values, which could



not be derived  from the method validation data were based



purely on judgement.   Additional values for the parameters,



determined either subjectively or  from more recent data,  are



needed to conduct sensitivity analyses of the results discussed



                                50

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                                                          DRAFT
above and any subsequent findings regarding alternative QC



proposals.
                               51

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                                                          DRAFT


REFERENCES
USEPA. 1986.  Analysis for Polychlorinated Dibenzo-p-Dioxins
(PCDD) and Dibenzofurans (PCDF) in Human Adipose Tissue: A
Method Evaluation Study.  Washington, D.C.  Office of Toxic
Substances.  EPA-560/5-86-020.


MRI.  1988.  Quality Assurance Project Plan for Work Assignment
27  (Revision No. 2)  Analysis of Adipose Tissue for Dioxins and
Furans.  Washington, D.C.  U.S Environmental Protection Agency
Contract No. 68-02-4252.
Heath, R.G.  1988.  Two Plans (A and B) for Allocation of
Quality Control Samples for Chemical Analysis of FY87 Composite
Samples.  Washington, D.C.  U.S. Environmental Protection
Agency Contract No. 68-02-4294


Chatterjee, S., B. Price. 1977.   Regression Analysis Bv
Example.  New York, N.Y.  John Wiley & Sons.
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