£%	United States

Environmental Protectio
^1 M^k. Agency

Office of Water

www.epa.gov	December 2022

Quality Assurance Report for the
National Coastal Condition Assessment
2015 Great Lakes Human Health Fish
Fillet Tissue Study


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U.S. Environmental Protection Agency
Office of Water
Office of Science and Technology (4305T)
Standards and Health Protection Division
1200 Pennsylvania Avenue, NW
Washington, DC 20460

EPA 820-F-22-005


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Table of Contents

Page

Acknowledgements	iii

Disclaimer 	iii

Contact 	iii

Chapter 1 Introduction	1

Section 1.1 Background	1

Section 1.2 Study Design	1

Section 1.3 Study Participants	3

Section 1.4 Study Results	4

Chapter 2 Quality Assurance Program	6

Section 2.1 Quality Assurance Project Plans	6

Section 2.2 Training	6

Section 2.3 Sample Preparation and Analysis QA/QC	7

Section 2.4 QA Oversight of Laboratory Operations	8

Chapter 3 Preparation and Analysis Methods	9

Section 3.1 Preparation of Fish Fillet Tissue Samples	9

Section 3.2 Analysis of Fish Tissue Samples for Mercury	9

Section 3.3 Analysis of Fish Tissue Samples for PCBs	9

Section 3.4 Analysis of Fish Tissue Samples for PCDD/PCDF	10

Section 3.5 Analysis of Fish Tissue Samples for PFAS	10

Section 3.6 Analysis of Fish Tissue Samples for Fatty Acids	11

Section 3.7 Analysis of Rinsates and Solvent Blanks	11

Section 3.8 Quality Control Procedures	12

Chapter 4 Data Quality Assessment	15

Section 4.1 Data Review	15

Section 4.2 Analysis of Blanks	17

Section 4.3 Analysis of Laboratory Control Samples	18

Section 4.4 Analysis of Matrix Spike, Matrix Spike Duplicate, and Laboratory

Duplicate Samples	19

Section 4.5 Surrogates and Labeled Compounds	20

Section 4.6 Ion Abundance Ratio	22

Section 4.7 Standard Reference Material for Fatty Acids	23

Section 4.8 Completeness	23

References 	24

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List of Tables

Page

Table 1. Quality Control Activities for Analysis of Fish Tissue Samples	12

Table 2. Quality Control Activities for Analysis of Rinsates	13

Table 3. Individual SCC Codes Applied to the GLHHFFTS Results	16

Table 4. Matrix Spike, Matrix Spike Duplicate, and Duplicate Sample Requirements

by Analysis Type	20

List of Figures

Page

Figure 1. Sampling locations of the 152 valid fish samples collected for the 2015 GLHHFFTS	2

Figure 2. GLHHFFTS project team organization	5

Figure 3. Impacts of Blank Contamination on the PCDD/PCDF Results	18

Figure 4. Impacts of Ion Abundance Ratios on the PCDD/PCDF Results	22

Figure 5. Impacts of SRMs on the Fatty Acid Results	23

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Acknowledgements

This quality assurance report was prepared by the U.S. Environmental Protection Agency (EPA), Office
of Water (OW), Office of Science and Technology (OST). The EPA Project Manager for the study was
Leanne Stahl, who provided overall project coordination and technical direction with assistance from
Elizabeth Murphy of EPA's Great Lakes National Program Office (GLNPO). GLNPO planned field
logistics and provided fish sample collection support for this study. Tetra Tech, Inc. also provided field
sampling support for this study under Contract Number EP-C-14-016. Quality assurance and analytical
subcontracting support was provided by General Dynamics Information Technology (GDIT) and several
predecessor organizations, including Computer Science Government Solutions (CSGov) and CSRA
(hereafter collectively referred to as GDIT) under Contract Numbers EP-C-12-008 and EP-C-17-024.
GDIT was responsible for production of this report under the direction of Leanne Stahl and John Healey.

Disclaimer

The U.S. Environmental Protection Agency, Office of Water, Office of Science and Technology has
approved this report for publication. Mention of trade names, commercial products, or services does not
constitute official EPA approval, endorsement, or recommendation for use.

Contact

Please address questions and comments to:

John Healey

Standards and Health Protection Division
OW/Office of Science and Technology (4305T)
US Environmental Protection Agency
1200 Pennsylvania Ave, NW
Washington, DC 20460
healey.john@epa.gov

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Chapter 1
Introduction

This report documents the quality of data gathered during the 2015 Great Lakes Human Health Fish Fillet
Tissue Study (GLHHFFTS), which was a regional component of EPA's Office of Wetlands, Oceans, and
Watersheds (OWOW) National Coastal Condition Assessment (NCCA). The NCCA is a probability-
based survey designed to assess the condition of coastal waters of the United States, which includes
nearshore waters of the Great Lakes. Multiple EPA offices collaborated to conduct this survey (which is
repeated every five years), including the Office of Research and Development (ORD) that developed the
survey design and conducted statistical analysis of the fish tissue data, OWOW that provided overall
management for implementation of the NCCA, and the Office of Science and Technology (OST) and the
Great Lakes National Program Office (GLNPO) that conducted the fish tissue studies under the NCCA.

Section 1.1 Background

Obtaining statistically representative environmental data on mercury, polychlorinated biphenyl (PCB)
congeners, and other chemicals of concern is a priority area of interest for EPA. Beginning in 1998, OST
partnered with ORD to conduct the first statistically based national-scale assessment of mercury, PCBs,
and selected other target chemicals in fish from U.S. lakes and reservoirs. This study was called The
National Study of Chemical Residues in Lake Fish Tissue, but it is commonly referred to as the National
Lake Fish Tissue Study. The Great Lakes were excluded from the National Lake Fish Tissue Study
because assessment of a freshwater system of that magnitude required a separate sampling design. Since
2008, OST has collaborated with OWOW and ORD to conduct a series of probability-based studies of
freshwater fish contamination. These include national-scale studies of river fish contamination under the
agency's National Rivers and Streams Assessment (NRSA), which are referred to as the 2008-09 NRSA
Fish Tissue Study and the 2013-14 NRSA Fish Tissue Study. They also include regional-scale studies of
fish contamination in the five Great Lakes, which are referred to as the NCCA 2010 Great Lakes Human
Health Fish Tissue Study (2010 GLHHFTS) and the NCCA 2015 Great Lakes Human Health Fish Fillet
Tissue Study (2015 GLHHFFTS). OST has been partnering with GLNPO to conduct the Great Lakes fish
tissue studies under the NCCA.

The regional Great Lakes fish tissue study component was added to the NCCA sampling design in 2010
and focused on analysis of chemical contaminants in fillet tissue samples (because consumption of fillet
tissue is an exposure pathway relevant to human health). As a result, the probability-based Great Lakes
sampling design developed for the 2010 NCCA offered the opportunity to conduct the 2010 GLHHFTS
as the first statistically representative study of chemical residues in Great Lakes fish relevant to human
health. The 2015 GLHHFFTS provided additional Great Lakes basin-wide data on the occurrence and
distribution of contaminants in the fillets from Great Lakes fish and, through comparison with the 2010
fillet tissue results, allowed EPA to evaluate temporal changes of these contaminants in Great Lakes fish.
Collecting statistically representative data for other contaminants not measured in 2010 (e.g., dioxins and
fiirans) was an additional goal of this 2015 study.

Section 1.2 Study Design

Within OW, OST collaborated with GLNPO and with ORD's Western Ecology Division (now called the
Pacific Ecological Systems Division) in Corvallis, Oregon, to conduct the 2015 GLHHFFTS. A total of
152 valid fish samples were collected for the study at a statistical subset of NCCA Great Lakes nearshore
sites distributed throughout the five Great Lakes (Figure 1). The majority of fish samples (147) were
collected from June through October 2015 and an additional five samples were collected in Lake
Michigan during May 2016.

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The following were the key design components for the 2015 GLHHFFTS:

•	sampling at least 150 randomly selected sites (about 30 sites per lake) in the nearshore regions
(depths up to 30 m or distances up to 5 km from shore).

•	collecting one fish composite sample for human health applications (i.e., five similarly sized adult
fish of the same species that are commonly consumed by humans) from each site.

•	shipping whole fish samples to an interim frozen storage facility.

•	transferring the whole fish samples to a laboratory for fish sample preparation, which includes
filleting the fish, homogenizing the fillet tissue composites, and preparing fillet tissue aliquots for
analysis of specific chemicals, along with a series of archive samples that may be used for future
analyses of other contaminants.

•	analyzing the fillet tissue samples for mercury (total), 209 PCB congeners, 13 perfluorinated
compounds that are a subset of the broader group known as per- and polyfluoroalkyl substances
(PFAS), 17 2,3,7,8- substituted dioxin and furan congeners (PCDDs/PCDFs), and 38 omega-3
and omega-6 fatty acids.

EPA stored the 2015 GLHFIFFTS whole fish samples in freezers leased by GDIT at Microbac Laboratories
in Baltimore, Maryland, prior to transporting them to the sample preparation laboratory. Tetra Tech's
Center for Ecological Sciences in Owings Mills, Maryland was the sample preparation laboratory
preparing the homogenized fish fillet tissue samples for analysis as outlined in the fourth bullet above,
under a purchase order issued from GDIT. The sample preparation laboratory also prepared aliquots of

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fillet tissue for mercury, PCBs, PFAS, polychlorinated dibenzo-/;-dioxins and polychlorinated
dibenzofurans (PCDDs/PCDFs), and omega-3 and omega-6 fatty acids. Commercial environmental
laboratories analyzed the 2015 GLHHFFTS fish fillet tissue samples for mercury, PCBs, PFAS,
PCDDs/PCDFs, and a university laboratory analyzed the samples for fatty acids, under project-specific
purchase orders issued by GDIT. Procedures for handling and shipping homogenized fish tissue samples
to the analysis laboratories are described in Appendix B of the Quality Assurance Project Plan for Fish
Sample Preparation and Analysis for the 2015 National Coastal Condition Assessment Great Lakes
Human Health Fish Fillet Tissue Study (USEPA, 2016a).

Section 1.3 Study Participants

The GLHHFFTS project team consisted of managers, scientists, statisticians, and QA personnel in OST,
the ORD Western Ecology Division, and GLNPO, along with contractors providing scientific and
technical support to OST from GDIT and Tetra Tech, Inc. (Figure 2). Project team members from
GLNPO provided support for developing and reviewing technical and program information related to all
aspects of the study, including training materials, standard operating procedures, Quality Assurance
Project Plans (QAPPs), analytical QA reports, briefings and reports on study results, and outreach
materials. Key members of the project team are listed below.

•	Leanne Stahl of OST was the GLHHFFTS Project Manager who provided overall direction for
planning and implementation of this regional Great Lakes study that was conducted under the NCCA.

•	Elizabeth Murphy of GLNPO was a 2015 GLHHFFTS Project Co-Manager who provided overall
direction for planning and implementation of this regional Great Lakes study that was conducted
under the NCCA.

•	Marion Kelly was the OST Quality Assurance Officer who was responsible for reviewing and
approving all QAPPs that involve scientific work being conducted by OST with support from Bill
Kramer, the SHPD QA Coordinator, and Louis Blume, the GLNPO QA Manager.

•	Blaine Snyder was the Tetra Tech Project Leader who was responsible for managing all aspects of the
technical support provided by Tetra Tech staff for the GLHHFFTS.

•	Susan Lanberg was the Tetra Tech QA Officer.

•	Harry McCarty was the GDIT Project Leader who was responsible for managing all aspects of the
technical support provided by GDIT staff for the GLHHFFTS.

•	Yildiz Chambers-Velarde was the GDIT Project Leader who was responsible for managing all aspects
of the administrative support provided by GDIT staff for the GLHHFFTS.

•	Marguerite Jones was the GDIT QA Officer.

•	Tony Olsen was the Senior Statistician at what was then the ORD Western Ecology Division in
Corvallis, Oregon who supported the GLHHFFTS by providing technical expertise for study design
planning and statistical analysis of fish tissue data.

The whole fish samples were stored in freezers leased by GDIT at Microbac Laboratories in Baltimore,
Maryland. Tetra Tech, in Owings Mills, Maryland, prepared the fish fillet samples and rinsates for
analysis. Tetra Tech held multiple aliquots of archived fillet tissue in a freezer at its facility to allow for
further analyses of GLHHFFTS samples in the future.

Note: Unless otherwise modified, all references to "fish" and "samples" in this report refer to
homogenized fish fillet tissue samples prepared by Tetra Tech.

Four commercial laboratories and one academic laboratory analyzed the GLHHFFTS fish tissue samples
for mercury, PCBs, PCDDs/PCDFs, PFAS, and omega-3 and omega-6 fatty acids, under subcontracts to
GDIT, as shown below and in Figure 2.

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Laboratory	Analysis Type

ALS-Environmental	Mercury

Vista Analytical	PCB congeners

AXYS Analytical	PCDDs/PCDFs

AXYS Analytical	PFAS

Clarkson University	omega-3 and omega-6 Fatty Acids

Section 1.4 Study Results

EPA posted the final analytical results for all of the samples in this study in MS Excel files at:
https://www.epa.gov/fish-tech/2015-great-lakes-human-health-fish-fillet-tissue-study

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Figure 2. GLHHFFTS project team organization

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Chapter 2
Quality Assurance Program

At the beginning of the study, EPA managers recognized that data gathered from the study would be used
extensively by individuals responsible for making environmental, economic, and policy decisions.
Environmental measurements always contain some level of uncertainty. Decision makers, therefore, must
recognize (and have the means to assess) the uncertainty associated with the data on which their decisions
are based. In recognition of this, the study managers established a quality assurance (QA) program to
ensure that data produced under the study would meet defined standards of quality.

Section 2.1 Quality Assurance Project Plans

Two separate Quality Assurance Project Plans (QAPPs) are associated with this study. In 2014, OWOW
and OST coordinated to develop the NCCA Quality Assurance Project Plan (USEPA 2014a) that
describes the procedures and associated quality assurance/quality control (QA/QC) activities for
collecting and shipping NCCA samples of all types. It includes the human health fish collection and
shipping procedures that OST developed for the GLHHFFTS based on the protocols used for the National
Lake Fish Tissue Study, as well as procedures for the collection of other types of samples.

In February 2016, OST developed the QAPP that covered the activities associated with GLHHFFTS fish
sample preparation and analysis of samples (USEPA 2016a). That QAPP was revised four times as
funding became available to carry out additional types of analyses of the fillet tissue samples. The first
revision of the OST QAPP added mercury analyses, and it was approved in April 2016 (USEPA 2016b).
The second revision added PCB and PFAS analyses, and it was approved in June 2016 (USEPA 2016c).
The third revision added fatty acid analysis, and it was approved in February 2017 (USEPA 2017a). The
final revision added PCDD/PCDF analysis, and it was approved in April 2017 (USEPA 2017b).

The OST QAPP for the study presented performance criteria, acceptance criteria, and objectives for the
analysis of mercury, PCBs, PCDDs/PCDFs, PFAS, and fatty acids in fish collected for the GLHHFFTS.
The QAPP also described the methods and procedures to be followed during the study to ensure that the
criteria and objectives are met. The QAPP addressed mercury, PCBs, PCDDs/PCDFs, PFAS, and fatty
acid analytical activities. The QAPP was prepared in accordance with the most recent version of EPA
QA/R-5, EPA Requirements for Quality Assurance Project Plans (USEPA 2001a), which was reissued in
2006.

Section 2.2 Training

Fish Tissue Sample Preparation

Specialized training was provided for laboratory technicians who prepared fish tissue fillets and
homogenates for the study. This training was conducted at Tetra Tech in Owings Mills, Maryland, on
March 2, 2016 for all laboratory staff involved with GLHHFFTS fish tissue sample preparation, to
accomplish the following objectives:

•	present the GLHHFFTS fish tissue preparation, homogenization and distribution procedures that are
described in the standardized operating procedure (SOP) found in Appendix B of the sample
preparation and analysis QAPP (USEPA 2016a)

•	demonstrate filleting and homogenizing techniques with fish from invalid GLHHFFTS samples, and

•	provide hands-on opportunities for fish preparation laboratory staff to become proficient at filleting
and homogenizing fish samples.

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Analysis of Fish Tissue Samples

All laboratory staff involved in the analysis of fish tissue samples were required to be proficient in the
associated tasks, as required by each analytical laboratory's existing quality system. All GDIT staff
involved in analytical data review and assessment were already proficient in data review, so no
specialized training was required for data reviewers for this project.

Section 2.3 Sample Preparation and Analysis QA/QC

EPA integrated various QA/QC activities into the study to ensure data comparability and generate
analytical data of known quality during preparation and analysis of the fish fillet tissue samples and
evaluation of analytical data quality. There were separate QA/QC activities associated with the
preparation of the fish fillet samples and the analyses of those samples.

Following is a summary of the critical QA/QC components associated with the sample preparation
process:

•	Development and implementation of the sample preparation activities in the QAPP (USEPA 2016a,
2016b, 2016c, 2017a, and 2017b)

•	Use of one laboratory for sample preparation (filleting, tissue homogenization, and preparation of
tissue aliquots)

•	Requirement for triplicate lipid analyses to test for tissue homogeneity during sample preparation

•	Requirement for preparation equipment rinsate samples with each batch of fish fillet tissue samples
prepared

•	Requirement for analyses of the rinsate samples for mercury and selected PCDD/PCDF and PCB
congeners

•	Review and acceptance of rinsate results by EPA before proceeding with preparation of additional
samples

Following is a summary of the critical QA/QC components associated with the sample analysis process:

•	Development and implementation of the analytical activities in the QAPP (USEPA 2016a, 2016b,
2016c, 2017a, and 2017b)

•	Use of one laboratory for the analyses of a given class of analytes

•	Identification of quantifiable measurement quality objectives

•	Use of pure and traceable reference standards

•	Demonstration of instrument calibration and system performance

•	Periodic calibration verification

•	Analysis of QC samples to assess performance of analytical methods

•	Specification of method detection limits (MDLs) and method/chemical QC acceptance criteria that
applied throughout the study

•	Use of a standardized data quality assessment process

The general measurement quality objective (MQO) for the study was to satisfy method-specific
performance criteria. The sample preparation and analysis QAPP provides a summary of the method
performance criteria and specifies MQOs and QC acceptance criteria to assess the bias and precision
associated with the analytical methods used for this study. Chapter 4 of this report describes the process
for data quality assessment and presents the results of these assessments, which includes data from the
following laboratory QC samples or measures: blanks, recoveries for spiking surrogate chemicals into
field-based tissue samples, matrix spiking (matrix spike/matrix spike duplicate [MS/MSD]), laboratory

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control samples (LCS), and calibration verifications. Chapter 4 also includes a discussion of data
completeness for the study.

Section 2.4 QA Oversight of Laboratory Operations

The GDIT Project Technical Leader scheduled and tracked all analytical work performed by laboratories
for mercury, PCB, PCDD/PCDF, PFAS, and fatty acids analyses. The GDIT Project Leader also
coordinated with staff at the Tetra Tech fish sample preparation laboratory regarding fish tissue sample
shipments.

When samples were shipped to an analytical laboratory, the GDIT Project Leader contacted designated
laboratory staff by email to notify them of the forthcoming shipment(s) and request that they contact
GDIT if the shipments did not arrive intact, as scheduled. Within 24 hours of scheduled sample receipt,
GDIT contacted the laboratory to verify that the samples arrived in good condition, and if problems were
noted, it worked with the laboratory and EPA to resolve any problems as quickly as possible to minimize
data integrity problems.

GDIT communicated periodically with laboratory staff by telephone or email to monitor the progress of
analytical sample preparation, sample analysis, and data reporting. If any technical problems were
encountered during sample preparation and analysis, GDIT identified a technical expert within GDIT to
assist in resolving the problem, and work with EPA to identify and implement a solution to the problem.
In cases in which the laboratory failed to deliver data on time, or if the laboratory notified GDIT of
anticipated reporting delays, GDIT notified the EPA Project Manager. To the extent possible, GDIT
adjusted schedules and shifted resources within GDIT as necessary to minimize the impact of any
laboratory delays on EPA schedules. GDIT also immediately notified the Project Manager of any
laboratory delays that were anticipated to affect EPA schedules.

Finally, the GDIT Project Leader monitored the progress of the data quality audits (data reviews) and
database development to ensure that each laboratory data submission was reviewed in a timely manner.
In the event that dedicated staff were not able to meet EPA schedules, GDIT identified additional staff
who were qualified and capable of reviewing the data so that EPA schedules could be met. In cases when
such resources could not be identified, and if training new employees was not feasible, GDIT met with
the EPA Project Manager to discuss an appropriate solution.

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Chapter 3
Preparation and Analysis Methods

To control variability among tissue sample results, all fillet samples prepared for the study were analyzed
by a single set of methods, and all analyses performed with a given method were performed by only one
laboratory. Further control of variability was ensured by utilizing a single laboratory to prepare (i.e.,
fillet, composite, homogenize, and aliquot) samples in a strictly controlled, contaminant-free
environment. The methods employed by the sample preparation laboratory and by the five analytical
laboratories are described below.

Section 3.1 Preparation of Fish Fillet Tissue Samples

Tetra Tech served as the fish sample preparation laboratory for the study. In this role, Tetra Tech was
responsible for filleting each valid fish sample, homogenizing the fillet tissue, preparing the required
number of fish tissue aliquots for analysis and archive, shipping the fish tissue aliquots for each type of
analysis to the designated analytical laboratory, storing archive fish tissue samples temporarily in a
freezer at its facility, and transferring archive fish tissue samples to Microbac Labs for long-term storage.
The specific procedures for all GLHHFFTS fish sample preparation activities are described in Appendix
B of the sample preparation and analysis QAPP for the study (USEPA 2016a).

Fish were filleted by qualified technicians using thoroughly clean utensils and cutting boards (cleaning
procedures are detailed in Appendix B of that QAPP). Each fish was weighed to the nearest gram wet
weight, rinsed with deionized water, and filleted on a glass cutting board. For the GLHHFFTS, fillets
from both sides of each fish were prepared with scales removed, skin on, and belly flap (ventral muscle
and skin) attached. Fillets were composited using the "batch" method, in which all of the individual
specimens that comprise the sample were homogenized together, regardless of each individual specimen's
proportion to one another (as opposed to the "individual" method, in which equal weights of each
specimen are added together), as described in USEPA 2000.

An electric meat grinder was used to homogenize the samples. Entire fillets (with skin and belly flap)
from both sides of each fish were homogenized, and the entire homogenized volume of all fillets from the
fish sample was used to prepare the tissue sample. Tissues were mixed thoroughly until they were
completely homogenized, as evidenced by a fillet homogenate that consisted of a fine paste of uniform
color and texture. The collective weight of the homogenized tissue from each sample was recorded to the
nearest gram (wet weight) after processing. Tetra Tech prepared the fillet tissue aliquots that are listed in
Step 15 of the fish sample preparation procedures in Appendix B of the QAPP.

Section 3.2 Analysis of Fish Tissue Samples for Mercury

The mercury samples were prepared and analyzed by ALS-Environmental (Kelso, WA), using EPA
Procedure I from "Appendix to Method 1631, Total Mercury in Tissue, Sludge, Sediment, and Soil by
Acid Digestion and BrCl Oxidation" from Revision B of Method 1631 (163 IB) for sample preparation
(USEPA 2001b), and Revision E of Method 1631 (1631E) for the analysis ofmercury in fish tissue
samples (USEPA 2002). Mercury was detected in all 152 of the fish tissue samples. Fillet tissue sample
results were reported based on the wet weight of the tissue sample, in nanograms per gram (ng/g).

Section 3.3 Analysis of Fish Tissue Samples for PCBs

The PCB samples were prepared and analyzed by Vista Analytical Laboratory, in general accordance
with EPA Method 1668C (USEPA 2010a) and as detailed in the laboratory's SOP. The samples were

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analyzed for all 209 PCB congeners, and reported as either individual congeners or coeluting groups of
congeners. The Vista SOP deviates from the published EPA method in several aspects, including:

•	Use of sodium sulfate as the reference matrix for QC samples instead of vegetable oil due to traces of
PCBs found in the vegetable oil

•	Use of sodium hydroxide to adjust the pH of the solution in the back extraction procedure rather than
potassium hydroxide

•	Use of mid-level calibration standard (CS-3) that contains all 209 congeners instead of the subset of
congeners listed in the method

•	Use of 44 13C-labeled compounds in each sample which is five more than the 39 specified in the
method

The entire list of modifications is presented in detail in the QAPP. These changes fall within the
method's established allowance for flexibility, and EPA accepted these deviations from Method 1668C
for the purposes of the study. Tissue sample results were reported based on the wet weight of the tissue
sample, in nanograms per gram (ng/g).

Section 3.4 Analysis of Fish Tissue Samples for PCDD/PCDF

The PCDD/PCDF samples were prepared and analyzed by AXYS Analytical Services Ltd. (Sidney, BC,
Canada) using Revision B of EPA Method 1613 (1613B), Tetra- through Octa-Chlorinated Dioxins and
Furans by Isotope Dilution HRGC/HRMS (USEPA 1994) and as detailed in the laboratory's SOP. The
samples were analyzed for the 17 2,3,7,8-substituted PCDD/PCDF congeners listed in Appendix C of the
QAPP. The AXYS SOP deviates from the published EPA method in several aspects, including:

•	Approximately 25 g of fish tissue was used for the analysis

•	A 6-point instrument calibration was performed using an additional low-level standard, (CS0.2) at
0.1-0.5 ng/mL, which lowers the method-specified initial calibration range by a factor of 5

•	The cleanup standard (37Cl4-2,3,7,8-TCDD) was not used due to the low detection limits required

These changes fall within the method's established allowance for flexibility, and EPA accepted these
deviations from Method 1613B for the purposes of the study. Tissue sample results were reported based
on the wet weight of the tissue sample, in picograms per gram (pg/g).

Section 3.5 Analysis of Fish Tissue Samples for PFAS

At the time of this study, there were no formal analytical methods from EPA or any voluntary consensus
standard bodies (VCSBs) for PFAS analyses of tissues. Therefore, PFAS samples were analyzed by
AXYS Analytical Services, Ltd. (Sidney, BC, Canada) using procedures developed, tested, and
documented in that laboratory. The SOP for the procedure is considered proprietary by the laboratory,
but was reviewed by GDIT prior to the study and the analytical procedure is briefly described below.

Approximately 2 g of fish tissue are required for analysis. (If matrix-related analytical problems are
identified during the analysis of a given fish tissue sample, a sample aliquot of 1 g may be used to
minimize those problems.) The sample is spiked with 10 isotopically labeled standards and extracted by
shaking the tissue in a caustic solution of methanol, water, and potassium hydroxide. The hydroxide
solution breaks down the tissue and allows the PFAS to be extracted into the methanol/water.

After extraction, the solution is centrifuged to remove the solids and the supernatant liquid is diluted with
reagent water and processed by solid-phase extraction (SPE). The PFAS are eluted from the SPE

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cartridge and the eluant is spiked with additional labeled recovery standards and analyzed by high
performance liquid chromatography with tandem mass spectrometry.

The concentration of each PFAS was determined using the responses from one of the 13C- or 180-labeled
standards added prior to sample extraction, applying the technique known as isotope dilution. As a result,
all of the target analyte concentrations were corrected for the recovery of the labeled standards, thus
accounting for extraction efficiencies and losses during cleanup. Because a labeled standard for
perfluorobutane sulfonic acid was not commercially available at the time of the study, this target analyte
was quantified using the response for 180-labeled perfluorohexanesulfonic acid, a closely related
compound. Tissue sample results were reported based on the wet weight of the tissue sample, in
nanograms per gram (ng/g).

Section 3.6 Analysis of Fish Tissue Samples for Fatty Acids

There are no formal analytical methods from EPA for the fatty acids, largely because they are natural
substances and not environmental contaminants. The samples were analyzed for fatty acids by Clarkson
University (Potsdam, NY), using procedures developed, tested, and documented in that laboratory and
employed under GLNPO Grant No. GL 00E01505. The SOP for the procedure is considered proprietary
by the laboratory but was reviewed by GDIT prior to the study and the analytical procedure is briefly
described below.

Approximately 2 g of homogenized fish tissue is spiked with a surrogate solution (nonadecanoic acid,
CI9:0), mixed with cross-linked polyacrylic acid, and extracted with methylene chloride using
pressurized fluid extraction. The extract is dried with sodium sulfate, concentrated to approximately
20 mL. A 10-fj.L aliquot of the extract is transferred to a clean autosampler vial, purged for 30 seconds
with nitrogen, capped, and then placed on the instrument for derivatization and injection.

The automated instrument adds 100 |_iL of deuterated CI8:0 (as an internal standard) and 250 |_iL of 12%
boron trifluoride (BF3) in methanol to each sample extract. The solution is mixed and heated to 70 °C for
50 minutes. After heating, 25 |_iL of water is added to quench the derivatization reaction and the
derivatized extract is mixed, followed by the addition of 0.65 mL of hexane and further mixing to
separate the fatty acid methyl esters (FAMEs) from the aqueous solution.

An aliquot of the hexane extract is analyzed by gas chromatography, with flame ionization detection
(GC/FID), using a 100 m x 250 |im x 0.2 |im HP-88 column. The concentration of each fatty acid is
calculated based on a multi-point calibration curve and reported based on the wet weight of the tissue
sample, in micrograms per gram (jj.g/g).

Section 3.7 Analysis of Rinsates and Solvent Blanks

As noted in Section 2.3, Tetra Tech prepared equipment rinsate samples with each batch of fish fillet
tissue samples. Aqueous rinsates were prepared for mercury and PFAS, and hexane rinsates were
prepared for PCBs and PCDDs/PCDFs. Paired rinsate and solvent blank samples were analyzed for
mercury and PCBs by subcontract laboratories under the control of Tetra Tech. ALS (Kelso, WA)
analyzed the rinsate and solvent blank samples for mercury using EPA Method 245.1 (USEPA 1983),
while Pace Analytical Services analyzed the rinsate and solvent blank samples for PCBs using SW-846
Method 8082A (USEPA 2007). Results for mercury were reported in micrograms per liter ((.ig/L). and
PCBs were reported in nanograms per liter (ng/L).

Tetra Tech stored the aqueous rinsate and solvent blank samples for PFAS analyses and the hexane
rinsate and solvent blank samples for PCDD/PCDF analyses until EPA obtained the funding for the tissue
analysis laboratories. PFAS and PCDD/PCDF rinsate and solvent blank samples were analyzed by

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AXYS Analytical Services (Sydney, BC, Canada) at the same time as the analyses of the fish fillet tissue
samples. Rinsate and solvent blank sample results were reported in ng/L for PFAS and PCDDs/PCDFs.

Rinsates and solvent blanks were not prepared for the fatty acids because they are naturally occurring
components of fish tissue that are present at much higher concentrations than the contaminants of interest
in this study. Based on experience with prior studies, EPA concluded that the rinsate results for
contaminants such as mercury and PCBs would be sufficient to demonstrate that the equipment cleaning
procedures employed for the study were effective for fatty acids as well.

Section 3.8 Quality Control Procedures

Fish Tissue Analyses

The analytical procedures applied by the laboratories designated for analysis of GLHHFFTS fish tissue
samples included many of the traditional EPA analytical quality control activities. For example, all
samples were analyzed in batches and each batch included:

•	up to 20 samples, including both field samples and QC samples

•	blanks - 5% of the samples within a batch are method blanks

Other quality control activities for fish tissue samples varied by the analysis type, as described in Table 1.

Table 1. Quality Control Activities for Analysis of Fish Tissue Samples

Analyte Type

Quality Control Sample

Frequency

Mercury

Bubbler blank

3 blanks run during calibration and with each analytical batch
of up to 20 field samples

Method blank

3 method blanks per batch of up to 20 field samples, with
analyses interspersed among the samples in the analysis batch

Laboratory control sample

Once per batch of up to 20 field samples, prior to the analysis
of any field samples, and again at the end of each analytical
batch, spiked at 4.0 ng

QC Sample

Once per batch of up to 20 field samples

Matrix spike and matrix
spike duplicate samples

Once per every 10 field samples (e.g., twice per 20 samples in
a preparation batch)

PCBs

Method blank

One per sample batch of up to 20 field samples

Laboratory control sample

One per sample batch of up to 20 field samples

Laboratory duplicate sample

One per sample batch of up to 20 field samples

Labeled compounds

Spiked into every field sample

PCDDs/PCDFs

Method blank

One per sample batch of up to 20 field samples

Laboratory control sample

One per sample batch of up to 20 field samples

Laboratory duplicate sample

One per sample batch of up to 20 field samples

Labeled compounds

Spiked into every field sample

PFAS

Method blank

One per sample batch of up to 20 field samples

Laboratory control sample

One per sample batch of up to 20 field samples

Laboratory duplicate sample

One per sample batch of up to 20 field samples

Labeled compounds

Every field and QC sample before extraction

Fatty Acids

Method blank

One per sample batch of up to 10 field samples

Surrogate

Every field and QC sample

Reference material

One per sample batch

Laboratory duplicate sample

One per sample batch of up to 10 field samples

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Rinsate and Solvent Blank Analyses

The quality control activities associated with the rinsate and solvent blank analyses were generally similar
to those for the tissue analyses, with the following exceptions. First, the rinsate and solvent blank
samples for mercury and PCBs were prepared and analyzed as individual pairs, not in batches of up to 20
samples, and analyzed by laboratories under subcontract to the sample preparation laboratory, in order to
provide timely feedback of the cleanliness of the homogenization equipment. The rinsates and solvent
blanks for PFAS and PCDDs/PCDFs were held for later analyses, so they were grouped together in
batches, each with its own associated QC activities. Secondly, because the rinsates for PCBs and
PCDDs/PCDFs were prepared in an organic solvent (hexane), there were no sample extraction procedures
required, so the typical QC procedures relevant to the sample extraction procedure were modified. The
common quality control activities for rinsate samples are described in Table 2.

Table 2. Quality Control Activities for Analysis of Rinsates

Analyte Type

Quality Control Sample

Frequency

Mercury

Instrument blank

With each rinsate sample

Laboratory control sample

With each rinsate sample

PCBs and
PCDDs/PCDFs

Instrument blank

With each rinsate sample

Surrogates or labeled compounds

Added to every rinsate sample

PFAS

Method blank

With each batch of rinsate samples

Laboratory control sample

With each batch of rinsate samples

Labeled compound recovery

Every rinsate sample

Because the mercury rinsates and the PFAS rinsates were prepared in reagent water, there was little
chance of a "matrix effect" and the laboratory control sample, which was also prepared in reagent water,
provided sufficient information on the performance of the method and the laboratory in reagent water, so
a separate matrix spike sample was not required.

Because the rinsates for PCB, PCDD/PCDF and fatty acids were prepared from hexane and no sample
extraction was required, "matrix effects" were not possible. Therefore, matrix spike and duplicate
samples were not required for these rinsate samples. A laboratory control sample was used for the fatty
acids to assess the performance of the derivatization process applied to the analytes.

GDIT reviewed the results for the mercury and PCB rinsates as soon as they were available from Tetra
Tech's subcontracted laboratories and relayed the review findings to EPA and Tetra Tech within hours of
receipt of the results. Mercury was never detected above the subcontracted laboratory's MDL in any of
the rinsate or aqueous (solvent) blank samples from the study. However, in making its assessments of the
rinsate results, GDIT took a conservative approach and assumed that mercury could be present in the
rinsate sample at exactly the MDL. Based on this assumption, GDIT calculated the total mass of mercury
that theoretically might be transferred to the smallest bulk homogenized tissue sample in the sample batch
(due to inadequate cleaning of the homogenization equipment). That "worst case" estimate was then
compared to the MDL for mercury in tissues and was always at least 6 times lower than the tissue sample
MDL. Therefore, in no instance was there any risk that the mercury reported in the fish tissue samples
was the result of inadequate equipment cleaning, and EPA authorized Tetra Tech to continue processing
fish tissue samples.

A similar review approach was utilized for the PCB rinsates and solvent blanks. Overall, only one of the
ten PCB congeners that were monitored was ever detected in the eight pairs of rinsates and solvent
blanks. PCB-118 was detected in one rinsate sample, at a concentration that was over 9,000 times lower
than the tissue sample MDL, based on the smallest bulk homogenized tissue sample in that sample batch.

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The rinsate results for the PCDDs/PCDFs were reviewed after all of the fish tissue samples had been
analyzed and were assessed using a similar approach as described for mercury and the PCBs. There were
only three instances of a PCDD or PCDF congener being reported in a rinsate sample. The rinsates for
Batches 1 and 2 contained 2,3,7,8-TCDF at sub-picogram levels and 1,2,3,4,6,7,8-HpCDD was reported
in the rinsate for Batch 4. However, in all three instances, the levels in the rinsates were more than 200
times lower than the tissue sample MDL, based on the smallest bulk homogenized tissue sample in each
sample batch.

The PFAS rinsates were reviewed in the same manner. PFOA was reported in two of the rinsates and one
solvent blank not paired with either of those rinsates and PFOSA was reported in one rinsate. When
assessed against their tissue MDLs in the smallest tissue sample in each of those batches, the levels were
300 to 900 times lower than could have been detected in a tissue sample.

Overall, the rinsate results demonstrate that the equipment cleaning procedures employed for the study
were more than adequate to ensure that cross contamination between tissue samples was not occurring
during processing.

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Chapter 4
Data Quality Assessment

Section 4.1 Data Review

All of the data from the study were subjected to two levels of review. First, all laboratory results and
calculations were reviewed by the respective laboratory manager for that analysis prior to submission.
Any errors identified during this peer review were returned to the analyst for correction prior to
submission of the data package. Following correction of the errors, the laboratory manager verified that
the final package was complete and compliant with the contract, and signed each data submission to
certify that the package was reviewed and determined to be in compliance with the terms and conditions
of the GDIT subcontract.

For the second level of review, GDIT data reviewers examined the results for each field-based tissue
sample and the available quality control data to assess and document the quality of the data relative to the
objectives of the study. Each data package was thoroughly reviewed by GDIT to ensure the following:

•	All samples were analyzed, and results were provided for each sample analyzed, including results for
any dilutions and re-analyses, and for all associated QC samples.

•	All required QC samples were analyzed, and these QC samples met specified acceptance criteria.

•	Data reporting forms and/or electronically formatted data were provided for each of the field-based
tissue samples and/or associated QC analyses.

•	Raw data associated with each field-based tissue sample and QC sample were provided with each
data package, and the instrument output (peak height, area, or other signal intensity) was traceable
from the raw data to the final result reported.

•	Any problems encountered and corrective actions taken were clearly documented.

When anomalies were identified, GDIT contacted the laboratory and asked them to provide the missing
data, clarifications, and/or explanations so that a comprehensive data review could be performed to verify
the quality of their results.

GDIT data reviewers documented their findings by adding standardized data qualifier flags and
descriptive comments concerning the reliability of the flagged results to the electronic data deliverables
(EDDs) submitted by each laboratory. Following an internal review of the flagged EDD, GDIT imported
the results into project-specific database. Table 3 contains the individual data qualifiers that were applied
to results from the study and provides an explanation of the implications of each qualifier for the use of
the data.

Note: The presence of data qualifiers is not intended to suggest that data are not useable; rather, the
qualifiers are intended to caution the user about an aspect of the data that does not meet the
acceptance criteria established in the project QAPP.

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Table 3. Individual SCC Codes Applied to the GLHHFFTS Results

SCC Code

Comments

Implication

B, RMAX

Blank

Contamination,
Result is a
Maximum Value

Blank contamination was observed and the target analyte was reported in the sample
at a concentration between 5 and 10 times higher than the blank value. The result
was considered to be of acceptable quality, but data users are cautioned that it may
be a maximum value due to possible influence of contamination.

B, RNAF

Blank

Contamination,
Result Not
Affected

Blank contamination was present but was not considered to adversely impact the
sample result. The presence of the analyte in the blank is not considered to adversely
affect the data in cases where the sample results are more than 10 times the
associated blank results or where the analyte is not detected in associated samples.

B, RNON

Blank

Contamination,
Result Reported as
a Non-detect

When the sample result is less than five times the blank result, there are no means by
which to ascertain whether or not the presence of the analyte may be attributed to
contamination. Therefore, the result is reported in the database as a non-detect at the
MDL, adjusted for sample size and dilution.

CONF

Confirmed Result

The result was confirmed on the method-specific second GC column. This only
applies to the analysis of 2,3,7,8-TCDD, one of the PCDD/PCDF analytes, and does
not imply a data quality issue, but identifies that the presence of the analyte was
confirmed as described in the method.

HIAR, J

High Ion
Abundance Ratio,
Estimated

Each analyte is identified and quantified based on the instrumental response for two
specific ions and the ratio of those two ions was above the upper acceptance limit,
suggesting a potential interference that may affect the sample result. Therefore, the
result also is flagged as an estimated value.

HLBL, J

High Labeled
Compound
Recovery,
Estimated

The labeled analog of the target analyte was recovered above acceptance criteria,
suggesting the possible presence of matrix interferences. Isolated instances of high
recovery are not uncommon, and patterns across multiple samples are more of a
concern. If the analyte was detected in a field sample, the result is considered an
estimate and the J is added to the HLBL flag.

HLBL, RNAF

High Labeled
Compound
Recovery, Result
Not Affected

The labeled analog of the target analyte was recovered above acceptance criteria,
suggesting the possible presence of matrix interferences. Isolated instances of high
recovery are not uncommon, and patterns across multiple samples are more of a
concern. If the analyte was not detected in a field sample, there is no concern and the
RNAF is added to the HLBL flag.

HLCS

High Lab Control
Sample Recovery

The lab control sample (LCS) was a clean reference matrix. If recovery in the LCS
was high, there may be a high bias for that analyte.

HLCS, RNAF

High Lab Control
Sample Recovery,
Result Not
Affected

The recovery in the LCS was high, but the analyte was not detected in the associated
tissue sample, so there was no high bias concern and the RNAF flag was applied.

HSRM

High Standard
Reference
Material Recovery

Reference standard had high recovery, results for that analyte in any of the associated
samples were qualified as estimated values.

HRPD, J

High RPD,
Estimated

The relative percent difference (RPD) between the results in the parent sample and
the laboratory duplicate is above the acceptance limit. This may be due to
inhomogeneity in the bulk sample or analytical variability. When high RPD was
observed for an analyte, all the detected results for that analyte in any of the samples
in the batch with the duplicate sample were qualified as estimated values.

HRPD, RNAF

High RPD, Result
Not Affected

The relative percent difference (RPD) between the results in the parent sample and
the laboratory duplicate is above the acceptance limit. This may be due to
inhomogeneity in the bulk sample or analytical variability. However, when high
RPD was observed for an analyte, the non-detected results for that analyte were not
affected, and the RNAF flag was applied.

HVER, RNAF

High CALVER,
Result Not
Affected

The results for the calibration verification associated with the analyte were above the
acceptance limit, suggesting a possible high bias. The non-detected results for that
analyte were not affected, and the RNAF flag was applied.

J

Estimated

When applied alone, this code indicates that the result is at or above the MDL, but
below the QL. This flag also may be applied in conjunction with other flags to
indicate the potential for greater uncertainty.

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Table 3. Individual SCC Codes Applied to the GLHHFFTS Results

SCC Code

Comments

Implication

LIAR, J

Low Ion

Abundance Ratio,
Estimated

Each analyte is identified and quantified based on the instrumental response for two
specific ions and the ratio of those two ions was below the lower acceptance limit,
suggesting a potential interference that may lower the sample result. Therefore, the
result also is flagged as an estimated value.

LLBL

Low Labeled

Compound

Recovery

The labeled analog of the target analyte was recovered below acceptance criteria,
suggesting the possible presence of matrix interferences or incomplete recovery of
both the labeled compound and target analyte during the extract cleanup processes
used in the analytical procedure. The use of isotope dilution quantitation
automatically corrects the results for the target analyte, even when the labeled
compound recovery is below expectations.

LLBL, J

Low Labeled
Compound
Recovery, Result
is an Estimate

The labeled analog of the target analyte was recovered below acceptance criteria,
suggesting the possible presence of matrix interferences or incomplete recovery of
both the labeled compound and target analyte during the extract cleanup processes
used in the analytical procedure. The use of isotope dilution quantitation
automatically corrects the results for the target analytes. For detects, results
considered an estimate.

NASA, J

No Authentic

Standard

Available

There is no authentic standard available for calibration. The result is considered an
estimated value. This flag only applies to some of the fatty acid analytes and does
not imply a data quality issue

REXC, J

Result Exceeds
Calibration

The result exceeded the calibration range; however, sample dilution was not
practical. The result is considered an estimated value.

Section 4.2 Analysis of Blanks

Blanks are used to verify the absence of contamination that may occur at any point in the measurement
process. The data reviewers evaluated each sample result in comparison to the result for that analyte in
the method blank prepared in the same extraction batch. For those analytes reported as present in the
method blank, the data reviewers applied the 5x and lOx rules (described in the first three SCC codes of
Table 3) to determine the potential impact of the blank contamination on the study results. The impacts
of blank contamination are discussed separately for each analyte class in Sections 4.2.1 to 4.2.5.

4.2.1	Blanks for Mercury Analysis

Mercury was never detected above the QC acceptance limit of 0.4 nanograms (ng) in any of the three
method blanks associated with each batch of samples. Therefore, no method blank qualifiers were
applied to the mercury results for the study.

4.2.2	Blanks for PCB Analysis

The method blanks associated with the analytical batches showed occasional minor PCB contamination.
More than 99.97% of the PCB results were not affected by the blank contamination, either because the
analytes were not detected in the sample (99.42%) or because the concentration was more than 5 times the
level observed in the blank (0.564%). For 0.0162% of these results, the data reviewers judged that the
sample result is likely a maximum value (RMAX) because there is some chance that the sample result
was inflated by the background contamination from the laboratory that is evident in the blank. This flag
was applied to the PCB-11 results for four samples. Only 0.0203% of the results for those congeners
were changed to non-detects (RNON) due of blank contamination. This flag was applied to the PCB-11
results for five samples. Because the percent of results affected was below 1%, a pie chart has not been
added to the report as the slivers will be barely visible.

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4.2.3 Blanks for PCDD/PCDF Analysis

There were a few data quality issues with
PCDDs/PCDFs in the blanks, as illustrated in the
figure to the right. Figure 3 shows that 96.33% of the
results were not affected by blank contamination,
either because the analyte was not detected in the
blank (95.09%) or because the concentration in the
sample was more than 10 times the level observed in
the blank (1.24%). For 0.77% of the results, the data
reviewers judged that the sample result is likely a
maximum value (RMAX) because there is some
chance that the sample result was inflated by the
background contamination from the laboratory that is
evident in the blank. A total of 2.86% of the
PCDD/PCDF results were changed to non-detects (RNON) because the sample results were less than 5
times the concentration in the method blank. Only seven of those results were for 2,3,7,8-TCDD and the
others were largely hexa-, hepta, and octa-chlorinated congeners.

4.2.4	Blanks for PFAS Analysis

No PFAS analytes were detected above the MDL in any of the method blanks associated with each batch
of samples. Therefore, no method blank qualifiers were applied to the results for the study.

4.2.5	Blanks for Fatty Acid Analysis

None of the fatty acids were detected above the MDL in any of the method blanks associated with the
samples. Therefore, no method blank qualifiers were applied to the fatty acid results for the study.

Section 4.3 Analysis of Laboratory Control Samples

A laboratory control sample (LCS) is a mass or volume of a clean reference matrix into which the
laboratory spikes the analytes of interest. In some EPA methods, it is also known as the ongoing
precision and recovery (OPR) sample. The laboratory analyzes the LCS or OPR using the same sample
preparation and analysis techniques that are applied to the field samples, and compares the results to
method- or project-specific acceptance criteria to demonstrate that the laboratory can perform the analysis
acceptably in the absence of matrix-specific interferences.

The QAPP for the study (USEPA 2017b) required that each laboratory performing analyses of fish tissue
samples prepare and analyze one LCS for each batch of 20 or less field samples. The impacts of LCS
results are discussed separately for each analyte class in Sections 4.3.1 to 4.3.5.

4.3.1	Mercury L CS Results

The LCS results associated with each batch of samples analyzed for mercury met the QC acceptance
limit. Therefore, no LCS qualifiers were applied to the mercury results for the study.

4.3.2	PCB LCS Results

The LCS results associated with each batch of samples analyzed for PCBs met the QC acceptance limits.
Therefore, no LCS qualifiers were applied to the PCB results for the study.

0.77%

2.86%

¦	No Blank Qualifier

¦	Results Not Affected

Results Considered a
Maximum Value
Results Changed to
N on-Detect

Figure 3. Impacts of Blank Contamination on the
PCDD/PCDF Results

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4.3.3 PCDD/PCDFLCSResults

There were few data quality issues with the LCS results for the PCDD/PCDF analyses. Almost 99.2% of
the results were not affected by LCS issues. Only 0.81% of the results were qualified because of a high
LCS result that might reflect a high bias in the results. Given that such small percentage of results were
affected by high LCS values, a pie chart has not been included in this section because the tiny sliver of
affected results would not be visible. All of the LCS qualifiers were applied to 21 results for
1,2,3,4,6,7,8-HpCDF. A total of 17 results were reported as estimated. Of those, fifteen were already
considered estimates because they were between the MDL and the ML for the sample. The four
remaining results were not detected and therefore are not affected.

4.3.4	PFAS LCS Results

The LCS results associated with each batch of samples analyzed for PFAS met the QC acceptance limit.
Therefore, no LCS qualifiers were applied to the PFAS results for the study.

4.3.5	Fatty Acid LCS Results

The LCS results associated with each batch of samples analyzed for fatty acids met the QC acceptance
limit. Therefore, no LCS qualifiers were applied to the fatty acid results for the study.

Section 4.4 Analysis of Matrix Spike, Matrix Spike Duplicate, and Laboratory Duplicate
Samples

A matrix spike sample (MS) is a mass or volume of a field sample into which the laboratory spikes the
analytes of interest. The laboratory analyzes the MS using the same sample preparation and analysis
techniques that are applied to the field samples, then compares the results to method- or project-specific
acceptance criteria to provide information on the effects of the sample matrix on method performance.

A laboratory duplicate sample is a second aliquot of one field sample that is prepared and analyzed to
provide information on the precision of the analytical method. Laboratory duplicate samples are routinely
used for analytes such as metals that are expected to be found in most or all samples. However, other
types of analytes, particularly organic contaminants, are not detected as frequently in field samples, and
the analysis of an unspiked duplicate sample often will not yield useful data on analytical precision when
both the original sample and the duplicate are reported as "not detected." Therefore, EPA methods for
organic contaminants often require that a second spiked aliquot of the sample matrix be prepared as a
matrix spike duplicate (MSD). By spiking the analytes into both, the MS and MSD aliquots, there is a
greater chance of generating useful data on method and laboratory precision.

Alternatively, EPA methods such as those used for the PCBs and PCDDs/PCDFs, spike labeled
compounds into every sample and the results for those labeled compounds provide sample-specific data
on method performance, as opposed to the batch-specific data generated from one MS/MSD pair per
batch.

The QAPP for the study (USEPA 2017b) required that the laboratories performing analyses of fish tissue
samples prepare and analyze MS/MSD and/or duplicate samples with each batch of field samples as
follows:

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Table 4. Matrix Spike, Matrix Spike Duplicate, and Laboratory Duplicate Sample
Requirements by Analysis Type

Analysis Type

Matrix Spike

Matrix Spike Duplicate

Laboratory Duplicate

Mercury

X

X



PCBs





X

PCDDs/PCDFs





X

PFAS*





X

Fatty acids





X

* The method developed by the PFAS laboratory includes the use of both labeled compounds and
duplicate analysis.

The data reviewers evaluated the results for each MS, MSD, and/or laboratory duplicate sample. The
impacts are discussed separately for each analyte class in Sections 4.4.1 to 4.4.5.

4.4.1	Mercury Matrix Spike and Duplicate Sample Results

The matrix spike and duplicate sample results associated with each batch of samples analyzed for
mercury met the QC acceptance limit. Therefore, no matrix spike or duplicate sample qualifiers were
applied to the mercury results for the study.

4.4.2	PCB Duplicate Sample Results

The PCB laboratory duplicate analyses exhibited excellent precision, with approximately 99.51% of the
PCB results not affected by duplicate issues. Given that only 0.49% of results were qualified due to high
RPD values, a pie chart has not been included in this section because the tiny sliver of affected results
would barely be visible. Of the 120 results with high RPD values, 16 were non-detect results, and
therefore not affected. An additional 11 results were already classified as estimated values because they
were between the MDL and the ML.

4.4.3	PCDD/PCDF Duplicate Sample Results

The PCDD/PCDF laboratory duplicate analyses exhibited excellent precision with each batch of samples
analyzed. Therefore, no duplicate sample qualifiers were applied to the results for the study.

4.4.4	PFAS Duplicate Sample Results

The PFAS laboratory duplicate analysis exhibited excellent precision with each batch of samples
analyzed. Therefore, no duplicate sample qualifiers were applied to the results for the study.

4.4.5	Fatty Acid Duplicate Sample Results

The fatty acids laboratory duplicate analysis exhibited excellent precision with each batch of samples
analyzed. Therefore, no duplicate sample qualifiers were applied to the results for the study.

Section 4.5 Surrogates and Labeled Compounds

A surrogate is a compound that is chemically similar to the analytes of interest, but one that is not
expected to occur in an environmental sample. A known amount of a surrogate is added to each sample
before any sample processing steps and the amount of the surrogate recovered during the analysis
provides information about the overall extraction and analysis process applied to each sample. As noted

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in Section 3.6, the fatty acid laboratory added a known amount of nonadecanoic acid, CI9:0, to each
sample before extraction, as a surrogate for the target analytes.

Some methods for organic contaminants use analogs of the target analytes that contain a stable
(nonradioactive) isotope of one or more of the atoms that make up the contaminant. These compounds
are referred to as "labeled compounds" and often incorporate multiple atoms of naturally occurring, but
less common isotopes such as 13C, 180, or 37C1. For example, because 13C makes up 1.1% of the carbon in
nature, some PCBs in the environment may contain a single occurrence of 13C among the 12 carbon atoms
that make up the basic PCB structure. However, if the labeled compound is synthesized with all 12 atoms
of the more common isotope 12C replaced by 13C, there is virtually no chance that the 13Ci2 labeled
compound will be present in an environmental sample. Therefore, the labeled compound is ideally suited
for use as a quantitation reference standard during the analysis of PCBs.

The labeled compounds in such methods serve two functions. First, their responses can be used to
quantify the responses for the unlabeled target analytes in each sample through the technique known as
isotope dilution. Secondly, the measured recovery of each labeled compound provides information about
the overall extraction and analysis process applied to each sample in a similar fashion as the surrogate
used for the fatty acids. Other labeled compounds are often added to each sample extract before any
cleanup steps to provide information on the performance of those cleanups as well.

The PCB laboratory added known amounts of 44 13C-labeled PCBs to each sample before extraction. The
PCDD/PCDF laboratory added known amounts of 6 13C-labeled dioxin and 9 13C-labeled compounds for
furans to each sample before extraction. The PFAS laboratory added known amounts of 8 13C-labeled
PFAS and one 180-labeled PFAS to each sample before extraction.

No surrogates or labeled compounds are required for the mercury analyses.

The QAPP for the study (USEPA 2017b) includes acceptance criteria for the recoveries of the various
surrogates and labeled compounds. The impacts of surrogate or labeled compound results are discussed
separately for each analyte class in Sections 4.5.1 to 4.5.4.

4.5.1	PCB Labeled Compoun d Recoveries

Virtually all (over 99.8%) of the labeled compound recoveries for the PCB samples met the QC
acceptance limits. Given that only 0.106% of results were affected by high labeled compound recoveries,
a pie chart has not been included in this section because the tiny sliver of affected results would not be
visible.

4.5.2	PCDD/PCDF Labeled Compoun d Recoveries

Likewise, virtually all (99.96%) of the labeled compound recoveries for the PCDD/PCDF samples met
the QC acceptance limits. Given that only 0.04% of results were affected by low labeled compound
recoveries, a pie chart has not been included in this section because the tiny sliver of affected results
would not be visible.

4.5.3	PFAS Labeled Compound Recoveries

Some labeled compounds for the PFAS analyses had high recoveries and some had low recoveries. Over
99.75% of sample results were not affected by the recoveries of the labeled compounds due to either the
compounds not being outside limits (99.6%) or because the associated native compounds were not
detected and therefore the results were not affected (0.15%). Only 0.10% of samples with high labeled
compound recoveries were qualified as estimated values, while 0.15% of samples with low labeled

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compound recoveries were affected and qualified as estimated values. Because the percent of results
affected by labeled compound recoveries was small, a pie chart was not added to this report.

4.5.4 Fatty Acid Surrogate Recoveries

The surrogate results associated with each batch of samples analyzed for fatty acids met the QC
acceptance limit. Therefore, no surrogate qualifiers were applied to the fatty acid results for the study.

Section 4.6 Ion Abundance Ratio

The methods for PCBs and PCDDs/PCDFs utilize a high-resolution mass spectrometer to detect the target
analytes and differentiate them from potential interferences. As part of those methods, the instrument
monitors the signals from two ions produced for each analyte. The resolution of the mass spectrometer is
sufficient to distinguish ions that differ in mass by a few ten-thousandths of an atomic mass unit. The
ratio of the abundances of these two ions is used as one of four criteria to identify the analyte. The
methods include QC acceptance criteria for the ion abundance ratios for each target analyte that are based
on the theoretical occurrence of each of the component atoms in nature, plus and minus some percentage
(e.g., ±15%).

In some cases, the observed ion abundance ratio may fall outside of the consensus-based acceptance limit.
That does not mean that the analyte is not present, but it suggests that there may be some contribution to
the response from an ion with a very similar mass produced by an interference. A higher-than-expected
ion abundance ratio suggests an interference with the ion in the pair for the target analyte with the smaller
mass, while a lower-than-expected ion abundance ratio suggests an interference with the ion in the pair
for the target analyte with the larger mass. When the exceedance from the acceptance limit is small (e.g.,
a few percent), the methods for PCBs and PCDDs/PCDFs allow the analyst to report the results in such
instances with a qualifier flag that alerts the data user to the situation. During the data review process,
any results reported with an ion abundance ratio issue are reviewed in more depth. If all of the other
identification criteria in the method are met, the results are reported for the analyte with the appropriate
qualifier flag. The impacts of ion abundance ratio concerns are discussed separately for the PCBs and
PCDDs/PCDFs in Sections 4.6.1 and 4.6.2.

4.6.1	PCB Ion Abundance Ratios

The PCB results did not exhibit ion abundance ratio concerns and therefore, no ion abundance ratio
qualifiers were applied to the results for the study.

4.6.2	PCDD/PCDFIon Abundance Ratios

Overall, 76.78% of the PCDD/PCDF results were not
qualified because of ion abundance ratio concerns. As
shown in Figure 4, the remaining 23.22% of the results
were almost equally divided among those with higher-
than-expected ion abundance ratios (10.29%) and those
with lower-than-expected ion abundance ratios (12.93%).
Because the areas of both monitored ions are used to
calculate the concentration of the analyte, the direction of
the ion abundance ratio failure does not reflect a similar
bias in the reported sample result, but each such value
is considered an estimated value.

12.93%

10.29%

¦	No Qualifier

¦	High Ion
Abundance Ratio

¦	Low Ion
Abundance Ratio

Figure 4. Impacts of Ion Abundance Ratios on the
PCDD/PCDF Results

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Section 4.7 Standard Reference Material for Fatty Acids

A reference material is a special type of sample that has been well characterized in terms of its physical
and chemical makeup. Unlike a laboratory control sample that is spiked with the analytes of interest, a
reference material is generally prepared by an outside organization and characterized by analyses from a
number of independent laboratories. Reference materials can be obtained from various sources, some of
them governmental bodies. In the U.S., the National Institute of Standards and Technology (NIST) has
trademarked the name "Standard Reference Material," or "SRM.' and sells reference material for a wide
variety of matrices, including fish tissues. Other organizations provide what are referred to a "Certified
Reference Materials," or "CRMs," to differentiate them from the NIST products.

As part of the fatty acid analyses, the laboratory analyzed an aliquot of NIST SRM 1947, which is a
frozen fish tissue homogenate which was prepared from lake trout (Salvelinus namciyciish) collected from
Lake Michigan. The NIST certificate of analysis provides "certified concentration values" for PCB
congeners, chlorinated pesticides, and fatty acids. Those fatty acids include only four of the 38 target
analytes in this study.

During data review, the results from the analysis of
NIST SRM 1947 associated with each batch of
field samples in this study were compared to the
reference values for the fatty acids. For the
purposes of this assessment, the SRM results were
viewed in context of all 38 of the fatty acids
analyzed in this study. The implications of the
SRM results on data quality for the fatty acids are
illustrated in Figure 5.

Overall, 99.27% of the fatty acid results are
associated with SRM results that agreed with the
certified values for the four analytes. The
remaining 0.73% of the results were associated with higher SRM results and therefore are considered
estimated values. All high SRM recoveries were for heptadecanoic acid and docosahexaenoic acid.

Section 4.8 Completeness

Completeness is a measure of the amount of data that are collected and deemed to be acceptable for use
the intended purpose. The completeness goal established in the QAPP for this study (USEPA 2016a) was
to obtain valid measurements from 95% of the samples analyzed.

For multi-analyte methodologies, analytical completeness is best calculated on the basis of the number of
possible sample/analyte combinations. Otherwise, a problem with a single analyte could be seen as
invalidating an entire field sample.

Combining the number of target analytes for the five types of analyses (mercury, PCB, PCDD/PCDF,
PFAS, and fatty acids) yields a total of 231 measured results for each sample (based on 162 results that
cover all 209 PCB congeners). For the 152 samples collected for the GLHHFFTS, the total number of
sample/analyte combinations is 35,112.

Despite the data quality concerns outlined in this report, all 152 samples were successfully analyzed for
all of the target analytes. Following an intensive review of the project data, none of the results were
excluded from consideration based on data quality concerns. Therefore, analytical completeness is 100%,
and OST met its completeness goal.

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References

USEPA. 1994. Tetra- through Octa-Chlorinated Dioxins and Furans by Isotope Dilution HRGC/HRMS,
October 1994. Office of Water, Washington, DC.

USEPA. 2000. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories, Volume
1: Fish Sampling and Analysis, Third Edition. U.S. Environmental Protection Agency, Office of Water,
Office of Science and Technology, Washington, DC. EPA/823-B-00-007.

USEPA. 2001a. EPA Requirements for Quality Assurance Project Plans, March 2001 (Reissued 2006).
Office of Environmental Information, Washington, DC. EPA-240-B-01-003

USEPA. 2001b. Appendix to Method 1631 Total Mercury in Tissue, Sludge, Sediment, and Soil by Acid
Digestion and BrCI Oxidation, January 2001. Office of Water, Washington, DC. EPA-821-R-01-013

USEPA. 2002. Method 1631, Revision E: Mercury in Water by Oxidation, Purge and Trap, and Cold
Vapor Atomic Fluorescence Spectrometry, August 2002. Office of Water, Washington, DC.

EPA-821 -R-02-019

USEPA. 2007.Method8082A, Revision 1. PolychlorinatedBiphenyls (PCBs) by Gas Chromatography.
February 2007. Third Edition of the Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods, EPA publication SW-846. U.S. Environmental Protection Agency, Office of Land and
Emergency Management, Washington, DC.

USEPA. 2010a.Method 1668C, ChlorinatedBiphenyl Congeners in Water, Soil, Sediment, Biosolids, and
Tissue by HRGC/HRMS, April 2010. Office of Water, Washington, DC. EPA-820-R-10-005

USEPA. 2014a. National Coastal Condition Assessment Quality Assurance Project Plan, U.S.
Environmental Protection Agency, Office of Environmental Information, Washington, DC. EPA/841-R-
14-005.

USEPA. 2016a. Quality Assurance Project Plan for Sample Preparation and Analysis for the 2015
National Coastal Condition Assessment Great Lakes Human Health Fish Fillet Tissue Study. February 2,
2016.

USEPA. 2016b. Quality Assurance Project Plan for Sample Preparation and Analysis for the 2015
National Coastal Condition Assessment Great Lakes Human Health Fish Fillet Tissue Study., Revision 1,
April 20, 2016.

USEPA. 2016c. Quality Assurance Project Plan for Sample Preparation and Analysis for the 2015
National Coastal Condition Assessment Great Lakes Human Health Fish Fillet Tissue Study., Revision 2,
June 2, 2016.

USEPA. 2017a. Quality Assurance Project Plan for Sample Preparation and Analysis for the 2015
National Coastal Condition Assessment Great Lakes Human Health Fish Fillet Tissue Study., Revision 3,
February 6, 2017.

USEPA. 2017b. Quality Assurance Project Plan for Sample Preparation and Analysis for the 2015
National Coastal Condition Assessment Great Lakes Human Health Fish Fillet Tissue Study., Revision 4,
April 4,2017.

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