Evaluation of Preservation and Holding Time Requirements for Hexavalent Chromium to Meet Data Quality Objectives for a Logistically Challenged Site

Oral Presentation

Prepared by R. Forman1, R. Vitale2, A. Kress3, M. Mc Anulty4
1 - Environmental Standards, Inc., 1140 Valley Forge Road PO Box 810, Valley Forge, PA, 19520
4 - BP Exploration (Alaska) Inc., 900 E. Benson Blvd, 442D, , Anchorage, AK, 99519


Contact Information: rforman@envstd.com; 610-935-5577


ABSTRACT

Hexavalent chromium is being considered for inclusion as a Compound of Potential Concern (COPC) under the Administrative Order for Corrective Action for BPXA’s Prudhoe Bay Facility. Previously, the analysis for hexavalent chromium in aqueous samples was performed according to US EPA Test Methods for Evaluating Solid Waste, Physical/Chemical Methods SW-846 Method 7196A. Method 7196A specifies a guidance 24-hour sample holding time (Section 6.3) from sample collection to analysis for hexavalent chromium.

Transportation and timing logistics from North Slope Project sites to the project laboratory precludes meeting the holding time guidance in Method 7196A as specified in the QAPP.

On Monday, March 12, 2007, the US EPA issued “40 CFR Part 122, 136, et al. – The “Method Update Rule (MUR)” extended the hexavalent chromium holding time to 28 days from the 24 hours stipulated in Section 8.3 of US EPA Method 218.6, Revision 3.3 if samples are preserved using ammonium sulfate buffer as indicated in the associated footnote. The allowance in this footnote supersedes preservation and holding time requirements in the approved hexavalent chromium methods, unless this supersession would compromise the measurement, in which case requirements in the method must be followed.

In accordance with the US EPA-recommended action relative to applying the ammonium sulfate buffer specified in Method 218.6 and extending the holding time to 28 days when using Method 218.6, the authors conducted a hexavalent chromium preservation and holding time study. The purpose of the holding time study was to evaluate and compare the long-term effects of collecting both unpreserved and buffer preserved samples when analyzing by US EPA Method 218.6. Results of the holding time study and the implications of the findings will be presented.