Update on USEPA Methods, Regulations, Accreditation and Related Activities Midwest Environmental Laboratory Stakeholders Summit December 3, 2011 Jerry L. Parr Catalyst Information Resources A SLOW YEAR (Except for TNI) No New SW-846 Methods Method Update Rule Not Finalized No progress on Detection and Quantitation UCMR 3 No other significant new regulations Many minor actions by EPA and States The NELAC Institute actions Will be presented on Friday Excluding Air methods For the period December 7, 2010 through December 2, 2011. SW-846 No new methods Look for revised Method 8000 in 2012 Methods Update Rule Proposed September 23, 2010 New methods Updated versions of approved methods Revised method modification and analytical requirements Clarifications and corrections Changes to sample collection, preservation, and holding time requirements Minimum QC requirements Expected to be final in January 2012 Regulations Affected Part 423: Steam Electric Power NPDES Revise definitions related to residual chlorine Part 430: Pulp and Paper NPDES Remove Methods 1650 and 1653 Part 435: Oil and Gas NPDES Method revisions and corrections Part 136: Wastewater Methods Many, many, many changes Part 260: RCRA Methods Update 1664A to 1664B Changes to Part 136 New EPA Methods Updated EPA Methods New and Updated Standard Methods New and Updated ASTM Methods > 250 New Analytes New table for microbiology in ambient water Table II: Preservation & Holding Time Sections 136.4 and 136.5 on ATP Section 136.6, Method Modifications New Section 136.7 on minimum QC Remove Appendices A (600 methods) and C (200.7) Revise Appendix D (metals P/A data) New EPA Methods 200.5 525.2 608.1 608.2 614 614.1 617 619 622 622.1 632 1614A 1668C 1627 Trace Elements by Axially Viewed ICP-AES Organics by GC/MS (Table 1G only) Organochloride Pesticides. (Table 1G only) Organochlorine Pesticides. (Table 1G only) Organophosphorus Pesticides. (Table 1G only) Organophosphorus Pesticides (Table 1G only) Organohalide Pesticides and PCBs. (Table 1G only) Triazine Pesticides. (Table 1G only) Organophosphorus Pesticides (Table 1G only) Thiophosphate Pesticides. (Table 1G only) Carbamate and Urea Pesticides (Table 1G only) Brominated Diphenyl Ethers by HRGC/HRMS. Chlorinated Biphenyl Congeners by HRGC/HRMS. Prediction of Mine Drainage Quality. Revised/Updated EPA Methods 1664B 624 1622 1623 1103.1 1106.1 1600 1603 1680 1650 1653 Oil and Grease (HEM and SGT-HEM) Add acrolein and acrylonitrile as approved analytes Cryptosporidium Giardia E. coli Enterococci Enterococci E. coli Fecal Coliform New Analyte 121. Adsorbable Organic Halides 122. Chlorinated Phenolics New Analyte A Closer Look: Methods 1622 and 1623 Update to 2005 version flexibility to choose among several types of filters, quality controls, and stains, clarification on measuring sample temperatures, quality control sample requirements and use of quality control sample results, minimizing carry-over debris, analyst verification procedures, and sample condition criteria upon receipt. Change preservation to 1-10 degrees C Methods 1103.1, 1106.1, 1600, 1603, and 1680 Minor technical corrections, e.g. tryptone broth should be tryptone water positive control organism for the cytochrome oxidase reagent has been changed to P. aeruginosa from E. faecalis, negative control organism for Simmons citrate agar has been changed to S. flexneri from E. coli Standard Methods Generally, only most recent version will now be approved 17th, 18th, 19th, etc. no longer approved Method approval is shown by the year, not the edition New Methods Updated Methods New method and a new analyte: 17A. Chlorine - Free available New and Updated Standard Methods 5520 B-2001 and 5520 F-2001 Oil and Grease. SM 5520 G-2001 not approved because it allows use of a co-solvent, such as acetone. 4500-NH3 G-1997 Ammonia (as N) and TKN 4500-B B-2000 Boron. 4140-1997 Inorganic Ions 3114 C-2009 Arsenic and Selenium. 3111 E-1999 Aluminum and Beryllium. 5220 B-1997 Chemical Oxygen Demand. 4500 NORG D-1997 Kjeldahl Nitrogen - Total. 4500 P G and 4500 P H-1999 Phosphorus. 4500 P E and 4500 P F-1999 Phosphorus. 4500 O B, D, E and F-2001 Oxygen. 4500 O D-2001 Oxygen. 4500 O E-2001 Oxygen. 3500 K C-1997 Potassium. 2540 E-1997 Residues – Volatile. 4500 SiO2 and 4500 SiO2 F- 1997 Silica. 4500 SO4 C, D, E, F and G-1997 Sulfate. 4500 S2- B-2000 and C-2000, Sulfide. New and Updated ASTM Methods D2036, D6888, D7284, and D7511 D888 D7573 Total Cyanide Dissolved Oxygen Total Carbon and Organic Carbon. ASTM New Analytes and Methods D4282 and D7237 D7065, D7574, & D7485 24A. Free Cyanide 114. Nonylphenol 115. Bisphenol A 116. p-tert-Octylphenol 117. Monoethoxylate 118. Nonylphenol Diethoxylate More New Methods SM 3125-2009 ASTM 1976-2007 ICP/MS for 24 metals ICP/AES for 25 metals Not discussed in preamble ICP/AES and ICP/MS for Additional Metals Gold by ICP/MS (4 methods) Iridium by ICP/MS (SM 3125) Magnesium by ICP/MS (4 methods) Mercury by ICP/AES and ICP/MS (4 methods) Palladium by ICP/MS (SM 3125) Phosphorous by ICP/AES (3 methods) Platinum by ICP/MS (SM 3125) Potassium by ICP/MS (4 methods) Not discussed in Rhodium by ICP/MS (SM 3125) preamble Rhodium by ICP/MS (SM 3125) Silica by ICP/MS (4 methods) Sodium by ICP/MS (4 methods) Tin by ICP/MS (4 methods) Titanium by ICP/MS (4 methods) ASTM - Oil and Grease Methods D7066 and D7575 not included Do not use n-hexane Other significant changes from 1664 TPH is not an analyte in Part 136 New Alternate Test Procedures Hach Method 10360 Luminescence Measurement of Dissolved Oxygen (LDO®), In-Situ Incorporated’s Method 1002-8 Dissolved Oxygen (DO), Method 1003-8 BOD, and Method 1004-8 CBOD, Mitchell Methods M5271 and M5331 for turbidity; Thermo Scientific’s Method AQ4500 for turbidity; Systea Scientific, LLC’s Systea Easy (1-Reagent) Nitrate. Clarifications and Corrections Grab samples must be filtered within 15 minutes for o-PO4 Preamble only Fecal coliform, total coliform, and fecal streptococcus methods added to Table 1H Other minor corrections Holding Times and Sample Preservation Information in this table takes precedence over instructions provided in specific methods or elsewhere unless a party documents the acceptability of an alternative to the Table II instructions. The nature, timing and extent of the required documentation (i.e. how to apply and review as well as the amount of supporting data) are left to the discretion of the permitting authority (State Agency or EPA Region) or other authority and may rely on instructions, such as those provided for method modifications at 136.6. Examples provided: 24-hour BOD Cyanide Holding Times and Sample Preservation E. Coli and Enterococcus Change from 2 hours to 8 hours Cyanide Footnotes 5 and 6 extensively rewritten (shortened) to reference ASTM Methods and allow analyst flexibility WET Samples cannot be frozen Do not need to be 0-6 C if analyzed on day of collection Hold time only refers to first use Alternate Test Procedures 136.4: Nationwide Application to National Coordinator Provide a detailed description of the proposed procedure. Provide comparability data Procedure may be used for limited use prior to regulation 136.5: Limited Application to Regional Coordinator Provide justification Provide a detailed description of the proposed procedure. Demonstrate applicability to specific effluents Method Modifications: 136.6 Extensively rewritten with more examples Acceptable reasons for an analyst to modify a method include: analytical practices that lower detection limits, improve precision, reduce interferences, lower laboratory costs, and promote environmental stewardship by reducing generation of laboratory wastes. Acceptable modifications may use existing or emerging analytical technologies that achieve these ends provided that they do not depart substantially from the underlying chemical principles employed in methods Examples of Allowed Modifications Changes between manual method, flow analyzer and discrete instrumentation. Changes between automated and manual sample preparation. Use of interference reduction for ICP-MS. Using a different acid to adjust pH in colorimetric methods. Changes in calibration model. Use of Relative Standard Error (RSE). Use of prepackaged reagents. Use of Selected Ion Monitoring (SIM). Changes in purge-and-trap sample volumes or operating conditions. Combine base/neutral and acid fractions for Method 625. New 136.7: Required Quality Control Mandatory for all methods 12 Essential QC Checks (1) Demonstration of Capability (DOC); (2) Method Detection Limit (MDL); (3) Laboratory reagent blank (LRB), also referred to as method blank; (4) Laboratory fortified blank (LFB), also referred to as a spiked blank, or laboratory control sample (LCS); (5) Matrix spike, matrix spike duplicate, or laboratory fortified blank duplicate (LFBD) for suspected difficult matrices; (6) Internal standards, surrogate standards (for organic analysis) or tracers (for radiochemistry); 12 QC Checks (the last 6) (7) Calibration (initial and continuing), initial and continuing performance (ICP) solution also referred to as initial calibration verification (ICV) and continuing calibration verification (CCV); (8) Control charts (or other trend analyses of quality control results); (9) Corrective action (root cause analyses); (10) QC acceptance criteria; (11) Definitions of a batch (preparation and analytical); and (12) Specify a minimum frequency for conducting these QC checks. Changes to Appendix D Precision and Accuracy Data for EPA AA Methods Almost all methods were deleted in 2007 MUR Proposed rule would remove all Appendix D data except for: 279.2, Thallium 289.2, Zinc Changes to Part 423 NPDES Regulations for power plants Revise definitions for residual and free chlorine Total residual chlorine (or total residual oxidants for intake water with bromides) means the value obtained using any of the chlorine-total residual methods in Table IB. Free available chlorine means the value obtained using any of the chlorine-free available methods in Table IB. Changes to Part 430 NPDES Regulations for pulp and paper plants Remove Methods 1650 and 1653 for adsorbable organic halides (AOX) and chlorinated phenolics Add adsorbable organic halides (AOX) and chlorinated phenolics as analytes 121 and 122 in Table 1C Analyte 122: Chlorinated Phenolics Trichlorosyringol 3,4,5-Trichlorocatechol 3,4,6-Trichlorocatechol 3,4,5-Trichloroguaiacol 3,4,6-Trichloroguaiacol 4,5,6-Trichloroguaiacol 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol Tetrachlorocatechol Tetrachloroguaiacol 2,3,4,6-Tetrachlorophenol Pentachlorophenol Changes to Part 435 NPDES Regulations for offshore oil and gas wells Remove methods and create Analytic Methods for the Oil and Gas Extraction Point Source Category Incorporate additional QA procedures in the marine anaerobic biodegradation analytic method Correct some erroneous references and omissions in the method for identification of crude oil contamination Add a schematic flow diagram for qualitative identification of crude oil Methods for Offshore Oil and Gas 1617 Static Sheen Test 1619 Drilling Fluids Toxicity Test 1646 Procedure for Mixing Base Fluids With Sediments. 1647 Degradation of Non Aqueous Base Fluids in a Marine Closed Bottle Biodegradation Test System: 1655 Crude Oil Contamination in Non-Aqueous Drilling Fluids by GC/MS. 1670 Detection of Oil Contamination in NonAqueous Drilling Fluids (NAF). 1674 Non- Aqueous Drilling Fluid (NAF) Base Fluid from Drill Cuttings UCMR 3 Unregulated Contaminant Monitoring Proposed Rule March 3, 2011; 76 FR 11713 30 contaminants for monitoring over a 5-year period 28 chemicals 2 viruses Monitoring provided by EPA contract labs and large municipals All labs will require EPA approval Monitoring scheduled to begin in 2013 UCMR 3 CHEMICALS 9 Volatile Organic Compounds using Method 524.3 1,2,3-trichloropropane 1,3-butadiene chloromethane 1,1-dichloroethane n-propylbenzene bromomethane sec-butylbenzene chlorodifluoromethane bromochloromethane Synthetic Organic Compound using Method 522 1,4-dioxane 7 Hormones using EPA Method 539 17-[beta]-estradiol 17-[alpha]-ethynylestradiol (ethinyl estradiol) estriol (16-[alpha]-hydroxy-17[beta]-estradiol) equilin estrone testosterone 4-androstene-3,17-dione UCMR 3 CHEMICALS 6 Perfluorinated Chemicals using Method 537 perfluorooctane sulfonate perfluorooctanoic acid perfluorononanoic acid perfluorohexane sulfonic acid perfluoroheptanoic acid perfluorobutane sulfonic acid 4 Metals using EPA Method 200.8 cobalt molybdenum strontium vanadium Oxyhalide Anion using Method 300.1 chlorate UCMR 3 VIRUSES Enterovirus Norovirus Would be monitored by a tissue culture or qPCR assay OTHER MINOR EPA ACTIONS New CLP Guidance for Field Samplers http://www.epa.gov/superfund/programs/clp/dow nload/sampler/CLPSamp-01-2011.pdf Saccharin removed from Appendix VIII (12/17/10; 75 FR 78918) Guidance for Enhanced Monitoring of Hexavalent Chromium in Drinking Water Where the systems should collect samples How often they should be collected Guidance on analytical methods http://water.epa.gov/drink/info/chromium/guidance.cfm OTHER MINOR EPA ACTIONS (Cont) EPA Publishes Water Laboratory Alliance Response Plan Procedures for coordinated laboratory response to water contamination incidents that may require additional analytical support and a broader response than a typical laboratory can provide. http://water.epa.gov/infrastructure/watersecurity/secres/upload/WLARe sponsPlan_November2010.pdf EPA Publishes Policy on Competency of Laboratories and Other Similar Organizations Requires organizations that provide data to EPA under contract submit documentation of their competency, which may include accreditation: Organizations performing environmental analysis for the Agency shall demonstrate their qualifications in the fields of analyses to be conducted, prior to performing such analyses. Where accreditation or certification is available for those fields of analysis, organizations may submit documentation of existing accreditations or certifications. Accreditation/ certification granted by an organization that accredits environmental data operations to an international consensus standard, or a state accreditation or certification program acceptable to EPA, or that the contracted laboratory is participating in the EPA Contract Laboratory Program. http://www.epa.gov/osa/fem/pdfs/fem-lab-competency-policy.pdf OTHER MINOR EPA ACTIONS (Cont) Training Courses on Analysis of Radionuclides in Water The training provides an understanding of how and why to analyze water samples for the presence of radionuclides according to the methods specified in the EPA 900 series procedures and EPA's Manual for the Certification of Laboratories Analyzing Drinking Water. The training also provides insight on how to plan, implement, and document appropriate quality control and quality assurance procedures for the analysis of radionuclides in water. http://www.epa.gov/safewater/radionuclides/training/index.html LCMRL Calculator Published The Lowest Concentration Minimum Reporting Level (LCMRL) is defined as the lowest spiking concentration at which recovery of between 50 and 150% is expected 99% of the time by a single analyst. The LCMRL is estimated using statistical procedures which estimates a probability distribution for spike recovery as a function of spiking concentration. This requires regression modeling that estimates expected value and expected variance for repeated measurements as functions of spiking concentration. http://water.epa.gov/scitech/drinkingwater/labcert/analyticalmethods_ogw dw.cfm#four OTHER MINOR EPA ACTIONS (Cont) Clarification on Sample Preservation for Total Phenolics CuSO4 not needed OK to use H2SO4 Etc. Memo available from Catalyst upon request STATE ACTIONS: PA Pennsylvania Develops Guidance for Homeowners for Basic Oil & Gas Parameters The PA DEP has developed a list of parameters that are recommended for homeowners who wish to have their private well tested before drilling operations for oil and gas production. http://files.dep.state.pa.us/RegionalResources/Labs/LabsPortalFil es/2010-10_OG_Pre-Drill_Guidance.pdf Pennsylvania Publishes Guidance on Compositing Samples for Volatile Organics http://files.dep.state.pa.us/RegionalResources/Labs/LabsPortalFil es/2011-0323_SDWA_Composite_Analysis_FAQ.pdf STATE ACTIONS: MN Free Webinar on Testing for Hexavalent Chromium http://slhstream.ad.slh.wisc.edu/Mediasite4/Viewer/Viewers/Viewer AudioOnly.aspx?mode=Default&peid=c6234999-2f57-4f45-8bfb9f7f0033aa80&pid=2a300f37-2483-44cf-9ccfb5c68083ba57&playerType=WM7# TBA Added to List of Volatiles in Wisconsin http://www.dnr.state.wi.us/org/es/science/lc/OUTREACH/3Guid/- VOC_List_WI.pdf OTHER INTERESTING NEWS Analyzing Data with Multiple Detection Limits This paper proposes rank-based procedures for analyzing non-normally distributed data collected at different sites over a period of time in the presence of multiple detection limits. http://pubs.acs.org/doi/abs/10.1021/es101304h Emerging Chemicals of Concern in the Great Lakes Synthetic musk fragrances ; Pharmaceuticals, including the antiepileptic drug, carbamazepine; Pesticides atrazine, metolachlor, and mecoprop; Brominated and chlorinated flame retardants and chlorinated paraffins; Perfluorinated surfactants; Alkylphenols including nonylphenol and octylphenol; Plasticizers, especially bisphenol A; and Polycyclic aromatic hydrocarbons. http://www.ijc.org/php/publications/pdf/ID696.pdf LABFACTS ONLINE Over 3000 documents All EPA methods EPA Regulations EPA Memos TNI and NELAC Standards State-specific information All in Microsoft Word for ease of use Key word search Internet search engine Weekly newsletter Jerry L. Parr Catalyst Information Resources The Information Resource for Environmental Professionals 817-598-1155 jparr@catalystinforesources.com www.CatalystInfoResources.com