United States
                            Environmental Protection
                            Agency
   Office of Ground Water
   and Drinking Water
Technical
Support Division
EPA-814-K-93-001
                                                                   September 1993
     EPA    Labcert    Bulletin
Welcome Back to the

Labcert Bulletin

INo, you weren't dropped from the  list.
Changing   government  regulations  have
interfered  with  our efforts  to publish this
bulletin in a more timely manner. In this issue
we discuss  items of current interest to the
certification  community.  If you have ideas
about  other  areas of certification  you  would
like to see covered, please call or write to the
editors. We have included a FAX  sheet  to
update  our  mailing list or to add or update
your name  to our mailing list. Feel free  to
use it as needed  or call one of the editors.

Ed Click 513 569-7939
Mary Ann Feige 513 569-7944
Carol  Madding 513 569-7402
26 W. Martin Luther King Dr.
Cincinnati,  OH 45268
    In This Issue-
    Analytical Methods
     Proposed Rule	 1
     Method Recommendations ... 2
    Mercuric Chloride  	2
    Nitrite  		 .2
    Simple Quality Control for the
    Membrane Filter Technique ... 3
    Compositing Guidance	.4
    A Better Way to Use
    Diazomethane	5
    Fax Sheet . .	 5
    Improper Interpretation	8
Analytical    Methods--

Proposed Rule and Method

Recommendations

A roposed Rule— EPA is preparing an
Analytical Methods   Federal Register Notice,
which  will be proposed in 1993.  EPA will
propose   to   update   89  chemical   or
microbiological methods to versions that are
in  the most current  manuals  published  by
ASTM, EPA and  Standard  Methods.
  The rule  will propose to  expand the
analytical  scope of five methods.  Ten new
methods  will be proposed,  and several older
methods   will  be  proposed   for  gradual
withdrawal. The latter include packed-column
GC methods, and inorganic chemical methods
which  have not been  updated  since 1979.
  Please Note — In an article about using SPE
disks,  written  by Craig Markell  in the April
1993 issue of Varian's SPE  Environmental
Newsletter, it was stated,  "If you  are using
525.1  for  compliance  purposes  and are
concerned about deviating  from the recipe,  we
have been told that alternate elution solvents
ARE ACCEPTABLE AS LONG AS QA/QC
REQUIREMENTS  ARE  MET."  This  is
incorrect.  EPA wishes to grant flexibility to
analysts  but this flexibility extends only  to
changes  which are  not chemical  in nature
(i.e.,  chromatography   columns/programs,
detectors,  etc.)   as  long   as   QA/QC
requirements  can be  met.  EPA  does  not
allow an  analyst to substitute alternate  elution
solvents since this is a change in the chemistry
of the method.
  An  updated   method,  525.2,  will   be
proposed  in the above mentioned Analytical
                     Labcert Bulletin is printed on recycled paper.

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 Methods  notice.  The  method  contains  data
 which demonstrates  that the sequence  of ethyl
 acetate and methylene  chloride to elute  SPE
 disks is critical  to obtain  acceptable  results.
   Additionally,  EPA does not recommend  the
 use of acetone as an extraction  solvent in any
 drinking water  method.
   Recommended Methods—  Readers  have
 asked  for  guidance  on  using appropriate
 methods to measure  analyles  for which there
 are  no MCLs  or monitoring   requirements.
 Although  EPA  only promulgates methods  for
 contaminants    regulated    under   tbe  Safe
 Drinking  Water  Act, the Agency  encourages
 use of these methods  for other  analytes  of
 interest, provided  they are specifically listed in
 the analytical  scope of the  method.
   New Trihalomethane Methods- Or August
 3, 1993 (58 FR  41344) EPA promulgated  two
 additional  methods  for the analysis of total
 trihalomethanes.     The  rule,  which  was
 effective  September   2,  1993, promulgated
 EPA  Methods  502.2 and  524.2  for  THMs.
 EPA believes  the  following  guidance will help
 laboratories  correctly preserve and analyze
 samples for compliance  monitoring  i nder 40
 CFR  141.30.
   Laboratories   must  carefully  follow  the
 dechlorination  procedure  described  in each
 method, especially the order in which reagents
 are added  to the sample.  The  methods allow
 analysts  to  choose  among   four  reagents
 (ammonium  chloride, ascorbic  acid, sodium
 sulfite  or sodium  thiosulfate) to dechlorinate
 a  water  sample.    However,  EPA  strongly
 recommends  sodium thiosulfate,  since EPA
 has  the  most   performance data  \\ith  this
 chemical.   The exception  is  that ascorbic acid
 should  be  used   when  SO2   may  be   an
 interference with  a  mass spectrometer.   All
 dechlorinated  VOC samples must be ; cidified
 immediately,  as directed  in  the  method.
   Comments— If  you have  any questions  or
operating   experiences   that   you  wish  to
communicate,  please write  to  editors  of the
Labcert bulletin.
 Mercuric  Chloride

 1 he  use of mercuric chloride as a preserva-
 tive has been  required  in  various U.S. EPA
 methods.       Concerns   relating   to   the
 environmental    hazards   and   the   costs
 associated  with  the  disposal of this  biocide
 have prompted  the Office  of Ground  Water
 and  Drinking  Water (OGWDW)  to issue new
 guidance  on the  subject.
   A  memo   from  Mike  Conlon,  Director,
 Drinking  Water   Standards   Division, dated
 March 25, 1993, removes the requirement  that
 mercuric  chloride  be used  as a preservative
 for  compliance  monitoring  samples  unless
 there is evidence of biological degradation  in
 any  specific sample or sample set.
   This should provide relief  to  the many
 laboratories    that  were  having  difficulties
 dealing with mercuric chloride.  However, it
 may  be  prudent  to  analyze  at  least  one
 sample set with and without mercuric chloride
 to prove that no biological degradation  occurs
 in the  matrix.
   For further information  please  call Baldev
 Bathija at 202-260-3040.	


 Nitrite

 W  e have received numerous calls regarding
 the  requirement   to  analyze   for  nitrite,
 glyphosate,  and  cyanide in  water  that  has
 been  chlorinated.   The presence  of chlorine
 oxidizes nitrite and glyphosate  and converts
 cyanide to cyanogen chloride. For glyphosate
 and cyanide, states can negotiate susceptibility
 waivers with their regions for systems that can
 demonstrate  a chlorine residual.  Nitrite is an
 acute contaminant,  so no waivers are allowed.
 However,  if the nitrite  or nitrite plus nitrate
concentration   in  the  initial  analysis  is  less
 than    1/2   MCL  of  nitrite   (0.5   mg/L),
continued  monitoring frequency  is established
by the  state.

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Simple Quality Control for

the     Membrane     Filter

Technique


In microbiological  analysis of water, quality
control  (QC)  procedures  recommended  for
the    membrane    filter   (MF)   technique
commonly   involve  the  use of laboratory
maintained   or commercially  available freeze
dried  bacteriological  cultures  or  bacterial
disks.    These   pure  cultures   must   be
reconstituted  and  diluted   until  a  volume
containing  20 to  80 organisms  is obtained.
This  volume  is  then   filtered  arid   the
membranes,   media,   and  procedure   are
evaluated.     Both  positive and  negative
bacterial  controls  are  analyzed   in duplicate
assays. This procedure is time consuming  and
labor  intensive, particularly  when performed
by a laboratory that analyzes  large numbers of
samples.  Also, since most water laboratories
do  not  routinely  need to  make dilutions,
errors can  occur.
  A direct  inoculation  (spot  test) is suggested
as a simple, rapid  QC procedure  of media,
membranes, and  incubation  conditions.  The
test involves little additional  effort other than
preparing   a  few  additional  plates  for  each
batch  of media  and using  appropriate  pure
cultures.  A positive  and negative  control  can
be easily tested with each membrane  filtration
series.  For example,  in the total  coliform
technique  with M-Endo media,  the  spot  test
procedure involves aseptically placing a sterile
MF on the  selected medium. The petn plate,
containing  the MF on  the medium, is divided
into  two  areas   using  a   marking   pencil.
Alternatively,  two individual MF's and  two
medium-containing  plates  may  be used,  one
for each  control  organism.  Escherichia  coji,
(positive)   and   Pseudomonas    alcaligenes,
(negative)  cultures could be  used  as controls.
Using a  sterile  loop,  needle,   or applicator
stick, a portion  of the positive control  culture
is spotted  on the  MF  five or  six  times in
different  places.  Likewise, a negative  culture
can be placed on the other half of the MF or
another plate. These QC plates  are incubated
under   the   same   time   and   temperature
conditions as the standard  test procedure.
  The  sample  analysis  plates  and  the  QC
plates   are  read  at  the   same  time   and
recorded.   The MF area  on  the QC plate
inoculated with the  positive culture  produces
growth   in   the   spotted   areas  with  the
characteristic  reaction for that organism  on
that  specific  medium.  In  the  total coliform
test,  for example,  the positive E.coli culture
produces  red  colonies with  metallic  green
sheen. The  negative control shows no growth
or,  if growth  occurs on  the   medium,  the
organism  produces   uncharacteristic   target
colonies.
  The spot test procedure is ideal for the QC
of a two  step,  two  media  technique.   After
checking  the  QC  on  the  first medium,  the
spot  test MF is lifted  from the first medium
and  placed on  the  second  following the  two
step  test procedure   for the samples. The QC
controls   are  then  tested  along  with  the
samples for the final reading. For example, in
the two step procedure for total  coliforms and
E. coli, after the spot tested  MF is checked
for  sheen, the  test  MF  is lifted  off the M-
Endo medium  and  placed  on   Nutrient Agar
with MUG  (NA-MUG),  incubated   for four
additional  hours,   and  then   inspected  for
fluorescence  on the NA-MUG, typical of E..
coli.  This method   not only provides QC of
the   media   and  MF's,  but   also  of  the
incubation times and temperature.
  This spot  test QC procedure  was found to
be most helpful in a recent water quality  MF
study in  which samples  were  analyzed  for
Clostridium.    A  good  QC procedure   was
critical  because the medium was difficult to
prepare   from   basic  ingredients,  required
anaerobic  incubation  conditions,  and  the
isolation of few Clostridium were  expected.
By using  a  spot test  QC  plate  with  a  pure
culture  of Clostridium perfringens  (positive
control)   and   a  negative   control  in  each
anaerobic jar incubated,  it was assured that

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  Clostridium. if present,  would grow  on the
  medium under the test conditions.
    The  spot test  QC procedure can he  used
  directly on  an  agar  medium surface if a two
  step media  evaluation is not needed  md the
  MF need  not be tested.  In this case the spot
  inoculum   is  placed  directly  on  the  agar
  surface,  and after  incubation,  typical  color
  characteristic growth colonies can be observed
  on  the  agar as the  positive control,  and no
  growth or uncharacteristic  growth colonies are
  seen on the negative control.   However, it is
  essential that  the  agar surface is dry,  as any
  moisture  on the agar might  cause the  spot
  inoculation  to spread over the entire  surface
  and the positive and  negative control cultures
  could not  be separated from each  other.
   For  further  information  please  call  Lois
  Shadix at  513-569-7864.


  Compositing Guidance
      most contaminants,  states may reduce
 the  total  number of samples which  must  be
 analyzed  by allowing the use of compositing.
 (THMs  and  fluoride  samples  may not  be
 composited    for  compliance    monitoring
 purposes.)    Composite   samples   from   a
 maximum of five sampling points are allowed,
 provided  that the  laboratory can, using the
 prescribed method, achieve  a detection  limit
 for the contaminant that is less than one-fifth
 of the maximum contaminant  level  (MCL).
 The  samples must  be  composited  in  the
 laboratory and the composite analyzed within
 appropriate    holding   times.      If   any
 contaminant  is detected,  a follow-up sample
 must be  analyzed within  14 days fron   each
 sampling  point  included  in the  composite.
 The   detect   triggers  for   each  class  of
 contaminant  are  listed  below.  If available,
 duplicates of the  original  sample taken  from
 each  sampling point  used in the composite
 (holding times must not  be exceeded), may be
 used for  the  analyses instead  of resampling.
The  duplicates  must be  analyzed  and  the
  results reported to the state within 14 days of
  collection.
    If the population served by  the  system  is
  more than  3,300 persons,  then  compositing
  may  only  be  permitted   by  the  state  at
  sampling  points  within  a  single system.  In
  systems serving less than  or equal  to 3,300
  persons,  the  state may permit  compositing
  among different systems.
    For economic reasons, if you anticipate the
  presence  of a contaminant  near the detect
  limit, it may be prudent to  forgo compositing,
  or  at  least  collect  duplicate  samples  for
  possible individual  analyses.   The economics
  of  compositing  in these  cases  must  be
  carefully weighed.

 ORGANICS

 VOLATILE ORGANICS
   Currently, there are  18 regulated VOCs.  A
 VOC   is    considered  detected   if  the
 concentration in  the  composite  sample  is
 equal to or greater than 0.0005 mg/L.
   When compositing  VOC samples, special
 precautions  must  be   taken   to minimize
 volatilization  losses.  Composite  cool (4 C)
 samples   only  and  always  maintain  zero
 headspace  in the  syringe. If purging a 5 mL
 sample, pour 5 mL (or equal  larger volumes,
 depending  on  the  number  of samples being
 composited)  of each sample to a 25 mL glass
 syringe,  mix  well,  and  draw out  a 5  mL
 aliquot  for  analysis.   Because   it  may  be
 difficult to pour exactly 5 mL of each  sample
 into one syringe and measure  perfectly,  you
 may choose to pour one  mL of each sample
 into each of five syringes and introduce each
 of these directly into the  sparger.  If purging
 25  mL,  introduce   5  mL  (or equal  larger
 volumes) of each  sample into a syringe by
pouring   the  sample.   As  above, you  may
choose to pour 5 mL of each sample into five
syringes and add these directly to  the sparger.
To avoid losses, VOC samples should  never
be drawn up into the syringe, they should' be
poured.

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OTHER  ORGANICS
  Organics other than volatiles are considered
detected if the concentrations  are greater than
or equal  to the regulatory detection  limits in
Table 1.
  When   using  liquid-liquid  extraction   to
extract these contaminants,  shake the sample,
and  using  one graduated  cylinder, transfer
equal volumes of each sample (to make one
liter), into a separatory  funnel.  Because  the
contaminants  may adhere to the  sides  of the
              (Continued on  Page 7)


A    Better    Way   To    Use

Diazomethane


Uiazomethane,  used to esterify  analytes in
methods   515.1  and  552,  is  a  hazardous
material and  must be handled with care.
  Method  515.1 offers two  means to prepare
and   use   diazomethane   when   esterifying
samples.  Method  552 allows only one.
  In  the   first   technique,   the   gaseous
technique, the extract is esterified by directly
passing   the  nitrogen   gas,   laden    with
diazomethane,  directly into the sample.  This
technique produces less consistent results than
the  one described  below.
  The  other   more  uniform   and   safer
technique  is the generation  of a small volume
of diazomethane  into a  vial of Methyl  tert-
Butyl Ether  (MtBE).  The analyst suspends  a
small (5 mL) screw capped  vial in a beaker of
water so  that the screw cap  is above  the
surface (we use  rubber  bands for this).   Fill
the  vial with MtBE and place this in a freezer
until the  water in the beaker is frozen.
  Use only the  amount  of reagents needed
and  generate diazomethane  directly into  the
MtBE in the vial.  This should be prepared
on  the day  needed.   Return  the vial  in  the
beaker  to   the  freezer  until  the  time  of
esterification.  (The  solution  may be kept in
the  freezer  and  used as  much  as  48 hours
later, but this is not a recommended  pi act ice.)
  When ready to esterify the samples, remove
the  vial from the freezer  and place in a hood.
Add 250 to 500 pL of the cold solution  to
each sample and ensure that a persistent  pale
yellow color remains. (If this does not occur,
add successive 50 /zL aliquots until the yellow
color  remains.)    The  yellow  indicates  an
excess of  diazomethane   is   available   for
esterification   of the  analytes.   Equal  and
consistent  esterification  between samples and
standards  will be  achieved in  this  manner.
The diazomethane  must  remain  in contact
with the  sample for exactly  20 minutes  in
method 552 and  30 minutes in  method 515.1.
  When the esterification  is completed for all
samples, the excess diazomethane  is reduced
in  the samples  and  in  the   vial   with  the
addition of 0.2 gin of silica gel per sample.
Add silica gel to  the vial until the yellow color
disappears.   Allow the nitrogen  gas to evolve
from the sample  before removing portions for
injection into the GC.
            FAX IT TO  US

Please add/change (circle one) my name to
the Labcert Bulletin mailing list.
Company

Address
Telephone

Fax#
Fax to: Grace Zile
        USEPA - TSD
        26 W. M.L.King Drive
        Cincinnati, OH 45268
        FAX 513-569-7191

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                              TABLE 1   MDLs and MCLs for Other Organics (in mg/L)
Contaminant
Alachlor
Atrazine
Benzo[a]pyrene
Carbofuran
Chlordane
Dalapon
Dibromochloropropane (DBCP)
Di(2-ethylhexyl)adipate
Di(2-ethy Ihexyl )pthalate
Dinoseb
Diquat
2,4-D
Endothall
Endrin
Ethylene dibromide (EDB)
Glyphosatc
Heptachlor
Heptachlor epoxide
Hexachlorobenzene
Hexachlorocyclopentadiene
Lindanc
Methoxyclilor
Oxamyl
Pic lo ram
PCBs (as dccachlorobiphenyl)
Pentachloroplicnol
Simazine
Toxaphcnc2
Dioxin
2,4,5-TP (Silvcx)
Regulation
Detect
.0002
.0001
.00002
.0004
.000;i
.001
.00002
.0006
.0006
.0002
.0004
.000!
.009
.00001
.00001
.006
.00004
.00002
.0001
.000;
.00002
.000,
.002
.000
.000.
.00004
.00007
.001
.OOOi '00005
.000.:
Lowest
MDL1
.00002
.00013
.00004
.0015
.00014
.0013
.00001
.0005
.00008
.0002
.00044
.0002
.011
.000015
.00001
.006
.00001
.000015
.000002
.0001
.000003
.00005
.002
.00014
.0001
.00008
.00008
.001

.00008
MCL
.002
.003
.0002
.04
.002
.2
.0002
.4
.006
.007
.02
.07
.1
.002
.00005
.7
.0004
.0002
.001
.05
.0002
.04
"i
.5
.0005
.001
.004
.003
.00000003
.05
MCL/5
.0004
.0006
.00004
.008
.0004
.04
.00004
.08
.0012
.0014
.004
.014
.02
.0004
.00001
.14
.00008
.00004
.0002
.01
.00004
.008
.04
.1
.0001
.0002
.0008
.0006
.000000006
.01
'This is the lowest published MDL of any regulated method.  1 abonttories may composite
which is at least l/5th of the MCL can be reached.
•laboratories may composite no more than 3 samples for toxaphene because lowest  MDL
five samples only if a detection limit

is 1/3 of MCL.

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 Compositing  Guidance
 (Continued from page 5)

 glass sample container and  cylinder,  it is  necessary to rinse  each sample  bottle and  the
 cylinder with the extracting solvent and add  this  to the  aliquot being extracted.   So, discard
 the remaining sample, rinse each empty bottle  with a portion of the extraction solvent, rinse
 the graduate, and  put all  solvent portions into the  separatory funnel.  Rinsing each sample
 container in this manner   may result in a high bias, but it is necessary in order to assure
 recovery of all of the contaminants.  An alternative procedure would be to collect a smaller
 size sample  (260 mL for instance)  when you  know your are going to composite.  Extract and
 continue according to the  EPA  Method  directions.
   For liquid-solid  extraction,  combine equal volumes of each sample (for a total volume of
 1 L) in the 2-L  separatory  funnel  as described in the method.   Extract the sample through
 the cartridge or disk  in the  in.inner  described in  the  method.   The method  requires  the
 sample bottle to be  rinsed  with  solvent  in order to  collect contaminants  that may adhere  to
 the glass. When compositing,  it  is necessary to rinse each sample bottle  with elution  solvent.
 Since a small solvent volume is used for extraction,  rinse each sample container  sequentially
 with the entire  solvent volume.

 INORGANICS
   An inorganic  contaminant  is considered detected if the concentration  of any contaminant
 in the  composite sample is greater than or equal  to one-fifth the MCL.  (This  is assuming
 five samples have been  composited.)    If  an  inorganic contaminant   is detected   in  the
 composite, the follow up sample  only  has to  be analyzed for the contaminants  that were
 detected in the composite  sample.   Except for Method 204.2 for  selenium and  Method  279.2
 for thallium,  all  method MDLs are low enough to reach 1/5  of the  MCL.  MCLs, in mg/L,
 are:
ANALYTE-
Antimony
Asbestos
Barium
Beryllium
Cadmium
Chromium
Copper
Cyanide
MCL
006
7 MFL
2
,004
005
.1
1.3*
2
/5 MCL
.0012
< .4 MFL
.4
.0012
.001
.02
.64
.04
ANALYTE
Lead
M e re u ry
Nickel
Nitrate
Nitrite
Selenium
Thallium
MCL
.015*
.002
.1
10 (as N)
1 .0 (as N)
.05
.002
1/5 MCL
.003
.0004
.02
2
2
.01
.0004
* Action Level
SPECIAL ASBESTOS GUIDANCE
  States  may allow systems to Composite  up to  five samples.  Sample compositing must be
done in the laboratory  on  samples  which are less than 48 hours old or have been  individually
ozone/UV  treated  in  their  original  sample containers.  Samples should be sonicated  and
equal  amounts  withdrawn  to make up  the composite.  It may also  be prudent  to filter an
aliquot of each individual  sample  for analysis in case the composite sample concentration
exceeds 1/5 of the MCL (1.4 MFL > lO^m long).  If this is not  done, the original samples
can only be filtered  if they are  less than  48 hours old and have been resonicated.   If the
sample is more than 48 hours old  it must be treated  with ozone/UV  and resonicated.
                         •tfll.S. GOVERNMENT PRINTING OFFICE: 1993 - 750 002/X0300

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 Improper  Interpretation
    Ivecently (2/19/93), a Regional certification official sent a copy of a SUPELCO
 flyer  to  us concerning purge  and  trap  analyses.  On  page  four of  that flyer  it
 states,"Although  EPA  methods  specify purge  traps,   provisions  for best available
 technology (BAT) allow the selection of traps  (and analytical  columns)  that offer
 improved  performance."   This  statement  contains  some  truth  but also a lot of
 misunderstanding.
    BAT stands  for Best Available Technology  and refers to treatment   technologies
 used by water treatment plants  to remove a regulated contaminant from the drinking
 water  supplied to its customers.  BAT  does not, in any rule that  the Agency  has
 promulgated,  refer to drinking  water analytical  methodology.
    All EPA  purge and trap methods  are very specific in the  detail  and description of
 the traps that MUST be used when  determining regulated contaminants in drinking
 water. This section  of the method  is part  of the extraction  of volatile contaminants
 from  drinking water and as such is considered  part of  the chemistry of the method.
 This is also true  for the purge  volume and  purge  time.   In order to  use a method for
 compliance  monitoring of drinking waters, the analyst must not change the chemistry of
 the method.
    Changes,  other  than  chemical  changes, are  allowed  as long  as  the QA/QC
 requirements  are met  to the satisfaction  of the certifying authority.  This would, as
 the flyer properly states, allow  the use of a  chromatographic  column (for separation
 and identification) other than that specified in the method  if all  QA/QC conditions
 could still be met.  Other  detectors  or chromatgraphic   conditions  can also be varied
 as long as  all QA/QC  conditions can be  met.
    We hope this clarifies the situation.
                                                        The Editors
United States                                                               Bulk Rate
Environmental Protection                  OGWDW-TSD                    Postage^jFees Paid
Agency                                 Cincinnati, OH  45268              Postage no. G-35

Official Business, Penalty for Private Use
$300

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