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. ------- 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. ------- 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 ------- 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. ------- 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 ------- 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. ------- 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 ------- 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 ------- |