c/EPA
United States Regir
Environmental Protection J.F. ., .1 Building
Agency Boston, MM «.~<.v/.j
REGION I
ANALYTIC NEEDS
A N D
LABORATORY CAPACITY
JANUARY 23, 1981
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REGION I
ANALYTIC NEEDS
A N D
LABORATORY CAPACITY
JANUARY 23, 1981
Analytic Center
Region I
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T .BLE OF CO I’H TS
Page
Region I Analytic Needs and Laboratory Capacity
SCOPE OF S’I JDY 1
IN9!I D1DtJc rIc 1
‘I’ES’TII’Z NEE1 ....... . . 2
STA! E LABORA’I DRlES ..... . 7
EPA REXI( 4 I LABcRP 1 I DRY ...... .. ...... 16
PHI VA!rE LA 3DRP 3 ]X)RIES . . . . . . . . . . . . . . . . . . . . . 18
OPTICtE FOR. XPANDI RD ICNAL ANAI2 TIC C.APACIT 1 22
. 25
Appendix A — Profiles of Laboratories Servicing New England States
Corlrkecticut •S.. A—i
Maine . . •. —5
Massachusett.s ...
New Harrpshire ..... .. —14
Rhode Island . . . . . . . A—lB
Ve iont . A—22
Appendix B
Cost of GC/ 4S . . . . . . . . . . . . . . . . . . . . . B—i
Charts
Figure A — Region I State Oil and Hazardous Materials Spills
Program .. . 5
Figure B — Laboratories Providing Services to State Environnental
Program Offices . 8
Figure C — Contract Autbority of Region I States’ Major
Environn ntal Laboratories 10
Figure D — GC/IIS in New Englard State Environn ntal and Public
Heal t abs ............ . . 12
Figure E — Factors Limiting Trace Organics Analysis Capacity . 14
Table I — New England Contract Laboratories with GC4IS Capacity .. 20
Figure F — Average Cost Per Shift of Advanced GC/MS Capacity -
Purchase GC/t’ .. B—2
Figure G — Average Cost Per Shift of Advanced GC/ S Capacity —
Lease GC/!’ S . B—2
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REX3IC I
ANAL? IC NEELS AND LABORMORY CAPACITY
SCOPE AND JRPOSE OF ThE S 1 ItIDY
The purpose of this study, requested by William R. Adaxrs, Regional Admin-
istrator, was to determine the current and projected New England regional need
for analytic services and the ability of EPA, state, and private labs to meet
demands for routine and errergency work. The study is based on Analytic Center
interviews with state laboratory personnel, EPA Regional senior management, EPA
Regional lab staff, and EPA Headquarters personnel. The Center also polled
state program managers through inailback questionnaires.
I}7fl DCUC ION
Region I and the New England states derronstrated widespread interest in pre-
dicting levels of future testing needs. None of the parties interviewed nor the
7 alytic Center itself was able to outline a suitable procedure with which to
project those needs with certainty. It would appear that until we have nore
experience with the unfolding of the toxics and hazardous waste programs, only
very general and speculative indicators of need can be provided.
In making recamndations, it has been difficult to avoid resorting to broad
stateirents: e.g., states and EPA should be alert to shifts in testing needs; EPA
Headquarters should vigorously pursue the question of analytic capability through-
out the country. As usual, there is nore than a grain of truth in these broad
statemants. The Region would be seriously misguided if it searched for a single
long—term “optimal decision” in this instance. A nore appropriate course of
action would be to adopt a policy of “interim decision—making” or “increirental
decision—making” while the evolution of program experience is closely watched.
The follc ing strnuary outlines the study’s major findings and conclusions.
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TESTING NEEDS — Some Indicators of Possible Demands
New England’s need for analytic services has grc n rapidly over the last
two years. WI-i ile requirements for conventional analysis have increased sl ly,
the need for trace organics analysis has mushroomed. Because of this develo tent,
the Analytic Center focused attention on the region’s capacity to perform trace
organ ics analysis.
Some trace orgariics analysis can be accomplished with the gas chranatograph
(CC). A trained analyst can use a GC to determine the presence of organic com-
pounds. In many cases, “screening” - samples with a GC is sufficient to define
the problem. When needed, more extensive analysis can be performed on the gas
chranatograph/mass spectrometer (GC,4.IS). With an “intermediate” GC/ , a lab can
identify and quantify the most frequently occurring organics among EPA’ s 129
Priority Pollutants. With the “advanced” GC/MS, a lab can accurately identify
and quantify all organics priority pollutants. A trace drganics analysis of a
single sample can take from 2 days to 2 weeks to accomplish depending on the
sample medium, chemical interference, stability and the lab staff’s familiarity
with the appr riate protocols where or if they exist.
Total laboratory tijte spent on trace organics testing needs throughout the
region is difficult to determine. Region I ’s Surveillance and Analysis (S&A)
laboratory estimates that it devoted 50 percent of total lab testing tine during
FY 1980 to organics analysis for state and EPA regional program offices. This re-
presents a 10 percent increase in analysis from the previous year.
The demand for trace organics analysis will continue to escalate. Although
hard data is unavailable at this tine, Region I program staff note the fol1c ing
trends:
I. Groundwater/Water Supply
Due to early recognition in New England of toxics and hazardous waste contam-
ination problems, Region I has marched steadily ahead of the rest of the country
in the testing of groundwater/water supplies. According to EPA Region I Water
Supply staff, water supply programs within Region I states currently utilize 10
to 20 percent of available state CC/MS machine tine for normal monitoring and
sampling purposes.
By 1981 to 1983, EPA Water Supply staff project the Region I states’ need
f or analytic time on the GC/ will increase 50 percent over current demand
for several reasons:
(1) TrihalaTethane regulations, promulgated in November 1979, will require
state testing of 22 water supply systems (each servicing 75,000 or more residents),
at a rate of four samples per quarter, beginning in November 1980. In addition, by
1982, 202 additional systems (each servicing 10,000 to 75,000 residents) will be
tested for trihalazethane at the same quarterly rate. Thus, an & ditiorial 352
analyses will be required of the New England states in 1981 and another 3,232
analyses in 1982; appr cimately 25 percent of these samples will involve the use
1 ”Screening ” in Region I applies exclusively to the process of GC volatile or—
ganics analysis which is taken to indicate the possible presence of other organic
cxitpounds.
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of GC/ 4S.
(2) A Headquarter& Advance Notice of Proposed Rulemaking, due in the Federal
Register in January 1981, will list an additional 6 to 15 organic chemicals re-
quiring GC4IS analytic work by 1983. Our New England states are expected to
axrmence preliminary testing and n nitoring for these chemicals inmediately.
(3) Sixty—six water supply systens in New England are already contaminated
by organics. This number will increase as the hazardous waste program gains
n irentum and as contaminated plumes already in uifers reach supply wells. An
unkn n number of private wells near hazardous waste sites also require testing.
Rhode Island’s laboratory staff reports that it is testing an average of 25 private
wells at each of its 16 controlled sites. Although this number cannot be extra-
polated for each state, it suggests the potential magnitude of testing needs in
the vicinity of such sites.
II. Uncontrolled Hazardous Waste Sites
Uncontrolled hazardous waste sites present the nost apparently pressing
need for trace organics analysis in the region. As of Decerrber 1, 1980, 525
sites were listed in the Region I log of potential hazardous waste sites in New
England. The number is expected to triple to 1,500 sites once the inventory is
complete. EPA Head uarters and Region I staff estimate that 20 percent of the
inventoried sites will be confirmed for hazardous waste. For New England, this
may mean 200 to 300 sites. Most of the sites are located in older, heavily
populated industrial areas where they present a potential threat to public health.
Not all sites require organic analysis. In some cases, a review of user re-
cords and/or sanitary chemical analysis is sufficient to approximate the contents
and therefore the probable environmental and health effects of the site.
Where historical records are not adequate, or when further information is
needed to determine appropriate remedial action or to support an enforcement ac-
tion, sampling and analysis are necessary. In some cases, analysis of a few
samples is sufficient. Other cases, e.g., Woburn, Massachusetts, will require
major attention fran Region I and the states. Woburn is the location of irultiple
waste disposal sites used by a variety of industries for many years. According to
Region I project staff, the number of samples requiring GC4IS analysis at Woburn
may well exceed 100 before the case is closed.
- The Region I uncontrolled sites project coordinator estimates an average of
10 samples will need GCA4S analysis at ead hazardous waste site. Given the
possibility of 300 sites, the region could need GCAIS analysis of 3,000 samples
over the next few years. The uncontrolled sites coordinator also stated that in
FY 1981, the Regional Office may be involved in 50 general inspections, 20 major
inspections and 4 to 5 enforcement actions (whether EPA is in the lead role or
the states take the lead). This involvement would require EPA to provide approxi-
mately 700 hours of lab time, including 500 hours of GC,4t5 work. These figures
represent a doubling of the workload devoted to uncontrolled sites by the Regional
lab in FY 1980.
The actual number of sanple analyses performed by EPA Region I over the
next few years will depend greatly on the availability of S&A and contractor lab
time. Uncontrolled sites work could consi. all of S&A’ s current laboratory
capacity if suth capacity were available. Fortunately, the EPA Regional lab is
caiimitted to screening samples to reduce the arrount of extensive GCAIS work
needed.
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III. Superfund
It is still too early to determine the extent of testing needs that may be
associated with the Superfund program. Some testing will be required to identify
and assess hazardous waste sites for clean up. Extensive testing may be needed
if all contents of a site must be determined before remedial action can be taken.
At this time, however, it appears that Superfund ironey cannot be used directly
for EPA Regional or state capital investment in lahoratory equipT nt.
IV. Section 311 — Hazardous Material Spills
Under section 311 of the Clean Water Act, EPA shares with the Coast Guard
the a.ithority to assure clean up of oil and “hazardous materials” spills which
present an “inininent threat” to surface water. EPA has defined 291 chemicals as
“hazardous materials” on the basis of their health and environmental effects and
the volume in which they are prcx uced and transported. If Irore than a given
airount of oil or “hazardous materials” is released in 24 hours at a spill site,
EPA has authority to arrange for clean up and to hold polluters liable for clean
up costs. Even if liability cannot be established, EPA can arrange for site
clean up with section 311 itoney appropriated by Congress for this purpose.
Regions are not given specific yearly allocations of 311 funds, but rather
use- nationally appropriated resources until they are gone. Congress intended
that 311 honey develop into a rei. olving fund through charges levied against
polluters. Frequently, however, it is impossible for EPA to recover from un-
controlled hazardous waste sites owners and operators the section 311 ironies
expended by the agency to clean up such sites. This is because in many cases
the quantities and rates of flow of “spills” at sites are below the requisite
thresholds established for recovety fran site owners and operators as specified
in agency regulations pratulgated pursuant to section 311.
Remedial action under section 311 requires GC/MS analysis to establish the
release or potential for release to surface waters of at least one of the 291
“hazardous materials”. ‘lb date, EPA Region I has expended approximately $1
million in section 311 funds to clean up 7 uncontrolled hazardous waste sites
in New England. None of these sites has met established liability criteria.
In FY 1980, Region I ‘s Oil and Hazardous Materials Section requested analysis of
350 samples. The need for hazardous materials analysis under 311 should diminish
as Ilore uncontrolled sites work is accaiplished under Superfund.
The states’ involv nt in spills clean up varies widely in Region I (see
Figure A).
V. ICR Permit Regulations
Both Regional and Hea uarters EPA personnel expect that the RCRA hazardous
waste permit program will necessitate GC/MS analysis by permittees. The extent
of the testing need, however, is still uncertain.
Permit applicants are not required by regulation to conduct testing before
applying for a RCRA permit. Most of the information required by 1 RA notification
and Part A applications is already available to permit applicants. However, EPA
will require sara applicants to conduct testing based on information suI nitted
in Part A applications. -
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FIGURE A
REXIC I STATE OIL AND HAZARJXXJS MATERIALS SPILLS PR RAMS
I Program Staff I Spills Response
State Size I Funds
I I
I I
NNECTICU’T I 5 I $200,000 (revolving)
I I
I I
I I
MAINE I l0_15 1 I $5 million (revolving) 2
I I
I I
MAss o1usETrS 6—8 I $400,000
I I
I I
NB’ HAMPSHIRE I 4—6 $1 million (revolving) 3
I I
I I
I I
RI DEISLAND I 1 I 0
I I
I I
VER1Ct T 1 I$25,000
½iaine’s spills program staff is dedicated exclusively to oil spill
program work (i.e., adninistration, research, clean up and damage
to third parties). The state does not have an organized hazardous
materials spills program.
2 Revenues for Maine’s response fund are collected from taxes on
oil transported into the state, clean up costs recovered from
polluters and pollution fines. When the fund reaches its $5
million limit, oil taxes irust be lcx’iered or ren ved until the
fund is drawn dawn.
3 New HalTpshire ’ s oil spills response fund is structured nuch like
Maine’ s fund except that New Hairpshire does not pay third party
damages. Also New Han shire ‘s fund is iruch newer and therefore
offets fewer available resources at this tima.
-5-
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EPA Region I has received 1,100 Part A applications from treatment, storage
and disposal facilities in New England. pp1icants with land disposal facilities
and/or incinerators may be required to analyze groundwater, leachate, arrbient air
and stack gas emissions for toxic organics. (This analysis can be accomplished rrost
efficiently and accurately with a GCAIS.) Until EPA catpletes its review of Part
A applications in late FY 1981 and early FY 1982, the vol re of permittee testing
cannot be determined. It appears, however, that testing for permit Part B will
be required in early and mid FY 1982. The testing burden will fall on industry,
impacting private laboratories, not the states or EPA.
Additional testing need will stem from requirements for permittee self—iron—
itoring and compliance ITonit oring by EPA and states with delegated responsibili-
ties. EPA Regional enforcement strategy will largely determine the extent of
this testing.
VI. Revised NPDES Regulations
Under NPDES requirements prc*rulgated in May, 1980, “primary industries” nust
test their effluent for the presence of 135 specific pollutants. Many of these
pollutants are organic compounds best analyzed with a GCAIS. There are approxi-
mately 400 major industries in Region I. Possibly 80 percent of these companies
will need GC,44S analysis to complete their NPDES permit applications.
According to local contract laboratories, industries ypica1ly su nit three
to four sauples (e.g., intake water, effluent, process stream water, field blank)
for NPDES permit analysis. Most permit applicants in New England are required to
analyze for all four GC,41S fractions (i.e., base neutrals, acids, pesticides and
volatile organics) specified in the permit application. Two private laboratories
in the region were asked to estimate the average arrount of time needed to analyze
each sample. One lab estimated an average of 3.5 hours of GC/ lS machine time
plus 9.5 hours of a3ditional time for sample preparation, data handling, etc.
The other lab estimated an average of 10.5 hours of GC,4tS time and 15.5 hours of
additional lab time. The difference between the two labs is partly explained by
the number of samples analyzed at one thre, the extent of quality assurance work
and the use of automated equipment. The average per sample cost for organics
analysis was $750 at the first lab and $870 at the second lab in 1980.
approximately 200 cc rpa flies are scheduled to su nit NPDES permit renewal
applications by June 30, 1981. Given our two estimates of average time for
analysis and the possibility that 80 percent of permit applicants will each re-
quire analysis of three samples, industry may generate a demand for 1,680 to
5,040 hours of GC,41S tiire within the next six ntnths. meet this demand,
private laboratories must be able to dedicate approximately 1.5 to 5 GC/MS plus
trained operators. After this initial six rronth surge of analytic need, the
demand for testing will be uore staggered as other NPDFS permits near expiration.
VII. ¶ftxics and Air
Air is inplicated increasingly as a pathway in the exposure of large popula-
tion groups to toxic and hazarãxis pollutants. With growing concern, greater
national and state emphasis may be placed on identification and control of toxics
from incineration, industrial emissions and emissions from hazardous waste sites.
Identification and control metbodologies still need development and/or refine-
ment. It is likely, however, that sate GC/ 4S analysis will be needed. The ex-
tent of that need will depend on assessment procedures to be utilized and the
status of air quality.
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STATE LABORNIORIES
With delegation of authority for NPDES, drinking water primacy arid pesti—
cides programs, the burden of testing is falling increasingly on state labora-
tories. This trend is expected to continue given EPA policy favoring state self—
reliance arid 0MB policy favoring development of state and private labs rather
than federal Regional laboratories. Gro zing public concern over public health
and safety issues also has intensified the pressure on state labs to perform
ccitplex analyses.
Overview
A variety of state laboratories serve the analytic needs of New England state
environmental programs. Some of these labs are directly responsible to environ-
nental agencies or to program offices of these agencies. Others are housed in
public health or agriculture departments. An outline of state laboratories pro-
viding services to Region I state environmental agencies is presented in Figure
B. Profiles of these laboratories are provided in Appendix A.
Laboratory Size
it is difficult to catpare laboratory staff sizes axr ng the states in a
meaningful way because lab clients served vary so greatly. In Rhode Island, for
exanpie, the Department of Health Laboratory conducts all food, drug, law enforce-
ment and environmental analyses in the state. New Hampshire’s Water Quality and
Pollution Control Lab, on the other hand, serves the water, pesticides, drinking
water and hazardous waste programs. Thus, to compare Rhode Island’s lab size to
New Hampshire’s water lab size would be misleading.
Sure sense of the range in lab size can be gathered from a icok at two compre—
hens ive environmental labs with comparable clientele: Vernont and Massachusetts.
Vernont is representative of the smaller labs in the region. Its lab employs
seven analysts arid four support staff with a total working budget of $161,000 in
F? 80. The Massachusetts laboratory is representative of larger labs in the
nore urban/industrial states of New England. It has 26 analysts and 14 support
staff with a total working budget of $559,000 in Fl 80.
Funding
State revenues constitute the chief source of state laboratory funding.
The Connecticut, Rhode Island and Vernont legislatures fund the labs directly
for equipment and supply purchases, but funds for laboratory staff come through
the labs’ clients (i.e., state agencies) on a contract basis. In Maine, Massa-
chusetts and New Hampshire, total state support for the labs canes from the envi—
ronnental agency budgets. In Massachusetts, lab funds are specifically earmarked
for laboratoi:y use and therefore cannot be used by other program in the Depart-
ment of Environmental Quality Engineering. New Hampshire’s environmental agency
director can redirect a small portion of laboratory funds (e.g., for lab equip-
ment) to other areas of the agency, but the majority of funds also are committed
to lab staff salaries. State laboratory funding is less protected in Maine’ s
Department of Environmental Prot’s budget.
With the exception of EPA pesticides funding to the New Hampshire laboratory,
state labs have no direct link with EPA grant program offices. EPA federal funds
are channelled to the labs through state program offices. State agencies can
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FIGURE 13
LADOIWIORIES PrOVIDING SERVICES
D STATE ENVII MENTAL PrOGRAM OFFICES
WATER
SUPPLY
PESTICIDES
RESIEUES
HAZAR [ XJUS
WASTE
STATE WATER
I I
I
I I I
I CONNECTICUT I state public
I contractor I state public I Agric. Experiment I state public
I health lab
I (Wesleyan I health lab I Station
health lab
I
I
University) I I
I
I
I
I
I
I I
I I
I
I
I I I state public I
MAINE
f air program lab
state
environ—
state public I state public health health lab
I
I mental
lab
health lab I lab I I
I
I I state environnen—I
I___________
I I tallab
I I
.
.
I state environmental I I
MASSAcHUSET1’S I air program labi state environmen—I state environmen— I lab I state environmen— I
I tal lab
tal lab I FDA* I tal lab
I
I I state public health I
.
lab I
I I
I I
I NEW HAMPSHIRE lair program lab
I water
program lab I water program lab I water program lab I water program lab I
I I
I
I I I I
I I
I
I
I
I
I
I
I
I
I
I I
I I
I
I I I I
RHODE ISLAND
state public
I state
public I state public I state public health I state public I
I I health lab
I health
lab I health lab
lab
health lab I
I
I.
I
I
I
I
I I
I
I
I
I I
I
I
I I
I
VEEMONT I water program
I water
program labi state public I State Department of
water program lab I
I lab
I
I health lab I Agriculture
I
I
I
I I
I
I
I
I I
I
+
*Se ndary service provic3er.
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use nonitoring noney in EPA grants (e.g., §106 of the Clean Water Act) to support
sampling and analysis. Most states, however, use the majority of their rronitoring
funds for sampling. This leaves little Troney for laboratory analysis.
State programs reportedly compensate public laboratories situated outside
environmental agencies through interdepartmental transfers of funds. These
transfers are sometimes inadequate or undependable. For exarrole, Connecticut t s
Department of Environmental Protection owes the general fund for services pro-
vided by the Department of Health lab. Compensation fran Rhode Island’ s air and
water and hazardous waste programs does not cover the Department of Health’ s
costs of providing lab services to these prcxrams.
All state labs have met with rapidly increasing wage and equipment costs
over the past few years. Per annum wages have risen 7 percent in Rhode Island
(where salaries were already high coirpared to the regional average) and 12 percent
in Maine. Connecticut personnel costs rose a total of 35 percent in 3 years due
to cost—of—living raises, position reclassif ications and upgradings. Inflation,
growing technical sophistication and expanding program demands for testing have
pushed up the cost of equipment as well as supplies (chemicals, glassware, media)
dramatically. In Massachusetts, even the cost of maintenance has “skyrocketed”.
In the face of these costs, all state labs claim that their budgets are too low
to meet the current volume of program requests f or analysis.
Contract Authority
The chart in Figure C outlines the contracting authority of lead state labora-
tories, the agency in which the lab is located and the EPA grants which go directly
to that agency. All lead state labs have clear authority to contract with private
rirercial labs or other sources (e.g., universities, private institutions). None
of the states has established a formal contract budget at its laboratory. However,
some state labs charge program offices requesting services provided through con-
tractors or irove funds for contracting fran other budget items. Maine has an in-
formal budget funded by its legislature. This budget allows the lab to purchase
$5,000 to $10,000 of outside services per year as needed. Without established con-
tracting budgets, the labs’ ability to exercise their contract authority is severely
limited. Even if nore noney were available, however, Trost labs would prefer to
conduct analysis in—house because of cost and quality assurance considerations.
Priority Setting
State environmental programs generally find state labs responsive to service
requests to the degree that lab capabilities and capacities permit. However, the
process for setting priori ties anong those requests varies significantly from
state to state. In Maine and Massachusetts, priorities are determined by the
labs in limited consultation with program offices. In both states, lab directors
have chosen to protect traditional program work by limiting the anount of trace
organics analysis conducted each itonth. In Connecticut and Rhode Island, the
Department of Public Health labs (which perform rrost of the environmental agencies’
analyses) conduct testing on a first cate, first serve basis. It is the environ—
mental agencies’ responsibility to set priorities anong requests submitted.
Vernont’s priority setting process is informal and flexible due to the environ-
mental agency’s small size. There, the agency director can shift priorities to
meet pressing needs. New Hampshire’s priority setting arrangement presents a
sc*newhat unique situation because the state’ s major environmental laboratory is
located within the Water Supply and Pollution Control Coninission. Because of
—9-.
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FIGURE C
CONTRACT AUTHORITY OF REGION I STATES t
MAJOR ENVIECNMENTAL LABORA!IORIES *
I I I
I I I
I (DNTRACT
ESTABLISHED
USE OF
STATE I AtYI’HORITY
BUIX3ET
AUTHORITY
I I
CONNECTICUT I Yes
No
occasional
I
Yes
MAINE I Yes
(limited)
occasional
I I I
MASSAQ USETTS I
Yes I No
No
I
I I I
NEW HAMPSHIRE
Yes I No I No
I
I
I
occasional
RHODE ISLAND
Yes
No
(to verify
state lab
____________
s Drk)
VERIONT
Yes
No
occasional
I
I I I
*C e icut
Maine
Massachusetts
New Hanpsh ire
Rhode Islar 5
Ver ont
— Departitent of Health Laboratory (S105, §106,
SDWA, RCRA)
— DEP Division of Laboratory ar i Field Services
(S 106)
— DEQE Lawrence Laboratory (S106, SDWA, pesticides,
RcR A)
— Water Supply arxl Pollution Control Coitmission
Laboratory (Sl06, St A, pesticides, RCRA)
— Departir nt of Health Laboratory (S105, §106,
SI , pesticides, RCRA)
— Agency of Enviorniiental Conservation Laboratory
(S105, §106, 1 RA)
—10-
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this arrangement, the lab tends to be particularly responsive to water program
needs and to critical needs such as hazardous waste. To deal with this situation,
New Hairpshire is establishing a coordinating coninittee to facilitate coordination
and better canninication aitong program directors.
Every state indicated that its priority setting process could be -irrproved by
better ccznrrunication between environmental program offices and labs as program
offices are in the best position to determine the need for testing while labs are
best able to estimate the tine and resource demands of analyses.
Analytic Capabilities
In general, state laboratories are able to conduct conventional analysis of
environmental pollutants to address ircst of the traditional water and air program
analytic needs. All New England states can analyze pesticide residues (very dilute
pesticides; chemicals measured in parts per million), but only Connecticut, New
Hanpshire and Ven nt have the capacity to analyze pesticide formulations (full
strength pesticide; chemicals measured in parts per hundred or less). Labs typi-
cally avoid doing forirulation work in—house because of the potential for serious
lab contamination. Rhode Island sends its formulation samples to a Mississippi
state chemical lab for analysis. Maine and Massachusetts just assumed pesticide
enforcement responsibility in July, 1980. It is still unclear whether they
will develop their a in formulation analysis capability or rely on that of other
state labs.
As mentioned previously, the states’ greatest weakness is in trace organics
analysis necessary for toxics and hazardous waste work. Although nxst state labs
have operating GCs, many state staffs are not skilled in screening. Also, as
indicated in Figure D, the availability of GC/ 1Ss is limited in the region. Only
Connecticut, New Hampshire and Rhode Island have “advanced” GC/1 4S in the princi-
pal state labs used by each state’s environmental agency. Massachusetts and
Maine have “intermediate” GC/MS capability in their environmental agency labs.
Maine also has some access to an advanced GC/ tS and VernDnt to an “intermediate”
GC/MS in their respective state public health labs. As the couplexity of analysis
needed increases, an “intermediate” machine will not be adequate in all cases.
GC,41S Cost
The cost of the GC/MS and trained analysts has been the critical factor lim-
iting develop rent of organics capabilities in the states. A CC unit costs about
$15,000 and can be operated by a bachelors level chemist. At this price, states
have been able to afford CC capability. In contrast an “advanced” CC/MS can cost
$160,000 or n re. A GC,41S requires specially trained operators, rrore expensive
maintenance and a nore controlled physical environment than a CC. For an “advanced”
machine, this results in an average cost of $318/single eight hour shift and $2051
double shift. (See Appendix B for costing details.) State laboratory budgets
have often been too restrictive to permit such expenditures. ¶I jpically, the
budgets only gr enough to maintain existing equi nt, staff and space.
GC/’ 4S equipment can also be leased at an average cost of $363/single shift,
$217/double shift (see Appendix B). Although a leasing arrangement costs 11
percent irore per shift, some states find this arrangement n’ore appealing. State
legislators may prefer to allot smaller sums of noney for several years, rather
than a single large lump sum. Leasing also permits states to irove to nore sophis-
ticated equi ent should the technological “state of art” change substantially.
—11—
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FIGURE D
GC/14S IN NEW ENGLAND STATE
ENVI NMENTAL ND PUBLIC HEAL LABS
I E2 VI N4 TAL
PUBLIC
S’]ME
I AGENCY LAB
I
I
I
I HEALTh LAB
I
—l
I
CONNECTICUT
I
—NA—
1—advanced’
MAINE
I 1-interrt diate
1—advanced
MASSAo JSE’rrS
1-inter mediate
—0—
NEW HAMPSHIRE
1—advanced 1
-0-
I
I
I
I
)
I ODE ISLAND
I
I -NA-
I I
1-advanced 2
I
I
I
I
I
I
I
I
I
I
VE1Gt 7T
I —0—
I l—intern diate
I
I
I
I
I
I
,1
1 New Hampshire and Connecticut are in the process of purchasing
aGC,44S.
2 Rbode Island is in the process of leasing another GC/ 1S.
S(XJRCE : Analytic Center I, based on interviews with state
laboratory directors.
I.
—12—
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rialytic Capacity
All state laboratories appear to be working at or near their rnaxirrum capaci-
ties. Connecticut, for exanple, has not refused samples yet but the current
saiple backlog is bec ning tiore difficult to reduce. In Rhode Island, mandated
programs are not suffering but recanmended programs are overlooked Out of practical
necessity. In Massachusetts, where laboratory resources are barely adequate to
handle conventional work, the lab “faces a crisis” each ti a hazardous waste
sample arrives for analysis. New program requirements and testing needs upset a
lab’s balance between testing requests arid capacity. Labs are forced to neglect
the new demands or cut back established testing services until iiore resources
become available.
Factors Limiting Capacity
Strained state lab capacity in the area of trace organics analysis stems
from:
0 inadequate technical screening,
0 insufficient equipment,
0 staffing problems arid
0 limited physical space.
The New England States exhibit these problems to varying degrees as shown in
Figure E.
Most states are reluctant to depe rid on GC screening to reduce the volume of
GC4IS analysis because of the possible public health consequences of misreading a
scan sample. Yet, the probability of an incorrect reading is slight. Massachu-
setts is actively seeking to improve its current screening efforts by adding
special equipment (flash point and field pH analyzers) to nplement GC capabili-
ties. The lab recognizes that with staff and space constraints, screening
could be nore useful to the lab than additional GC/MS units. The same could be
true for other states. Connecticut has recognized this potential and has begun
develcping a itore systematic method of judging samples subtiitted for analysis.
As noted earlier, all state environmental programs need access to GC/Ms
analysis when detailed information on priority pollutants is required.
0 Although Rhode Island has the rr t extensive GC4IS capacity aziong
the six New England states, anticipated increases in drinking water
program needs could strain existing capacity.
0 Connecticut has just purchased an advanced GC/ 4S for its Depart-
ment of Health lab, the major health and environmental laboratory
in the state.
0 Vernont’s health laboratory has an “intermediate” GC,44S, but,
since machine time is occupied with drinking water samples
arid other health department program needs, its availability to
the Agency of Environmental Conservation is very limited.
0 New Hampshire anticipates increased trace organics analytic needs
at uncontrolled waste sites and in association with the drinking
water and NPDES programs. New Haxrpshire is in the process of
purchasing a GCAIS to meet these needs.
—13—
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FIGURE E
FACIORS LIMITING TRACE O ANICS ANALYSIS CAPACI
X = PRESENCE OF LIMITING FACIOR
I I I I
I I
S’] TE E JIPM T I STAFFING SPACE
I
I
cONNECTIC(JT
x
•.
I I I I
INE I I X I
I I I
ssAcHr.JsETrs I I X X
I
:
NEW I1PSHIRE I X I X I X
I I I
I I
I I
1 I
1 1ODE ISLAND I I I
I I I
t I
I
VER4ONT X X X
I I I
I I I
*In the process of acquiring a GC/ 4S.
—14—
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o Maine’s traditional testing services have been reduced in an
effort to n et the state ‘s expanding organic testing needs.
0 Massachusetts will cperate its GC/MS on a secorx3 shift beginning
early in 1981 to rt et state demand for analysis.
All states except Rhode Island have limited or inadequate (i.e., non—air
conditioned) lab space. This restricts the labs’ ability to accomin date addi—
tiona.1. machinery, at least in the short run, even if rroney for machines were
available. Most states also have a problem attracting and retaining skilled
GC,41S operators because of salary conpetition in the private sector.
—15-
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EPA REGI I L1 BORNIORY
Overview
EPA Region I’s Surveillance and Analysis Division is the technical service
and support arm of the Regional Office. The Division has two components. The
Surveillance Branch conducts special arid routine field investigations, n x3eling
studies and technical reviews of state arid private n nitoring data in support of
EPA regional arid national ironitoring programs and enforcement actions. The
Technical Support Services Branch houses the Reg’s chemistry and biology
laboratories (i.e., the Regional lab).
The Regional lab’s primary responsibility is to provide analytic work and
other technical support for EPA Regional program offices. The lab also provides
assistance to Region I states if public health is jeopardized arid when states
lack specific expertise or equipment to perform needed analysis therrselves. This
assistance takes the form of direct testing services arid technical aid including
lab certification, state personnel training, consultation, verification of findings
and referrals to national EPA contractors. Finally, the lab provides advice arid
training in quality control and equipi nt use to local governments and other
federal agencies.
Analytic Capability
Originally, S&A. concentrated on routine laboratory work, particularly in
the area of water quality planning analysis. With growing state expertise in
traditional analysis, the passage of new environmantal laws and the creation
of new EPA programs, S&A’s capabilities expanded to include air pollution work,
sore xii lex water analysis arid finally toxics arid hazardous materials analyses.
Only pesticides fornLilation arid radiological work are not perfors d in-house
because of the potential for contaminating other sensitive arid expensive pieces
of lab equipnent.
The Regional lab’ s Chemistry Section is c tpe tent in conventional sanitary
chemistry, air analysis, water, soil and tissue analysis for metals and trace
organics contaminants. It has two GC4IS and a sufficient nuirber of trained staff
to operate double shifts on one machine when needed. The lab’s Biology Section
has analytic ability in benthic invertebrate sanpling arid taxonar J, sediment
oxygen demand, chlorophyll A, productivity studies, phytoplankton, biomass,
acute toxicity studies (bioassays), total and fecai. coliform analysis, pathogenic
bacteria analysis and asbestos fiber identification. At present, the Biology
Section is upgrading its bioassay capacity to meet anticipated demand.
Analytic Capacity
The size of Region I ’s , lab staff has remained constant at 16 people (with
occasional co-op students and other thn orary personnel) since 1972. With three
experienced supervisors, the laboratory has the ability to support high level
technical assistance to the states.
Although the lab is not organized to operate on a production scale, it is
expected to be able to meet urgent regional analytic needs as they arise. Thus,
personnel are trained to do a wide variety of analyses which are not needed on a
constant basis. A benefit of this arrangement is that the laboratory is able to
allow state arid local labs to use S&A equipment arid facilities otherwise unavail-
able to them. For exartple, the lab’s X—Ray Flourescent Spectrophaneter has been
—16—
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used by Main& s Hazardous Waste Program, the Suffolk County Massachusetts “lead
in soil” program and the air labs of Rhode Island and Massachusetts. The cost
of the machine (approximately $80,000) is nore than any one of these programs
could justify by itself, but the availability of the equiptent is extremely useful.
Factors Limiting EPA Regional Lab Capacity
The Region I lab is supported with funds from Regional program office budgets.
Each year, program offices project their analytic needs and direct resources to S&A
to finance these activities. Although sate consideration is given to analytic
needs of state counterpart programs, Regional program offices itust concentrate on
direct Regional responsibilities because of Heaã uarters’ budget directives (i.e.,
workload nodels for projected program accatplishnents). This leaves limited re-
sources for direct asistarice to states.
State/EPA Relations
- State labs rely heavily on technical assistance and occasional testing ser-
vices made available through EPA’s Regional lalxratory. Most states recognize
the lab’s resource constraints and keep their requests to a mininum. State
requests for help in public health emergencies requiring nore than a day’s cam-
mithient of Regional lab time are channelled through the Regional Administrator’s
office. There, decisions are m de on which requests will be met by the lab.
Sometimes. resources required to meet the Peg ional Administrator’ s approved state
requests are not included in the air, water su ly, or enforcement program plans.
In these cases, Regional program staff are contacted directly to obtain clearance
for use of program resources to meet these emergency needs.
()1 the other hand, state lab directors and staff freely consult with the
Region I lab on testing methodologies and general training matters. The states
praise the quality and timeliness of EPA Regional lab setvices, but would like
to see the lab’s capacity expanded to handle nore requests for analytic work,
especially for energency assistance. In addition, Rhode Island’s lab suggests
that Region I S&A act in a coordinating capacity to nobilize the r egion’s manpa ier
for response to major emergencies (e.g., major “hazardous materials” spill, nuclear
pcwer plant accidents).
—17—
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PRIVATE IABORA’IORIES
National EPA Contracts
EPA sp nsors a series of national contracts available for use by Regional
program offices. The contracts cover a wide range of analytic needs related to
research and development, enforcement, NPDES permitting, etc. The contracts of
particular interest in this study are those which provide trace organios analysis.
These contracts are managed by the Oil and Special Materials Control Division
(OSMCD) in the Office of Water and Waste Materials, the Office of Enforcement and
the Office of Research and Develo t nt labs in Cincinnatti and Research Triangle
Park. The enforcement contracts provide a broad range of organic analyses,
but require that testing be related directly to an enforcement action (e.g.,
suspected NPDES permit violation) and to the law authorizing the contract expen-
diture. The ORE) contracts are geared primarily toward longer term research
efforts. However, contract use has been approved for hazardous waste projects
where experimental technology was enployed (Conventry, Rhode Island). The rrost
relevant contract for uncontrolled hazardous waste sites work, however, has
been the OSMCD contract.
The ( MCD contract provides total analytic capacity for 400 single phase
aqueous organic samples per rronth. The contract is spread out anong 20 labs
around the country in bid lots of 20 samples per nonth. The labs receive
a flat fee of $600 per sample regardless of whether the lab analyzes the sample
for all 114 EPA priority organic pollutants or whether a partial analysis of
volatile organ ics is requested.
The national contracts are intended primarily for EPA Regional Office use.
Given the volume of Regional Offices’ need for analyses, the contracts are rarely
extended to state referrals frai’ Regional Offices. Shortfalls in meeting some
egns’ needs are already apparent and suggest that a few major problem spots in
the country could absorb rros t of the available contract capacity. The majority
of existing contract labs are al1. It is unlikely that EPA could expand their
wo icIoad, at least in the short run. Nor is there an untapped pool of other
private contractors ready to take on complex organics analysis. This is especially
true for soil, and sediment analysis for which there are no established EPA proto-
cols.
Although many Regions are increasing their use of national contracts, some
Reg ions (including Region I) have problems with the use of those contracts.
Basic objections center on the quality of contract work and sairple turnaround
time. The Region I lab would UJce to assume nore management and direct quality
control over national contract work completed for the Region. The wide geographic
distribution of contractors frequently precludes close contacts between contractors
and their clients.
O D has recognized many of these problema with national contractors and
is trying to correct them wherever possible. For exarrple, OS 4D has reserved
15 sanple analysis units in a Massachusetts contract lab for Region I. This
arrangement should facilitate better conTilmicat ion between Region I and the
contractor. As to sanple turnaround tine, OSMCD is trying to develop new con-
tracts which will provide limited organic analysis (e.g., volatile organics
asses rent) in a shorter time frame. A new contract agreement for the primary
contract is also expected next year. Under the proposed scope of work, the
national contractors would analyze air samples and high concentration samples
—18—
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(including soil and sediment) in addition to aqueous samples. Another potential
avenue for better contract services is subcontracting through the Viar Cartpany
• (OSMCD’s coordinating tracking consultant) with OR]) contractors. Many of the
OR]) contractors are capable of doing organic analysis, can be available on short
notice and are cheaper than OSMCD contractors for limited analysis. Finally,
the Field Investigation Team (FIT) contracts can also be tapped. FIT people can
be placed in Regional S&A labs to assist in sample collection and analysis.
Lccal Private Laboratories
Regional EPA and state reliance on private laboratories has been limited to
date. Contracting for trace organics analysis has been particularly difficult
because of the limited availability of “advanced” GC 1S in the private sector.
The Analytic Center was able to identify 12 contract laboratories in New England
offering trace organics analysis of environmental samples (Table I). ‘Itgether
these labs have a total of 15 GC/MS, but at this time tt st equipnent is fully
utilized in ongoing work. The prospect for future GC,44S availability looks nuch
brighter. According to two major GC,’ producers (Finnigan and Hewlett-Packard)
and several private laboratories, the private sector is eager to acquire GC/MS
as soon as clear demand for trace organics analysis materializes. New England
also has a nunter of me ica1 labs which conduct GC4IS analysis of biological
samples. Several of these labs are considering expanding their data base to
meet the EPA protocol for priority pollutant analysis.
With the possibility of expanded GC/ 1S capacity in contract laboratories,
the private sector presents a potentially iirçortant service option for meeting
regional analytic needs. Increased reliance on the private sector will require
careful contract management to overcome the follcwing problems conrron to past
contracting experience:
(1) Uneven quality of work — Regional lab staff attribute variable quality
to high staff turnover and concentration of skills in a few key
analysts. The result is that work may be excellent when skilled
analysts are assigned to projects, but inferior when junior or new
staff carplete work. This risk of questionable quality has been
viewed as unacceptable where a public health emergency or enforcement
action are concerned. A strong quality assurance program, clearly
established technical procedures and protocols, and a vigorous over-
view of private laboratories could alleviate these problems.
(2) Delays and s1c sample turnaround time — Private labs are responsible
to a nunter of clients and have less flexibility in scheduling work
than a public facility. State and EPA program offices consequently
have desired nore direct control over priority setting afforded by
pthlic labs. Carefully constructed contract agreements could provide
nore of the scheduling control that states are seeking. Obviously,
when rapid turnaround tine is essential, costs to analyze will increase.
(3) Poor coordination between field and lab staffs - The State of Vernont
made particular note of problems resulting frcxn inadequate coordination
between field sampling teams and contract lab staff. According to
agency staff, close interaction between sampling and testing units
—19—
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TABLE I
NEW ENGL D ODNTPAC LABOP IORIES
WITH GC/ 4S CAPACITY
Connecticut
Hartford Managenent Services* (subsidiary of Hartford Insurance
Group) - Hartford
Springborn Laboratories — Erifield
Travelers Insurance - Hartford
Maine
E.C. Jordan, Co. — Portlar 5
Massachusetts
Arthur D. Li tUe — Cairbridge (3 GC/ 1S)
Bioran Medical Lab — Canibridge
Caxrbridge Analytical Associates - Watertown
Canp, Dresser & McKee - Boston
E D - Cantridge (2 GC,4’IS)
GCA — Bedford
GTE - Waltham
Vernait
Aqua-Tech - Burlington
*GC/ 4S to be delivered in May, 1981; trained operator already on staff.
—20—
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pra tes efficiencies in the environmental agency’s planning acti-
vities. Again, contract agreements could provide the avenue for
establishing coordination between the contract lab ar.d state per-
sonnel.
(4) Cost considerations — At the state level, the costs of private con-
tracting are a particular concern. As noted before, all local state
labs have authority to contract, but no established contract bud-
gets. Connecticut, New Hai shire and Rhode Island also indicated
they prefer to cor uct analysis in-house when a large nuirber of
sa1T ples are involved and they can reap economies of scale. Better
definition of analytic needs could help states control unnecessary
costs. By consolidating their requests for analysis, states may
also be in a better position to take advantage of discounts which
many private labs offer to customers with large volume orders.
Relying on a third party (e.g., New Englar 3 Interstate) for contract manage-
ment could relieve sone of the administrative burden on states. The third party
could be responsible for certifying a group of reliable private contractors,
developing expertise in project management arid coordinating quality control pro-
grans. EPA prc ram grant funds can be used for contracting where the states
sh z that contract rk is not duplicative of state rk and that contracts are
used to meet outputs or accoiTplishnents specified in the grant agreement.
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OPTIC S FOR EXPANDING REGIC AL ANAL?TIC CAPACITL
The following options s re explored as possible means of expanding and/or
enhancing regional trace organics analysis capacity:
tion 1 — Expand S&A capacity
Since the S&A lab already has experience and skill in GCAIS work and physical
space to acconitxdate additional machines, S&A could expand its capacity by doubling
GC/HS work shifts and/or adding machines and staff.
The advantages of this option are S&A’s caTmitment to a strong quality assur-
ance program, its established working relationships with state labs, and its cen-
tral location in the region. S&A conducts screening to reduce unnecessary analytic
work and has an enviable reputation with the states for high quality work. Con-
centrating extra regional capacity in one central facility would also eliminate
the need for each state to develop extra capacity to meet unpredictable peak
demands and would encourage the fullest use of expensive equipment. This could
result in a cost saving to the region as a whole.
A primary disadvantage of this option is the absence of a clear line of
federal funding to support lab work for the states. Expanding the regional lab
to production scale to service state needs conflicts with EPA pDlicy and would
eirbroil EPA Pegional personnel in disputes arising fran the need to set inter—
state priorities for analysis.
( tion 2 — Enhance each State’s capacity
1)irthg Analytic Center interviews, state laboratory personnel stated that
they wanted GC4IS capacity “in-house” to assure ready GC,41S availability when
iiwrediate and dependable analysis is needed (e.g., public health emergencies,
enforcement actions, etc.). They also noted substantial advantages to having
GC,44S—trained personnel able to advise program personnel. Each state could
enhance its capacity by a uiring nore GC/MS or, in those states which have
machines, by doubling shifts on existing equipment.
The advantages of this option are that it makes it x)ssible for states to
set their own priorities, provides proximity to sample collection sites, decreases
reliance on the federal government for testing, and spares the Region the necessity
of choosing airong caiipeting state requests for service. It guarantees that states
will bear at least some cost of doing analyses; this will help ensure that only
appropriate analytic work is done. Also, availability of GC,4tS in each state
would provide the region with back—up analytic capability for emergencies.
The primary disadvantages with this option are that it requires expensive
capital investment in machines and greatly increased program expenditures for
trained staff and appropriate lab space. The option would be especially costly
on a per—analysis basis in states which do not yet have sufficient unmet analytic
need to occupy a full GC44S shift. Aoguiring nore staff will be difficult for
states experiencing hiring freezes and double shifting may meet union opposition.
Finally, ready availability of GC,41S may divert state attention away fran screening
techniques, making it difficult for EPA to decide where federal funding assistance
is really justified.
—22—
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Option 3 — Increase reliance on contractor services
Rather than invest in additional equi ent for public labs, the states
and Region I could increase their reliance on the private sector. States
could contract directly or a neutral third party could be assigned to provide
contract management, quality control and scheduling.
The advantage of this option is that it eliminates the need for federal
and/or state governments to invest in expensive equipment. Because of cost to
the states for analyses, only necessary analytic work will be requested. It also
will result in lower costs per analysis for states with limited testing needs.
The disadvantag s are the pcesibility of uneven quality of work, slow turn-
around time, transportation of sanples and limited available capacity, at least
in the short run. Cost per analysis will alttcst certainly be higher than that of
public provision in states with sufficient testing need to fully use an in—house
GC/ 4S. Contract work in the private sector would still require quality control
prcx rans by the states and Region I. Also, unless state personnel are experienced
in GC/ analysis, they will not have sufficient knowledge of analytic procedures
and protocols to provide necessary overview for contract labs. In. such cases,
states will need contract management assistance.
Option 4 — Share state laboratory services
Another alternative to enhancing each state’s analytic capacity is to share
services auong states through interstate contract arrangements by: (a) concentra-
ting specialized analytic capability in state labs according to existing strengths,
(b) having one or two state labs do trace organics and each state do its own
traditional work or c) enhancing one lab to address any increases in demand for
analysis.
Shared services increase the likelihood of full GC/MS use and thereby
lower costs per analysis. This arrangement also pr iotes inter-state reliance
rather than greater dependence on the federal government.
The greatest disadvantage of this option is that possible political problems
nay arise in priority setting, especially when the needs of the state owning the
lab compete with the needs of client states. Clear priority setting procedures
would have to be set out in advance in the contract terma. Also, the option
would require joint purchase of new equip nt or that states sacrifice sare of
their already owned equipment to the shared state laboratory. The same is true
of staff to operate the equip ent. There are no clear lines of federal funding
for such an arrangement. There would also be costs in transporting saii les to
the lab.
Option 5 — Establish a new regional facility
Rather than build on existing labs, the states could pool their resources to
build a new facility managed by a neutral third party.
The advantage of this option is that joint use again increases the likeli-
hood of full machine use and lower cost per analysis. State ownership also
ensures that any cost savings return to the states.
The disadvantages, as in option four, are that states would have to jointly
purchase new equipt nt or sacrifice some of their own equipnent, and resolve dif-
—23—
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ficult staffing probleiTs. Again, there are no clear lines of funding for such a
facility. Also, a coit n venture would require broad political and financial
cc mitnents fran the states which may be difficult to secure. There would be
very large start—up costs in building a new staff and facility. Finally,
political problens may arise in priority setting and regional facility siting.
Option 6 — Increase reliance on university laboratories or other federal
labs which may have excess GCA4S capacity to serve regional
analytic needs.
States could enter interagency agreements with these labs to provide analytic
services or access to machines as needed. H zever, the Regional laboratory staff
noted that a GC44S for “research” purposes (typically found in university labs)
is programed differently from an “off the shelf” GC4’tS as purchased by the Regional
lab .or the states. A “research” GC/MS can use different conputer software as well
as hardware and thus is sometimes not appropriately sensitive to perform trace
organics analysis as required by EPA protocols.
The advantage of this option is elimination of state need to invest in
expensive equipment.
The disadvantages of this option are high cost per unit of analys , limited
availability of machines which are not fufly dedicated to other work, and a re-
luctance by university and other federal labs to take on hazardous waste testing.
Probleme in priority setting could occur with competition from primary clients
and state environmental agencies would lack direct control over analysis.
Option. 7 - Retain Status Quo
The major difficulty with the current system is that the workload is rapidly
saturating all available capacity.
Option 8 — Conbination of options 1, 2 and 3 and other findings from
the report
This is the option reconuiended to satisfy the si-ort term needs of the region.
The option is discussed under “Recanmendatiorts”.
—24—
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The problem of regional analytic capacity will continue to require attention.
The following recommendations are provided based on suggestions of interviewees,
reviewers and the Analytic Center:
A. R corritendations for Enhancing G IS Analytic Capacity
1) ImprOve Methods of Predicting Regional Analytic Needs
TO assist in planning to flEet regional analytic needs, the Regional lab should
continue in its efforts to seek projections of analytic demand from state and EPA
regional program offices as well as Heaô uarters. Because the Regional lab will
not have sufficient resourcEs to respond to all state requests for analyses, it
should continue to concentrate efforts on those requests which constitute iirmediate
public health threats.
2) Screen candidate samples for trace organics analysis
S&A should encourage all states to enploy technical procedures for “screening”
candidate sairples for trace organics analyses. Using these procedures, states can
refrain from analysis of those samples which show no indication of a problem, and
thus greatly reduce the aim unt of GC/ 4S work needed. A ta’ s failure to use
such procedures should militate strongly against EPA provision of additional
financial and analytic support for trace organics analysis.
3) Establish GC/MS capacity in each State
Region I should assist states lacking “in—house” GC/MS capacity to acquire
it. Although available EPA. grant n ney alone is not sufficient to finance GC/tlS
purchases, Region I can take steps to help states acquire funding from other
state and federal sources. For example, the Regional Administrator could, upon
reqi st, present governors, state legislatures and other federal agencies with
evidence of testing needs and recc!nnendations for new or additional equipment,
space and staff. Only by having their own trace organics analytic capacity can
states be assured of its availability when high priority emergency needs arise.
States are concerned about allowing priority setting decisions to be made outside
of their control (e.g., by S&A, some other regional facility or contractor’s
schedule). In addition, states are not eager to use their EPA grant ironies to
establish a regional lab center outside their jurisdictions.
In—state capacity assures reasonable proximity of labs to sample sites. This
arrangement will allow for frequent interchange between lab and field sampling
staff, thereby focusing sampling efforts and eliminating unnecessary sampling
and analysis. Physical proximity of labs to sample sites is also inportant in
handling quickly deteriorating samples of hazardous and toxic wastes. With
“in—state” capacity, states can set testing priorities and control sample turn-
around tine. States can also control the quality of analysis and have ready
access to expert testiffony if needed in court.
4) Use double shifts before acquiring irore than one GC,4 1S machine per state
As testing needs increase, both the states and the EPA Region I lab should
use double shifts to increase production from their existing GC4IS equipment
before acquiring additional machines. (S&A is currently using one of its two
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machines on two shifts and Massachusetts will add a second shift early in 1981.)
As the cost of analytic time from a second GC,4tS shift is approximately 30 percent
of the average cost of analytic time from a first shift, it is economical to use
double shifts where equiprent is available.
5) Rely on private labs as needs escalate
As state and EPA regional needs for GC/ work increase beyond the analytic
capacity of state and EPA machines operated on double shifts, the region’s labs
should rely on private contract labs for analysis.
Available (i.e., not carinitted under contract) GC,41S analytic capacity in
the private sector is 1iJ e1y to increase. Private labs in the region have been
very cautious about expanding organics testing capacity, however, they are eager
to do so when there is a clear indication that sufficient analytic demand will
exist to auortize their investments. The private sector will need six to nine
ironths before equipment delivery, machine debugging and analyst training are
canple ted.
As the states reach their capacities, states will need to establish their
contract administration and quality control procedures for contract work. Although
states with GC/ 4S capability can manage their own oversight, consideration should
be given to organizing a cOnsortium of states to facilitate contracting, perhaps
eirploying a third party (such as New England Interstate Water Pollution Control
C n.ission) to negotiate contracts. LcMer costs may be realized by consolidating
states’ requests for analysis.
The EPA Regional office should offer assistance in developing contracts and
explore avenues for using EPA grant funds for contracting. The EPA Regional
laboratory could help states in determining the capability of private labs and
in establishing quality control procedures.
6) Continue S&A support to the states
S&A should continue to assume a strong educational and support role to Region
I states to the extent that regional budget resources allow. Although New England
is fortunate to have state labs which are very caTpetent, all state labs require
accelerated quality control and technical assistance as the need for their services
increase. Until state and private laboratory capacity fully materializes, states
will continue to need analytic assistance in sare emergency situations.
States also request that EPA Region I provide an increased level of direct
analysis when car lex pollution probleire and/or developing protocols are involved.
This arrangement would make it easier for the states to meet other needs for trace
organics analysis. However, EPA and Ct4B policies to provide resources to state
agencies or to rely on the private sector may preclude any significant increase
in direct analytic support fran EPA.
7) Increase reliance on EPA national contracts
EPA Region I should encourage EPA Heaà uarters to expand the scope of national
laboratory contracts to allow for nxre state work referred through EPA Regional
laboratories. Heaã uarters’ Oil and Special Materials Control Division is already
exploring this possibility. Under current proposals, EPA Regional Offices would
be able to refer state saxTples when state and EPA labs were overcomitted or other-
wise incapable of conducting the necessary analysis. ‘PD ensure that states have
access to these services on an equitable basis, criteria should be developed for
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accepting state requests. In addition, EPA Headquarters should develop a quality
assurance program acceptable to the users.
(Ed. Note) It might be possible to discontinue the EPA national contracts
and redirect the contract funds to the Regions or to the States. The director
of the S&A laboratory feels that S&A rnanagen nt of regional contract funds would
result in provision of higher quality data that is rtore responsive to regional
needs.
B. Recarn ndation for Preparing for a “Worst Case” Situation
It is possible that Region I could face a “worst case” situation of the
magnitude of Love Canal. The Regional Administrator should be prepared with an
internal action plan to respond initially to the level of testing needs which
would be required in such an energency. ‘While it is hoped that Headquarters
will be in a position to assist if a “worst case” occurs in the region (either
through Superfund or the concentration of National Contracting efforts to a
specific regional problem), the occurence of several “worst case” situations
sintiltaneously around the country, although extremely iirçrobable, could make it
essential for the Region to be able to take action in the short run. If all
states in Region I had a GCAIS, a reserve analytic capacity of kncwn quality
would always be available. This is an invaluable resource.
The Region should consider preparing a “contingency” plan with all the
New England States (possibly using a third party such as the New England
Regional Catinission or the federal/state offices of emergency preparedness) in
advance of a “worst case”. The Regional Administrator should be fully aware of
all regional testing capacity (state, S&A, university and private) which could
be nobilized on short notice. Elected officials and the public will need to be
shown that the Region can nobilize federal (i.e., FDPA, Corps of Engineers, etc.)
and state (i.e., environmental agencies, public health, etc.) efforts to address
a crisis situation.
C. Recatitendation to Seek Other Funding Sources
All possible avenues of funding should be explored for provision of analytic
services. For exanpie, the possibility of National Science Foundation ( F)
or Health and Human Services (HHS) funding for machinery for a regional service
has been suggested. In states where public health and environn ntal analytic
facilities are located in one laboratory, the environmental progran frequently
benefit frau the political strength of the public health programs’ efforts to
expand service. Once the states with lower projected testing needs (New Hai shire
and Ve tont) have acquired their requested GC/ 1S equipment, they may be in a
position to assist states with higher potential needs (Massachusetts and Connec—
ticut).
Some EPA grants may be used for contract dollars. For exanpie, St A funds
may not be used as contract dollars for routine nonitoring work, but can be
directed to ccir liance spot checks, emergency work, and/or special survey work.
On the other hand, SlOG noney under the Clean Water Act can be used for routine
nonitoring of surface water quality as long as that work is not duplicative of
other state work.
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APPENDIX A
PROFILES OF LABORATORIES SERVICING
NEW ENGLAND STATE ENVIRONNENTAL PROGRAMS
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P )FILE OF ( )NNECTICUT’S E2 1VI )NMENTAL LABORA IOPY FACILITIES
I L BORATtRY FACILITIES
A. Location
Laboratory facilities currently used by the Department of Environmental
Protection (DEP) in Connecticut are the State Department of Health Laboratory
in Hartford and the Water Resources Laboratory of Wesleyan University in
Middlet n, Connecticut.
B. Capabilities
The laboratory of Wesleyan University has capabilities in conventional
chemical analyses. The DEP and its predecessor agencies have cOntracted with
the Wesleyan Laboratory for wet chemical analysis for 40 years. The Department
of Health (tOH) Laboratory is the major health and environmental laboratory
in the state. It lacks GC/MS capability but has capability in environmental
microbiolc y, and in sanitary and environmental chemistry, including water,
sewage, and sludge testing for pollutants. The laboratory has air and toxic
hazards capabilities as well as a broad range of radiochemistry capabilities.
It has pesticide and PCB analytic capabilities.
C. Personnel
The IX)H laboratory has a personnel ceiling of 195 state—funded positions.
As well, it has 10 positions funded through the Center for Disease Control.
An additional 10 positions are funded by other programs, including 2.5 work
years provided by the Safe Drinking Water Act. Of the 215 total positions,
36 are in the Environirental Chemistry section and 8 are in the Environmental
Microbiology section.
D. Relation to Environmental Agency
The DEP, through its ccxtinissioner, is responsible to the Governor of the
State. The LX)H Laboratory is located in the Bureau of Health Proitot ion and
Disease Prevention, reporting through its Deputy Cormdssioner on A ninistra—
tion to its Ccztinissiorier, also responsible to the Governor. Thus, there is no
loi ier level of authority than the Governor’ s Office with line authority over
both the environmental agency and the major laboratory on which it relies.
C€P does not have control over the priorities given to its sair 1es relative to
saxm les taken for health programs. Men randa of Agreement exist between DEP
and 1 H on those issues.
II JNDI
A. Budget Size
Total laboratory expenditures reported by the t DH Laboratory in the Center
for Disease Control Report for the Association of State and Territorial Public
Health Laboratory Directors submitted in November 1979 were $3,824,259. The
report also considered units of analysis by relative value, giving a sum of
$1,483,215. The laboratory allocated 424,963 of the units for environmental
work, suggesting an environmental laboratory cost of $1,095,355.
A-i
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Laboratory personnel feel current funding is inadequate to meet the volume
of requests for services. While no work has been refused yet, it is difficult
for the laboratory to reduce its backlog. While sunmer workers and resche-
duling have provided “extra hands” during the summer ntnths, there is uncertainty
about personnel availability in the fall.
B. Cost Changes
In three years there were two major increases in personnel wages in the
State: a 7—8% per annum cost—of—living increase, and a reclassification and two-
step upgrading of state postions. These changes resulted in a total increase
in nominal dollar wages paid of approximately 35% over the period, for the
same positions. In addition, individuals have received longevity increases.
C. Capacity for Provision of GC/MS Capacity
Connecticut will have an “advanced” GC/MS by January, 1981.
The average costs of establishing a GCAIS capacity are discussed in the
Overview section of this report. The costs in Connecticut will be slightly
higher than the average, as its personnel costs are higher than average. To
establish one shift of capacity will cost $38,180 in personnel expense — the
chemists involved will be paid $14,311 and $13,000, and there is an additional
cost of 28.5% for fringe benefits and 11.3% overhead. A second shift could be
added for the provision of one additional chemist, at the $14 ,3l1 wage, plus
10% night differential, 11.3% overhead, and 28.5% fringe benefits, total $21,440.
The other costs of machine capacity provision would be similar to the
average, so the total cost per year for the provision of one—shift capacity
would be $78,180. This is a per—shift cost of $390, close to the current
contracted cost of private provision. However, laboratory personnel believe
that sufficient need exists in the state to justify a two—shift operation. A
two shift operation would cost on additional $21,440, for a total cost of
$96,620. This is a per—shift cost of $250, less than the cost of private
provision.
D. Funding Path
The laboratory has 195 state—funded positions and receives a $100,000
appropriation directly fran the legislature to buy equipment for all sections
in the laboratory. Conpensation from the state for services rendered to other
state agencies is through the transfer of funds. While DEP formerly paid for
its laboratory services (arrounting to $250,000 this year) by providing people
and equi *i nt to 1))!, it stopped doing so when its appropriation was cut. The
)H lab continued to provide services, though. At present, there are no DEP—
funded positions in the laboratory. DEP “owes” the general fund for services
the Health Laboratory has performed at its request.
Other than the purchase of an automated analyzer two years ago, lab personnel
did not identify EPA funded laboratory equipment purchases. The Water Quality
Management 5—year needs assessment docunent, hcxm ever, shows $270,000 funding
fran EPA for FY 80 and projects need for $2,300,000 from EPA for equipment and
building in 1981—84. EPA grants are not provided directly to the laboratory,
but are channelled through the environmental program offices.
A-2
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III CURR T SERVICE PIOVISICt SIWP TICN
A. Service Users and Trends
In addition to DEP, other offices relying on the laboratory for services
include all local health departments and water supplies, both municipal and
private. The laboratory anticipates rtore requests for analytic services in—
volving testing for toxic substances, metals, and hydrocarbons. To increase
productivity will require ITore equipment. Also, as the “state of the art”
continues to evolve, successful court cases will require more GC,41S evidence
as a basis for action.
B. Contracting Possibilities
The laboratory addresses nearly all service requests by itself. It has the
authority to contract out work and occasionally does so (e.g., some herbicides
work). As there is no budget for contract services, the work is financed by
suheiitting the bills to the requesting agency.
The WH laboratory personnel do not believe contracting out is a viable
option for Connecticut. First, the laboratory ‘s costs, as shc in in their
yearly reports to the Center for Disease Control, are l .z co pared to those
of private contractors, so it does make sense to encourage the agencies to
contract out. If there is any volume of demand for a test, the laboratory
would prefer to set up procedures and do the work itself. Second, the avail-
ability of ccitprehensive private laboratory services in Connecticut is limited.
Providers are small operations unable to expand their capacities. There is
neither the volume nor the potential for profit to encourage contractors to
develop capacity to do the routine, time—consuming analyses. Quality control
is another factor in the laboratory’s reluctance to contract out. Given the
state’s need for evidence which will stand up in court, the laboratory feels it
cannot risk using data of questionable quality.
C. Testing Priorities
The Director of the Health Laboratory sets priorities among the agencies’
requests for services. The process is institutionalized to the extent that
memoranda are sent to program directors. These memos have been an itrportant
priority setting tool, helping the laboratory sort out requests and control
its backlog. Laboratory personnel feel cominication with program directors
is good and that in rovement in the priority setting process was a matter of
discussing the prcble n with the agencies and making sure that they kzxz i the
rules of the game. The agencies have been asked to set their c m program
priorities and limit their requests, recognizing that the laboratory can only
do so ITuch. The laboratory is giving eii hasis to properly planned studies
with a greater attention on sample quality. They want service requests which
“cut out the junk” and leave them more time to do the necessary work. The
laboratory also requires notification of any expected increases in workload
fron an agency. As a general rule, the laboratory’s policy is first in, first
out except in emergencies.
Solid waste, sewage, and drinking water have separate benches in the lab-
oratory. Personnel indicated that hazardous wastes work has not displaced
other analyses in the laboratory, but has merely added to the total workload.
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IV EPA RELATIC SHIPS
While the laboratory has not referred service requests to EPA, it has
sent a chemist to use EPA’s Regional lab equipment at Lexington. Similarly,
the EOH lab has used the facilities of the FDA lab in Boston. Overall, the 1 JH
laboratory is satisfied with the quality and timeliness of technical assistance
frci n EPA.
Laboratory personnel discussed the changes made by EPA in certification
pro dures which they described as “arbitrary” ar maintained that the standard
deviation scale of acceptable performance was adjusted without clear notice to
the state laboratories.
A-4
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PW)FILE OF INE VI 1EN’Th.L LABORATORY FACILITIES
I LABORATORY FACILITIES
A. Location
The major environmental laboratory in the state of Maine is the Division of
Laboratory and Field Services (DLFS) within the Bureau of Water Quality Control.
The Bureau of Air Quality Control has its own laboratory. In addition, the
Bureau of Human Services supports the environmental laboratories on a fee—for-
service basis when DLES lacks a particular analytic capability.
B. Capabilities and Personnel
The DLFS laboratory has capabilities in GC and GC,4’IS for use in analysis
of trace organics. It has capabilities in the conventional chemical and physical
analyses for environmental pollutants, bacteriological testing, IR, tJV, AA,
fluorescence and metals.
The air laboratory activities include field auditing, calibration, and am-
bient n nitoring. It is currently engaged in fuel and air analyses on waste oil
burning in the state. The air lab also conducts wet chemistry analyses on bubble
boxes for chlorine, nitrates, arsenic, lead and sulfates. All trace organics
work for the air lab is done by DLFS.
The DIES has an authorized staff of 8. At this time its staff consists of
5 analysts, and the Director. It has 2 vacancies for lab technicians. The air
laboratory has a staff of 3. The Public Health Laboratory has a staff of approxi—
mately 30.
C. Organization
DIES is located within the Bureau of Water Quality Control of the Department
of Environmental Protection and reports to the Bureau Director. The Division
laboratory provides services to the Water, Land, and Hazardous Wastes Bureaus.
It also provides some services to the Air Bureau. The Public Health Laboratory is
located within the Department of Ht.mian Services and provides analytic services
for the drinking water and pesticides programs.
II UNDD
A. Lab Budget
The total laboratory budget is approximately $200,000. Laboratory person-
nel state that current funding is inadequate to meet the voluzre of requests for
services. The lab’s functions have been shifting over the past two years toward
fore expensive work. While previously 100% of the lab’s effort was devoted to
traditional types of analyses, at this time 50% of its efforts are devoted to
non—traditional types of analyses, e.g. trace organics. Some of this shift has
care at the expense of the traditional work.
B. Cost Changes
The increase in state laboratory costs are evidenced in rising wages
A-5
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and cost of equipment. The wages of lab enployees have been rising at approxi—
mately 12% per annum. This increase is due to annual 7% yearly across the board
cost—of—living increases and to 5% merit raises for alrr st all continuing
employees. Since turnover at the lab is low, most lab employees qualify for the
merit raises. Increases in equipment costs have resulted from inflation and
technical progress.
C. Capability Maintenance
Two years ago, the lab had virtually no non—traditional pollutants capacity,
but at present about half of the lab ‘s time is devoted to these new testing areas.
The laboratory Director noted it has become itore costly to maintain complete
analytic capability . Because the lab “got into the business late”, its space
was laid out to acco modate traditional capabilities and has to be adjusted for
the requirements of the new procedure. Since the lab is already very nuch smaller
than it should be for the work it does, any increases in CC/MS capacity will
require expansion of the lab’s physical size.
D. Cost of Addition to GC,41S Capacity
Maine has an intermediate—capacity CC/MS. This machine has a replacement
cost of approximately $90,000. The lab has a staff of only six analysts, and
its Director feels that this indicates that double shifting is not an option.
He feels that for safety and other reasons there should be at least two people
in the lab at all times if there is anyone on it.
On the other hand, the laboratory is desperately crowded in its present
quarters, and noving two people to an evening shift would help correct the situa-
tion. The general assumptions involved in calculating the cost of capacity
provision are discussed in the Overview section of this report.
The cheapest way to increase CC/MS capacity in Maine is to put the state’s
GC..44S on a double shift. This would require hiring one additional chemist and
diverting a fraction of the time of one technician. It would cost $20,000 in
wages, another 25% fringe benefits, and approximately 10% shift differentials.
This would be a total of $27,000, or a cost for the additional shifts of $134
each. At two samples per shift, the per sample cost would he approximately $67.
E. Funding Path
Located within the Department of Environmental Protection, the laboratory is
funded in the Department’s budget, by a grant from the state legislature. EPA
grants are channeled through the state program offices. Laboratory personnel
noted they have no direct lir k with EPA; DEP management allocates federal funds
received by the agency. About 50% of the lab’s operating budget is financed by
EPA Clean Water Act grants. In addition, EPA has been the major source for
equipuent funding, supplying nore than 50% of the funds for the lab’s capital
expenditures. Air and RCRA have allocated no funds to support the DLFS laboratory.
Other than an average 10% yearly increase in nominal dollars, the lab’ s
budget has not changed significantly over the past five years.
A-6
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III CURRENT SERVICE PFOVISICN SI’UJATICt 1
A. Service Users and Trends
The laboratory provides services to the Air, Water, and Hazardous Waste
Bureaus within the DEP. While about 95% of the lab’s tin is divided between
1 RA and the Clean Water Act prcxgrarns, the hazardous waste work is an increasing
priority. Since there is r direct RCRA funding for this lab work, it is
currently su orted by the state through the water program. The lab antici-
pates hazardous waste work will have a substantial impact on the availability
of its trace organics capacity for other prc rarns.
The lab addresses virtually all of the service requests it receives by
itself.
B. Contracting Possibilities
Within budget limits, the laboratory has the authority to contract services.
The lab Director has the authority to spend itoney fran a “professional services t ’
line item in the budget, to finance contract work. Because there is a $5,000—
$10,000 limit on the arrount of funds in this budget item, contracting is limited.
If a “big task” requires contract services, the Director will request additional
funding from upper managerrent.
The laboratory’s Director feels that routine, tirre—consuming, high voluire
analyses perforxred by the lab could be contracted out without loss of quality,
but only if the quality control is “built in” to the contract. He is skeptical
about contracting out the iiore sophisticated testing, and feels it is irore
appropriate to assign the lab’ s own people to the nore difficult analytic
demands.
C. Testing Priorities
The laboratory’s priority setting process is an informal one. Priorities
anong service requests are established “at the first level” by the analyst and
the sample gatherer. Those dissatisfied with the staff’s decision can work
their way “up the ladder” from the analyst, to the lab Director, to the Bureau
Director, to the Coninissioner. In establishing priorities, the laboratory’s
instinctive reaction is to give primacy to public health considerations. Tech-
nical screening and political considerations are other criteria e ir loyed in
the process.
The lab Director described the current priority setting process as the
only practical one. He prefers that issues be resolved amicably at the staff
level, rather than invoBiing upper managerrent in priority setting.
As hazardous waste work has become a top priority for the lab, it has
tended to displace the irore traditional lab work. The laboratory has instituted
a nonthly ceiling to protect traditional programs, and refuses to accept any
nore hazardous waste samples after its capacity for them is reached in any
given nonth.
A-7
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IV EPA RELATICt 1SHIPS
Because it recognizes the magnitude of the demands being made of S&A,
Maine’s laboratory attempts to minimize its requests for S&A assistance. For
the nost part the lab looks to S&A for training and consultation setvices. On
occasion, such as when equip nt is unavailable or the GC/ 4S procedures are
poorly defined, its Director will ask S&A to do salte analyses. The Director
is satisfied with the quality and timeliness of services provided by EPA. and
praised S&A’s willingness to take Maine’s trainees “under its wings.”
The Director would like to see increases in general inf oimat ion exchange
with S&A (because of DLFS’ location in Augusta, it is geographically isolated
frm peer laboratories) and ITore quality control. The Director also wishes EPA
had nore capacity to handle requests for direct analytic assistance.
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P FII.E OF SSACHtJSETrS VII NMENTAL LA3DRA IORY FACILITIES
I L1 BORA’KRY FACILITIES
A. Location
Massachusetts has major environmental laboratory facilities at Lawrence and
Tewksbury with subsidiary environmental laboratory facilities in Amherst and Lake—
yule. Some laboratory work is done by field personnel frcrn the Massachusetts
Department of Environmental Quality Engineering Regional Offices (DEQE).
B. Capabilities and Personnel
The Lawrence Experiment Station (LES) is the major support lab for the Divisions
of Water Pollution Control, Water Supply, Hazardous Waste and Air Quality of the
Massachusetts DEQE. The laboratory conducts hazardous waste, water and pesticides
analysis as well as some specialized analyses for the air program. The laboratory
has capabilities in ir st of the conventional pollutants for the traditional programs:
bacteriological tests as well as in tests for levels of chemical and physical para-
meters. The LES also does some quality control work for the other states through
a reciprocal agreement.
The Lakeville and Amherst labs are very small and subsidiary to the LES.
These labs perform water analyses such as pH, temperature, and microbiology
which are better done near the site of sanpie collection, and some rudimentary
hazardous waste work. The Tewksbury laboratory specializes in air sample analysis
serving the arrbient air program of the State. The Tewksbury lab also does calibra-
tion for criteria pollutants ironitoring under the air program’s quality assurance
program.
Though the LES is equipped to do exotic analytic work, staff size and expertise
are limited. The laboratory is understaffed to meet the analytic demands of its
historical programe, let alone to meet the needs of the new hazardous waste and
organic contamination programs. It is difficult for the State to hold its personnel,
as wages at the LES are l er than wages for comparable work in private industry
or the federal government. Capabilities include: volatile organic analysis (VOA)
with the gas chrat atcgraph/mass spectrograph (GC,41S), volatile halogenated organics
(VHA) with the gas chromatograph, and pesticides and polychlorinated biphenyls
(PCBs) with the gas chranatograph. The lab recently analyzed 730 water samples
for tetrachloroethylene ( E) using the gas chromatograph. The LES has 26 3/4
rkyears of analytic personnel and 14 1/4 working years of support staff personnel.
The Lakeville laboratory has one analyst arid the 1 itherst latxDratory has 3 analysts.
C. Organization
The long arid distinguished history of the Lawrence Experimental Station is
helpful in understanding its relationship to the environmental programs and its
ixidgeting arrangements. This was the first irrportant sanitary engineering experi-
mental station in the nation and became an analytical arm of the Conaronwealth of
Massachusetts in 1886, funded through the public health fund. During the 1950’s it
entered into an agreement with the State Legislature and became solely a sanitary
engineering laboratory having previously responded to all kinds of public health
arid engineering needs for the State. It existed before the Environmental Protec-
tion Agency or the DEQE and was funded out of the state general fund. It has been
funded as a Division of the DEQE since the Reorganization Act of 1974.
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The DEQE operates satellite labs at M herst and Lakeville. These services are
directed on a day-to—day basis by DEQE Regional engineers within the framework of
overall support and direction fran the LES.
Most LES eirphasis is on support to the DEQE Division of Water Supply, Hazardous
Waste, Water Pollution Control, Air Quality and Waterways. In addition, a small
fraction of its work is support for environmental programs located in other state
agencies. For example, the lab provides NPC€S analysis on sewage treatment plants
for the Department of Public Health. It analyzes well water for the Office for
Children when it wishes to place foster children in a hare with its n water supply.
It also serves the State Depar ent of Agriculture and provides analyses for the
Department of Environmental Management (State Forests).
Five of the personnel at the LES are funded by other programs and are on detail
to the laboratory. ‘I\ o are chemists fran the State Air Program and three hold pos i-
tions funded fran the Aáninistration account of the Bureau of Environmental Sanita-
tion. The latter account also funds two chemists at the Miherst subsidiary lab.
The other chemist at the Amherst subsidiary lab as well as the chemists at Lakeville
are funded through the LES’ operating budget.
II 1NDTh13
A. Laboratory Budget
The Director of the Lawrence experiment station requested a State budget of
$782,034 for FY 81. The budget recorrurended by the Governor is $755,000, and this
was the ailcunt which was passed by the Legislature.
The lab’s reconrended $782,000 budget included staff salary, contract services,
utilities, travel, maintenance equipment, and rental. It did not include capital
maintenance, building rental, fringe benefits or pension obligations. (The Carnion—
wealth cMns the building outright). It also did not include the 5 LES positions funded
through other programs at $103,000, nor the 2 positions also funded through another
program at $29,000. Thus, the lab’s total proposed budget for FY ‘81 was $914,000.
The current budget for Lawrence station analyst salaries is $559,000; the budget
for support staff salaries is $154,000. The nonsalaries budget is $170,000. Capital
outlays are funded separately and infrequently through the State Legislature. This
year they have been funded to the extent of $80,000 for a new roof. The last previous
substantial capital outlay budget was 10 years ago when the oil tanks for the building
were replaced. Fringe benefits funded by the state are given by DEQE at 28.8% of
salaries, so total cost attributable to the lab for this year is $1,222,000.
B. Cost Changes
Driven by inflation, lab costs have risen in every expense category. Staff
salaries have risen nr st slc dy but chemicals, glassware, media and maintenance
have skyrocketed. Maintenance costs are nc generally $40-50 per hour for personnel
tiire plus dcxnicile if the mechanic comes fran out of the area. A maintenance call
on a major piece of equipment can easily cost $1,000. The lab has responded to this
situation by using its equipi nt very heavily, thus its instrurrentati.on has
received accelerated wear.
The laboratory* s budget had teen relatively stable for a number of years until
1980 when the appropriated budget rose from $558,000 in 1979 to $637,000 in 1980.
A-lU
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This increase reflected the provision of 4 new positions for trace organic chemical
analysis and the leasing of a GC/ tS, also for trace organic chemical analysis.
Other budget changes have been incremental and inflation driven since 1972.
C. Capability Maintenance
The laboratory Director stated that it is difficult to keep up with increasing
demands for trace organics analysis. Without adequate capacity, his lab faces a
crisis each tiii samples arrive for trace organic analysis. At times samples are
stored without analysis because there are not enough people and equiptent to do
the work. The Director has sought to continue meeting the analytic requirements
of traditional programs. The added burden of hazardous waste samples has required
the establishment of a priority assessment system. He feels that current funding
level is barely adequate to handle current programs, and that EPA and/or the states
should provide trore rroney to enable the LES to handle the influx of hazardous
waste samples.
The LES does not have the capacity to do acid extractable or base neutral ex-
tractable GC/ 4S work. When analysis of extractables is needed, the State seeks out-
side services. The LES however, has rarely contracted for analyses by private labora-
tories.
The Director is unable to supply Amherst and Lakeville with equipment for gross
screening of hazardous wastes samples, i.e., flashpoint field analyzers, pH analy-
zers, headspace gas chrc atographs. The proposed 1982 budget for LES includes pro-
visions to establish hazardous waste screening capability at Lakeville and Amherst.
This capability will enable regional hazardous waste coordinators to screen samples
before sending them to the LES, thereby reducing the number of analyses required by
IES.
D. Cost of Adding to GCA .IS Capacity
As Massachusetts has an intermediate—capacity GC/MS, the cost of adding to its
capacity by running the machine for two shifts a day would be low. It would require
hiring one additional chemist, arid diverting of some support staff tiire, approximately
half the wages of a technician. The total cost would be approximately $30,000 a year,
and the cost per shift approximately $149. The Deputy Corrunissioner of DEQE reports
that the laboratory plans to use its GC/MS on a double shift arrangement by early in
1981.
E. Funding Path
DEQE funded two laboratory Chiefs arid an assistant chemist through Section 105
Air Grants arid Safe Drinking Water Act, another EPA funding source. The Tewksbury
air lab is wholly funded through the 105 grant. The Safe Drinking Water Program
funded 6 manifolds for the labs membrane filter and a gas chromatograph 3 years ago.
Historically, EPA has provided very little funding to the laboratory. However,
the five year needs projection which has been provided by the laboratory for 106
grant planning asks for $195,000 worth of laboratory equipment during fiscal years
1980—84, and 27 work years for lab and field work.
III CUBRENr SERVICE PRDVISICt’ SI’IUATION
A. Service Users and Trends
Nearly 100% of the analyses for the environmental programs are conducted by
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the Lawrence experiment station. A very few are referred to the Region I S&A
laboratory. However, those which are referred to the S&A laboratory are extremely
iirportant to the environmental prcxrams. EPA’s S&A Division assists the LES
quality control effort.
B. Contracting Possibilities
The LES’ Director feels that there is both a need for and a potential advan-
tage to contracting out testing for organic materials, given the economies of
testing for non—purgeable corrpounds with the GC/ 1S. Consequently, for 1981, he
has obtained an additional $20,000 contracts budget to send complicated organic
analyses to private analytical laboratories. It is his hope that this new Troney
can be pooled with some monies from existing environmental programa to provide
funds for contracting out a nurrber of samples. The Director will administer the
contracts budget.
The Director provided EPA with estimated corrparative costs of running certain
tests in his laboratory and contractor laboratories. The estimates for work done in
his laboratory were uniformly lower than the prices he gave for having the same work
done in contract laboratories. Because of the difference in cost, the Director sug-
gests that the state lab conduct tests in which it already has established competence,
and contract out some of the more exotic tests. Private labs may be able to apply
econanies of scale to non—VO CC/MS work which the state lab cannot realize. It
is worth noting, however, that state labs are under much tighter quality assurance
observation and procedures than are private laboratories.
C. Testing Priorities
Priorities are generally set on incoming samples by the Chiefs of Laboratory
in consultation with the Director of the Lawrence Laboratory. Their judgement is
sar tixres altered t r reqt sts from other State government officials. For example, the
Division of Hazardous Wastes allocates priority between its samples through a task
force but the priority of its work in general is set by the Chiefs and the Director.
However, urgent requests from officials higher in State government can change that
priority.
The Laboratory Director described the lab’s primary considerations in order
as follows: public health considerations, political considerations and technical
screening. The Director felt that priority setting could be improved if there
were better conitunication between the program directors and the laboratory analysts.
Witbout such coordination, there is a real danger of swanping the laboratory with
samples. In this context he felt that training should be provided to field per-
sonnel on the best methods for collecting samples and that guides should be made
available to the field personnel on equipment to take on saupling assignments.
This training could avoid the taking of unnecessary samples which tax the
lab’s capacity.
The Commissioner of DEQE has stated his intention that the LES shall soon direct
a greater fraction of its effort to applied environmental research and to the certi—
ficati n of private environmental testing laboratories. Areas of effort may include
fate and rate of transport of hazardous waste leachate, etc. This redirection means
that LES will return to local municipalities responsibility for some of the services
the lab has been providing.
IV EPA REEJ. TIC SHIPS
The S&A Division detailed an analyst to the LES for 3 nonths to train its
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personnel in the use of the GC,44S when it was purchased. Training assistance is
extremely useful to the laboratory, either by sending Lawrence staff to the S&A
lab or by having S&A staff in the LES. The training is limited in availability
because of tine constraints and program responsibilities.
The Laborato’s Director stated that EPA or the New England Interstate
Water Pollution Control Coinnission could be extremely useful to the Laboratory
in describing the procedures used in various states for sample collection and
analysis of complicated high priority samples. The Laboratory Director reported
that he was generally satisfied with the quality and timeliness of EPA services
when they were provided. He noted, however, that requests are rarely made.
Recently S&A was unable to provide assistance to LES in analyzing for tetra-
chioroethylene in public water su lies. He noted further that S&A had agreed
to send samples fraiL the Woburn hazardous waste site to a national contractor
to be analyzed for the 129 priority pollutants, and that S&A will do quality
control on all five of these samples. He said, however, that it would take 80
to 90 days to get the results and that such turn—around lags limited the useful-
ness of EPA national contracts.
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PBOFILE OF NEW HAMPSHIRE VI )NM TAL LABORATORY FACILITIES
I LABORAT Y FACILITIES
A. Location
The major environmental laboratory in New Harrpshire is the Water Supply and
Pollution Control Carimiss ion (NHWS&PCC) Laboratory in Concord, NH.
B. Capabilities and Personnel
The laboratory is responsible for the state’s hazardous industrial arid solid
waste, water and pesticides analytic work. It analyzes waste streams, surface water,
groundwater and durrp leachate and has capabilities in BOD, nutrients, bacteriological
tests, and conventional chemical and physical parameters. The lab has no GC/MS but
has gas chratiatoraphs, IR, and an atomic absorption capability.
Because state wages are lc ’ier than the wages paid for canparable work in the
private sector or the federal government, it is difficult for the state to hire and
retain perso inel. While the lab tried to address this problem by hiring personnel
wl-xse degrees are not in chemistry, it has lost a number of analysts to industry.
The laboratory has 14 analysts and 7 support staff.
C. Organization
The Director of the N}IWS&PCC Laboratory, Dr. Donald Bent, reports to the
N} S&PCC Laboratory Committee. The Committee, headed by Michael Donahue, P..E.,
Director of Municipal Services, is conposed of 8 nEirbers, 4 of whom are Commission
Engineers. The caiiniittee sets the policy according to which Dr. Bent directs his
daily operations. Dr. Bent is himself a meniDer of this Committee.
Most state agencies have menoranda of agreement with the NHWS&PCC, regarding
the analyses to be done for their programs.
II FUNDII’X
A. Budget Size
The NH S&PCC laboratory is not a separately funded organization. Its personnel
are employees of the NHWS&PCC so the budget figures given are necessarily approxi-
mate. Michael Donahue reports that the current budget is $405,000 as total expense.
This breaks dc n to $217,000 for fourteen analysts’ salaries, $70,000 for seven
su ort staff salaries, and $118,000 for nonsalary expenses. Nonsalary expenses
were generally associated with equipnent purchases for the organic laboratory.
Gas chranatograph and infra—red equipirent were purchased during FY80, and the pesti-
cides work area was expanded.
B. Cost Changes
The laboratory’s budget has increased approximately $200,000 in five years
reaching the $405,000 figure today. Most of that increase resulted from new program
responsibilities. The Safe Drinking Water Act accounted for approxiately $80,000 of
the increase and pesticides responsibility accounts for approximately $50,000.
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Increases in the laboratory’s cost are attributed to the recordkeeping demands of
the Safe Drinking Water Act, the cost of Irore sophisticated expensive equipment
and the hiring of 7 to 8 Irore people in the past five years.
C. Cost of Estab1ishrr nt of GC/ 4S Capacity
The Chairman of the Laboratory Corrmittee stated that New Harripshire is unwilling
to accept the rental of a GC/MS. The reasons for the NHWS&PCC’s unwillingness to
lease or rent are discussed later in this report under the heading, “EPA Relation-
ships”.
Some of the costs of capacity provision for a GC,kIS in New Hanpshire were
estimated in a June 26, 1980 letter from Mr. Donahue to William Walsh of the S&A
Division. The purchase price of a GC/ 4S is $160,000. Space rental would be essen-
tial in New Haiipshire, where a room is available for $18,000/year. Approximately
a third of the room cost should be irtputed to the GC/MS capacity. The intent is
to run a two-shift operation, and to use personnel currently in place. A chemist
with three years experience and a technician would be required to staff one shift,
at a total salary and fringe benefit cost of $29,956. Operating the GC/MS for
two shifts would require an extra experienced chemist with a 10 percent added
shift differential to bring the total personnel costs to $44,972.
The machine has an expected life of 8 years, and a new machine can be expected
to be functional approximately 80 per nt of the time. A machine maintenance con-
tract can be estimated to cost $8,000/year. Thus, the approximate cost of functional
machine time is $310/B hours for one shift and $196/8 hours for two shifts. This
catpares favorably with the cost of contracting out the work, if there is sufficient
need to use the machine to capacity.
D. Funding Pattern
The laboratory receives state funds from the state legislature as part of
the NHWS&PCC. It has no separate budget. While there is interagency coordination,
nest state agencies have Me iroranda of Agreement with the Corrmission regarding
the accomirodation and priority required of their program needs. All services
provided to other agencies are without conpensation.
EPA grant funds are channelled through the state programe and mist be approved
by the Governor and Council. Approximately 45% of the laboratory’s operating bud-
get and 90% of total equipnent purchases are financed by EPA. The state provides
$5,000 for replacement costs.
III QJRREN SERVICE PI WISICt SflUATION
A. Service Users and Trends
As the central water quality laboratory for the state, the laboratory provides
services for the variety of water programa administered by the NHWS&FCC. Water
program activities assisted by the laboratory include the folk iing:
— NPDES compliance information
— waste load allocations and total maxinl.im daily load investigations
— primary ironitoring network and national water quality surveillance
system
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— primary monitoring network and national water quality surveillance
— national urban runoff program (NtJPP) water quality data
facilities
— radiological monitoring of nuclear facilities
— analysis of individual and municipal water supplies, administration
of the certification program, and monitoring of all treatment facili-
ties under the Safe Drinking Water Act.
— monitoring analyses for inventory work, lake restoration projects, and
eutrc hication studies associated with the 314 Clean Lakes Program
— analysis of oil spill samples for the 311 Emergency Response Team and
the state oil spills prevention unit.
— analysis of stream and ground water samples for toxic and hazardous
waste substances, including pesticide analysis.
In addition to the Department of Agriculture, the Department of Fish and
Game and the Bureau of Solid Waste rely on the laboratory for analytic services.
Non—environmental agencies which depend on the laboratory for support include
the Department of Public Works and Highways and the Public Health and Consumer
Protection Divisions, within the Department of Health and Welfare.
The laboratory is anticipating changes in the kinds and amount of requests
for analytic services from the environmental program offices. More sophisti-
cated testing needs are expected in organics. The volume of analyses conducted
under the Safe Drinking Water program is expected to increase as irore private
wells and non—corrinunity water supplies are sampled. Finally, increased citizen
concern and media exposure are likely to bring more unidentified hazardous
wastes sites to the laboratory’s attention, increasing its sampling and monitoring
workload in this area.
B. Contracting Pcssibilities
There are no other state laboratories available to the environmental program
offices and the water laboratory meets almost all their service requests by itself.
The laboratory does not contract out, either to private firme or to other states’
laboratories, and there is no b get established for contract services. Even if
funding were available, the laboratory feels it would te cheaper to do the work
in—house. The lab’s personnel feel contracting out is not a viable option because
the state has no private laboratory certification program for chemical analysis,
and thus cannot vouch for the quality of results from contracts. They believe
contracting to out—of—state laboratories is infeasible. Additionally, the labora-
tory feels its equipt nt and resources are inadequate to perform the necessary
quality control for a certification program for chemical analysis. In the past,
the N S&PCC has used S&A expertise to evaluate laboratories. Difficulty in trans-
porting samples and time considerations are factors in the state’s reluctance to
contract outside of New Hampshire.
The Director of the Laboratory noted that it would be convenient if the
coliform analysis for northern New Hampshire, required under the Safe Drinking
Water Act, could be done by one of the water districts in the northern por—
tiori of the state. This would require that the district maintain a certified
laboratory.
C. Testing Priorities
Overall policies for the laboratory are set by the head of the Laboratory
Ccziuitttee, the Director of Municipal Services. The priorities for organics
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work are set by the Director of Municipal Services. The priorities for other
chemical, physical, and microbiological analyses are administered by the Laboratory
Director. The criteria used to establish priorities include technical screening,
public health considerations, and level of public interest.
At the suggestion of Bob Thompson, while serving as acting Deputy Regional
Administrator, a 4—Agency/EPA Agreement was entered into establishing a State/EPA
coordinating committee. This new priority setting tool will be used by the labora-
tory to facilitate interagency coordination and promote better communication with
the program directors. The c nittee will include representatives of the water,
air, pesticides, and solid waste programs and will be coordinated by Dr. Spittler,
Director of S&A’ s Technical Branch. The group plans to asserrble quarterly to set
priorities for the laboratory.
An example of how priorities are being set for the laboratory is the displace-
ment of pesticides analysis in order to do hazardous waste work. The EPA Pesticide
Division’s grant was used by the laboratory to purchase equipment, to remodel, and
to hire a chemist to fill an upgraded position. The urgency of the hazardous
waste work and the absence of any RCBA or other form of federal assistance resulted
in the diversion of these resources away from pesticides. The work initially
contracted for is now being done by the lab, as a result of pressures from the
granting program within EPA.
IV EPA RELATICt SHIPS
The training provided by the Region I S&A Division has been useful to the New
Hairpshire Water Laboratory, as has the open request system set up with the Region
I Library. The Laboratory Director spoke highly of the quarterly meetings of the
state laboratory directors which are coordinated by Ed Taylor, head of the Chemistry
Section in S&A. These meetings allow the directors to share analytic questions
and promote frequent consultation.
While the Water Laboratory rarely looks to EPA for analytic services (they
estimated less than 1% of their organic analysis is handled by EPA) its personnel
were satisfied with the quality and timeliness of those services when provided.
While S&A has responded to the Water Laboratory’s requests when “exotic” testing
and difficult analytic problems were encountered, or when there was a serious
public health threat, other requests for assistance, like sanpling and monitoring
of uninvestigated hazardous waste sites have been refused.
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P FILE OF RHODE ISLAND LIA3DR IORY FACILITIES
I LABORATORY FACILITIES
A. Location
All state environmental laboratory capability is located in the State Depart—
irent of Health Laboratory in Providence. Rhode Island has had only one laboratory
since 1966 at which time all environmental departments became part of the State
Health Department. In 1976, environmental program departments were transferred
out of the health department into the Department of Environmental Management in
a major reorganization. H ever, environmental laboratories were not transferred
out of the health department laboratory. tx.iririg the last year a consolidated
laboratory has been built and operations are in the new building at this time.
B. Capabilities
The Department of Laboratory is a broadly capable institution handling food,
drug, disease law enforcement, and environmental rk for the State of Rhode
Island. Its environirental capabilities include water microbiology, airbient air
rr onitoring for pollutant, pesticides residue analysis, conventional and organic
pollutants in water su ly and organics in leachates from hazardous wastes dunps.
C. Personnel
The Department of Health Laboratory has 113 employees.
D. Relation to Environmental Agency
There are meni randa of agreement between the Department of Environmental
Management and the Department of Health and they have no a rrir n superior at any
administrative level below the Governor’s office.
II F iNDI 73
A. Budget
Total budget of the Department of Health Laboratories is $2,800,000. This
bodget has risen fran $1,700,000 in 1974 as the number of employees has risen
frc*n 74 people to 113 people. The arrount of n ney contributed towards the OCR
laboratory b .x3get by environmental prograire is $50,000 from Water & Hazardous
Waste and $200,000 fran Air. The head of the laboratory stated that this anount
of noney does not cover his costs in providing those services to the programs.
B. Cost Changes
Cost increases have been driven partly by wage increases which have averaged
about 7% per year in the last several years. They are increased according to a
fonrula which ties them to to the percent increases in Massachusetts and Connec—
ticut. They have been driven also by increases in the costs for equipnent; k5oth
for the sane sort of equipment as has always been used and by the fact that the
state of the art has been advancing and the same equipment will no longer suffice
for mar y programs.
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C. Capacity for Expansion of Gas Chromatograph/Mass Spec Capacity (GC/MS)
The State Legislature of Rhode Island financed a GC/MS five years ago for
the Department of Health Laboratory and it has been used both for race track
analytic work and environirental purposes since that time. The Legislature
has approved the leasing of another instrument to add to the labs capacity and
the new instrument is to be delivered in September, 1980. Though the lab’s
director stated that he thought both machines would be busy he did not feel
that there was a crisis of unmet analytic demand in the state.
Additional GC/ 4S capacity added through addition of shift personnel in
the DOH laboratory would be arr ng the cheapest new capacity in New England.
Its director, however, stated that there would be union problems in any attenpt
to go to a two—shift operation, with the machines. With the machine already
in place, the cost would be merely the salary cost of the personnel need to
operate the machine. Rhode Island would need to pay the necessary additional
personnel approximately $40,000 per annum, including benefits, leading to a
cost per additional shift capacity added of approximately $180.
1). Funding Path
The laboratory receives state funds directly from the legislatu’re in the
form of annual and special appropriations, and from the state agencies for
which it does work on a contract or “statistical account” basis. Menoranda of
Agreement are entered into with the state environmental program offices to
carç)ensate the lab for its services.
With regard to federal funds, in FY80 EPA did not directly fund any labora-
tory equi rent purchases. Federal funds are channelled to the program offices.
Program offices allocate funding to the lab from their budgets, which include
federal and state funds. As a result of this arrangement, the lab receives
budget anount, and is often given unallocated funds by the agencies at the end
of the fiscal year. The work the laboratory does for the Division of Water
Resources within DE 4 costs far in excess of the $50,000 contributed by the
1 M. Laboratory personnel are Troving towards the generation of defensible
cost—per—test figures. One of the uses to which these figures will be put is
justification of nore adequate compensation for the lab from the DEM for the
work the lab does for DEM.
Fran 1974 to 1980, the laboratory staff size grew from 74 to 113. Over
the same period the total laboratory budget went from $1,700,000 to alntst
$2,900,000, broken down as follows:
State appropriation — $2, 554,870
program office Air pollution — 200,000
contributions Water and hazardous — 50,000
wastes
CDC federal contracts — 80,000
Pesticides residue — 4,000
10’ThL 2, 888,870
The Assistant Director noted the fraction of the laboratory’s budget
devoted to environmental programs has grown dramatically over the last five
years.
Laboratory personnel do not consider the current funding level adequate.
A-l9
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For exarrple, while they requested $200,000 for laboratory supplies from the
legislature, it appropriated $130,000. Since $113,000 was already tied up in
blanket orders, very little remains to address unanticipated needs. Despite
dissatisfaction with its funding level, the laboratory has not yet been unable
to meet any of its analytic demands. This is primarily a result of receiving
surplus funds frcxn client agencies at the end of the fiscal year. Laboratory
personnel feel they cannot do as many sai 1es as they would like to do and
noted that while the mandated environmental programs are not being hurt by
lntu.ted resources, they are restricted in their ability to provide the lab
services necessary to implement recaTirended programs.
III CJBRENT SERVICE P1OVISICt SI IU1iTION
A. Service Users and Trends
In addition to the Health Department and the state law enforcement agencies
the Health Laboratory provides services to the foll ing state environmental
programs: drinking water program (within the Division of Water Supply, Depart-
ment of Health), water pollution and groundwater programs (within the Division
of Water Resources, Department of Environmental Management), and air pollution
and solid and hazardous waste programs (within the Division of Air Resources
and Hazardous Waste, Department of Environmental Management).
The laboratory anticipates increased demand for services from the water
and hazardous waste programs.
B. Contracting Possibilities
At present, the laboratory addresses virtually all of the service requests
it receives by itself. It has occasionally asked S&A for confirmation of the
results of analyses done either by contractors or the Division of Laboratories,
when the results were publicly impugned.
While laboratory personnel feel there is the analytic capability in the
private sector to do routine, time—consuming analyses, they doubted that the
work could be contracted cut without loss of quality (so important for strong
court cases). An exception is in areas where testing needs are small and infre-
quent, (e.g., pesticides). If there is substantial volume in any procedure,
the laboratory is likely to find that the cost of setting up its n procedures
and doing the work carpares favorably with private provision.
While the Health Laboratory has the authority to contract out, this year
there was no established budget for contract services. Rather, blanket orders
— “not to exceed x dollars” are used. Hc ever, if the laboratory encounters a
greater need than anticipated, the blanket order is increased.
At present, the agriculture program within E€M contracts out the analyses
of pesticides for forni.ilation. Other than sending out split samples for
accuracy checks when its accuracy is challenged, the laboratory has
little contact with private laboratories.
C. Testing Priorities
There is frequent ca T irunicatiOn between the laboratory and the program
offices about the lab’s capabilities. The priority setting process is
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institutionalized in that its general rule is first in, first out. The process
is informal in that accommodations are made between program directors and each
director as free to establish the lab work priorities within his program area.
The Assistant Director feels the priority—setting process is adequate and that
cat runicataon with program directors is gocx3. The criteria used in establishing
priorities are, in order of importance, public health considerations, technical
screening, arx3 political considerations.
While there has been a substantial increase in the volume of hazardous waste
work, the flexible arrangement of the laboratory (i. e •, all ing people and equip-
ment to be shifted to meet the workload) and a special state appropriation for
the private well testing program have minimized the impact on other environmental
programs. Laboratory personnel noted though that some programs have suffered
time delays as the hazardous waste workload creates a backlog.
IV EPA RELATI S HIPS
While the laboratory personnel participates in EPA’s quarterly meetings of
the New England Environmental Chemists, there is little interaction with the
other states’ laboratories. The lab does quality control work for the labs of
other states, but this activity is limited because the testing is time—const.nming
and expensive and neither the legislature nor the EPA provide funding for it.
Although the laboratory is adequately handling the routine day-to-day analyses,
its director would like to see the role of S&A enlarged to serve as a resource—
reference laboratory to which states could direct their more serious problems.
The Assistant Director stressed the need to develop standard operating procedures
to n bilize the Region’s or even the Nation’s experts to respond quickly to an
emergency situation.
At present, the laboratory’s “arrangement” with the chief chemist at S&A is
informal. While the relationship with S&A has been good, the laboratory recog-
nizes that S&A t s resources are limited. The laboratory recotr rended expanding
S&A’ s capacity to accommodate the role described above. In particular, the
laboratory feels it will need S&A’ s assistance to handle the major hazardous
waste uncontrolled sites in the state.
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PR)FILE OF VE 4C T VI N €NT L tABDR ORY FACILITIES
I IABORA IORY FACILITIES
A. Location
Vernont has two laboratories with a role in providing services to the en-
vironmental programs. They are the laboratory of the Department of Water
Resources of the Agency of Environmental Conservation (AECL) and the Vernont
Department of Health laboratory (EXDHL). The major role is played by the AECL,
located in 1 ntpelier. The IX)HL is located in Burlington.
B. Capabilities and Personnel
The AECL has capability in bacteriology, conventional chemical and physical
analyses for liquid and solid samples, and air pollutants analysis. It has no
GC,’ 4S, so does organics work with a gas chromatograph. The laboratory has seven
full time analysts, including two coirpliance Tronitors.
When analyses not within the capabilities of the AECL are needed by the pro-
grame it serves, AEXL first calls on other laboratories of the State of Verxtont.
The £OHL has a small GC,44S, with limited capacity and, though constrained by the
demands of its in programs, does analyses for the AEC when able. Other Veritont
state laboratories on which the AECL is able to call are the highway department
laboratory, the agricultural laboratory, the radiological laboratory, the public
safety laboratory, and the occupational safety laboratory.
C. Organization
The AECL is a unit of the Department of Water Resources, Agency of Environ-
mental Conservation.
II FUNDTh
A. Budget Size
The AECL is a unit of the Agency of Environmental Conservation through which
it receives its funding. Thus, budget figures for the AECL are necessarily approxi—
imate. The approximate size of AECL’s FY 1980 budget is $161,000. This includes
$100,000 for the salaries of seven analysts, $44,000 for the salaries of four sup-
port staff and $17,000 for equipment and supplies. These figures do not include
funds made available to the laboratory on an ad hoc basis by the Air Program and
through §208 grant funding for specific projects.
B. Cost Changes
Wages in Vernont have risen very little in the last five years. There was a
six per cent increase in nominal dollar wages last year, but a decrease in real
dollar wages for several years running. The lab’s supply budget has risen $5,000
to the present level of $17,000 in the last five years. Though the budget has re—
mained relatively constant, expenditures have risen due to the rise in equipment
and supply costs.
C. Capacity Maintenance
Although samples are being analyzed, there has been a deterioration in AECL ‘s
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sairple turnaround time. With current funding levels, AECL is unable to expand
existing capacity or develop new capacity. Moreover, the Verrront state legisla—
tire has becai e extremely unwilling to approve increases in government size
unless an agency can derronstrate pressing need to do so. Veriront is the only
New England state with difficulty dramatizing analytic needs. There have been
no major hazardous waste site discoveries, the apparent quality of the environ-
ment is high, and environmental program work is getting done.
D. Cost of Establishing CC/MS Capacity
The AECL has no CC/MS. There is a small machine in the 1)DHE,, which is
largely tied up in meeting drinking water and other health department needs.
ECL personnel feel that there is a need for a mach the in their l boratory,
and intend to aoguire one through a lease—purchase arrangement. According to
AECL, it is unlikely that the Verrront legislature will provide new laboratory
positions or even allow EPA to fund additional personnel for the laboratory.
Consequently, development of GC/MS capacity will come at the expense of ongoing
program needs currently being met by AECL.
Given AECL staffing constraints, the apparent cost of a GC/MS would be only
the lease and maintenance costs of the machine. However, there are other hidden
costs with pDssible machine underutilization and loss of other capacity in the
laboratory. Basically, since there are no idle personnel in the state environ-
mental programs, any tine spent on CC/MS wotk is tine taken from other programs.
The AECL has been offered a full capacity GC,41S on a lease—purchase arrange-
ment at a cost of $3200 per nonth for five years, at a total cost of $192,000.
Assuming a useful life of eight years, this is a cost of $24,000 a year to have
the machine available. Assuming that the machine is operational 80 percent of
the time, it will be available approximately 200 working days per year, for a
cost per working day of $120. Maintenance ty contract would cost over $10,000
per year (AEX2L is intending to pay for maintenance on an as-needed basis), which
could raise the cost of availability to $170 per day. If the machine is used
only part time, the cost of available capability rises dramatically. If the
machine is used half tine during one shift per day, the cost of availability
rises to $330 per shift of use. Consequently, GC,4’4S cost is justifiable only if
the demand exists for full utilization of the machine capacity. The yearly
wages of personnel required to run the machine are $12,000 for a chemist arid
$8200 for a technician. Vernont overhead for state employees is 15%. So we are
talking about an operating cost of $100 per shift. If the machine is used full
tine, allowing for down time on the machine but not for employee training time
and cost, GC/ cost will be $268 per shift. This is less than it will cost to
contract out the sanples.
There is an implicit assumption that there is no cost to diverting employees
from their current duties. The assumption that the machine will be in use full
tiire is crucial. Also, interest costs to the state on the noney involved is
not included here.
E. Funding Path
The laboratory’s funding for supplies and equipment comes directly from the
legislature and through the AEC. Laboratory equi *nent is alir t exclusively
paid for by the Environmental Protect ion Agency through 106 grants. The state
propriation for supplies and equi ent is only $17,000. The laboratory has
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found some flexibility in this last figure due to additional funding received on
an ad hoc basis from the air pollution and §208 water planning prograns.
Funding for salaries, for the nost part EPA dollars, is also channeled through
the state program offices. AECL personnel is 50% state funded, 50% funded by the
S106 program.
III CURRENT SERVICE P VISICt
A. Service Users and Trends
The following environmental program offices within the AEC rely on the labora—
tory for services. The percentage shown indicates the portion of the lab’s total
tine devoted to meeting the program’s requests for service.
Water quality and underground water: 70—75%
Air Pollution 10 %
Solid Waste 10 %
Oil and HM 1%
Fish and Game 1%
Enforcement 1%
Environmental Planning 1%
Environmental Engineering 1%
While the AECL has become ucre of an Agency” laboratory than strictly a water
testing facility, the bulk of its workload is associated with the water prograne.
Another trend noted by AEX personnel was that increases in the airount of service
requests have transformed the laboratory front a seasonal to a year-round operation.
While laboratory personnel are uncertain about the scope of the state’s hazar-
dous waste problem, they anticipate increased requests for organic pollutants analy-
ses. They identified these analyses as the area of their lab irost in need of growth.
The Water Supply Program will require additional analyses for a variety of organic
chemical compounds in drinking supplies from ground and surface origins.
B. Contracting Possibilities
The laboratory addresses about 80% of the service requests made of it. About
1% of the requests are referred to the DOHL. The remainder, primarily requests for
organics analyses, are never addressed because of staff and equipment deficien-
ci es.
While laboratory personnel have the aut rity to contract out, private lab
services are employed rarely. The AECL prefers instead to arrange for another
state’s laboratory or the S& laboratory to do work. AECL is the only State lab
interviewed which had been successful at getting work done by another state’s lab.
The incident in which this was done involved PCB analyses in streane flowing into
New York State. New York’s lab had the necessary lab capacity and conducted the
analyses at no charge to Vernont. Since the AECL has no budget for contract ser-
vices, prograne requesting outside services are responsible for paying for them.
Though AECL personnel feel that it would be possible for them to contract out
routine analyses, they stated that to do so would increase the state ‘s cost. They
also stated that the quality of the analyses done would be variable (there are no
certified private laboratories in the State) and that there would be a loss of the
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efficiencies praroted by direct interaction between the AECL and AEC field personnel.
C. Testing Priorities
Laboratory priorities are set by the head of the Division of Water Resources
and the AECL Director. An institutionalized process is employed and gives con-
sideration to the type of analysis requested, and to scheduling needs. The small
size of the AECL facilitates coituninication with the agencies. The priority—set--
ting process is flexible enough to accorr x ate shifts in priorities due to emer-
gencies or shifting Agency priorities. AECL personnel stated that though they
are getting irore telepI ne requests for service than before, hazardous waste
work has not displaced other analyses in the laboratory.
Emergencies arid spills are autanatic top priorities for the AECL. Next in
priority are major studies and last, base data collection for the ongoing programs.
IV EPA REL TICt 1SHIPS
While in general AECL personnel have been pleased with the technical assis-
tance provided by the S&A laboratory, they identify a need for irore training
frar S&A. They would like a formal program established to provide training in
hazardous waste sartpling and analysis. The laboratory does feel, however,
that there is some problem with timeliness of S&A assistance.
There is “outstanding cooperation” between the AECL and the S&A labs. While
S&A’s response to routine program-oriented requests for assistance from the AECL
has been good, nore urgent EPA regional needs do take priority over AECL needs,
sometirx making it impossible for S&A to meet AECL requests. If an S&A request
is refused by S&A and tOHL, AECL has to leave such requests unanswered.
A-25
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APP DIX B
WST OF GCA1S
A GCA4S ranges in price fran $90,000 for an intermediate unit to $160,000
for an advanced unit. Two people are needed to operate the machine: a specially
trained chemist and a lab technician. The regional average salary and fringe
benefits for a B.S. chemist with three years experience is $17,550; the regional
average personnel cost for a technician is $13,000. Looking to the possibility
of two shifts, two experienced chemists with the support of one lab technician
could maintain a double shift operation. Adding a 10 percent differential to the
personnel cost of the second shift chemist brings his/her rate to $18,900. Most
state labs in New England would require 3ditiona1 tenperature controlled space
(approximately 300 square feet) to accanrrodate a GC4IS. Assuming an average
yearly cost of $10/square foot, the space costs for a GC4IS would be $4,000/year.
The GC/ tS has an approximate machine life of 8 years. Maintenance contracts
are $9,000 per year for 3vanced machines and $7,500 per year for intermediate
machines. Since a new machine can be expected to be functional about 80 percent
of the time (assuming some “dam time”), the machine will be operational for
approximately 201 working days each year. Therefore the approximate average cost
of functional machine time under a machine purchase arrangement time is $316/8
hours for one shift and $205/8 hours for double shifts. (See Figure F.) This
carpared favorably with the cost of contracting out the work, if there is suff i—
cient need to use the machine to capacity.
Leasing a GC/ 1S is also possible. Since states negotiate leasing contracts,
there is a range of lease prices between those quoted by machine manufacturers
and those ultimately negotiated by the states. Hewlett—Packard will lease an
advanced GC/MS (purchase price — $160,000) for $80,000/year for three years fol—
la’ied by an option to buy at $15,000 in the fourth year. The Finnegan Corporation
will lease an advanced GC/ 1S at $45,000/year for five years, with an option to
buy at $10,000 in the sixth year. (See Figure G.) Under a leasing arrangement,
the approximate average cost of functional machine time is $363/8 hours for one
shift and $217/8 hours for two shifts. This also cai ares favorably with the
cost of contracting, provided there is sufficient need to use the machine to
capacity.
B—i
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FIGURE F
AVERA.GE CtST PER SHIFT OF ADVANCED GC4’tS CAPACITY
PURQIP$E GC,41S
One Shift Operation o Shifts Operation
$20,000.00 Machine $20,000.00
9,000.00 Maintenance Contract 9,000.00
4,000.00 Space Rental 4,000.00
30,550.00 Personnel 49,450.00
$63,550.00 201 Shifts = $82,450.00 - 402 Shifts =
$316/Shift $205/Shift
FIGURE G
AVERAGE (DST PER SHIFT CF ADVANCED (X/MS CAPACITY
LEASE GC/?IS
One Shift Operation T Shifts Operation
$29,375.00 Machine $29,375.00
9,000.00 Maintenance Contract 9,000.00
4,000.00 Space Rental 4,000.00
30,550.00 Personnel 49,500.00
$72,925 - 201 Shifts = $91,825.00 — 402 Shifts =
$363/Shift $228/Shift
8—2
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