UNITED STATES ENVIRONMENTAL PROTECTION AGENCY I WASHINGTON, D,C, 20460 OFFICE OF tMe ADMINISTRATOR * -i OA irt«* SCIENCE ADVISORY BOARD April 30, 1993 EPA-SAB-DWC-COM-93-002 Honorable Carol M. Browner Administrator U.S. Environmental Protection Agency 401 M Street, SW Washington, DC 20460 Subject: Science Advisory Board's Commentary on "Requirements for Nationwide Approval of New and Optionally Revised Methods for Inorganic and Organic Analyses in National Primary Drinking Water Regulations Monitoring" Dear Ms. Browner: On April 19, 1993, the Drinking Water Committee of EPA's Science Advisory Board (SAB) received a briefing concerning the "Requirements for Nationwide Approval of New and Optionally Revised Methods for Inorganic and Organic Analyses in National Primary Drinking Water Regulations Monitoring" (Revision 1.1, dated 4/14/93), This document was prepared by the Office of Research and Development and is often identified as the "Alternative Testing Procedxo-e Protocol" (ATP). The Office of Groundwater and Drinking Water (OGWDW) had requested input from the SAB on this document kte last year, and the Drinking Water Committee had received an earlier version (Eevision 1.0, dated 7/7/92) before its meeting of February 1993, but had not been able to discuss it at that time. The overview of the ATP provided to the Committee included: a historical background of the activities of the Environmental Monitoring Systems Lab (EMSLrCincinnati) with regard to water testing methods; a description of the two-tiered system in the ATP; general requirements of the application; and EMSL-Gincinnatf s evaluation procedure. The Drinking Water Committee has decided on its own initiative to provide this commentary on the ATP. From 1978 to-date, a total of 1250 alternative testing procedures were received by the US EPA under the mechanism promulgated in Section 141.27 of Title 40 of the Code of Federal Regulations (CFR). For drinking water, a total of 320 procedures have been approved, one hundred forty-four of them for nationwide use and 176 for limited use. Eighty-eight percent of these 320 were for chemical procedures. ------- The US EPA is proposing to repeal this regulation and establish, in its place, a two-tiered system for rapid nationwide adoption of new and revised analytical methods for drinking water. The first tier is for any new method, significantly revised method, or a new application of a currently approved method. The second tier will cover optional minor modifications of an approved method. The following are our findings and recommendations with regard to the ATP: a) The ATP requires the use of 10 drinking water sources (6 surface and 4 groundwater). This number is too small to adequately represent the nation's diversity in water quality and treatment conditions. There should be guidance as to the range of water qualities to be sampled and less emphasis based on the samples representing 10 regions of the country. The water quality variables should include pH, TOG (Total Organic Carbon), alkalinity, and TOX (Total Organic Halides), similar to those currently under consideration in the Regulatory Negotiation process for Disinfectants and Disinfection by- Products. For example, TOGs ranging from concentrations below 2mg/L to concentrations above 8 mg/L should be included. TOX ranging from 50 to 500 ug/L should be used when appropriate to challenge the proposed method. b) The ATP suggests testing methods at four concentrations. This number may be inappropriate in certain cases. The concentrations should include a level that is five times the method detection limit (MDL), a level that is two times the maximum contaminant level (MOD and additional levels that take into account the dynamic range on a case-by-case basis. c) We are not clear how the ATP program may impact other methods- developing organizations (e.g., joint APHA/AWWA/WEF, ASTM). d) During the briefing, the possibility of performance-based standards for analytical methods was discussed, although changes along these Hues are not currently under consideration for the proposed two-tiered ATP process. Developments along this line would have some potential advantages and we encourage them. However, we are concerned about the practical application of this approach across a wide variety of methods for an increasingly complex group of chemicals. Caution should be exercised in approving laboratory methods with detection capabilities very near the MCL, because then- use may result in loss of valuable monitoring data at levels below the MCL, with little savings in cost or efficiency. In general, facilitation of the ATP process should encourage the development and use of procedures which serve to improve the efficiency and reduce the cost of ------- contaminant analysis. We request, however, that the scientific merits of any changes to a performance-based standard approach be provided to the Committee with appropriate time for a detailed review of the approach and its potential impact on the industry. The SAB appreciates the opportunity to assist and provide suggestions on issues such as these, which can eventually permit better monitoring strategies to be adopted by the Agency, and we look forward to your response to the comments contained in this letter. Sincerely, Dr. ^Raymond C. Loehr, Chair Executive Committee Science Advisory Board Ray, Drinking Water CoiMuttee Science Advisory Board ------- NOTICE This report has been written as a part of the activities of the Science Advisory Board, a public advisory group providing extramural scientific information and advice to the Administrator and other officials of the Environmental Protection Agency, The Board is structured to provide balanced, expert assessment of scientific matters related to problems facing the Agency. This report has not been reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor does mention of trade names or commercial products constitute a recommendation for use. ------- ENV1EONMENTM, PROTECTION AGENCY SCIENCE ADVISORY BOARD DRINKING WATER COMMITTEE Commentary on Alternative Testing Protocol Procedure (ATP) CHAIBMAM Dr. Verne A Bay, Medical Research Laboratory, Pfizer Inc., Groton, Connecticut MEMBERS Dr. Richard J. BuU, College of Pharmacy, Washington State University, Pullman, Washington Dr. Gary P, Carlson, Department of Pharmacology and Toxicology, School of Pharmacy, Purdue University, West Lafayette, Indiana Dr. Keith E. Cams, East Bay Municipal Utility District, Oakland, California Dr. Lenore S. Clesceri, Rensselaer Polytechnic Institute, Materials Research Center, Troy, New York Dr. Ramon G, Lee, American Water Works Service Company, Voorhees, New Jersey Dr. Edo D. PeUizzari, Research Triangle Institute, Research Triangle Park, North Carolina Dr. Mark D, Sdbsey, Department of Environmental Sciences and Engineering, School of Public Health, University of North Carolina, Chapel Hill, North Carolina Dr. James M. Symons, Department of Civil and Environmental Engineering, University of Houston, Houston, Texas 3QRY BOARD STAFF Mr. Manuel R. Gomez, Designated Federal Official, Science Advisory Board (A-101F), ILS. EPA, 401 M Street, SW, Washington, DC 20460 Mrs. Marcy Joly, Staff Secretary, Drinking Water Committee, Science Advisory Board (A-101F), U.S. EPA, 401 M Street, SW, Washington, DC 20460 '•M* ------- Distribution List Administrator Deputy Administrator Assistant Administrators EPA Regional Administrators EPA Laboratory Directors Director, Office of Ground Water and Drinking Water Director, Office of Science and Technology Office of Modeling, Monitoring Systems, and Quality Assurance Director, Environmental Monitoring and Assessment Program Environmental Monitoring Management Council Director, Risk Assessment Forum EPA Headquarters Library EPA Regional Libraries EPA Laboratory Libraries ------- ------- ENVIRONMENTAL PROTECTION AGENCY SCIENCE ADVISORY BOARD DRINKING WATER COMMITTEE Commentary on Alternative Testing Protocol Procedure (ATP) CHAIRMAN Dr. Verne A. Bay, Medical Research Laboratory, Pfizer Inc., Groton, Connecticut MTCMTfflRS Dr. Richard J. Bull, College of Pharmacy, Washington State University, Pullman, Washington Dr. Gary P. Carlson, Department of Pharmacology and Toxicology, School of Pharmacy, Purdue University, West Lafayette, Indiana Dr. Keith E. Cams, East Bay Municipal Utility District, Oakland, California Dr. Lenore S. Cleseeri, Kensselaer Polytechnic Institute, Materials Research Center, Troy, New York Dr. Ramon G. Lee, American Water Works Service Company, Voorhees, New Jersey Dr. Edo D. Peffizzari, Eesearch Triangle Institute, Eesearch Triangle Park, North Carolina Dr. Mark D. Sobsey, Department of Environmental Sciences and Engineering, School of Public Health, University of North Carolina, Chapel Hill, North Carolina Dr. James M, Symons, Department of Civil and Environmental Engineering, University of Houston, Houston, Texas SCIENCE ADVISORY BOARD STAFF Mr. Manuel R. Gomez, Designated Federal Official, Science Advisory Board (A-101F), U.S. EPA, 401 M Street, SW, Washington, DC 20460 Mrs. Marcy Jolly, Staff Secretary, Drinking Water Committee, Science Advisory Board (A-101F), U.S. EPA, 401 M Street, SW, Washington, DC 20460 ------- Distribution List Administrator Deputy Administrator Assistant Administrators BPA Regional Administrators EPA Laboratory Directors Director, Office of Ground Water and Drinking Water Director, Office of Science and Technology Office of Modeling, Monitoring Systems, and Quality Assurance Director, Environmental Monitoring and Assessment Program Environmental Monitoring Management Council Director, Risk Assessment Forum EPA Headquarters Library EPA Regional Libraries EPA Laboratory Libraries ------- |