ENVIRONMENTAL LABORATORY ADVISORY BOARD MEETING Monthly Teleconference: 202-991 -0477/793925J#, March 20, 2019; 1:00-3:00 p.m. ET MEETING SUMMARY The U.S. Environmental Protection Agency's (EPA) Environmental Laboratory Advisory Board (ELAB or Board) teleconference meeting was held on March 20. 2019. The agenda for this meeting is provided as Attachment A. a list of meeting participants is provided as Attachment B. and action items are included as Attachment C. The official certification of the minutes by the Chair or Vice-Chair and the Designated Federal Officer is included as Attachment D. ROLL CALL/ INTRODUCTION Dr. Tom O'Farreil called the meeting to order and called roll. APPROVAL OF THE PRIOR MINUTES Mr. Mike Flournoy motioned to approve the February 2019 meeting minutes. The minutes were approved unanimously. OPENING REMARKS AND UPDATES FROM THE DFO Dr. O'Farreil thanked Mr. Flournoy for accepting the role as ELAB Chair, and ELAB members for participating in the voting process for Vice Chair. He congratulated Mr. Brad Meadows for being voted in as the new Vice Chair of ELAB. Mr. Meadows thanked Mr. Flournoy for his leadership. His goal is to use everyone's input to improve ELAB. TASK GROUP UPDATES ON CURRENT TOPICS User-Generated Mass SpectraI Library Acceptance Criteria Dr. Brian Buckley presented this topic. ELAB received two response letters from the EPA. stating that the methods 8260D and 8270E - already have provisions that allows users to generate libraries. These methods specify users can generate their own libraries for identification, using the same conditions required for sample analysis. There is no requirement to duplicate the N1ST generated libraries in terms of performance or ion ratios. These methods permit the use of the best instrumentation available and ion traps. However. Dr. Buckley is concerned that some users may be constrained to 624 and 625 methods and may not have the flexibility to use 8260D and 8270E. ------- Ms. Deb Waller slated that K26UD and 8270!-. cannot be used because the\ arc not yet approved in the Federal Register, and that for regulated wastewater, the 600 series methods are required. Dr. O'barrel I confirmed that Dr. Buckley has read Mr. Adrian Jlanley s response from CPAs ()W. Dr. Chauvin had concerns with Adrian I lanley's response, due to timing limitations, California is still using ll)% regulations, that allow the use of other methods. This means tlicy could potentially use K260D and 8270E, instead of the 600 series methods. Ms. Waller disagrees because this is policy, and not regulation, and the States could potentially overrule it, Mr. Richard Gossett stated because the States are responsible for regulating this polie\. they arc potentially an impediment. Ms, Waller recommended entities cheek with the Stale before proceeding to be safe. A follow-up from FLAB may not be necessary because the topic is an issue with the States. Dr. OT'arrell identified a similar recommendation in EPA response letters, stating the EPA methods are guidance and to make sure to check with the regulating authoriiv, The letters are going to be posted on El AB's website, and ELAB can reference them when communicating with labs regarding this issue. Ms. Waller reminded EEAB thai SW-846 is not being referenced in the current 600 series methods, and clarification may he needed. Mr. Hournoy will send a follow-up letter to Adrian 1 lanley to clarify a couple points in the OW response regarding the 8260'82 70 criteria. . Icroh'in and Acrylonitri/e /'reservation Mr. Meadows has a template letter from the ACII. l-.SS and he is going to modify it to solicit laboratory participation in the preservation studies. 1 le is going to coordinate with the eo-chairs of the ESS committee to complete the letter. Dr. Mike Delaney slated that there are labs outside of ACII. that may be interested in participating in the preservation study and inquired about the possibility. Mr. Meadows response is the AC IE is being used because they have large lab membership, but labs outside of ACII are welcome. The study is more likely to be accepted b\ the EPA if more labs are involved, feedback from Adrian Hartley stated thai previous studies were too limited. Ms. Stacie Crandall volunteered 1ISRD to participate in the study, slating that IISRI) has a diverse pre-treatmcnt program. I1SRD has already asked pre-treatmenl personnel to collect a variety of different sample matrices for testing. Ms. Crandall suggested adding resources to this effort to get the data for the preservation .studies. f>tW-Serie\ Methods Dr. I lent*)' Leibovitz presented this topic. The task Ibrce- consisting of Mike Delaney. Francois Chauvin. Jayesh (ihandi. Ray Erederici. Rich Gossett. David Thai met. and will meet again before the March 2019 meeting. They discussed two topics: 1) the letter the EEAB originally sent EPA when the method update rule was proposed, and 2) the comments Dr. Richard Burrows from TestAmcriea submitted. Dr. Delaney found a copy to the EPA response letter. The EPA did revise the method rule according to the comments they received. Dr. Chauvin asked Richard Burrows to prov ide an example where a calibration curve generated a R: of 0.92. which is believed to be too low and unacceptable. Richard Burrows provided an example which concerned Dr. 1 eibovitz. Another concern is the "blanket statement" in the method for all the ------- anaKtes. Some analyles arc "bad actors." or do nol perform as expected in analysis. The task group will rev iew (he regulated anaKtes lo make reeommendalions k> the HPA for selling additional criteria. The reeommendalions will he more flexible fur I lie "had actors" and more slringent on the more predictable analyles. I.astlv. Dr. Lcibovii/ presented Richard Burrows question regarding calibration: When the calibration for sex era! anaKtes fail, is it acceptable to rerun the calibration and ignore the performance of the other analyles'.' 1 he task group w ill meet and have an update on this topic at the next I:LAB meeting. Dr. Delano) discussed concerns raised by a laboraton in Massachusetts: the 625.1 method has a now requirement to compare internal standards lo the LCS. I hoy reached out to the Region i OA chemist. Mr. Lemuel Walker, who replied thai this requirement was a mistake. 1 he\ were attempting to make the regulation consistent with 624. forgetting that the I.CS for 624 and 625 arc not the same. Dr. Dclaney would like to include (his concern in a letter to HP A regarding the 600 series. Dr. l.eibovit/ added thai 624.1 is a volatile organic method that does nol require an extraction. It requires a purge and trap. The ICS is treated the same way as a CC'V. f or 625.1 the LCS is extracted, while the CCV is not. The two methods are nol comparable. Ms. Sharon Merlons received a call from TeslAmcriea regarding the "blanket statement". TeslAmcriea received a violation from a customer {customer A). A different customer (customer B) requested samples tesled al a strict QC specific lo a project. Customer A requested their samples tested, and TeslAmcriea performed the test for both customers simultaneous!) using customer B"s strict QC. Customer A issued a v iolation, staling that the customer B's QC did not pass normal QC. Customer A wanted the entire batch to be reanaK/.ed. Dr. Leibovitz responded that LLAH raised this concern previously, and LPA did not change the method. Ms. Mertens stated that this concern is costing laboratories monetary resources. Dr. l.eibovit/ stated the I-PA response: the promulgated methods already provide the laboratories with the Ilexihi 1 it) desired, fhe task group will lake a closer look at this concern and decide how to respond. Dr. Delane) asked if labs are doing what is required b) method and if there arc extra components. Is there a wa> to ilag it? Ms. Mertens answered that there is a way and that TestAmeriea did compK. It was the customers interpretation ofLPAs "blanket statement" that caused the issue. Dr. l.eibovit/. wonders if it was LPA's intention with this method to avoid the usage of data qualifiers. The "blanket statement" is an ethics concern causing laboratories to throw oul "defensible" data. Ms. Mertens would like the task group to address this issue with potential changes to the language used in the current 600 series regulation. Ms. Stacie Crandall added that I IRC has ahead) submitted suggested language changes to llie LPA in the past and received no response. She suggested the task group could look at those suggested language changes as a stalling point. LLAB ma)" make new recommendations for criteria lor some regulator) and non-regulator) analytes. (Kill D11' (init/aiicc on Drinking Water MDLs Dr. Delane). Ms. Mertens. and Ms. Waller offered a letter lo the HPA for approval b\ f.l.AB. I he letter is a recommendation for the HPA to publish documents public!) and distinguish between policy requirements, guidances, and suggestions. A participant from the Massachusetts DPP asked a question regarding the ion chromotograph) methods: If you are following new ------- procedures to test \!i)i.s every 6 months, do you have to still do the 6-roortih Ml)l. testing? Ms. Mertens would like litis issue addressed in the letter to the EPA. An HPA Region 1 representative told Dr. Delaney that state labs should recalculate MDI s every 6 months because that is what is in the method. "Should" is not a requirement. The letter will address the issue of the HPA creating memos and guidances that are riot readily available to the entities that need to be using them and are open to interpretation by regulatory officials. Inactive Topics a) Improved PC H (\mgeihr Method Adrian Hanley provided an update at the March 2011) meeting that the analysis has begun for the multi-lab study. Dr. Delaney suggested revisiting this subject once the data for the study becomes available later in the year. h) I f "We Effluent Toxicity P T Standards Dr. Delanev contacted Mr. Greg Savitskc before the 1 ebruary 1 11 AN meeting. Greg Savitske is willing to ha\e task group meeting with KLAB and the WET testing task group, after the middle of April. This topic will remain inactive for now. c) In-Line On-Line Monitoring Mr. I lournoy stated there was not enough interest from HPA on this topic. Ms. (Tandall informed ELAB that HPA is performing actions for chlorine, and that she w ill talk to Lemuel Walker about whether KLAB can play a role in developing In-I.ine. On-l inc methods. To date. (T AB has not received further feedback from the EPA. ELAN discussed the rofc of ELAB to the HPA. The question is "Does the HPA need anything from ELAB"'" Lastly, Ms. Mertens reminded ELAB thai this topic pertains to not onl\ wastewater, but also air. and other things measured with sensor technology. Mr. I'lournoy adds that the EPA has already approved on-line monitoring for air. I here was a session at NHMC to address this topic. This topic is inactive for now. ) Addressing Emerging Contaminants Ms. Mertens presented this topic. HPA has started to work on PFAS'PSOS. ELAB is awaiting EPA response. e) Drinking Water Program Adoption of Recently Approved Methods Ms. Waller presented this topic. This topic will remain inactive. ------- NEW TOPICS/ISSl'ES FOR CONSIDERATION Dr. Chauvin led a discussion on tho requirements lor QC failures and addressing outliers and presented J-.LAB with a Idler to EPA on this topic. ELAB agreed to distribute this letter In email and \ote on it al the next meeting. WRAP-lT/Sl'MMARY OF ACTION ITEMS 1. Mike Flournoy will send a letter to Tom to distribute to Adrian Hanley {EPA, OWi to clarif\ a point from his recent comments on the I scr-Generate Library Acceptance Criteria letter sent front ELAB to EPA in Oct. of 2018. 2. Brad Meadows will ask the ACIL about the possibility of conducting a study to address pll preservation of acrolein and acrylonitrile in wastewater samples. 3. Mike Dektne\ will send the summar\ of comments in the docket from the last 600 Series Ml R. 4. Deb Waller will make final edits to the l)\V MD1. letter and send to ELAB via email for approval. 5. Mike Delancy will follow up with (.ireg Savitske about selling up a meeting with ELAB and INI on \YL f PT probabK in April 20 E>. 6. Staeie Crandall will ask Lemuel Walker about whether ELAR should play a role in developing In-line'On-l.ine monitoring methods. 7. lTancoise Chauvin will send a letter that will go to LPA on 1DOC guidance to ELAB first for re\ iew In email. The final \ersion of Ihe letter will be voted on at the April 201'J HI AB meeting. CLOSES (, R [MARKS/ADJOURNMENT Ihe April 2010 HI.AB Meeling will be held on .April 17. 2010 at I pm 1-astern. Dr. Deluney mo\ed to adjourn at 2:54 p.m.. and it was passed. ------- At (itch merit A AGENDA. Teleconference Numbers 202-991-0477 / 79392518 March 20, 2019 Webconference: epawebconferencing.acms.com/ofarrel 11/ I. Call Meeting to Order Flournoy II. Introduction of Board Members/Roll Call Board III. Approval of Minutes for Previous Meetings Flournoy IV. Remarks .md Updates from the DFO O'Farrell • Vice chair selection VI. Updates on Current Topics a. User-Generated Library Acceptance Criteria.......... Buckley b. Acrolein and Acrylonitrile Preservation and pH Meadows c. 600-Series Methods leibovitz d. OGWDW Guidance on Drinking Water MDls Oelaney f. Inactive topics awaiting feedback/input: • Improved PCB Congener Method Delaney ¦ Whole Effluent Toxicity proficiency study standards (is this back to active?) leibovitz ¦ In line/On-line Monitoring Flournoy ¦ Addressing Emerging Contaminants Mertens ¦ Drinking Water Program Adoption of Recent Approved Methods Waller VII. New Topics/Issues for Consideration Flournoy What does the Laboratory community want ELAB to work on? (Waller) VIII. Wrap Up/Summaryof Action Items Q'Farrelf/Ftournoy IX. Closing Remarks/Adjourn O'Farrell/ Flournoy ------- Attachment B Name Dr. Michael {Mike) Dclaney Affiliation Massachusetts Water Resources Authority (MWRA) ' Representing: MWRA PARTICIPANTS LIST Board Memht'is Attendance Y Y Y Y Y N Mr, Michael Flournoy (Chair) I)t I homas ()' 1 nneil (DLO| Dr. Kim Anderson Dr. Brian Bucklev Dr. i'raneoise Chain in Di. Dcyuan (Kitty) Kong Furofins Lnvironment Testing USA Representing: American Council of Independent Laboratories 1:.S. Hn\ironmental Protection Agcno Representing: i'PA Oregon State Cni\ersity Representing: Aeademia- Oregon State I ni\ ersitx Rutgers Ln\ ironmental and Occupational Health Sciences Institute Representing: Academia and I .allocators - Rutgers NYC Dept. of i jn ironmental Protection Representing: NYCDEP Chevron Lnergv "technology Company ------- N N N Ms. Slacie Crunch II _L i)r. Hcnrv Leibmit/ Mr. Brad Meadow: Ms, Sharon Mortens Mr, Richard (iossett Dr. Javesh Cihandt Ms. Debra (Deb) Waller Representing: Chevron I lampion Roads Sanitation District Representing: 1ISR1) Rhode Island State I lealth Laboratories Representing: Association of Public Health Laboratories Ikibeoek Laboratories, Inc. Representing: Commercial Laboratorx -- Babcoek I Laboratories. lite. Miluaukee Melropolitan Sewerage District Representing: The Nbl.AC Institute VIr. David Ilia ; PHYSIS Labs , Representing: I'i 1YSIS Labs Hnvironmental Standards Inc. i ; Representing: Lnvironnienial ! Standards Inc. ; Melrolim USA 1 1 Representing: Metrohm USA New Jersey Department of Hnvironmenta! Protection INJDLPI Representing: State ------- Government- NJI)1.1' N Mr, Ray Frederici TestAmeriea Representing: TestAmeriea I'ARTIC.'II'ANTS LIST (CO.NT) t (mtractors and (iuosts Attendance (Y/N) Name Affiliation Y Ms. Alexis !in ant I- !5A Y Mr. Nick Ramos 1 lunUm. .Andrews, Kurth ¦ Y Mr. Dale Tapp \\ aterOne Penny Shandons I lunton'Acicr ------- \Much men t i Action Items 1. Mike llournoy will send a letter to Tom to distribute to Adrian I lanley (I I'A. 0\V) to ckiiif> a point from his recent comments on the I ';set-(.icneratc 1 ibr.try Acceptance Criteria letter sent from J:LAB to EPA in t >ct. of 2018, 2. Brad Meadows will ask the AC'i 1. about the possibility of conducting a study to address pi I preservation of acrolein and aerylonitrile in wastewater samples. 3. Mike Dekinev will send the summary of comments in the docket from the last 600 Scries Ml JR. 4. Deb Waller will make final edits to the DW MDL letter and send to ELAB via email for approval, 5. Mike Dekiney will follow up with Greg Savitske about setting up a meeting with ELAB and TNI on WET P f probably in April 201*), 6. Stacie ("randall will ask Lemuel Walker about whether I .LAB should play a role in developing In-line/'On-Line monitoring methods. ?. I-'rancoise ("hauvin will send a letter that will go io EPA on I DOC guidance to ELAB first for review b\ email. The final version of the letter will be voted on ai the April 2019 ELAB meeting. ------- Attachment I) 1 hereby certify that this is the final version of the minutes for the I .in ironmenta! Laboratory Advisory Board Meeting held on March 20. 20i 9. X Mr. Michael Floumov CJwir Di. Thomas O'Farrell Designated Federal Officer ------- ------- |