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Procedures for Detection and Quantitation
Facilitator Summary of Key Issues
Identified at the First Committee Meeting
September 30, 2005
At its first meeting, the Federal Advisory Committee on Detection and Quantitation Approaches and Uses in Clean Water Act Programs (FACDQ) identified a list of key issues. The facilitators reviewed the list and identified the following as policy issues.
Policy Issues and Questions
- What is the problem we are trying to fix?
- Should detection be used as a permit limit?
- What is an acceptable range of risk (qualitative and quantitative) and for whom?
- What quality of data do we need to make decisions for different uses?
- Will one procedure ("size") fit all and meet the needs of all (i.e., states, labs, industry, utilities, environmental community, EPA)?
- What is the impact, if any, on water quality of adopting different analytical procedures?
- Will a procedure(s) result in guidance on how to use limits in Clean Water Act programs?
The facilitators sorted the remaining "key" issues into three categories and recommend that they be addressed through these categories: criteria, informational requests/suggestions, and post-process or transition issues.
Criteria
- Don't create new problems trying to fix detection and quantitation.
- Are there appropriate tools (e.g. software) for detection and quantitation procedures? If so, under what conditions are the tools used?
- Should calculation of detection and quantitation limits be an interlaboratory procedure?
- It has to be feasible (i.e. implementation, technology, cost, resources, training).
Informational requests/suggestions
- Describe the situation of detection and quantitation uses across all 50 states and how they are using them in Clean Water Act programs.
- Identify the properties of detection and quantitation procedures and how they are used.
- Definitions could be standard benchmarks for detection and quantitation limits, critical level and others.
- Understanding the different uses between detection and quantitation across all user groups.
Post-process, transition issues
- Describe transition times for implementation (e.g. existing NPDES, EPA and state guidance development)
- What are the implications of change across the board? What happens to existing analytical methods?
- What steps are taken to implement consensus recommendations on detection and quantitation procedures?
- What tools may facilitate implementation of new procedures?
- How are new procedure(s) implemented in Clean Water Act programs (e.g. TMDLs, permits)?