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Procedures for Detection and Quantitation

Policy Workgroup

Federal Advisory Committee on Detection and Quantitation Approaches and Uses in Clean Water Act (CWA) Programs

Summary of Policy Work Group Conference Call #4
November 21, 2005
1:00 – 3:00 p.m. EST

Welcome and Introductions

Facilitator Alice Shorett convened the conference call at 1:00 PM EST and called the roll of participants. She briefly reviewed the agenda for the call, noting that the primary purposes were to finalize documents to be sent to the FACDQ on November 22 and to reach agreement on who and how the policy issues would be presented to the FACDQ at its third meeting on December 8-9, 2005.

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Meeting Summary Review and Approval

Ms. Shorett asked for comments on the Draft Summary of the November 7 Policy Work Group call. A question was raised about the priority issues identified in the summary for discussion on December 8 and 9. It was clarified that several issues had been discussed as possible priorities and that a subgroup had been asked to work on a "decision tree" to facilitate that discussion. It was agreed that the policy issues associated with three uses were to be "teed up" for discussion at the December 8-9 FACDQ meeting. The three uses were:

  1. Permit Applications
  2. Compliance Assurance and Enforcement
  3. Data Reporting

With that change, the summary was approved.

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Review of Revised Components of a White Paper on Uses

Continuum of Uses: Ms. Shorett noted that Mary Smith had revised the Continuum of Uses based on comments. Larry LaFleur asked if TMDLs were imbedded in the paper or were not included. Barry Sulkin responded that TMDLs were not included because there were issues with TMDLs that were not appropriate to address through the FACDQ process. Another member noted a typo that needed to be corrected.

Decision-Tree: Larry LaFleur (a member of the subgroup of the Policy Work Group) walked the Group through a four-page PowerPoint presentation and explained that the four pages were intended to show what happened sequentially. The subgroup recommended that the focus of the committee's discussion at the December meeting be on setting permit limits (page 3) and on permit compliance and enforcement (page 4).

As noted above, after discussion about the appropriate issues to "tee up", it was agreed that three issues would be the priority and that the committee discussion would flow in the following order: page 3 (Permit Applications), page 4 (Compliance Assurance and Enforcement), and page 1 (Data Reporting). It was noted that data reporting issues often were intertwined with compliance and enforcement. It was suggested that examples and scenarios would be helpful to the discussion.

It was agreed that Larry LaFleur would retitle the first two pages of the PowerPoint presentation related to "reasonable potential" and send the revised document to the subgroup and the facilitators for a quick review. The facilitators would send the revised PowerPoint presentation to the committee along with the other meeting documents on November 22.

Consolidated Policy Issues: Chris Hornback noted that his comments had not been incorporated into Pretreatment and Other Studies. The facilitators were to make the changes.

Revised Description of Uses: A typo was noted on page 11. On page 13 ("Compliance Assurance and Enforcement") it was agreed that this section should be revised to avoid confusion over the use of the terms Ld and Lc. Dave Akers noted that he is having a telephone call with the state representatives and he would ask for clarification about what states mean when they use the term "detection" and whether they equate detection with EPA's MDL. Mr. Akers was to send the revised document to the facilitators for the November 22 mailing. Mary Smith noted that the policy issue Chris Hornback had added relative to the "Other Studies" use was related to the issue of Performance-Based Measurement Systems that the Forum on Environmental Monitoring (FEM) is promoting.

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Presentation Materials related to Key Policy Issues

It was agreed that Policy Work Group materials would be presented in PowerPoint at the December 8-9 committee meeting. The facilitators were to work with the presenters to finalize the materials and the PowerPoint presentation. Coordination was to occur via email and telephone calls between the facilitation team and the presenters.

Document Focus/Goals Examples Presenters
Continuum of Uses Overview/Orientation   Mary Smith
Decision-Tree Overview of sequential flow   Larry LaFleur
1. Permit applications Discussion leading to 1) agreement or 2) options to take to constituents for input to March meeting
  • EPA Region 10 Guidance
  • Great Lakes Initiative (GLI)
  • CA Toxics Rule (implementation)
  • State-specific
Mary Smith, Tom Mugan, David Kimbrough, Dave Akers
Permit compliance and enforcement Discussion leading to 1) agreement or 2) options to take to constituents for input to March meeting
  • 1991 EPA Draft Permit Guidance – example of an analyte
  • EPA Region 10 Guidance
  • GLI
  • Other state-specific examples
Mary Smith, Tom Mugan, Dave Akers
Data reporting Discussion leading to 1) agreement or 2) options to take to constituents for input to March meeting Graphic to show implications of reporting different values for permits Larry LaFleur, Tom Mugan, Dave Akers

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Discussion of Major Considerations Related to Detection and Quantitation

Ms. Shorett called on Richard Burrows to describe a fundamental issue related to detection and quantitation that had arisen in both the Technical Work Group and the Policy Work Group subgroup. Mr. Burrows said that the issue came down to whether the committee wanted laboratories to demonstrate their lowest possible detection limit or to demonstrate that their lowest detection level was less than what was needed. Another way to pose the choice was between a "prescriptive" procedure and a "descriptive" procedure. The answer, he said, was critical to the design of a pilot test because it affected the number of spikes and samples and the overall level of effort. He said that if the committee wanted lab procedures to do one or the other or both, the Technical Work Group would need to review and revise the procedures for those purposes.

After discussion, it was agreed that Richard Burrows, David Kimbrough, Larry LaFleur and Richard Reding (EPA) would redraft the paper describing the issue. Depending on how quickly the paper could be ready, the facilitators would either send it to the committee in advance of the December meeting or hand it out at the meeting.

Attendance

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