From the Sufficiently
Sensitive Method Rule
to Laboratory
Accreditation
EFO June 26, 2015
Chris Armstrong
Oklahoma Department of Environmental Quality
State Environmental Laboratory Services Division
What is EPA’s Sufficiently Sensitive
Method Rule?
•  A new Rule that modifies NPDES
application, compliance, compliance
monitoring and analytical methods
What the SSMR Does...
•  Permittees may have to perform two
rounds of testing for initial permits and
renewals
•  The SSM may require much lower
Minimal Reporting levels for pollutants
•  Required test methods are determined
by EPA’s Method Update Rule and
companioned with the Sufficiently
Sensitive Methods Rule
What it does to the DEQ and, in part,
OWRB
•  DEQ permit engineers, the State Environmental
Lab, and OWRB evaluate environmental risk,
analytical capability (all labs), and realistic
Minimal Levels as compared to State WQ
Standards.
•  If a pollutant has never been detected with a
less sensitive method or tested with a more
sensitive method, testing with the sufficiently
sensitive method may be required.
What it means for the analytical labs
•  Instrument Purchases
•  Facility Modification
•  New Method Development to accomodate
analysis at much lower Minimal Levels or Minimal
Quantification Levels.
Mercury as a Worst Case
Currently Permi-ed at: 0.2 ppb (OK MQL) OWRB-­‐ Most Stringent WQ 0.005 ppb Criteria SSM Minimal Level or MQL 5.0 ppt (0.005 ppb)/ 0.5 ppt (0.0005 ppb) The Bottom Line
•  The Sufficiently Sensitive Methods Rule has the
potential to be expensive for us and for you.
•  The private labs will pass their expense to you (the
customer).
•  DEQ has documented concerns to EPA for 10 years.
•  Do the lower limits result in reduced environmental
and human health risk??
•  The DEQ will continue to negotiate required permit
Minimal Levels with EAP