Printreg Archive
Re: Detection limits in "no detection" situations


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From: Wayne Pferdehirt (pferdehi@epd.engr.wisc.edu)
Date: Mon Mar 24 1997 - 09:26:54 CST


Date: Mon, 24 Mar 1997 09:18:52 -0600
From: JOAN KARNAUSKAS <KARNAUSKAS.JOAN@EPAMAIL.EPA.GOV>
To: printreg@great-lakes.net
Subject: Re: Detection limits in "no detection" situations

This issue was addressed in the Great Lakes Water quality guidance,
published March 23, 1995. It is found at 40 CFR part 132, Procedure 8
of Appendix F. I can forward a copy if you'd like. Note also that
procedure 3 of appendix F discusses the determination of backgroound
levels (see speciifically Prcedure 3, part B. 9. c.

>>> Wayne Pferdehirt <pferdehi@epd.engr.wisc.edu> 03/19/97 01:40pm
>>>
------- Forwarded Message Follows -------
Date: Wed, 19 Mar 1997 14:17:52 -0500 (EST)
From: Holly Lynch <hlynch@sayer.com>
To: "'p2tech@great-lakes.net'" <p2tech@great-lakes.net>
Subject: Detection limits in "no detection" situations Reply-to:
     p2tech@great-lakes.net

A printed wiring board manufacturer would like information on any EPA
regions, states, or localities that have addressed the issue of water
discharge detection limits in "no detection" situations

Specifically, he would like to know whether any EPA regions, state, or
localities have moved from current U.S. EPA guidance, which requires
point and nonpoint sources to assume that point source and non-point
source flows contain one-half the detection limit if the sample comes
back "non-detect."

I understand that the South San Francisco Bay region has been
struggling with this guidance because it may overregulate flows that,
in fact, contain pollutant levels that are significantly lower than
the one-half detection limit. This overregulation has the effect of
discouraging pollution prevention, since there is no incentive to get
pollutant discharge levels below the one-half detection limit since
the flows are automatically assumed to contain one-half the detection
limit.

I would appreciate any and all insight on this issue and I will
forward all responses to the PWB manufacturer.

Thanks for your assistance.

Holly Lynch
Director of EHS Programs
Institute for Interconnecting and Packaging Electronic Circuits

**********************************************************
Wayne P. Pferdehirt, P.E., AICP
U. of Wis., Solid & Hazardous Waste Education Center
610 Langdon Street, Room 529, Madison, WI 53703-1195
Phone: 608/265-2361 Fax: 608/262-6250
pferdehi@epd.engr.wisc.edu
**********************************************************


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