1. Chemical Monitoring Activity Draft Guidance Document on Chemical Monitoring of Surface Water (Version 3.0)

2. Comments on Version 2.0 Comments to the draft were submitted by
Denmark
France
Germany
Norway
The Netherlands
Sweden UK
HELCOM
Eurometeaux
ESPO
Case studies were submitted by
Spain, Sweden and Germany

3. What’s new? New version V3.0! 3. TERMS AND DEFINITIONS
4. MONITORING DESIGN
4.1 General – Monitoring Design
4.2 Sampling Strategy (Matrix selection is now included in this chapter)
5. TECHNIQUES FOR SAMPLING (according to the discussion we had at the Rome meeting the chapter was shortened substantially)
6. TECHNIQUES FOR ANALYSIS
6.1.2 Limit of detection/Limit of quantification
7. Complementary Methods
New version V3.0!
The Term determinant was substituted by measurand. Measurand is the technical term specified in the VIM
The Chapter Monitoring design was re-arranged, matrix selection was included in the new section „Sampling strategy
According to our discussion in Rome the Chapter sampling was revised and adjusted in size and level of detail to the other chapters
By DK and France
A new section LOD/LOQ has been added, drafted by UK
The term alternative methods was substituted by complementary methods taking into account discussions at the last SWIFT meeting which was held in September in Porthmouth. It was noticed that the term alternative might indicate that methods dealt with in this chapter could acutally be used as substitute for laboratory methods. But the intention of SWIFT was to develop method, which can complemet existing method and not substitue them.

4. Comments not (yet) considered
General Comments
The time period after which the document is to be reviewed and updated has to be specified (NL)
Is there need for a specific marine guidance chapter or annex? (JRC)
Issues of compliance, statistical treatment and reporting of monitoring data are not within the mandate of this guidance document
A political decision is required because the consequences can be enormous (NL)
The time period after which the document is to be updated has to be specified (NL)
Is there need for a specific marine guidance chapter or annex? (JRC)
Issues of compliance, statistical treatment and reporting of monitoring data are not within the mandate of this guidance document
A political decision is required because the consequences can be enormous (NL)

5. Comments not (yet) considered
Definition of Total Measurand Concentration
Total concentration of the measurand shall mean the total concentration of the measurand in the whole water sample, reflecting both dissolved and particle bound concentrations of the measurand.
Comment (NL)
This definition must be changed otherwise one should always determine the sum of the determinant in water PLUS the determinant in suspended solid
Proposal (NL)
… the extractable fraction of the whole water sample by liquid-liquid extraction, solid phase extraction, passive sampling extraction or other extraction techniques
Comment (NL)
This definition must be changed otherwise one should always determine the sum of the determinant in water PLUS the determinant in suspended solid
Proposal (NL)
… the extractable fraction of the whole water sample by liquid-liquid extraction, solid phase extraction, passive sampling extraction or other extraction techniques
Definition of „discharged“
Proposal (Eurometeaux)
A substance is considered as being discharged into a river basin when it leaves an engineered system of structures or use/end of use product or article either directly, in a diffuse manner or accidentally

6. Comments not (yet) considered
Filtration of Water Samples
Draft Guidance
……… for metals, the liquid fraction obtained by filtration or any equivalent pre-treatment of the whole water sample, …………
Comment (JRC)
Equivalent pre-treatment procedures should be specified and/or examples should be given examples
Collection of SPM
Commonly, filtration through glass-fibre depth filters with a nominal retention rate of 99% at 0.7 µm is used
Commment (NL, France, Germany)
0.45 µm filtration should be recommended

7. Comments not (yet) considered
How to demonstrate compliance if methods are not sufficiently sensitive or accurate?
Comment (NL)
Decision to be taken by the commission
Proposal (NL)
In those cases where compliance checking (analysis in whole water with cost effective analytical methods) is not possible, it is sufficient for a Member State only to check on the no-deterioration principle. This can be done for instance by determining concentrations in sediment.
Draft Guidance Document
However, demonstrating compliance with EQS in water may be problematic in some cases. Examples include:
Available analytical methods are not sufficiently sensitive or accurate for quantification of substances at the required concentration level.
Comment (NL)
Decision to be taken by the commission, only proposal
Proposal (NL)
In those cases where compliance checking (analysis in whole water with cost effective analytical methods) is not possible, it is sufficient for a Member State only to check on the no-deterioration principle. This can be done for instance by determining concentrations in sediment One should remind that it takes at least 5 years for concentrations in the top sediment layer to change as a consequence of changing water quality. Using a higher frequency than once per RBMP will not give a better insight

8. Comments not (yet) considered
Use of Models
Comment (NL, JRC)
Information given in chapter 4.3 should be moved as possible approach or best practice to Annex III “Case Studies”
Comment (Norway)
CMA must discuss if relationship curves models (BAF/Kow) could be used in compliance checking of water bodies at least in surveillance monitoring where the water bodies classiefied in this way are clearly not at risk
Chapter 4.3 Use of Models
Comment (NL, JRC)
Information given in chapter 4.3 should be moved as possible approach or best practice to Annex III “Case Studies”
More specific information should be included in chapter 4.3 on how models might be used to design a monitoring network
Proposal (Norway)
Since no EQS values are decided for biota CMA must discuss if relationship curves models (BAF/Kow) could be used in compliance checking of water bodies, for instance to propose reasonable border values to be used in monitoring. If necessary a safety factor could be added to ensure that the uncertainty of the relationship curve does not lead to misclassification.
At least this approach should be considered in surveillance monitoring where the water bodies classified in this way are clearly not at risk

9. Comments not (yet) considered
Monitoring Frequency
Comment (NL)
According to the WFD, the frequency is set and compliance checking should be done on the mean of these values. The accompanying level of confidence and precision should be taken accepted
There should be no mandatory frequency for seasonal substances in the case of surveillance monitoring
It should be acknowledged that surface water in general is a dynamic system and variability in nature is large, especially for micro-pollutants. Achieving “adequate confidence” is only possible with very high frequencies and corresponding costs.
Recommendation in the draft
To estimate the pollutant load biweekly sampling, 26 samples a year, is recommended

10. Comments not (yet) considered
Group Parameters
Comment: Germany, NL
Endosulfan
only the alpha-isomer should be monitored
Hexachlorocyclohexane
only the gamma-isomer should be monitored
Comment, NL
The number of isomers which have to be summed up for calculating concentrations of group parameters should be as small as possible
Comment: Italy
Octylphenol
The CAS No as specified in the list of priority substances as well as in the Directive on EQS corresponds to the linear isomer
The toxic isomer released to the environment is 4-tert-octylphenol (CAS No ) 
Endosulfan
only the alpha iomer should be monitored, the beta is hard to analyse, it will cost a lot to comply with the LOQ and U, and is of much less importance
Hexachlorocyclohexane
only the gamma isomer should be monitored, the other isomers are of much less important, it will cost a lot to comply with the LOQ and U
Comment: Italy
Octylphenol
The CAS No of Octylphenol as specified in the list of priority substances as well as in the Directive on EQS corresponds to the liniear isomer
The toxic isomer released to the environment is 4-tert-octylphenol (CAS No ) 
Required LOQ for the individual isomers of a group of substances
With 6 components, each should have a factor 6 lower LOQ!!!. Because the results are summed before compliance checking. This means that these group compounds analyses are much harder to comply with the required LOQs
Example: PBDE
PBDEs: 6 congeners: the required LOQ is already very low: If each congener reports a “<LOQ” value. The addition of 6 times 50% of the LOQ gives already a high result which may be well above the EQS

11. Open Questions
Treatment of “less than” values as well as specification of indicator substances
How to assess results if method performance criteria cannot be met?
Proposal was made
Group parameters – Indicator compounds
Polybrominated diphenyl ethers, HCH, Endosulfan
What congeners/isomers should be analysed for?
How to report results for substance groups or mixtures of isomers?
How to set performance criteria?
How to handle “less than” results for individual isomers/congeners?
CAS No Octylphenol
Use of relationship curves models in compliance checking
Support is required from DG/ENV and Drafting Group on Common Issues!!!

12. Future Work
Taking into account comments on version 3.0 received from CMA members
Completion of Substance Guidance Sheets
Analysis of HCB, hexachlorobutadiene and methy-mercury in biota to be included?
Groundwater relevant parameters?
A list of complementary methods relevant to WFD chemical monitoring to be added to chapter 7
including method performance criteria
CASE Studies
Further examples to be submitted
Please be brief and use the template provided

13. Suggested Time Schedule
Filling the existing gaps in the current document
Substance Guidance Sheets
Annex III: CASE STUDIES
List of complementary methods
December 15
Written comments on V3 of the draft guidance document
Revised draft V4
January 15, 2007
Final Drafting Group Meeting
January 22/23, 2007 at JRC Ispra
Completion of the Guidance Document
February 28, 2007

14. Thank you to all who have participated actively in the drafting process