DEP develops pseudo-SOPs, reports spoofed data, punishes opponents

Yonghe Zhang

American Huilin Institute


Two years ago, I wrote that an American bureaucracy was born, and now it is growing strong [1].


NYC DEP DWQ Operation Lab for a long time arbitrarily developed pseudo-science SOPs (rules), for example, the SOP ask the analysts doing a calibration curve, the curve’s low part must be linear. How could the analysts make this curve!  However, it might be done by taking a long-time chance. Therefore, the SOP (calibration) could not correctly work in testing the NYC drinking water and could not expectedly get a good result. Nevertheless, the Lab asked analysts to re-run the same drinking water sample by this pseudo-science SOP calibration until get a good result. Then the Lab threw away the bad data and pick up the good one to report. Do we trust these reports of our New York City drinking water quality data? All these happened for a long time in 5 items of 5 Methods of hundred more chemical compounds in the organic section of this lab. If there are some opponents, they will be gotten revenge. One senior chemist has criticized the lab and he was subjected to a long time retaliation and demotion. The Lab director Ian Hurley always take advantage of the SOP to revenge his opponent by changing the SOP into most complicated, difficult and even pseudo-science. Here is the evidence:


Director Ian Hurley changed SOP Method 552.2 Revision 4 by personal opinion without any qualified chemist review and approve. If the analysts not complete his annual requirements (calibrations, initial Dem, MDL and LOQ studies) in two weeks will be fired


1) Violating of EPA method 552.2 (Revision 1.0, page 17):

 “A five point calibration curve should be “evenly distributed throughout the concentration range with correlation of 0.997”


Hurley changed into four criteria of SOP Method 552.2 (Revision 4, page 33-49):

a 7 point quadratic curve with correlation of 0.997 and ABS 0.33 and 4 point linear curve with correlation of 0.997 and ABC 0.33, resulting in a 7 point quadratic curve has a linear lower part” ? !, violating basic scientific knowledge and the EPA method 552.2 (Revision 1.0, page 17.


2) Violating of EPAGuidance 1.3 and 3.0:

a) “SOPs should be organized to ensure ease and efficiency in use”

(“The guidance for preparing SOPs” 3.0, page 6, April 2007).

b) “Ultimately, the benefits of a valid SOP are reduced work effort.

(“The guidance for preparing SOPs” 1.3, page 2, April 2007).

EPA Calibration only 2 page,  SOP is changed into 16 pages. Therefore, SOP results in a long performance period. Analysts might meet the critron BY CHANCE:  One person even has not met the criteria for a period of more than 2 years (Logbook M552-ALL-6-5, page 73-207; Logbook M552-ALL-6-6, page 1-208; Logbook M552-ALL-4-9, page 135-201; Logbook M552-ALL-4-10, page 1-54 ).


3) Reports spoofed data for  Method 551, Method 552, Method 524, Method 525 and Method 508 (please check logbooks of these Methods in recent years)


As I wrote two years ago [1], “SOP’s disadvantages have some strong temptations to give those bureaucratic organizations and individuals a chance to strength their power and greed to become a totalitarian bureaucrat to achieve some purposes such as to shirk responsibility, resist complain from employees or make a personal discrimination. Nevertheless, the cost is huge for not only increasing more management system wasting a lot of assets and resourcesbut also for challenging a democracy where all employees brought into full play of a initiative enthusiasm and activity of ethics and talents of human nature instead of laying on the stress of SOP provisions, being treated as a part of machines or tools.


[1] A bureaucracy is hurting American democracy andeconomy



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