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Status of Methods and Method Regulations in EPA’s Water Programs. ASTM D19 Meeting Cocoa Beach, Florida January, 2006 Dale Rushneck, Interface, Inc. Methods Update Proposal.
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Status of Methods and Method Regulationsin EPA’s Water Programs ASTM D19 Meeting Cocoa Beach, Florida January, 2006 Dale Rushneck, Interface, Inc.
Methods Update Proposal • EPA proposed revisions and updates to wastewater and drinking water methods and monitoring regulations on April 6, 2004 (69 FR 18166) • The proposal addressed: • Wastewater Methods • Other Updates to Wastewater Regulations • Drinking Water Methods • Request for Comments on Guidance Document • A final rule is anticipated in Spring 2006
Wastewater Methods • EPA proposed: • Three chemical ATPs for general use in NPDES monitoring: • ASTM International Method D6508 for determination of anions by capillary ion electrophoresis • Lachat QuikChem Method 10-204-00-1-X for determination of total cyanide using MICRODIST • Kelada-01 method for determination of total and available cyanide using UV-digestion, flash distillation and colorimetry • One chemical ATP for use in the pulp and paper industry • NCASI Method CP–86.07 for determination of chlorinated phenolics by In situ Acetylation and GC/MS
EPA Method 245.7 – Mercury by CVAFS • EPA proposed EPA Method 245.7, “Mercury in Water by Cold Vapor Atomic Fluorescence Spectrometry.” • The Association of Metropolitan Sewerage Agencies (AMSA) petitioned the Agency to approve Method 245.7 as an alternative to EPA Method 1631. • However, EPA 245.7 omits the gold traps. • EPA conducted a inter-laboratory study of Method 245.7 in 2001. • Method detection limit = 5 ng/L. • Average recovery = 85 – 105% in reagent water. • Relative standard deviation (RSD) in reagent water <15%. • Average recovery in industrial and municipal effluent = 64 – 120%
Previously Proposed Methods • EPA reproposed methods from a 10-18-95 proposal. • The methods have been used through interim approvals since that time, so reproposal allowed EPA to receive comments on their use. • Approval of the methods would harmonize approved revisions of drinking water and wastewater versions of inorganic methods, and would formalize approval of new technologies for wastewater monitoring, including: • Inductively Coupled Plasma-Mass Spectrometry (e.g., EPA 200.8) • Stabilized Temperature Graphite Furnace Atomic Absorption Spectroscopy (i.e., EPA 200.9) • Ion Chromatography (e.g., EPA 300.0, EPA 218.6)
VCSB Methods for Wastewater • EPA proposed updated revisions of methods approved from voluntary consensus standards bodies (VCSBs). • Eighty-five (85) revised Standard Methods • Seventy (70) revised ASTM International methods • EPA proposed two new ASTM International methods. • D6888-03: Standard Test Method for Available Cyanide with Ligand Displacement and Flow Injection Analysis (FIA) Utilizing Gas Diffusion Separation and Amperometric Detection • D6919-03: Determination of Dissolved Alkali and Alkaline Earth Cations and Ammonium in Water and Wastewater by Ion Chromatography
Method Flexibility for Wastewater • EPA proposed and requested comment on increased flexibility in methods used for wastewater monitoring. • Under the proposal, analysts would be allowed to modify a method provided that: • The analyte measured is not “method-defined” • The chemistry of the method or the determinative technique are not changed • The performance meets specified performance requirements and is documented
Sampling Collection, Handling, and Preservation • The proposal revised sample collection, handling, and preservation requirements, including: • Raising the maximum holding temperature from 4oC to 6.00oC • Revising preservation procedures for Cr(VI) and extending the holding time from 24 hours to 28 days • Suggesting metals samples be preserved in the lab, not the field • Removing requirement for icing metals samples for shipment • Updating holding time requirements based on new studies
Cyanide Preservation • Based on comments and on ASTM D19 discussions, EPA is revising cyanide preservation to: • Remove ascorbic acid as a preservative • Add sodium borohydride and sodium arsenite as preservatives • EPA is revising preservation requirements to address interferences from: • Sulfur • Sulfide • Thiocyanate • Aldehydes • Carbonates • Chlorine and hypochlorite
Turbidity Update • EPA reproposed use of an alternative primary turbidity calibration standard (AMCO-AEPA-1 or AMCO-Clear)
Withdrawal of MCAWW Methods • EPA proposed to withdraw 109 Methods for Chemical Analysis of Water and Wastes (MCAWW) from 40 CFR part 136, or replace them with newer versions of the same numbered method. • The majority are single-analyte 200-Series methods for metals. • Older methods for metals are largely supplanted by multi-analyte methods such as 200.7, 200.8, and 200.9, or newer VCSB methods that utilize the same analytical techniques as the methods to be withdrawn. • MCAAW methods contain minimal QC requirements compared to VCSB and newer EPA methods.
Withdrawal of MCAWW Methods (cont.) • EPA proposed to withdraw Method 413.1, and other Freon-based oil and grease methods • Freon is presently banned for testing oil and grease, and total petroleum hydrocarbons (TPH), in wastewater. • EPA has been accepting data from tests using “old” Freon (made or imported prior to 2002) until Freon-base methods are withdrawn. • After withdrawal, hexane-based methods would serve as the sole standard for oil and grease measurements. • EPA may propose ASTM S-316-based method in future.
New Drinking Water Methods • EPA proposed four new chemical ATPs for drinking water monitoring: • ASTM Method D6508 for the determination of anions by capillary ion electrophoresis • Industrial Test Systems (ITS) free chlorine test strip method • OI Analytical Method 1677-DW for determination of available cyanide by ligand exchange and amperometry • Georgia Institute of Technology’s method for “The Determination of Radium-226 and Radium-228 in Drinking Water by Gamma-ray Spectrometry Using HPGE or Ge(Li) Detectors”
New Drinking Water Methods (cont.) • EPA proposed the addition of EPA Method 327.0 to 40 CFR 141.74 for the measurement of chlorine dioxide residuals. • EPA proposed updated revisions of methods approved from voluntary consensus standards bodies (VCSBs). • Fifty-two (52) revised Standard Methods • Twenty-four (24) revised ASTM International methods • EPA proposed two new ASTM International methods • D6888-03: Standard Test Method for Available Cyanide with Ligand Displacement and Flow Injection Analysis (FIA) Utilizing Gas Diffusion Separation and Amperometric Detection • D6919-03: Determination of Dissolved Alkali and Alkaline Earth Cations and Ammonium in Water and Wastewater by Ion Chromatography
Comments • EPA received over 100 comments on the proposal from: • Wastewater and drinking water utilities • Academics • Industry or trade groups • Method developers • VCSBs • State regulatory agencies • Citizens
Notice of Data Availability – 2/16/05 (70 FR 7909) • The NODA announced the availability of new information on methods for wastewater analyses (40 CFR 136): • A microdistillation procedure for cyanide and its ability to recover particulate forms of cyanide • Total Kjeldahl nitrogen (TKN) analyses • Mercury analyses • Total suspended solids analyses • Microtox • Method 624 for volatiles • Waters Method D6508
NODA (cont.) • The NODA also provides new information on drinking water analyses (40 CFR 141) regarding: • Interferences affecting Syngenta Method AG-625 • Revised versions of VCSB methods proposed in 2004: • ASTM D6888-04 for available cyanide • ASTM D5673-03 for metals by ICP/MS • ASTM D4658-03 for sulfide • Revisions to Georgia Institute of Technology’s method for Radium-226 and Radium-228 in Drinking Water by Gamma-ray Spectrometry
Wastewater Methods Under Development • Method 1668A - PCB congeners by GC/HRMS • Awaiting method detection limit data from EPA Regional labs • Method 1614 - PBDE congeners by GC/HRMS • Method being revised to incorporate 15-m column and temperature-programmed injector to improve precision and recovery of BDE 209 • Nonylphenol and alkylphenol ethoxylates by GC/MS • Development in collaboration with ASTM International • Development by EPA Region V laboratory
Wastewater Methods Under Development (cont) • Methods to support studies of pollutants discharged from Publicly Owned Treatment Works (POTWs) • Based on study by USGS • Organo-chlorine and organo-phosphate pesticides by GC/HRMS • Herbicides by GC/HRMS • Antibiotics by LC/MS/MS • Drugs by LC/MS/MS • Steroids and hormones by GC/HRMS • Kinetic test procedure for prediction of coal mine drainage
Detection/quantitation FACA Committee • EPA created a Federal Advisory Committee Act (FACA) committee to attempt to resolve issues surrounding detection and quantitation in EPA’s wastewater programs • Main FACA committee has held three meetings • Main FACA committee has established several workgroups • Policy workgroup • Technical workgroup • Workgroup for single-laboratory studies • Workgroup for inter-laboratory studies • Details at EPA’s FACA Committee web site: http://www.epa.gov/waterscience/methods/det/