Method Update Rule II

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					US EPA Method Update Rule
                        Ray Terhune

          Questions and Answers
 This presentation is for training purposes. Any contradiction
   to the Code of Federal Regulations is unintentional and
    should not be substituted for established regulations.
Time for a Change!
        Changes to the CFR
 Over 100 methods (mostly EPA) removed
 Addition of several methods (EPA 200.2,
  200.8, 200.9, 218.6, 300.0 etc.)
 Corrected errors in tables
 Clarified method requirements.
 Will provide better data, overall
          What IS the CFR?
 Code of Federal Regulations
 Title 40 is for Environmental Rules
 It is FREE on the Internet
 It is a PAIN to use
    How to Use the On-line CFR
 Click on “Browse and/or Search CFR
 Scroll down to Title 40 (left column
 Click on the July 1, 2008 (blue)
 Click parts 136 - 149 in the numbers list
 Click on part 136
 Pick the section you want, usually 136.2
  or 136.3 and a .pdf file will appear
CFR in .pdf Form
When Did This Happen?
             MUR Timeline
 Proposed in April 2004
 Published in Federal Register, March 12th,
 Published in Federal Register, March 26th,
 Published in 40 CFR, part 136 July 2007
 Next Major Update in Late 2009 or 2010
 Read the FOOTNOTES
 Make sure the FOOTNOTES are followed
 Defines several parameters (such as
 Did I mention to “Read the FOOTNOTES”!
What Happens Now?
Changes to the Community
    Changes in the Community
 Required “updating” to approved
 “Grandfathering” allowed under certain
 Alternate Test Procedures are not affected
  if base method is dropped.
 Easier Method Modification Rules
 More Choices of Methods
 Approved Methods Have More Flexibility
 New Methods Use Current Technology
    Latest PROPOSED Changes
 Only latest edition of Standard Methods is
  approved with as few exceptions as
 Specify essential QC and other missing or
  inconsistent instructions.
 Add approved methods that have passed
  the ATP process, i.e. D888-05 LDO,
  D7284-08 & D7511-09 for cyanide, etc.
    PROPOSED Changes continued
 Revise Oil and Grease 1664 with
 Other method revisions: 1614, 1668 and
 Better explanation concerning holding
  times in Table II overriding method
    PROPOSED Changes continued
 Revise 136.6, Method Flexibility with more
 Numerous clarifications and modifications.
 Remove mercury based reagents from
  methods and use of mercury
    Where to get Method Updates
 Chemistry and Microbiology: Current Code
  of Federal Regulations (July 2007 or later)
 Chemistry: Federal Register, March 12,
 Microbiology: Federal Register, March 26,
 Internet:
Frequently Asked Questions
Microbiology Questions
      Microbiological Questions
 1. How do you interpret Footnote 22 of
  CFR 136.3 Table II? Does the laboratory
  have 8 hours holding time now instead of
  6 hours?
 No. The rule is pretty specific and says the
  laboratory has 2 hours to process samples
  after receipt from up to 6 hours of travel.
 However, for all practical purposes,
  samples have a 6 hour hold time and 2
  hours processing time.
         Micro Questions Continued
 2. Does a sample have to be maintained at 6° C
  or less during collection, transport and receipt at
  the laboratory?
 Yes.
       A “grab” sample is collected and should be chilled to
        ≤ 6°C as quickly as possible and maintained at that
        temperature until analysis by the laboratory.
       A “composite” sample should be maintained at ≤ 6°C
        throughout the process and kept at that temperature
        until analyzed by the laboratory.
     Micro Questions continued
 3. What does EPA mean by “immediately”
  for some of their analyses and how does
  this affect preservation?
 EPA defines immediately as ≤ 15 minutes.
  If a sample isn’t analyzed “immediately”, it
  must be preserved (if allowed).
Chemistry Questions
    Chemistry Questions Continued
 1. If a method is removed, will an
  associated Alternate Test Procedure (ATP)
  also be removed?
 No. If an ATP has been approved for any
  method (except Freon related methods), it
  is still considered a valid procedure for
  NPDES analyses.
    Chemistry Questions Continued
 2. What if a method has different sample
  preservation requirements than the Code
  of Federal Regulations? Which
  preservation is appropriate?
 The Code of Federal Regulations is the
  law. A method is an approved procedure.
  The CFR takes precedence.
Chemistry Question #2 Continued
   Example, NPDES: Ammonia by Standard
    Methods, 20th ed. (4500-NH3 A) states
    that samples analyzed within 24 hours
    should not be preserved with acid to avoid
    unwanted interferences. But 40CFR 136.3
    Table II requires acid preservation unless
    analyzed immediately (< 15 minutes). The
    CFR takes precedence.
    Chemistry Questions Continued
 Has the ASTM method D888-05 for
  Luminescent Dissolved Oxygen been
 Sort of. It has approval for use as an
  Alternate Test Procedure (ATP) in Region
  4. However, the PROPOSED update will
  give it national approval.
 Ray Terhune – Chemist, USEPA Region 4,
 Marilyn Maycock – Chief, QA Section
  USEPA Region 4, tel: 706-355-8553,

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