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Joined: 7/28/2011
Posts: 1
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When a laboratory wants to use a new method that has been recen'tly approved by EPA (i.e. EPA Method Update Rule), does the NPDES permit need to be changed to accomadate the new method? Or, are NPDES permits written in a fashion that allow a laboratory to use any approved 40 CFR 136 method?
Your response and insight is most appreciated,
Agua Dr
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Joined: 12/17/2010
Posts: 23
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It would be highly unusual for an NPDES permit to require use of a specific method...but anything is possible! My advice is to check your plant's permit and see what it says on methods to be used for monitoring tests. My guess is that it will say you (and your supporting labs) may used an method approved by EPA in 40 CFR 136. There are exceptions, however. For example, some states require the used of the most recent edition of Standard Methods.
If your lab is required to be accredited/certified by you state regulatory agency, be sure to let the lab accreditation folks know you if you change to the new method.
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Joined: 10/5/2009
Posts: 46
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After a long hiatus, I finally get a chance to comment to a posting, and Perry Brake beats me to it. At least some things in this crazy world haven't changed. 
In our just-renewed permit, the details are in Schedule F (NPDES General Conditions), Section C (Monitoring and Records): 40 CFR 136. Any update promulgated at 136 will thus be automatically approved.
I should note that our biosolids program, SW-846 is specified as the source of required methods.
Chuck Lytle
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