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Another EPA Method Update Rule
Keith Chapman
Posted: Wednesday, August 25, 2010 10:48 AM
Joined: 10/2/2009
Posts: 35


EPA is proposing more Method updates for Clean Water Act work.  I think it was posted in the Federal Register on August 6.  Here is a link: http://water.epa.gov/scitech/swguidance/methods/upload/methodsprepub.pdf


Anonymous
Posted: Tuesday, August 31, 2010 10:21 AM

It's mentioned on page 48 of the proposed regs that EPA wants to add "twelve essential quality control checks" for every method. Does anyone have any idea about these checks? I would like to get a head start on revising SOP's before the next EPA on-site visit.


Anonymous
Posted: Tuesday, August 31, 2010 12:55 PM

Hello "Anonymous:"

 

If you click on the link that Keith provides and open up the pdf of the proposed rule, just scroll down to document page 140.  There they are.

 

Chuck Lytle,

City of Portland, OR


Anonymous
Posted: Tuesday, August 31, 2010 1:04 PM

Thanks.


Gary Sain
Posted: Tuesday, September 7, 2010 6:46 AM
Joined: 4/8/2010
Posts: 9


Been chasing this myself.  Here is a link I got from our state Lab Certification folks for the EPA memo that's apparently the source for what's being proposed in the Update Rule.


http://water.epa.gov/scitech/swguidance/methods/qaqc.cfm

 

 

I haven't had time to review it yet, but the Lab Cert folks say its essentially the same as what's being proposed.


GSain
Posted: Monday, September 27, 2010 12:51 PM
Joined: 8/4/2010
Posts: 6


The update rule was actually published in the Federal Register on September 23. 

Hopefully this link will work:

http://frwebgate3.access.gpo.gov/cgi-bin/TEXTgate.cgi?WAISdocID=uzqeiu/28/1/0&WAISaction=retrieve

 

Haven't had a chance to see if it varies significantly with what the EPA had on their webpage earlier.  It does include the QC requirements (40 CFR 136.7) discussed earlier in this thread.


Keith Chapman
Posted: Monday, September 27, 2010 5:22 PM
Joined: 10/2/2009
Posts: 35


YEP.  There it is; 54 pages of update!  There are a couple of things to take a close look at (maybe more than a couple):

 

Ortho-Phosphates MUST be filtered within 15 minutes of sampling!  For a composite sample, each grab must be filtered within 15 minutes!!  If you have to test for Ortho-Phosphate in stormwater composites....GOOD LUCK.  If you are unable/unwilling to do this you'll have to flag each sample with something to the effect of "samples not filtered within 15 minutes".

 

The only approved Standard Methods listed are the MOST RECENT approved version.  Does this force everyone to have a subscription to SM Online in order to know when methods were approved?  No longer are methods listed by Edition.  Big Change, no?

 

There is also are two new BOD methods (Hach and In-Situ) which basically allow the use of luminescent DO Probles.  I am under the impression that the In-Situ probe does not include a stirrer.  Anyone know about this method?  My experience with LDO probes is that you have better stir your BOD samples when measuring DO after 5 day incubation!

 

Have fun reading! 


Charles Lytle
Posted: Tuesday, September 28, 2010 7:45 AM
Joined: 10/5/2009
Posts: 49


Yes!  This is what prompted me to start the post on Hg by ICP/MS.  The proposed update lists a 2009 method, and the latest print SM is 2005.  According to a news article not long ago in Laboratory Solutions, the next print edition of SM, due out in a year or so, will be the last.  We'll all have to take out an online subscription if we want to stay current.

 

Chuck Lytle


James Royer
Posted: Tuesday, September 28, 2010 8:24 AM
Joined: 9/21/2009
Posts: 98


It appears that laboratories around the coutry will have to add a lot of extra time to accomplish the more strengent QA/QC requirements. I know that lab data requirements are important and I want to generate reliable data, but, at the end of the day the mass is calculated using flow data that is plus or minus an acceptable 5 %. The laboratory has little control of flow data and a lot of time it is minus 5 to 15 % of actual flow depending on the plant conditions. The EPA needs to write a QA/QC procedure for flow as strengent as for the lab analysis.


GSain
Posted: Tuesday, September 28, 2010 8:26 AM
Joined: 8/4/2010
Posts: 6


One point on approved methods.  As I understand it, and it was explained this way at a recent state seminar, the approved method will be listed as the method number followed by a dash and the year of approval.  So if you have an older version of Std Methods that has the currently approved method, you're still ok.  So if you're only certified to just a few methods, you probably won't have to immediately subscribe to the online service.

 

However, ultimately, as methods do get changed it looks like we will be subscribing online.  I work for a large corporation and am looking forward to running that approval past our bean counters. 


Charles Lytle
Posted: Tuesday, September 28, 2010 10:50 AM
Joined: 10/5/2009
Posts: 49


The EPA claims everybody was "confused" by there being more than one SM approved for many analyses.  Thus, we'll no longer be seeing the various editions of SM cited for any single analysis.  As they state in the proposed update, "...EPA is proposing to approve only the most recent version of a method...with as few exceptions as possible..."

 

Chuck Lytle

 

 


Keith Chapman
Posted: Tuesday, September 28, 2010 1:50 PM
Joined: 10/2/2009
Posts: 35


Pay close attention to Section 136.7: Quality Assurances and Quality Control which contains "Twelve essential Quality Control checks" and the statement "These twelve quality control checks must be clearly documented in the written method along with a performance specification or description for each of the twelve quality control checks."

MUST! 


dsmith
Posted: Tuesday, September 28, 2010 4:27 PM
Joined: 12/31/2009
Posts: 40


Charles Lytle wrote:

The EPA claims everybody was "confused" by there being more than one SM approved for many analyses.  Thus, we'll no longer be seeing the various editions of SM cited for any single analysis.  As they state in the proposed update, "...EPA is proposing to approve only the most recent version of a method...with as few exceptions as possible..."

 

Chuck Lytle

 

The most recent version isn't necessarily solely what is in the most recent edition of SM.  If you look at 4500 NH3 from the 20th and 21st editions, you will see that both of them have the footnote "Approved by the Standard Methods Committee in 1997"  I think it is still the same in the 19th edition as well.  The rule lists 4500 NH3 - 1997 as the approved method.  So you only need to make sure your edition has the correct year on the method and everything is good to go.  The tough part will be making sure you are in the loop when a new version is approved.



Anonymous
Posted: Wednesday, September 29, 2010 11:49 AM

 I have a question about QC check #11. Is there a definition of "batch" somewhere? It looks like we may be running more QC than actual samples if "batch" means each time the test is run. For example, we do nitrites (Colorimetric Method)on the plant effluent four times a week, twice on grabs & twice on composites. These tests are for process control & are not on our NPDES permit. Should we be running a Lab-Fortified Blank, Lab-Fortified Matrix, and Duplicate samples every day? We currently run the samples and a standard.

 

Thanks

 


dsmith
Posted: Wednesday, September 29, 2010 5:29 PM
Joined: 12/31/2009
Posts: 40


A batch is usually defined as "A maximum of X number of samples prepped or analyzed together within Y amount of time"  In my lab X = 20 and Y = 24 hours.


Charles Lytle
Posted: Thursday, October 14, 2010 7:54 AM
Joined: 10/5/2009
Posts: 49


 I think "analyzed together" means "at the same time," not "within 24 hrs."  Thus, if you have 18 samples and a 12-sample digestion block, you would split the samples into two, nine-sample batches and digest them with their own QC samples.  Basically, you end up turning a single "sample delivery group" into two "sample digestion groups."

 

Long ago, the EPA Contract Lab Program solved this dilemma by redefining the acronym SDG from the former to the latter.  When that still didn't help, they started packaging and sending samples by digestion group, so each set delivered was just the right number (or less) for a single set of QC samples.  Clever, no?

 

Where's Perry???  I need a yea/nay on this.

 

Chuck Lytle


dsmith
Posted: Thursday, October 14, 2010 10:25 AM
Joined: 12/31/2009
Posts: 40


Chuck, yes the time constraint is a bit long, but typically if you have the capacity to do that many samples at one time you don't need the full 24 hours to fill your batch of 20 samples.  Some of the more time and space intensive preps such as some of the surfactant pretreatments can only be done one sample at a time.  Therefore we extend the time window to allow analyses to be done over two consecutive work shifts.  I didn't go into the full definition as found in our QAP, with all the particulars and details and exceptions, instead opting for the simplified definition to address the main idea.