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| | | Forum Newbie
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| | The following was posted by Standard Methods at http://www.standardmethods.org/ViewArticle.cfm?articleID=70. Please note: Although the LDO® method developed by the Hach Company is not currently approved by Standard Methods for determining dissolved oxygen, either as a stand-alone procedure or as part of the Standard Methods BOD procedures, USEPA has approved the LDO® method for 40 CFR 136 compliance monitoring via the Alternative Test Procedure (ATP) program. See the attached memo from USEPA dated April 14, 2008 for specific details of requirements to use the ATP protocol. Standard Methods hopes there has been no misunderstanding within the user community regarding compliance testing that may have arisen out of these circumstances. This should take care of the confusion out their in the regulatory community! |
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| | | Supreme Being
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| As much as I wish the April 14 memo were HQ EPA's approval to use LDO, I don't read it that way. I see it as HQ EPA encouraging ALL of the EPA Regions to follow the lead of those that have gone to the effort of approving ATP requests for limited use of LDO. It's beyond my understanding why EPA can't just issue a one sentence memo..."Use of LDO is allowed for NPDES compliance testing...period" I know...I know...that's too easy...
Perry |
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| | | Supreme Being
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| P. Brake (4/25/2008)
As much as I wish the April 14 memo were HQ EPA's approval to use LDO, I don't read it that way. I see it as HQ EPA encouraging ALL of the EPA Regions to follow the lead of those that have gone to the effort of approving ATP requests for limited use of LDO. It's beyond my understanding why EPA can't just issue a one sentence memo..."Use of LDO is allowed for NPDES compliance testing...period" I know...I know...that's too easy...
Perry
It is a little better than that. The ATP has already been accepted by HQ EPA. The underlying data is already available and can be submitted to any EPA region that has questions. IN MOST cases all a user should have to do is say they are going to use it. There is at least one region that is refusing to accept the data and is requiring additional data from the user. That is a real shame because the study was an interlaboratory one. In Colorado we have had some submit the data to local regulators along with the letter from the EPA and they were granted a go ahead right away. As you can imagine this is a real headache for us. We can't give straight answers because we really can't get straight answers to give.
Christopher Fair
R&D Chemist III
Hach Company
cfair@hach.com
www.boddoctor.com |
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| | | Supreme Being
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| | That's exactly my point, Chris. HQ EPA leaves it up to the individual regions to approve use of LDO, and at least one of them (which I won't name) requires each NPDES permittee to submit an ATP approval request to show that for their wastewater, LDO and currently approved DO measurement methods provide essentially identical data. Bureaucracy at its best! Perry |
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| | | Forum Guru
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| | ok, folks. Which region isn't willing to accept LDO? Why don't you wanna say? |
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| | | Supreme Being
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| I will try and find out for you. I don't don't remember which one won't accept the LBOD outright. So far I don't think there are any that won't let you use it if you do a side by side study for them first.
Christopher Fair
R&D Chemist III
Hach Company
cfair@hach.com
www.boddoctor.com |
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| | | Supreme Being
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Last Login: Today @ 3:10:37 PM
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| I hope this doesn't constitute advertising because I don't want to do that, but on the Hach Website there is a very useful map that helps you find out the status of your state. There is also a packet available for requesting approval in states where approval has not been granted yet. To get the packet for your state you just click on your state on the map.
http://www.hqdmeter.com/epa/epa.htm
Christopher Fair
R&D Chemist III
Hach Company
cfair@hach.com
www.boddoctor.com |
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