Clean Water Act Methods Overview of EPA’s CWA Method Activities August 2017• Adrian Hanley, U.S. EPA

CWA Analytical Methods Program Many industries and municipalities are permitted under the CWA NPDES program to discharge pollutants They use analytical methods to analyze the chemical, physical, and biological components of wastewater and other environmental samples CWA requires EPA, through rulemaking, to establish test procedures to measure pollutants for CWA programs EPA promulgates test procedures in 40 CFR Part 136

Method Update Rule (MUR) Clean Water Act Methods Update Rule for the Analysis of Effluent Proposed February 19, 2015 175 sets of comments received Originally signed on December 15, 2016 Withdrawn from the FR, being reconsidered

6 Alternate Test Procedures (ATPs) 1 USGS Method (based off of an ATP) 2015 MUR Proposal Summary Proposed ~100 method revisions from ASTM International and Standard Methods 6 Alternate Test Procedures (ATPs) 1 USGS Method (based off of an ATP) Revisions to Methods 608, 624, and 625 Method Detection Limit (MDL) Revision The method revisions are minor changes/updates to methods that are already in 40 CFR 136.  They usually are wording changes and small additions or clarifications to the method.  They do not contain any significant procedural changes or changes to the QC requirements.  For instance, ASTM Standard D0516 - 2007 will likely be changed to the more updated version D0516 – 2011. Alternate testing procedures are typically submitted by vendors who would like to approve a new technology to be used as part of a method already in 40 CFR 136.  These applications are throughly reviewed by my division’s Alternate Testing Procedure Program.  The applications usually require that the technology is tested in 9 matrices at 9 different laboratories before they are approved (less testing is required for technologies that are only applying for use in one industry).  The revision to the Method Detection Limit (Appendix B of 40 CFR 136) was submitted by the NELAC institute.  It has already been reviewed and revised extensively by my office, and a few hundred other people from EPA, laboratory organizations, states, and industry.  It is a small addition to the current procedure that adds a step to account for laboratory contamination.

CWA Microbiology Method Activities Coliphage method Completed multi-laboratory validation for wastewater and recreational water Method and study report forthcoming Human microbial source tracking ORD collaboration Completed multi-laboratory validation study for recreational water Coliphage = bacterial virus The coliphage method includes male specific and somatic.

CWA Chemistry Method Activities Peracetic acid and hydrogen peroxide method Continuous monitoring – total residual chlorine PCB congener method ATP reviews

Peracetic Acid and H2O2 Alternative antimicrobial Almost no residual – unlike chlorine Hydrogen peroxide and acetic acid byproducts Already in use at some POTWs Drafting white paper (pre-study plan) Received input from multiple vendors and voluntary consensus standard bodies Colorimetric method most commonly used Must be performed onsite Degrades quickly

Continuous Monitoring Total residual chlorine pilot study Based on EPA Drinking Water Method 334.0 Recruited POTWs to generate side-by-side data for monitors and an onsite lab One POTW currently compiling data packages Next steps may include a multi-utility study

PCB Congener Method Single-laboratory validation goals: Identifies and quantifies PCB contamination using individual congeners Improves sensitivity over Method 608, less sensitive than typical laboratory background Implementable at a typical mid-sized full-service environmental laboratory Single-laboratory testing completed Drafting method and study report

PCB Cong. Method Cont. Quantification Extraction Sensitivity 29 carbon-13 isotope dilution standards Calibration of 65 congeners Other 144 congeners quantified indirectly Extraction Tested 2 SPE procedures and 1 LLE procedure Tested Soxhlet extraction for biosolids, sediment, and fish tissue Sensitivity Aqueous MDL generally 0.2 to 1.5 ng/L (except mono chloro congeners)

PCB Cong. Method Cont. Aqueous Mean Matrix Spike Recovery

PCB Cong. Method Cont. Aqueous Min/Max Matrix Spike Recovery

PCB Cong. Method Cont. Want more details? See poster presentation!

ATP Reviews Alternate test procedures (ATPs) for nationwide use are submitted to EPA HQ for review Codified at 40 CFR 136.4 and 136.5 Protocols for EPA review of alternate test procedures are available at: https://www.epa.gov/cwa-methods/alternate-test-procedures The Clean Water Act Alternate Test Procedure (ATP) program is described at 40 CFR 136.4 and 136.5. This program provides a mechanism for submission and review of an application for nationwide use or limited use of an ATP for measurement of a pollutant as an alternative to the methods approved at 40 CFR Part 136. An ATP may fall into one of two categories: A method using a determinative technique (e.g., a pollutant detector) different from that in an existing Part 136 method (for method validation and evaluation purposes this type of method is referred to as a new method), or A modification to a Part 136 method that falls outside the scope of the modification flexibility described in the Part 136 method, or at 40 CFR 136.6 (for validation and evaluation purposes this type of method is referred to as an ATP). A method developer may apply for review of a method modification or a new method through the ATP program.

Anticipated Projects Microbiology Chemistry Cyanotoxin single-laboratory study Chemistry Multi-laboratory validation of PCB congener method Multi-laboratory validation of 608.3, 624.1, and 625.1 Total nitrogen

For more information or additional feedback, please contact: Contact Information For more information or additional feedback, please contact: Adrian Hanley, US EPA CWA Method Team Leader Office of Science and Technology Office of Water Phone: 202-564-1564 E-Mail: hanley.adrian@epa.gov Does anyone have any questions, comments, or feedback? If you have additional comments or would like to provide feedback on the issues raised in this presentation, please feel free to contact me.