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

2. 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

3. 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Withdrawn from the FR, being reconsidered

4. 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 D 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.

5. 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.

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

7. 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

8. 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

9. 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

10. 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)

11. PCB Cong. Method Cont.
Aqueous Mean Matrix Spike Recovery

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

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

14. ATP Reviews
Alternate test procedures (ATPs) for nationwide use are submitted to EPA HQ for review
Codified at 40 CFR and 136.5
Protocols for EPA review of alternate test procedures are available at:
The Clean Water Act Alternate Test Procedure (ATP) program is described at 40 CFR and 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 (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.

15. 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

16. 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:
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.