If your laboratory runs samples for Clean Water Act compliance, you should be aware of the 2017 Methods Update Rule finalized by the EPA. This regulation was effective on September 27, 2017.
EPA is promulgating changes to analytical test procedures that are used by industries and municipalities to analyze the chemical, physical, and biological components of wastewater and other environmental samples that are required by regulations under the Clean Water Act.
The changes include revised methods published by EPA and voluntary consensus standard bodies, such as ASTM International and the Standard Methods Committee. EPA is adding certain methods reviewed under the alternate test procedures (ATP) program to 40 CFR Part 136 and clarifying the procedures for EPA approval of nationwide and limited use ATPs. Further, EPA is revising the procedure for determination of the method detection limit (MDL).
Why is EPA proposing these changes?
EPA Believes that these revisions:
- provide increased flexibility to the regulated community
- improve data quality
- update the methods, to keep current with technology advances
- address laboratory contamination issues related to the MDL and better account for intra-laboratory variability.
For example, updating to revised versions of currently approved methods improves data quality because the new versions often clarify or improve the method instructions, improve the method quality control, or make editorial corrections.
Do these changes affect me?
Examples where EPA-approved analytical methods must be used under the CWA include, among others: (1) Applications for NPDES permits, (2) sampling or other reports required under NPDES permits, (3) other requests for quantitative or qualitative effluent data under the NPDES regulations, (4) State CWA 401 certifications and (5) sampling and analysis required under EPA’s General Pre-Treatment Regulations for Existing and New Sources of Pollution 40 CFR 136.1 and 40 CFR 403.12(b)(5)(v). Keep in mind that you usually have a choice of analytical methods for a specific analyte, because more than one EPA-approved method generally is available. If your laboratory hasn’t contacted you to discuss these proposed changes to your NPDES projects, we suggest you contact them.
Your facility may also be affected even if you’re not regulated under the CWA. Many CWA-approved methods are used for non-CWA projects to analyze parameters for which other methods are not available. For example, SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (analytical methods approved for use in complying with RCRA regulations) does not include a method for alkalinity. If your RCRA project analyzes for alkalinity a CWA-approved method might be used.