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Chapter 3   Regulatory Reporting vs. Process Control

 

                 Analyses performed in the wastewater laboratory can be categorized by the use to which the data will be applied.  The first category of analyses is that performed as a result of a monitoring requirement imposed by the municipality, state or federal government often in support of a National Pollutant Discharge Elimination System (NPDES) permit.  Analyses fitting in this category are termed either “regulatory reporting”, or “compliance monitoring”.  The other category of analyses results from the need to obtain quantitative measures about some aspect of the plant operations which lead to decisions as to whether or not the plant is performing as designed.  These types of analyses are termed “process control”. 

                 The major difference between the two categories of testing exists in the test methods, although this is, for the most part, highly artificial.  For compliance monitoring, the laboratory must use methods approved by the regulatory agency.  The federally approved methods are published in Title 40, Code of Federal Regulations, Part 136 (40 CFR 136).  An updated version of 40 CFR 136 is published by the Government Printing Office on 1 July every year in the Federal Register.  These amendments are printed in 40 CFR 136 at the next annual update, but are effective as of the publication date of the Federal Register notice.  A major amendment was printed in the 31Jan1994 issue of the Federal Register.  It is reproduced in Table 1.  The EPA methods are from EPA manuals and the Standard Method citations are from the 18th Edition of Standard Methods for the Examination of Water and Wastewater.  A number of ASTM (American Society for Testing Materials) and USGS (US Geological Survey) methods are also approved, however they are rarely encountered in the municipal wastewater laboratory.  The Georgia EPD (Georgia Environmental Protection Division) accepts as approved methods those listed in Table 1.

                 Approved methods have several characteristics in common.  They are written, detailed, step-by-step instructions for the preparation of reagents and standards, calibrating the method, performing the test procedure and determining the accuracy and precision of results.  The chemistry of the method has been examined by experts and found to be suitable.  Possible and actual interferences are identified and avoidance measures specified.  The method has been verified by testing in a large number of laboratories.  In general, when methods are listed as approved which are not EPA or Standard Methods procedures, this means the chemistry of the method has been examined by a panel of experts and found to be suitable as a procedure for measurement of the tested parameter.  However, in most cases the directions provided by the manufacturer are unsuitable for establishing the analytical validity of the method, i.e. the test procedure must be fully calibrated by the analyst and other quality control measures taken to ensure the test is giving reliable results free from interferences and laboratory artifacts, whether the manufacturer mentions these or not.

 

Table 1. Approved methods for NPDES compliance monitoring

parameter

epa

standard methods

other

Acidity (as Calcium Carbonate)

305.1

2310 B

 

Alkalinity (as Calcium Carbonate)

310.1, 310.2

2320 B

 

Ammonia (as N)

 

 

 

    Manual distillation followed by:

350.2

4500-NH3 B

 

    Nesslerization

350.2

4500-NH3 C

 

      Titration

350.2

4500-NH3 E

 

      Electrode

350.2

4500-NH3 F or G

 

      Automated Phenate

350.2

4500-NH3 H

 

Biochemical Oxygen Demand

405.1

5210 B

 

Chemical Oxygen Demand

 

 

 

    Titrimetric

410.1, 410.2, 410.3

5220 C

 

    Spectrophotometric

410.4

5220 D

 

Chloride

 

 

 

    Titrimetric (silver nitrate)

 

4500-Cl ¯ B

 

    Titrimetric (mercuric nitrate)

325.3

4500-Cl ¯ C

 

    Colorimetric, automated

325.1, 325.2

4500-Cl ¯ E

 

Chlorine, total residual

 

 

 

330.1

4500-Cl ¯ D

 

    Iodometric, direct titration

330.3

4500-Cl ¯ B

 

    Back titration, either endpoint

330.2

4500-Cl ¯ C

 

    DPD-FAS titration

330.4

4500-Cl ¯ F

 

    DPD spectrophotometric

330.5

4500-Cl ¯G

 

    Electrode

 

 

 

Copper (Total, digested)

 

 

 

    AA direct aspiration

220.1

3111 B or C

 

    AA furnace

220.2

3113 B

 

    ICP/AES

200.7

3120 B

 

    Colorimetric (Neocuproine)

 

3500-Cu D

 

    Colorimetric (Bicinchoninate)

 

3500-Cu E

 

Cyanide (Total, distilled)

 

 

 

    Titrimetric

 

4500-CN C

 

    Spectrophotometric manual

335.3

4500-CN E

 

    Spectrophotometric automated

335.3

 

 

Fluoride (Total, distilled)

 

4500-F ¯ B

 

    Electrode manual

340.2

4500-F ¯ C

 

    Colorimetric (SPADNS)

340.1

4500-F ¯ D

 

    Automated Complexone

340.3

4500-F ¯ E

 

Hardness (as Calcium Carbonate)

 

 

 

    Automated colorimetric

130.1

 

 

    Titrimetric or calculated from ICP

130.2

2340 C

 

Hydrogen ion (pH)

 

 

 

    Electrometric

150.1

4500-H + B

 

Iron (Total, digested)

 

 

 

    AA direct aspiration

236.1

3111 B or C

 

    AA furnace

236.2

3113 B

 

    ICP/AES

200.7

3120 B

 

    Colorimetric (Phenanthroline)

 

3500-Fe D

 

Kjeldahl Nitrogen (Total as N)

 

 

 

    Digestion and distillation followed by

351.3

4500-NH3 B or C

 

    Titration

351.3

4500-NH3 E

 

    Nesslerization

351.3

4500-NH3 C

 

    Electrode

351.3

4500-NH3 F or G

 

    Automated phenate

351.1

 

 

    Block digester colorimetric

351.2

 

 

    Manual or block digester colorimetric

351.4

 

 

Nitrate

 

 

 

    Colorimetric (Brucine sulfate)

352.1

 

 

    Nitrate-Nitrite (N) minus Nitrite (N)

352.1

 

 

Nitrate-Nitrite (N)

 

 

 

    Manual cadmium reduction

353.3

4500-NO3 E

 

    Automated cadmium reduction

353.2

4500-NO3 F

 

    Automated hydrazine

353.1

4500-NO3 H

 

Nitrite (N)

 

 

 

    Manual spectrophotometric

354.1

 

 

Oil and Grease

 

 

 

    Gravimetric Total recoverable

413.1

5520 B

 

Orthophosphate

 

 

 

    Automated ascorbic acid

365.1

4500-P F

 

    Manual single reagent

365.2

4500-P E

 

    Manual two reagent

365.3

 

 

Oxygen, dissolved

 

 

 

    Winkler (azide modification)

360.2

4500-O C

 

    Electrode

360.1

4500-O G

 

Phenols (manual distillation)

 

 

 

    Colorimetric 4AAP

420.1

 

 

    Automated 4AAP

420.2

 

 

Residual, total

160.3

2540 B

 

Residual, filterable

160.1

2540 C

 

Residual, settleable

160.5

2540 F

 

Residual, volatile

160.4

2540 E

 

Sulfate

 

 

 

    Automated colorimetric

375.1

 

 

    Gravimetric

375.3

4500-SO4 -2 C or D

 

    Turbidimetric

375.4

 

 

Sulfide

 

 

 

    Titrimetric

376.1

4500-S -2 E

 

    Colorimetric

376.2

45000S -2 D

 

Temperature

170.1

2550 B

 

Turbidity, Nephelometric

180.1

2130 B

 

Zinc (Total, digested)

 

 

 

    AA direct aspiration

289.1

3111 B or C

 

    AA furnace

289.2

 

 

    ICP/AES

200.7

3120 B

 

    Dithizone colorimetric

3500-Zn E

 

 

    Zincon colorimetric

3500-Zn F

 

 

 

                 The heart of the regulatory reporting process is the National Pollutant discharge Elimination System (NPDES) permit and the Discharge Monitoring Report (DMR), EPA Form 3320 -- I will insert  here soon---

  The information supplied on the monthly DMR relies upon a self-monitoring program.  The signature of the facility manager at the bottom of Form 3320 is a legal verification that the monitoring was conducted according to all applicable regulations and  further, that the person accepts full legal responsibility for the reported monitoring.  EPA and EPD have found that civil penalties are insufficient to enforce compliance with these regulations and have now turned to criminal prosecution with the attached threat (they have followed through in some cases) of felony convictions and penal system quality time.

                 It is not the legal responsibility of the equipment supplier nor the contract laboratory to ensure compliance.  It is the facility manager’s responsibility.  A close examination of regulations and contact with regulatory representatives on a continuing basis is the only way to obtain correct information about what is approved and what is not.  The laws are in place for the health and well-being of all people.  The intent and spirit of the law is to goad us into doing what we should be doing without threats.  The long term benefits are for us all.

                 Each facility which produces wastewater and is discharged to a receiving stream is required to have a NPDES permit, industries which do not discharge to a receiving stream are permitted by the State of Georgia to dispose of the wastestream by other methods.  In Georgia, the NPDES permits and other applicable permits (LAND APPLICATION, AIR QUALITY) are issued by the Environmental Protection Division of the Department of Natural Resources under the authority of the Georgia Water Quality Control Act (Georgia Laws 1964, p. 416, as amended).  The centerpiece of the permit is the table of “Effluent Limitations and Monitoring Requirements”.  An example of such a table is provided in Appendix II (real soon).  In 1955, EPD changed the standard language (boilerplate?) for NPDES permits to read as follows:

PART I

EPD is the Environmental Protection Division of the Department of Natural Resources of the State of Georgia

The Federal Act referred to is the Clean Water Act

The State Act referred to is the Water Quality Control Act (Act No. 870)

The State Rules referred to are The Rules and Regulations for Water Quality Control (Chapter 391-3-6)

 

A.     SPECIAL CONDITIONS

1.  Monitoring

The concentration of pollutants in the discharge will be limited as indicated by the table(s) labeled “Effluent Limitations and Monitoring Requirements”.  The effluent shall meet the requirements in the table(s) or the conditions in paragraph I.A.1.a, whichever yields the higher quality effluent.

a.  For 5 day biochemical oxygen demand (BOD5) and total suspended solids (TSS), the arithmetic mean of values of the effluent samples collected during the month shall not exceed 15 percent of the arithmetic mean of values for influent samples collected at approximately the same times (or 85 percent removal).  For water pollution control plants