United States
Environmental Protection
Agency
Off ice of Water
Mail Code 4303
EPA821-B-99-003
August 1999
&EPA
Analytical Method Guidance for the
Pharmaceutical Manufacturing
Point Source Category
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Contents
1 Introduction 1-1
2 Overview of Approved Analytical Methods for Complying with the
Pharmaceutical Regulation 2-1
What parameters are being regulated? 2-1
What are the approved analytical methods for the regulated parameters? 2-1
Where can these approved analytical methods be found? 2-2
3 Flexibility in Performing Analytical Methods 3-1
Is there flexibility in performing analytical methods? 3-1
Why would a method be modified? 3-1
How does someone demonstrate equivalency of a modified method? 3-2
4 Solutions to Matrix Problems 4-1
How to Solve Matrix Problems Involving Volatile Organic Pollutants 4-1
Use of selective GC detectors 4-1
Micro-extraction and gas chromatography with selective detectors 4-1
Sample dilution 4-1
Isotope dilution 4-2
How to Solve Matrix Problems Involving Semivolatile Organic Pollutants 4-2
Use of selective GC detectors 4-2
pH change 4-2
Gel-permeation (size-exclusion) chromatography 4-2
Solid-phase extraction (SPE) cartridge 4-2
Florisil, alumina, and silica gel 4-2
Isotope dilution 4-2
5 Choosing the Appropriate Analytical Method 5-1
Which parameters should be measured in the wastewater? 5-1
What are the approved analytical methods for the wastewater? 5-1
How does someone choose between approved methods? 5-1
Can the analytes that need to be monitored be grouped? 5-2
Is the analytical method chosen sensitive enough? 5-3
How much does an analysis using the analytical method cost? 5-4
How does someone determine if there will be wastewater matrix
interference problems? 5-4
6 Answers to Specific Concerns from Industry Regarding Analytical Methods 6-1
Isotope Dilution Methods 6-1
Office of Solid Waste (OSW) SW-846 Methods 6-1
Transfer of an Analyte Between Methods 6-2
Is This Guidance Applicable to Other Rules? 6-4
Second Column Confirmation Using Method 1671 6-4
Can Different Labeled Compounds be Used with the Isotope Dilution Methods? ... 6-4
What Laboratories are Capable of Practicing the Approved Methods? 6-4
In What Fraction (Volatiles or Semi-Volatiles) are the Analytes That Are
Determined by Direct Aqueous Injection? 6-4
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Contents (Continued)
7 Where to Get Additional Help 7-1
Documents Supporting the 1998 Promulgated Rule 7-1
Documents on Compliance Monitoring and Methods 7-2
Websites 7-2
Tables
2-1 Pollutants Regulated Under Effluent Limitations Guidelines and Standards 2-3
2-2 Approved Test Methods 2-5
5-1 Test Methods for Example Analytes 5-2
5-2 Limitations for Example Analytes 5-3
5-3 Pharmaceutical Effluent Limitations for Direct Discharging Facilities 5-5
5-4 Pharmaceutical Effluent Limitations for Indirect Discharging Facilities 5-6
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Disclaimer
This Analytical Methods Guidance (Guidance) is provided to help implement national policy on
effluent limitations guidelines and standards for the pharmaceutical industry. This Guidance
does not, however, substitute for the CWA or EPA's regulations, nor is it a regulation itself.
Thus, it cannot impose legally binding requirements on EPA, States, or the regulated community
and may not apply to a particular situation based upon case-specific circumstances. EPA and
State decision makers retain the discretion to adopt approaches on a case-by-case basis that
differ from this Guidance where appropriate. EPA may change this Guidance in the future.
IV
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Executive Summary
On September 21, 1998, the U.S. Environmental Protection Agency (EPA)
promulgated revised regulations for the pharmaceutical industry to control both
effluent discharges and air emissions. The purpose of this Guidance is to assist
dischargers in the selection of appropriate methods for determination of pollutants in
wastewater from pharmaceutical facilities with operations in fermentation; extraction; chemical
synthesis; mixing, compounding, and formulating; and research. The material presented is
intended solely for guidance and does not alter any statutory requirements.
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Introduction
o
n September 21, 1998, the U.S. Environmental Protection Agency (EPA)
promulgated final effluent limitations guidelines and standards at 40 CFR 439 under
the Clean Water Act (CWA) for the following four subcategories of the
pharmaceutical industry:
Subcategory A Fermentation
Subcategory B Extraction
Subcategory C Chemical Synthesis
Subcategory D Mixing, Compounding, and Formulating
EPA also reformatted and clarified language without revision to certain specified provisions in
the Subcategory E - Research Subcategory. This Guidance is specifically written to help in
selecting appropriate methods to measure pollutants in wastewater from pharmaceutical facilities
that fall within the purview of the subcategories listed above. To help in this process, EPA has
addressed the following topics:
Section 2 presents an overview of the parameters regulated in the final effluent
limitations guidelines and standards and approved methods to analyze for these
parameters;
Section 3 discusses flexibility in performing the approved analytical methods
and equivalence among methods;
Section 4 discusses how to solve matrix problems;
Section 5 walks through the process of choosing the most appropriate analytical
method to use in analyzing for regulated parameters; and
Section 6 presents responses to specific concerns from industry regarding
analytical methods.
1-1
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EPA hopes that this Guidance provides help on the use of analytical methods when measuring
for parameters from facilities with operations in the above mentioned subcategories in an easy-
to-read format. While this Guidance attempts to address issues and situations that may be
covered by the regulation, there are other sources that one may wish to consult in selection of an
analytical method for facilities that conduct Subcategory A, B, C, D and E operations.
Therefore, this Guidance identifies and references other sources throughout the text that provide
additional guidance. Also included in Section 7 is a list of these and other sources, and a list of
EPA and other authorities to contact for more guidance.
1-2
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Overview of Approved
Analytical Methods for
Complying with the
Pharmaceutical
Regulation
This section provides a brief overview of the parameters (analytes) regulated under the
pharmaceutical effluent limitations guidelines and standards. It also provides a
description of approved analytical methods, and where these methods can be located.
For more background information on the parameters regulated or the approved
analytical methods, refer to the Pharmaceutical Manufacturing Category Effluent Limitations
Guidelines, Pretreatment Standards, and New Source Performance Standards; Final Rule at 40
CFR Parts 136 and 439.
What parameters are being regulated?
In the September 21, 1998 rule, EPA established effluent limitations guidelines and standards
for conventional, toxic, and nonconventional pollutants found in wastewater from
pharmaceutical facilities in Subcategories A, B, C, and D. Table 2-1 presents a comprehensive
list of pollutants regulated for these facilities; however, not all pollutants listed are regulated at
each regulatory level. These pollutants are also listed in 40 CFR 439.
What are the approved analytical methods for the regulated parameters?
Dischargers are required to use the test methods promulgated in tables at 40 CFR 136.3 or
incorporated by reference in those tables, when available, to monitor pollutant discharges from
the pharmaceutical manufacturing industry, unless specified otherwise by the permitting
authority. The full list of approved test methods for the conventional, toxic, and non-
conventional pollutants regulated under the effluent limitations guidelines and standards for the
pharmaceutical industry are presented in Table 2-2. Applicable drinking water methods that
have been promulgated at 40 CFR Part 141 and American Society for Testing Materials
(ASTM) Methods D3371, D3695, and D4763 have been incorporated by reference in 40 CFR
136.3. Also, EPA Methods 1666, 1667, and 1671 have been promulgated with the final
2-1
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pharmaceutical effluent limitations guidelines and standards and may be used to monitor
discharges from the pharmaceutical industry.
In addition EPA expects to promulgate a performance-based measurement system (PBMS) for
water programs in the Federal Register during 1999. PBMS is designed to increase the
flexibility to select suitable analytical methods for compliance monitoring, and would reduce the
need for prior EPA approval of methods. Under PBMS, EPA would specify "performance
criteria" for methods, which the Agency would derive from the existing approved methods. For
additional information on PBMS, see the proposed rule published March 28, 1997 (62 FR
14976) and the notice of intent to adopt PBMS Agency-wide, published October 6, 1997 (62 FR
52098).
Where can these approved analytical methods be found?
Some EPA test methods are published at 40 CFR 136, Appendix A, while other methods are
available in compendia. Test methods for pharmaceutical pollutants of concern published at 40
CFR 136, Appendix A are methods 601, 602, 604, 612, 624, 625, 1624, and 1625. Compendia
of pharmaceutical methods are available from the National Technical Information Services
(NTIS) PB91-231480 and PB92-207703, U.S. Department of Commerce, 5285 Port Royal
Road, Springfield, Virginia 22161. The NTIS toll free number is 1-800-553-6847. These EPA
methods are published in the following compendia:
EPA Methods 1666, 1667, and 1671 - Analytical Methods for the
Determination of Pollutants in Pharmaceutical Manufacturing Industry
Wastewater (EPA 821-B-98-016). This compendium is also available from the
pharmaceutical rulemaking action homepage on the World Wide Web.
EPA Method 502.2 -Methods for the Determination of Organic Compounds
in Drinking Water (EPA-600/4-88-039)
EPA Method 524.2 -Methods for the Determination of Organic Compounds
in Drinking Water-SupplementII (EPA-600/R-92-129)
ASTM test methods D3371, D3695, and D4763 are available from the American Society for
Testing and Materials, 100 Barr Harbor Drive, West Conshohocken, Pennsylvania 19428-2959
(610-832-9500).
2-2
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Table 2-1: Pollutants Regulated Under Effluent Limitations Guidelines and Standards1
Pollutants
BOD5
Chemical oxygen demand (COD)
pH
TSS
Acetone
Acetonitrile
Ammonia
n-Amyl acetate
Amyl alcohol
Benzene
n-Butyl acetate
Chlorobenzne
Chloroform
Cyanide
o-Dichlorobenzene
1 ,2-Dichloroethane
Diethylamine
Dimethyl sulfoxide
Ethanol
Ethyl acetate
n-Heptane
n-Hexane
Isobutyraldehyde
Isopropanol
Isopropyl acetate
Isopropyl ether
Methanol
Methyl cellosolve
Methyl formate
Methyl isobutyl ketone (MIBK)
Methylene chloride
Phenol
Subcategory
A
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Subcategory
B
/
/
/
/
/
/
/
/
/
Subcategory
C
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
/
Subcategory
D
/
/
/
/
/
/
/
/
/
Subcategory
E
/
/
/
/
2-3
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Table 2-1 (Continued)
Pollutants
Tetrahydrofuran
Toluene
Triethylamine
Xylenes
Subcategory
A
/
/
/
/
Subcategory
B
Subcategory
C
/
/
/
/
Subcategory
D
Subcategory
E
'Not all pollutants are regulated at each regulatory level.
2-4
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Table 2-2: Approved Test Methods
Pharmaceutical Pollutants
BOD5
COD
TSS
pH
acetone (2-propanone)
acetonitrile
ammonia (as N)
n-amyl acetate
n-amyl alcohol
benzene
n-butyl-acetate
tert-butyl alcohol
CAS Registry No.
C-002
C-004
C-009
C-006
67-64-1
75-05-8
1336-21-6
628-63-7
71-41-0
71-43-2
123-86-4
75-65-0
Analytical Method Number
405.1
410.1
410.2
410.3
410.4
160.2
150.1
D3695
D4763
524.2
1624
1666
1671
D3371
D3695
350.2
350.3
350.1
1666
D3695
1666
D3695
602
624
1624
D4763
D3695
502.2
524.2
1666
D3695
1666
Minimum Level1
2mg/L
50 mg/L
5mg/L
250 mg/L
3 mg/L; 20 mg/L2
4 mg/L
N/A
TBD
TBD
TBD
50^ig/L
5 mg/L
50 mg/L
TBD
TBD
50^ig/L
50^ig/L
10ug/L
5ug/L
TBD
500 ug/L
TBD
0.5 ug/L
10ug/L
10ug/L
TBD
TBD
TBD
TBD
5ug/L
TBD
100 ug/L
2-5
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Table 2-2 (Continued)
Pharmaceutical Pollutants
chlorobenzene
chloroform
cyanide(total)
o-dichlorobenzene
1,2-dichloroethane
diethylamine
dimethyl sulfoxide
ethanol
CAS Registry No.
108-90-7
67-66-3
95-50-1
107-06-2
109-89-7
67-68-5
64-17-5
Analytical Method Number
601
602
624
1624
502.2
524.2
601
624
1624
502.2
524.2
551
335.2
335.3
601
602
612
624
625
1625
502.2
524.2
601
624
1624
D3695
502.2
524.2
1666
1671
1666
1671
1666
1671
D3695
Minimum Level1
lug/L
0.5 ng/L
20^g/L
10ug/L
TBD
TBD
0.2 ng/L
5.0 ng/L
10ug/L
TBD
TBD
TBD
TBD
TBD
0.5 ng/L
l.Oug/L
5.0 ng/L
ND
5.0 ng/L
10ug/L
TBD
TBD
O.lug/L
10ug/L
10ug/L
TBD
TBD
TBD
200 mg/L
50 mg/L
100 mg/L
20 mg/L
20 mg/L
2 mg/L
TBD
2-6
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Table 2-2 (Continued)
Pharmaceutical Pollutants
ethyl acetate
n-heptane
n-hexane
isobutyr aldehyde
isopropanol
isopropyl acetate
isopropyl ether
methanol
Methyl Cellosolveฎ
methylene chloride
methyl formate
4-methyl-2-pentanone (MIBK)
phenol
CAS Registry No.
141-78-6
142-82-5
110-54-3
78-84-2
67-63-0
108-21-4
108-20-3
67-56-1
109-86-4
75-09-2
107-31-3
108-10-1
108-95-2
Analytical Method Number
1666
D3695
1666
D3695
1666
D3695
1666
1667
1666
D3695
1666
D3695
1666
D3695
1666
1671
D3695
1666
1671
601
624
1624
502.2
524.2
1666
1624C
1666
D3695
D4763
524.2
604
625
1625
D4763
Minimum Level1
10 ug/L
TBD
10 ug/L
TBD
10 ug/L
TBD
10 ug/L
50 ug/L
200 ug/L
TBD
10 ug/L
TBD
5 ug/L
TBD
50 mg/L
2mg/L
TBD
50 mg/L
20 mg/L
1.0 ug/L
10 ug/L
10 ug/L
TBD
TBD
100 ug/L
50 ug/L
10 ug/L
TBD
TBD
TBD
0.5 ug/L
5.0 ug/L
10 ug/L
TBD
2-7
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Table 2-2 (Continued)
Pharmaceutical Pollutants
n-propanol
tetrahydrofuran
toluene
triethlyamine
xylenes3
CAS Registry No.
71-23-8
109-99-9
108-88-3
121-44-8
N/A
Analytical Method Number
1666
1671
D3695
1666
524.2
602
624
1624
D3695
D4763
502.2
524.2
1666
1671
1624C
1666
Minimum Level1
20 mg/L
50 mg/L
TBD
20 ug/L
TBD
0.5 ug/L
20 ug/L
10 ug/L
TBD
TBD
TBD
TBD
200 mg/L
50 mg/L
10 ug/L
10 ug/L, 5 ug/L
'Some analytical methods report a Method Detection Limit (MDL) only. This specifically applies to the 600-series methods. In
those cases, EPA calculated a minimum level (ML) from the MDL originally reported in the method. The minimum level value
was determined by multiplying the MDL by 3.18 and rounding to the nearest number in the series (1, 2, or 5) x 1 On, where n is an
integer. In addition, EPA added MLs for the Method 1624C entries associated with 4-methyl-2-pentanone and xylenes. These
Method 1624C MLs correspond to the reporting limits used in EAD's analytical databases.
2For Method 410.4, two MLs are listed. The 3 mg/L ML corresponds to the automated procedure, and the 20 mg/L ML
corresponds to the manual procedure.
3m+p-xylene (CAS No. 136777-61-2) has a ML of 10 ug/L, while o-xylene (CAS No. 95-47-C) has a ML of 5 ug/L in Method
1666.
TBD - To be determined from the analytical method by the laboratory. The laboratory must first use the MDL procedure
specified in 40 CFR Part 136, Appendix B, and then calculate the ML from the MDL using the procedure specified in footnote 1
above. The resulting ML must be equal to or less than the ML listed for that analyte in Table 2-2 or must be less than or equal to
the regulatory compliance level specified by the control authority.
ND - not determined
N/A - not applicable
2-8
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Flexibility in
Performing Analytical
Methods
This section discusses flexibility in analytical methods applicable to wastewater from
pharmaceutical operations. This section also discusses the process of demonstrating
equivalency using a modified analytical method. This discussion is summarized from
Guidance on Evaluation, Resolution, and Documentation of Analytical Problems
Associated with Compliance Monitoring (EPA 821-B-93-001).
Is there flexibility in performing analytical methods?
In promulgating analytical methods for measurement of pollutants, EPA has provided flexibility for
dealing with interferences. The major flexibility options are discussed in the preamble to the 40 CFR
Part 136 methods (49 FR 43234) and include a mechanism for obtaining approval of an alternative
test procedure on a nationwide basis and/or on a site-specific basis (40 CFR 136.4 and 136.5). In
addition to the flexibility outlined in 40 CFR Part 136, flexibility is permitted in each analytical
method. The analyst is permitted to "improve separations or lower the cost of analyses" provided
that the results obtained are not less precise and accurate than the results obtained using the
unmodified method."
Why would a method be modified?
The objective in modifying a method is to overcome interferences and to make the method more
specific for a given pollutant, more sensitive, more accurate, or in some other way improve the
method. Improvements can be made to a method but require the analyst to demonstrate that results
by any modification would be equal to or better than results obtained with the unmodified method.
3-1
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How does someone demonstrate equivalency of a modified method?
The performance of a modified method is measured by precision and bias or recovery, and can be
extended to include detection limit, gas chromatographic resolution, mass spectral resolution, and
other measures of method performance. A start-up test is required prior to practicing a method. This
test is described in detail in Section 8 of the 600-series and 1600-series wastewater methods and is
also used in the Office of Drinking Water 500-series methods. Results of the start-up test must meet
the precision and recovery requirements of that method. After the requirements are met for the
unmodified method the start-up test must be repeated with the modification as a part of the modified
method. The modification is permitted if the precision and recovery specified in the unmodified
method are achieved.
3-2
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Solutions to Matrix
Problems
T
his section describes some of the available solutions to matrix interference problems.
These solutions are summarized from the document, Guidance on Evaluation, Resolution,
and Documentation of Analytical Problems Associated with Compliance Monitoring
(EPA 821-B-93-001).
How to Solve Matrix Problems Involving Volatile Organic Pollutants
Some of the available solutions to matrix problems for volatile organic pollutants are:
Use of selective GC detectors
The specificity provided by the electrolytic conductivity detector allows the detection of halogenated
analytes in complex matrices. Likewise the photoionization detector allows the detection of aromatic
analytes in complex matrices. For example, if chloroform is being monitored at the daily maximum
pretreatment limit of 0.02 mg/L, and the unregulated compounds methanol, ethanol, and/or propanol
interfere with EPA Method 624, EPA Method 601 will allow the sample to be diluted by a factor of
more than 100 because the MDL in EPA Method 601 (0.00005 mg/L) is 400 times lower than the
limit. Similarly, EPA Method 502.2 would allow the sample to be diluted by a factor of more than
300 because the MDL in EPA Method 502.2 is 1,000 times lower than the limit. Further, the
electrolytic conductivity detector is specific to halogenated compounds and would respond very
strongly to chloroform and very poorly to methanol, ethanol, and/or propanol, thereby providing
great specificity for chloroform.
Micro-extraction and gas chromatography with selective detectors
For selective GC detectors that provide sensitivity beyond that required to detect analytes of interest,
micro-extraction can be substituted in place of purge-and-trap. Using the micro-extraction
technique, the pH of the water can be adjusted to attempt to keep the interferences in the water while
the analytes of interest are extracted.
Sample dilution
4-1
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For selective GC detectors that provide sensitivity beyond that required to detect analytes of interest,
the sample can be diluted, by a factor of 10 - 100 to overcome matrix problems.
Isotope dilution
The use of labeled compounds frequently permit the pollutant to be determined in the presence of
interferences because the unique spectrum of the labeled compound can be located in the presence of
these interferences, and the pollutant can then be located by reference to the labeled compound.
Isotope dilution requires mass spectrometry for detection.
How to Solve Matrix Problems Involving Semivolatile Organic Pollutants
Some of the available solutions to matrix problems for semivolatile organic pollutants are:
Use of selective GC detectors
The use of selective detectors allows the detection of a specific class of analytes in complex matrices.
In addition, the added sensitivity gained by the use of selective detectors can allow for dilution to
overcome matrix problems.
pH change
Allows for the separation of the pollutants of interest from interferences. For example, if the
pollutant of interest is neutral and the main interferences are acidic, the pH can be adjusted in the
range of 12-13 and the acidic interferences will remain in the water as their salts while the neutral
pollutants are extracted using an organic solvent.
Gel-permeation (size-exclusion) chromatography
This technique has been shown to be effective for removing lipids and high-molecular-weight
interferences that can degrade GC and mass spectrometer performance. This technique is described
in Revision C of Method 1625.
Solid-phase extraction (SPE) cartridge
Although not fully evaluated, SPE has been shown to be effective in removing interferences from
extracts containing pesticides and in the extraction of pollutants from drinking water.
Florisil, alumina, and silica gel
These absorbents are effective in separating neutral species from polar interferences.
Isotope dilution
4-2
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The use of labeled compounds frequently permit the pollutant to be determined in the presence of
interferences because the unique spectrum of the labeled compound can be located in the presence of
these interferences, and the pollutant can then be located by reference to the labeled compound.
Isotope dilution requires mass spectrometry for detection.
4-3
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Choosing the
Appropriate Analytical
Method
T
his section walks through the process of establishing the most appropriate analytical
method to use for determination of the regulated parameters. This process is not
exclusive, but should help in identifying an appropriate method to use in determining
particular analytes.
Which parameters should be measured in the wastewater?
As part of the implementation of national policy on effluent limitations guidelines and standards for
the pharmaceutical industry, a facility will be issued a National Pollutant Discharge Elimination
System (NPDES) permit or pretreatment requirement. This permit or requirement will outline what
is necessary for monitoring wastewater discharges for compliance, including which parameters are
regulated and their associated discharge standards. This permit will determine which parameters
need to be monitored through sample analysis.
What are the approved analytical methods for the wastewater?
The approved analytical methods for compliance monitoring are those promulgated at 40 CFR 136.3
or incorporated by reference in the tables in 40 CFR 136.3. Table 2-2 presents the approved test
methods for the conventional, toxic, and non-conventional pollutants regulated under the
pharmaceutical effluent limitations guidelines and standards.
How does someone choose between approved methods?
For most analytes, multiple methods have been approved for analysis. To make a determination of
which approved methods to use, a facility should consider the following:
The groups of analytes that need to be monitored for compliance;
The minimum level for the analyte versus the limitation that needs to be met to show
compliance;
The cost of the analytical method; and
The wastewater matrix that is being analyzed.
5-1
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Can the analytes that need to be monitored be grouped?
Depending on the pollutants to be monitored and the limitations for those pollutants, it may
be possible to measure for several pollutants with the same method. As an example, a
facility that is required to monitor for ammonia, isopropanol, acetonitrile, 1,2-dichloroethene
and methyl formate could monitor using the approved methods listed in Table 5-1 (taken
from Table 2-2).
Table 5-1: Test Methods for Example Analytes
Analyte
acetonitrile
ammonia (as N)
1,2-
dichloroethane
isopropanol
methyl formate
CAS Registry
No.
75-05-8
107-06-2
67-63-0
107-31-3
Analytical Method
Number
1666
1671
D3371
D3695
350.2
350.3
350.1
601
624
1624
D3695
502.2
524.2
1666
D3695
1666
Minimum Level1
5mg/L
50 mg/L
TBD
TBD
50 ug/L
50 ug/L
10 ug/L
0.1 ug/L
10 ug/L
10 ug/L
TBD
TBD
TBD
200 ug/L
TBD
100 ug/L
'Some analytical methods report a Method Detection Limit (MDL) only. This specifically applies to the
600-series methods. In those cases, EPA calculated a minimum level (ML) from the MDL originally
reported in the method. The minimum level value was determined by multiplying the MDL by 3.18 and
rounding this value to the nearest number in the series (1, 2, or 5) x 10n, where n is an integer.
TBD - To be determined from the analytical method by the laboratory. The laboratory must first use the
MDL procedure specified in 40 CFR Part 136, Appendix B, and then calculate the ML from the MDL
using the procedure specified in footnote 1 above. The resulting ML must be equal to or less than the ML
listed for that analyte in Table 2-2 or must be less than or equal to the regulatory compliance level
specified in the permit.
Our example facility has the opportunity to group several analytes under EPA Method 1666
and ASTM Method D3695. Acetonitrile, isopropanol, and methyl formate can all be
analyzed using EPA Method 1666. Similarly, acetonitrile, 1,2-dichloroethene, and
isopropanol can all be analyzed using ASTM Method D3695. In both cases ammonia can
not be grouped under the same analytical method as the other analytes. It is typically
5-2
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advisable to choose the fewest number of methods that covers all analytes, while considering
the other factors such as the minimum level of quantitation (ML) relevant to the permit limit.
Is the analytical method chosen sensitive enough?
To determine if an approved analytical method is sensitive enough to measure for the
analyte, the ML for the analyte needs to be compared to the limitation for that analyte. For
each analyte there may exist a daily maximum and monthly average concentration limitation
in the final effluent limitations guidelines and standards for the pharmaceutical
manufacturing industry. These limitations will depend also on the discharging status of the
facility. The monthly average limits for the analytes listed above are shown in Table 5-2.
Table 5-2: Limitations for Example Analytes
Analyte
Acetonitrile
Ammonia
1 ,2-Dichloroethane
Isopropanol
Methyl formate
Effluent Monthly Average Limitation
Direct Discharger
(mg/L)
10.2
29.4
0.1
1.6
0.5
Indirect Discharger (mg/L)
NR
29.4
8.2
NR
8.2
NR - Not regulated
Presented in Table 5-3 and 5-4 are the effluent limitations for the non-conventional
pollutants for the pharmaceutical industry based on discharge type.
Comparing these limits with the MLS for the analytes in the approved analytical methods
shows that EPA Method 1671 cannot be used to perform compliance monitoring for
acetonitrile because its ML of 50 mg/L is above the monthly average limitation. Any of the
approved analytical methods can be used for the remaining pollutants because the MLs for
the analytes in these methods are below the monthly average limitation.
Examples of selected methods for both direct and indirect discharging facilities under this
case study are provided below. For a direct discharging facility with our example group of
pollutants, one possible solution would be to analyze samples by the following methods:
350.1, 350.2, or 350.3 for ammonia;
601, 624, or 1624 for 1,2-dichloroethene; and
1666 for acetonitrile, isopropanol, and methyl formate.
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For an indirect discharging facility with our list of pollutants one possible solution would be
to analyze samples by the following methods:
350.1, 350.2, or 350.3 for ammonia;
601, 624, or 1624 for 1,2-dichloroethene; and
1666 for methyl formate.
How much does an analysis using the analytical method cost?
Analytical costs by method will vary by laboratory, region of the country, and number of
samples submitted for analysis. In general, the simpler the analytical technique, the less
expensive the analysis (for example: Methods 601 and 602 are generally less expensive than
Methods 624 and 625, which are generally less expensive than Methods 1624 and 1625). A
facility should work with its analytical laboratory to determine the least costly method of
analysis. By grouping parameters that can be measured by the same method, a cost saving
may be possible over using different analytical methods.
How does someone determine if there will be wastewater matrix interference problems?
Determination of wastewater matrix interference problems will be a case-by-case situation. A
facility will likely know the most about what substances are in its wastewater. The substances likely
to be in a given wastewater may be known from previous wastewater analyses or may be deduced
from a knowledge of the chemicals and solvents used in production and the parameters and
byproducts likely to be generated in these processes.
A facility will need to work with its analytical laboratory to identify matrix interference problems and
to determine if techniques are available to address these problems. ***Matrix interference problems
may be indicated by a failure of the laboratory to achieve the ML for an analyte in the method or a
failure to meet the QC requirements in the method.
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Table 5-3: Pharmaceutical Effluent Limitations for Direct Discharging Facilities
Regulated parameter
Ammonia (as N)
Acetone
4-Methyl-2-pentanone (MIBK)
Isobutyraldehyde
n-Amyl acetate
n-Butyl acetate
Ethyl acetate
Isopropyl acetate
Methyl formate
Amyl alcohol
Ethanol
Isopropanol
Methanol
Methyl Cellosolve
Dimethyl Sulfoxide
Triethyl Amine
Phenol
Benzene
Toluene
Xylenes
n-Hexane
n-Heptane
Methylene chloride
Chloroform
1 ,2-Dichloroethane
Chlorobenzene
o-Dichlorobenzene
Tetrahydrofuran
Isopropyl ether
Diethyl amine
Acetonitrile
Effluent limitations
Maximum Daily
Discharge (mg/L)
84.1
0.5
0.5
1.2
1.3
1.3
1.3
1.3
1.3
10.0
10.0
3.9
10.0
100.0
91.5
250.0
0.05
0.05
0.06
0.03
0.03
0.05
0.9
0.02
0.4
0.15
0.15
8.4
8.4
250.0
25.0
Average Monthly Discharge
Must Not Exceed (mg/L)
29.4
0.2
0.2
0.5
0.5
0.5
0.5
0.5
0.5
4.1
4.1
1.6
4.1
40.6
37.5
102.0
0.02
0.02
0.02
0.01
0.02
0.02
0.3
0.01
0.1
0.06
0.06
2.6
2.6
102.0
10.2
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Table 5-4: Pharmaceutical Effluent Limitations for Indirect Discharging Facilities
Regulated parameter
Ammonia (as N)
Acetone
4-Methyl-2-pentanone (MIBK)
Isobutyraldehyde
n-Amyl acetate
n-Butyl acetate
Ethyl acetate
Isopropyl acetate
Methyl formate
Methyl Cellosolve
Isopropyl ether
Tetrahydrofuran
Benzene
Toluene
Xylenes
n-Hexane
n-Heptane
Methylene chloride
Chloroform
1 ,2-Dichloroethane
Chlorobenzene
o-Dichlorobenzene
Diethyl amine
Triethyl amine
Pretreatment standards
Maximum Daily
Discharge (mg/L)
84.1
20.7
20.7
20.7
20.7
20.7
20.7
20.7
20.7
275.0
20.7
9.2
3.0
0.3
3.0
3.0
3.0
3.0
0.1
20.7
3.0
20.7
255.0
255.0
Average Monthly Discharge
Must Not Exceed (mg/L)
29.4
8.2
8.2
8.2
8.2
8.2
8.2
8.2
8.2
59.7
8.2
3.4
0.6
0.1
0.7
0.7
0.7
0.7
0.03
8.2
0.7
8.2
100.0
100.0
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Answers to Specific
Concerns from
Industry Regarding
Analytical Methods
T
his section provides responses to some of the industry's comments regarding analytical
methods. For a complete listing of comment responses see the Pharmaceutical Comment
Response Document in the public record for the final pharmaceutical effluent limitations
guidelines and standards.
Isotope Dilution Methods
Some industry commenters were concerned that the isotope dilution gas chromatography/mass
spectrometry (GC/MS) methods have not been demonstrated to give more accurate or precise results
than the equivalent non-isotope dilution methods. EPA has demonstrated that isotope dilution
methods are approximately twice as precise (half the relative standard deviation) as non-isotope
dilution methods and yield an average recovery of approximately 100 percent vs 80 percent for non-
isotope dilution methods. The results of the study are given in reference 10 listed at the end of
Method 1625 at 40 CFR Part 136, Appendix A. However, to allow dischargers to use lower cost
methods, EPA has approved use of the GC methods and the non-isotope dilution GCMS methods
listed at 40 CFR Part 136. The facility has the flexibility to choose any approved method that will
provide a result showing compliance.
Office of Solid Waste (OSW) SW-846 Methods
Some industry commenters wanted Office of Solid Waste (OSW) SW-846 Methods to be approved
for pharmaceutical wastewater. However, EPA concluded that it should not include OSW SW-846
methods in the list of approved methods because SW-846 methods are published only as "guidance."
The Clean Water Act requires EPA to promulgate guidelines establishing test procedures (analytical
methods) to support categorical regulations and other activities in the wastewater program. EPA did
not feel that the guidance provided by SW-846 met this criteria. During the development of the
Pharmaceuticals industry final rule, data were submitted by the industry and accepted by EPA. These
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data were gathered using a modification of EPA Office of Solid Waste Method 8015. Modifications
to this method consisted of the addition of several analytes and increased quality assurance and
quality control (QA/QC). The modifications were consistent with the procedures used for
determination of these analytes in EPA Method 1671 which was approved for use at 40 CFR Part
136 in the pharmaceutical manufacturing industry final rule. In the future, EPA may allow use of the
SW-846 methods, and any other method, when EPA promulgates guidelines establishing test
procedures under a performance-based measurement system (PBMS). In the meantime, laboratories
may request approval for use of the SW-846 methods, or other methods, under EPA's alternate test
procedure (ATP) program at 40 CFR 136.4 and 136.5.
Transfer of an Analyte Between Methods
Some laboratories asked whether a target analyte from one EPA-approved method could be
transferred to another EPA-approved method, thereby reducing the number of methods required for
monitoring. During development of the Pharmaceuticals Industry final rule, EPA did not evaluate the
effect of transferring analytes between methods. On March 28, 1997, when EPA proposed the
Streamlining Initiative (now referred to as the performance-based measurement system or "PBMS"),
the Agency included a procedure to allow the addition of an analyte to an existing method. This
procedure centered around meeting the quality control (QC) acceptance criteria for performance tests
for the analyte. As of the date of the issuance of this Guidance, the PBMS rule has not been
promulgated.
Using PBMS as the basis for transfer of an analyte from one method to another, EPA recommends
allowance of a transfer, provided the following conditions are met: (1) the QC tests in the method
from which the analyte is transferred mus be run as an integral part of the method to which the
analyte is transferred, (2) the QC acceptance criteria in the method from which the analyte is
transferred must be met when the QC tests are run as an integral part of the method to which the
analyte is transferred, and (3) the MDL obtained for the analyte in the method to which the analyte is
transferred must be equal to or less than MDL in the method from which the analyte is transferred or
less than one third the regulatory compliance limit specified in the permit, whichever is greater.
QC tests in the 600- and 1600-series EPA methods include calibration, calibration verification,
initial and ongoing precision and recovery, analysis of blanks, and matrix spike/matrix spike
duplicates. EPA recommends that these QC tests be performed and the QC acceptance criteria be
met, as follows:
1) When the analyte is transferred to a method, the added analyte must be included in the initial
calibration and ongoing calibration checks, and the QC acceptance criteria in the method
from which the analyte is transferred must be met for both initial calibration and calibration
verification.
2) All initial and ongoing performance tests in the method from which the analyte is transferred
must be performed as an integral part of the method to which the analyte is transferred, and
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the QC acceptance criteria in the method from which the analyte is transferred must be met.
The initial and ongoing tests must include a blank with the initial demonstration of
performance and with each sample batch.
3) The quality control check or matrix spike/matrix spike duplicate test (whichever is
applicable) in the method from which the analyte is transferred must be performed as an
integral part of the method to which the analyte is transferred, and the QC acceptance criteria
in the method from which the analyte is transferred must be met.
4) An MDL study must be performed for the analyte as an integral part of the method to which
the analyte is transferred, and the MDL obtained must be equal to or less than either a) the
MDL in the method from which the analyte is transferred or b) one-third the regulatory
compliance limit specified in the permit, whichever is greater.
Notes:
1. A possible conflict could arise if the methods are chromatographic (i.e., GC or GC/MS). Some
EPA chromatographic methods contain QC tests and QC acceptance criteria for absolute and/or
relative retention time. When transferring an analyte between methods, it is unlikely that the two
methods would require use of the same chromatographic column and it is therefore unlikely that the
retention time criteria in the method from which the analyte is transferred could be met in the method
to which the analyte is transferred. To resolve this issue, the absolute and/or relative retention time
requirements are waived for the transferred analyte only. If there are absolute and/or relative
retention time requirements for the target analytes in the method to which the analyte is transferred,
those requirements must continue to be met.
2. Some methods do not contain an MDL but contain a minimum level of quantitation (ML) for each
analyte. MLs were created by multiplying the MDL by 3.18 and rounding. Therefore, for the
purpose of establishing that the MDL for a transferred analyte is less than or equal to the MDL in the
method from which the analyte is transferred, divide the ML by 3.18 to establish the MDL.
Examples:
Example 1: The final rule requires that certain volatile analytes be determined by EPA
Method 524.2. These analytes may be added to EPA Method 1666 or any other approved method
provided the three conditions specified above are met.
Example 2: The final rule requires that tert-butyl alcohol, diethylamine, dimethyl sulfoxide,
isobutyraldehyde, methyl cellosolve, methyl formate, and triethyl amine be analyzed by EPA Method
1666 or 1671. These analytes may be added to EPA Method 624, 625, or any other approved
method provided that the three conditions specified above are met.
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Is This Guidance Applicable to Other Rules?
This Guidance allows transfer of analytes between methods without prior EPA approval under the
Pharmaceuticals Manufacturing Industry final rule only. For industrial categories and subcategories
other than for Pharmaceuticals Manufacturing, EPA will handle requests for transfer of analytes
between methods on a case-by-case basis until a PBMS final rule is promulgated.
Second Column Confirmation Using Method 1671
Some laboratories have asked if second-column confirmation is required when Method 1671 is used.
Method 1671 was developed using a single column and second-column confirmation is not required
with this method. However, EPA believes that it is prudent to confirm the identity of any pollutant
detected by use of a second column or other confirmatory technique (e.g., GCMS). Confirming
pollutant identity will assure that an interferant is not causing a false positive, possibly causing a
false violation of a permit limit.
Can Different Labeled Compounds be Used with the Isotope Dilution Methods?
Yes, provided that the same labeled compound is used for calibration on all performance tests.
What Laboratories are Capable of Practicing the Approved Methods?
Many laboratories routinely practice wastewater and drinking water methods. For methods specific
to the PMI analytes listed in Table IF at 40 CFR 136.3 (63 FR 50424), EPA has had inquiries from a
number of industry representatives to identify laboratories that are either practicing these methods or
are considering setting up to practice the methods. For assistance in identifying laboratories, contact
those individuals listed in Section 7 of this Guidance.
In What Fraction (Volatiles or Semi-Volatiles) are the Analytes That Are Determined by Direct
Aqueous Injection?
Historically, EPA has classified any non-pesticide organic pollutant that can be measured by the
purge-and-trap technique as a "volatile" pollutant and any pollutant determined by extraction,
concentration, and extract injection as a "semi-volatile" pollutant. Certain Pharmaceutical Industry
analytes (e.g., methanol, triethylamine, methyl formate) are not determined using either of these
techniques but are determined by direct aqueous injection (DAI).
Samples to be tested for volatiles pollutants are collected into volatile organic analysis (VOA) vials
with zero headspace; samples to be tested for semi-volatile pollutants are collected into open
containers using continuous sampling techniques. EPA is concerned that certain of the DAI analytes
may be lost by volatilization if a sample containing these analytes is collected into an open container
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using continuous sampling techniques. To prevent this loss, samples to be tested for the DAI
analytes must be collected in the same way as samples for volatiles; i.e., they should be collected as
grab samples in VOA vials with zero headspace. If compositing is required, the samples should be
composited in the laboratory in the same way as with VOA samples.
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Where to Get
Additional Help
Provided in this section are additional sources of information, and EPA contacts, that may
provide additional information related to the final pharmaceutical effluent limitations
guidelines and standards. Specifically, this section presents a list of documents and
websites either relating to the final pharmaceutical effluent limitations guidelines and
standards or compliance monitoring and methods. These lists also include information on how to
reach EPA program personnel and how to access these information sources.
Questions specifically related to the effluent limitations guidelines and standards for the
pharmaceutical industry should be directed to:
Dr. Frank Hund
Engineering and Analysis Division (4303)
U.S. EPA
401M Street, SW
Washington, DC 20460
Tel: (202) 260-7182
Fax:(202)260-7185
E-Mail: hund.frank@epa.gov
Questions specifically related to analytical methods for the pharmaceutical industry should be
directed to:
Maria Gomez-Taylor
Engineering and Analysis Division (4303)
U.S. EPA
401M Street, SW
Washington, DC 20460
Tel: (202) 260-1639
Fax:(202)260-7185
E-Mail: gomez-taylor.maria@epa.gov
Documents Supporting the 1998 Promulgated Rule
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Development Document for Effluent Limitations Guidelines and Standards for
the Pharmaceutical Manufacturing Point Source Category, EPA-821-R-98-
0005, July 1998.
Environmental Assessment of the Final Effluent Limitations Guidelines and
Standards for the Pharmaceutical Manufacturing Industry, EPA-821-B-98-
008, July 1998.
Statistical Support Document for Final Effluent Limitations Guidelines and
Standards for the Pharmaceutical Manufacturing Industry, EPA-821-B-98-
007, July 1998.
Background Information Document for the Final Air Rules
Permit Guidance Document for the Pharmaceutical Manufacturing Point
Source Category
Documents on Compliance Monitoring and Methods
Guidance on Evaluation, Resolution, and Documentation of Analytical
Problems Associated with Compliance Monitoring, EPA-821-B-93-00" June
1993.
40 CFR Part 13 6, Appendix A (EPA Methods 601, 602, 604, 612, 624, 625, 1624,
and 1625).
Analytical Methods for the Determination of Pollutants in Pharmaceutical
Manufacturing Industry Wastewater, EPA-821-B-98-016, July 1998.
Methods for the Determination of Organic Compounds in Drinking Water,
EPA-600/4-88-039.
Methods for the Determination of Organic Compounds in Drinking Water-
Supplement II, EPA-600/R-92-129.
American Society for Testing and Materials (ASTM Methods D3371, D3695, and
D4763).
Websites
EPA's homepage on the World Wide Web: http://www.epa.gov
EPA's office of science and technology's analytical methods page on the World
Wide Web: http://www.epa.gov/OST/Methods/
EPA's Office of Ground Water and Drinking Water's analytical methods page on
the World Wide Web: http://www.epa.gov/OGWDW/Methods/methods.html
EPA's pharmaceutical rulemaking actions homepages on the World Wide Web:
http://www.epa.gov/ost/guide/pharm (water documents)
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http://www.epa.gov/ttn/oarpg (air documents)
ASTM's homepage on the World Wide Web: http://www.astm.org
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