CSO Post Construction
Compliance Monitoring Guidance
April 2011
&EPA
United States
Environmental Protection
Agency
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CSO Post Construction Compliance
Monitoring Guidance
April 2011
EPA-833-K-11-001
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MEMORANDUM
SUBJECT: Combined Sewer Overflows: Draft Post Construction Compliance Monitoring
Guidance
FROM: James A. Hanlon, Director
Office of Wastewater Management (OWM)
TO: Interested Parties
The 1994 Combined Sewer Overflow (CSO) Control Policy provides a national framework for
control of CSOs. The CSO Policy provides that the permittees with CSOs are responsible for developing
and implementing long-term CSO control plans that will ultimately result in compliance with the
requirements of the Clean Water Act (CWA). The CSO Policy provides that each long-term control plan
should include a post-construction compliance monitoring program to verify compliance with water quality
standards and protection of designated uses as well as to ascertain the effectiveness of CSO controls.
Many communities that are served by combined sewer systems have developed and are implementing
long term control plans are already implementing or about to take the next step of implementing a
post-construction compliance monitoring program.
EPA is developing guidance on post-construction compliance monitoring programs to assist
communities with this effort. A draft guidance is available at http://www.epa.gov/npdes/cso. The draft
guidance summarize the requirements to develop a post-construction monitoring program and
approaches for monitoring to verify the effectiveness of CSO controls and to assess compliance with
water quality standards. The draft guadance also contains supplemental information that is intended for
communities to use as they develop and implement their plans.
I invite you to review this draft guidance and provide us with your comments by September 30, 2011.
We are especially interested in your views about how the recommended approaches can be tailored to
small communities. Comments should be directed to Mohammed Billah. His email is
billlah.mohammed@epa.gov. Please contact me if you would like to discuss this guidance or call
Mohammed at 202-564-2228.
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CSO Post Construction Compliance Monitoring Guidance
Acknowledgements
The U.S. Environmental Protection Agency (EPA) wants to express appreciation to those individuals and
organizations that took the time and energy to review and submit comments as part of the review
process during the development of this document. EPA believes that these comments greatly improved
the technical and scientific aspects of the manual and we hope that readers will find the information in
the manual informative and useful as they develop and implement CSO post construction monitoring
plans.
EPA also thanks the Northeast Ohio Regional Sewer District, and the New York City Department of
Environmental Protection for allowing EPA to use their experiences in post construction compliance
monitoring as case studies for this manual. EPA believes that the inclusion of case studies greatly
enhances the value of the document.
Support in developing this manual was provided to EPA under contract number EP-C-05-046.
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CSO Post Construction Compliance Monitoring Guidance
NOTICE
The statements in this document are intended solely as guidance. This document is not intended, nor
can it be relied on, to create any rights enforceable by any party in litigation with the United States. EPA
and State officials may decide to follow the guidance provided in this document, or to act at variance
with the guidance, based on any analysis of specific site circumstances. This guidance may be revised
without public notice to reflect changes in EPA's strategy for implementation of the Clean Water Act and
its implementing regulations, or to clarify and update the text.
Mention of trade names or commercial products in this document does not constitute an endorsement
or recommendation for use.
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Acronyms and Abbreviations
BEACH Act
BOD
CCC
CFR
C.L
CPR
CSO
CSS
CWA
DMR
EPA
GLI
HPLC
IC25
ID
L
Ibs
LCS
LC50
LTCP
MDL
mg
MG
ml
MS
MSD
NELAC
NELAP
NHD
Beaches Environmental Assessment and Coastal Health Act
Biochemical Oxygen Demand
Criteria Continuous Concentration
Code of Federal Regulations
Confidence Limit
Cardiopulmonary Resuscitation
Combined Sewer Overflow
Combined Sewer System
Clean Water Act
Discharge Monitoring Report
U.S. Environmental Protection Agency
Great Lakes Initiative
High Performance Liquid Chromatography
Concentration at which the response of test organisms is 25 percent below that
observed in the control
Identification
Liter
Pounds
Laboratory Control Sample
Concentration that is lethal to 50 percent of the test organisms
Long-Term Control Plan
Method Detection Limit
Milligram
Million Gallons
Milliliter
Matrix Spike
Matrix Spiked Duplicate
National Environmental Laboratory Accreditation Conference
National Environmental Laboratory Accreditation Program
National Hydrography Dataset
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CSO Post Construction Compliance Monitoring Guidance
NMCs
NOEC
NP
NPDES
NRC
NSQD
NTU
NURP
OECA
OFR
OPR
ORSANCO
POTW
QA
QAPP
QC
RBPs
SOP
SRM
SSM
SSO
TMDL
TSD
TSS
TUa
TUc
USGS
WET
WQS
Nine Minimum Controls
No Observed Effect Concentration
Nonpotable
National Pollutant Discharge Elimination System
National Research Council
National Stormwater Quality Database
Nephelometric Turbidity Unit
Nationwide Urban Runoff Program
Office of Enforcement and Compliance Assurance
Office of the Federal Register
Ongoing Precision and Recovery
Ohio River Valley Water Sanitation Commission
Publicly Owned Treatment Works
Quality Assurance
Quality Assurance Project Plan
Quality Control
Rapid Bioassessment Protocols
Standard Operating Procedure
Certified Standard Reference Materials
Single Sample Maximum
Sanitary Sewer Overflow
Total Maximum Daily Load
EPA's 1991 Technical Support Document for Water Quality-Based Toxics Control
Total Suspended Solids
Acute Toxic Units
Chronic Toxic Units
U.S. Geological Survey
Whole Effluent Toxicity
Water Quality Standards
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CSO Post Construction Compliance Monitoring Guidance
CONTENTS
Acronyms and Abbreviations ix
Section 1. Introduction 1
Section 2. Background 3
2.1 CSO Control Policy 3
2.2 NPDES Permit Program Requirements 6
2.3 Previous EPA Guidance on Post Construction Compliance Monitoring 6
2.4 Compliance Monitoring Strategy from the Office of Compliance and Enforcement 8
2.5 Roles and Responsibilities 8
Section 3. Development of a Post Construction Compliance Monitoring Plan 11
3.1 The Post Construction Compliance Monitoring Plan and its Relationship to the
Implementation of the NMCs and Development of LTCPs 12
3.2.1. Defining the Causes of Water Quality Impairment and Determining Study
Questions 15
3.3 CSO Control Assessment Plan 16
3.3.1 Verifying Effectiveness of CSO Controls Using the Presumption Approach 16
3.3.2 Verifying Effectiveness of CSO Controls Using the Demonstration Approach 18
3.3.3 Verifying Effectiveness of Pre-Policy CSO Control Plans 18
3.4 Field Sampling Plan 19
3.4.1 Data Monitoring Needs 21
3.4.2 Combined Sewer System and Receiving Water Quality Monitoring 22
3.5 Standard Operating Procedures 22
3.6 Example Planning Documents 23
Section 4. Post Construction Compliance Monitoring 25
4.1 Monitoring to Verify the Effectiveness of CSO Controls 26
4.1.1 CSO Frequency Control Targets 27
4.1.2 CSO Volume Control Targets 32
4.1.3 Pollutant Mass Removal Control Targets 42
4.1.4 Water Quality-Based Targets 44
4.1.5 Treatment Requirements 44
4.1.6 Other CSO Control Targets 46
4.2 Ambient Monitoring for Assessing Compliance with Water Quality Standards 48
4.2.1 Who Should Conduct the Monitoring? 48
4.2.2 What Should be Monitored? 51
4.2.3 Where Should Monitoring Be Performed? 58
4.2.4 When Should Monitoring Be Performed? 62
4.2.5 How Should Monitoring Be Conducted? 66
References 77
Appendix A-Supplemental QAPP Information 81
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CSO Post Construction Compliance Monitoring Guidance
Group A- Project Management 81
Group B - Data Generation and Acquisition 86
Group C -Assessment and Oversight 89
Group D - Data Validation and Usability 90
Appendix B. Recommended Reporting Requirements 91
Appendix C. Resources Relevant to Applicable Water Quality Standards 95
Appendix D. CSS Contracting for Laboratory Services 105
Appendix E. 40 CFR - SUBCHAPTER D - Part 136 121
Appendix F. Case Studies 187
Tables
Table 1. Example calculation for percentage of combined sewage captured or treated in CSS 40
Table 2. Example calculation for annual average of percentage of combined sewage captured or
treated in an example CSS 41
Table 3. Example Parameters for which NPDES Authorities Might Require Post Construction
Monitoring 57
Table A-l. Example performance criteria for a CSO post construction compliance monitoring
program 84
Table A-2. Example sample collection and analyses at each sampling location 86
Table A-3. Example sample handling requirements for samples to be analyzed by the laboratory 87
Figures
Figure 1. Annual Overflow Events Used to Evaluate Criterion i of the Presumption Approach 29
Figure 2. Sanitary flow in CSS overtime 37
Figure 3. Runoff into the CSS over time caused by rainfall 37
Figure 4. Sum of sanitary runoff flows in the CSS over time 38
Figure 5. Flows to the CSS during a particular 24-hour precipitation event 40
Figure A-l. Example QAPP organization chart 82
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CSO Post Construction Compliance Monitoring Guidance
Section 1. Introduction
This document presents guidance on how to conduct effective post construction compliance monitoring,
as provided in the 1994 Combined Sewer Overflow (CSO) Control Policy (59 Fed. Reg. 18688;
http://www.epa.gov/npdes/pubs/owm0111.pdf). which established a national approach under the
National Pollutant Discharge Elimination System (NPDES) permit program for controlling discharges into
the nation's waters from combined sewer systems (CSSs). This document provides technical assistance
to NPDES authorities (permit writers, water quality specialists and CSO permittees) so that the post
construction compliance monitoring plans collect sufficient data for (1) evaluating the effectiveness of
CSO controls in meeting performance goals; and (2) assessing compliance with water quality standards.
The CSO Control Policy defines expectations for regulated communities, state water quality standards
(WQS) authorities, and NPDES authorities. One of these expectations is that regulated communities
should develop comprehensive CSO control measures. The term CSO control measures, as it is used in
this document, includes controls based on an LTCP, but also controls that were agreed upon prior to the
CSO Control Policy (and therefore not part of an LTCP). The ninth element of an LTCP listed in the CSO
Control Policy, and the subject of this document, is the development of a post construction compliance
monitoring program adequate to verify compliance with water quality-based requirements and
ascertain the effectiveness of CSO controls. EPA expects, however, that all CSO communities, regardless
of whether they have an LTCP, will conduct post construction compliance monitoring. In case of sewer
separation, permittees need to coordinate with the NPDES and WQS authorities for the requirements
and duration of conducting post construction compliance monitoring.
It is important that moitoring requirements in NPDES permits result in the generation of
appropriate information to ascertain the effectiveness of CSO controls and to verify CSO-specific
performance criteria and NPDES permit requirements. Because this information will ultimately be used
to verify compliance with water quality-based requirements, reducing data uncertainty should be a high
priority. Thus, data quality considerations are included in this document to assist permit writers and the
regulated community in ensuring that the data collected are of the type and quality needed to meet the
expectations established by the CSO Control Policy.
Permit writers and permittees should remain mindful that phased implementation of control measures
and design features suggests an iterative monitoring program that will continue to support the
implementation schedule. Evaluation of CSO control measures, CSO volume, loadings of conventional
and toxic pollutants, and receiving water quality environmental indicators can be used to measure
compliance, and post construction compliance monitoring requirements may evolve as different
construction phases are implemented. The performance of the controls should be assessed during each
phase. This document presents information about the continuum of monitoring needed to assess a CSO
program so that if at any point in a monitoring program's evolution the results reveal evidence of
controls that do not fulfill their design requirements, appropriate corrective actions can be identified.
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Section 2. Background
2.1 CSO Control Policy
The 1994 CSO Control Policy established a consistent national approach for controlling discharges from
Combined Sewer Systems (CSSs) to the nation's waters. On December 15, 2000, Congress enacted
Pub. L No. 106-554, which amended section 402 of the Federal Water Pollution Control Act (33 U.S.C. 1342)
(the Clean Water Act) to add new paragraph (q) to that section. Section 402 (q) (1) provides:
(q) COMBINED SEWER OVERFLOWS. — (1) REQUIREMENT FOR PERMITS, ORDERS, AND
DECREES.—Each permit, order, or decree issued pursuant to this Act after the date of
enactment of this subsection for a discharge from a municipal combined storm and sanitary
sewer shall conform to the Combined Sewer Overflow Control Policy signed by the
Administrator on April 11, 1994 (in this subsection referred to as the 'CSO control policy').
As a result, NPDES permits issued to operators of publicly owned treatment works (POTWs) with
combined sewer systems are required to "conform" to the CSO Control Policy. Under the Policy and
Section 402 (q), "Phase I" permits were required to include provisions for permittees to immediately
implement the Nine Minimum Controls (NMCs), which are technology-based controls that address CSO
problems without extensive engineering studies or significant construction costs. Permittees are also required
to develop LTCPs as the primary planning tools to document the specific approach or approaches that each
permittee will use to control its CSOs to meet the requirements of the Clean Water Act, including
attainment of WQS. Phase II permits must include requirements for permittees to implement LTCPs, as
well as requirements to implement the NMCs, and other provisions.
The data gathering conducted in the earliest stages of the Phase I permits informs the selection of
appropriate CSO controls, and follow-up data monitoring is used to ensure that the chosen controls are
achieving the control objectives. The selected CSO controls should include a post construction water
quality monitoring program adequate to verify compliance with water quality standards and protection
of designated uses as well as to ascertain the effectiveness of CSO controls. This water quality
compliance monitoring program should include a plan to be approved by the NPDES authority that
details the monitoring protocols to be followed, including the necessary effluent and ambient
monitoring and, where appropriate, other monitoring protocols such as biological assessments, whole
effluent toxicity testing, and sediment sampling.
Because the post construction compliance monitoring program evaluates what has been done to control
CSOs, it is necessarily based on what has been done in previous phases of the permittee's CSO control
program. It should build on previous data-collection efforts conducted under both the NMCs and the
LTCP process and provide follow-up data to allow a determination of whether the controls that have
been put in place have met their objectives and whether the permittee is complying with water quality-
based effluent limits in its NPDES permit.
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CSO Post Construction Compliance Monitoring Guidance
Data Collection Strategy Defined by the CSO Control Policy
The data collection that underpins the long-term control planning, and the subsequent evaluation of
that control planning in the post construction compliance monitoring plan, begins during the
implementation of the NMCs and continues with the development of the LTCP. Both Section II.B of the
policy, which discusses implementation of the NMCs, and Section II.C, which discusses the CSO LTCP,
include recommendations to collect data to characterize various aspects of the CSS and its impacts.
These initial data-collection efforts should have established a baseline against which CSO controls are
evaluated using data collected during post construction compliance monitoring.
The initial monitoring of the CSO should be done under the Phase I permit requirement to implement
the NMCs. Section II.B of the policy describes the ninth NMC as "monitoring to effectively characterize
CSO impacts and the efficacy of CSO controls." Characterizing CSO impacts implicitly requires the
permittee to identify the WQS of the receiving water and to evaluate how the CSO discharges are
affecting the receiving waters with respect to these standards. This crucial step in the process was the
first assessment of how to achieve receiving WQS. Characterizing the efficacy of CSO controls is also
important because it leads to an initial assessment of the potential to control these CSOs, which can be
used in later planning efforts to design controls for the CSS.
Subsequent monitoring is described under the LTCP requirements implemented through the Phase II
permits. Section II.C of the policy defines the elements of the LTCP, with the first step being
characterization, monitoring, and modeling of the CSS. Section II.C.I states that "to design a CSO control
plan adequate to meet the requirements of the CWA, a permittee should have a thorough
understanding of its sewer system, the response of the system to various precipitation events, the
characteristics of overflows, and the water quality impacts from CSOs."
The policy states that the monitoring data "will be used to evaluate the expected effectiveness...of...the
long-term CSO controls to meet water quality standards." Section II.C.l.c goes on to state that "the
permittee should develop a comprehensive, representative monitoring program that measures the
frequency, duration, flow rate, volume and pollutant concentration of CSO discharges and assesses the
impacts of CSOs in the receiving water. The monitoring program should include necessary CSO effluent
and in-stream ambient monitoring and, where appropriate, other monitoring protocols such as
biological assessment, toxicity testing and sediment sampling."
These characterization monitoring requirements define the baseline effluent and ambient water quality
against which the effectiveness of the CSO controls are measured in the post construction compliance
monitoring plan. These requirements also establish the procedures and methods which should be
followed when designing and implementing the post construction compliance monitoring plan to ensure
that the data collected under this plan are comparable to previously collected data, and therefore that it
allows a valid comparison "to verify compliance with water quality standards and protection of
designated uses as well as to ascertain the effectiveness of CSO controls" as is required of the post
construction compliance monitoring plan (discussed in the next section).
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What is the role of post construction compliance monitoring in developing effective CSO long-
term control plans?
The CSO Control Policy contains provisions for developing appropriate, site-specific NPDES permits for
all combined sewer systems that overflow as a result of wet weather events. Permittees with CSOs are
required to develop an adequate long term control plan (LTCP) designed to meet Clean Water Act (CWA)
requirements. In addition to control overflows in sensitive areas, the plan should consider alternatives and
adopt either the presumption or demonstration approach in its LTCP. The alternatives presented in the
LTCP should be selected based on a "knee-of-the- curve" statistical analysis that considers water quality
requirements to determine the appropriate level of control and a financial analysis to determine the
appropriate time frame for implementation. Communities should give consideration to including the
protection of sensitive areas in their LTCPs. If the planned implementation of feasible control measures
would not result in attainment of water quality standards (WQSs), the community may consider revisions
to the standards and if necessary revise the LTCP and or the standards accordingly. The WQSs may be
permanently or temporarily revised by Use Attainability Analysis (UAA) or variance respectively. A UAA is
a structured scientific assessment of the factors effecting the use, including the physical, chemical,
biological, and economic factors described in 40 CFR 131.10 (g). Variances are short-term modifications
in water quality standards, and subject to EPA approval. States with their own statutory authority may
grant variance to a specific discharger for a specific pollutant. Justifications for variances are the same as
those identified in 40 CFR 131.10 (g).
As communities implement their LTCPs, they should conduct post construction compliance
monitoring to determine whether the controls specified by the LTCP are meeting their objectives and to
assess whether the water quality standards (WQSs) are being met. The post construction compliance
monitoring is a continuous process to determine whether the CSO LTCP is meeting the regulatory
requirements as planned.
After reviewing their post construction compliance monitoring data, the permittee, in conjunction with the
NPDES authority, should evaluate the need for additional controls that would meet WQS and then revise
their LTCP and implement the appropriate additional controls. If, however, the data analysis indicates that
a community could not meet WQS due to financial and/or technological infeasibility, they should develop
a schedule for incremental improvements and then revisit additional controls as financial conditions
change or as new control technologies emerge. The community can also request that the NPDES
authority consider enforcement discretion, or they could seek a revised TMDL or try to obtain approval of
UAA or variance and revise their WQS.
Post Construction Compliance Monitoring Defined by the CSO Control Policy
Section II.C.9 of the policy defines the post construction compliance monitoring element of the LTCP.
This water quality compliance monitoring should include a plan to be approved by the NPDES authority
that details the monitoring protocols to be followed, including the necessary effluent and ambient
monitoring, and, where appropriate, other monitoring protocols such as biological assessments, whole
effluent toxicity [WET] testing, and sediment sampling."
The policy also discusses requirements for NPDES permits. Section B.2.d of the policy states that the
Phase II permits should include "a requirement to implement, with an established schedule, the
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approved post construction water quality assessment program including requirements to monitor and
collect sufficient information to demonstrate compliance with WQS and protection of designated uses
as well as to determine the effectiveness of CSO controls."
2.2 NPDES Permit Program Requirements
The CSO Control Policy established the LTCP as the planning process for controlling CSOs that was to be
implemented through the NPDES permitting program. The development and implementation of the
LTCP, including the development and the implementation of the post construction compliance
monitoring plan, are part of the requirements implemented by the permittee's NPDES permit, order or
decree. However, there may be CSO-related requirements in a permittee's NPDES permit, order or
decree—such as requirements to conduct end-of-pipe and effluent monitoring to collect data to support
the development of water quality-based effluent limits—that are in addition to the LTCP requirements.
It is important to keep both sets of requirements in mind when developing a post construction
compliance monitoring plan, because NPDES requirements outside the LTCP process might influence the
data collection done in the LTCP, and consequently influence the development of the post construction
compliance monitoring plan. For example, the post construction compliance monitoring plan should
include monitoring to provide data for evaluating compliance with water quality-based effluent limits in
the NPDES permit.
EPA bypass regulations at 40 CFR 122.41 (m) allow for a facility to bypass some or all the flow from its
treatment process under specified limited circumstances. Bypass means the intentional diversion of
waste streams from any portion of a treatment facility. For approval of a CSO related bypass, the LTCP,
at a minimum, should provide justification for the cut-off point at which the flow will be diverted from
secondary treatment portion of the treatment plant. Where approval of anticipated bypass is provided in the
NPDES permit, the permit must define under what specific wet weather conditions a CSO related bypass is approved
and also specify what treatment or what monitoring, and effluent limitations and requirements apply to the bypass
flow. The permit should also make it clear that all wet weather flow passing the headworks of the POTW treatment
plant will receive at least primary clarification and solids and floatable removal and disposal, and disinfection, where
necessary, and any other treatment that can reasonably be provided.
The monitoring requirements for CSO related bypass are the same as for other discharge and are very
much site-specific.
2.3 Previous EPA Guidance on Post Construction Compliance
Monitoring
Subsequent to the issuance of the CSO Control Policy, EPA developed technical guidance to facilitate
implementation of the policy. EPA has previously issued Guidance for Long-Term Control Plan (1995b;
http://www.epa.gov/npdes/pubs/owm0272.pdf). and Combined Sewer Overflows Guidance for Permit
Writers (1995c; http://cfpub.epa.gov/npdes/cso/guidedocs.cfm). both of which provide specific
guidance on the development and implementation of post construction compliance monitoring
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programs. EPA has also issued Guidance for Nine Minimum Controls (1995d;
http://www.epa.gov/npdes/pubs/owm0030.pdf) and Combined Sewer Overflows Guidance on
Monitoring and Modeling (1999; http://www.epa.gov/npdes/pubs/sewer.pdf), which provide
information on the monitoring programs on which the post construction compliance monitoring
programs may be based. The various sets of monitoring data should be coordinated with each other to
provide consistent data that allows the evaluation of long-term trends to determine the effectiveness of
the LTCP and the CSO controls. Permittees should evaluate the guidance on characterization of the CSS
and receiving waters, and development of monitoring and modeling plans, to ensure that these plans
and the data generated from the monitoring provides acceptable baseline data, and that later post
construction monitoring data can be compared to these earlier data in a straightforward manner that
allows the assessment of progress in controlling CSOs. Post construction compliance monitoring
requirements based on previous guidance are summarized below.
• The post construction compliance monitoring plan should be implemented during the
implementation of the LTCP, and it should continue after the LTCP has been implemented.
• The plan should be designed to measure effectiveness of the overall LTCP and provide
accountability. It should include a discussion of appropriate measures of success.
• The plan should account for variability of rainfall and CSOs and should focus on ensuring that
the data specifically allow the evaluation of the effect of a particular control on the receiving
water(s).
• The plan should include a map of the monitoring stations, monitoring schedules (including the
frequency and duration of sampling at each station) a parameter list, a discussion of monitoring
protocols, and a quality assurance project plan (QAPP).
• The ambient monitoring locations should be appropriate to determine the full range of CSO
impacts on the waterbody(ies).
• To the extent possible, the plan should incorporate existing monitoring stations (both those
used in previous studies and those used for collecting data during system characterization). This
will allow the comparison of post construction data to pre-construction data to evaluate long-
term trends.
• The plan should include two types of data collection:
o Data collection to measure the overall effects of the program on water quality
o Data collection to determine the effectiveness of CSO controls
• The types of pollutants and parameters to be analyzed should be based on pollutants key to the
attainment of designated use(s) of the receiving water, and pollutants affected by the CSO
controls, and might include chemical, physical, or biological parameters.
• The monitoring should be coordinated with any ongoing or planned state monitoring programs,
programs of other permittees within the same watershed, or both.
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2.4 Compliance Monitoring Strategy from the Office of Compliance
and Enforcement
On September 16, 2003, EPA's Office of Enforcement and Compliance Assurance (OECA) and the U.S.
Department of Justice released a policy on the Negotiation of CSO Consent Decrees. The policy
acknowledges that during the course of consent decree negotiations with representatives of publicly
owned treatment works (POTWs) regarding long-term remedial measures to address CSOs, issues have
arisen regarding the incorporation of LTCPs into CSO consent decrees. The policy addressed the need to
specify an end date for completion of all construction and to define the compliance that the POTW
should achieve before the decree can be terminated. LTCP's may be modified to account for certain
circumstances including, for example, where the LTCP was based on an anticipated change in water
quality standards that did not occur, or where subsequent monitoring or other information indicates
that the LTCP will not meet water quality standards. The policy also envisions that all construction and
all post construction compliance monitoring envisioned in the LTCP or consent decree (or both) would
have been satisfactorily completed in accordance with the consent decree.
OECA's policy on Clean Water Act NPDES Compliance Monitoring Strategy for the Core Program and Wet
Weather Sources dated October 17, 2007, describes that verifying implementation of a [post
construction compliance] monitoring program is recommended when inspecting CSSs.
2.5 Roles and Responsibilities
Different parties are responsible for different aspects of the post construction compliance monitoring
program. This section discusses the parties and their roles in this process.
Permittees
Permittees are responsible for developing and implementing the post construction compliance
monitoring plan. Permittees should develop the post construction compliance monitoring plan as an
integrated part of their LTCP, and they should ensure that the plan is informed by the data collected
during system and receiving water characterization efforts that are done in the early phases of planning.
They should also ensure that the post construction compliance monitoring plan results in collecting data
that allows an evaluation of the effectiveness of CSO controls and their impacts on water quality. This
includes ensuring that the plan includes sampling sufficient to allow evaluation of ambient WQS. The
permittee should work with the NPDES authority to coordinate the post construction compliance
monitoring plan with other monitoring that is occurring in the receiving waters. The permittee is
responsible for implementing the plan and doing the data collection and then reporting the resulting
data to the NPDES authority.
Permittees are also responsible for complying with their NPDES permit requirements and any specific
monitoring done outside the LTCP requirements that could affect post construction compliance. For
example, permittees are responsible for conducting any effluent or ambient monitoring required by the
permit and for complying with any water quality-based effluent limits. Permittees are required to report
these data on their Discharge Monitoring Reports (DMRs).
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NPDES Authorities
NPDES authorities are responsible for reviewing and
approving the post construction compliance
monitoring plan as part of their evaluation of the
LTCP. NPDES authorities should review the plan to
determine if it will provide sufficient data to
evaluate the effectiveness of CSO controls and their
impacts on water quality. NPDES authorities should
evaluate the proposed sampling to ensure that it
provides data to evaluate representative CSO
impacts on receiving waters. NPDES authorities
should also help coordinate a permittee's post
construction compliance monitoring plan with any
other monitoring in the receiving water to maximize
the data collection efforts in providing a
comprehensive picture of water quality and water
quality trends in the receiving water, while
minimizing cost to the permittees and potential
overlap in efforts.
NPDES authorities are also responsible for evaluating
the data provided by the permittee to determine if
the permittee is achieving the goals of the LTCP.
Evaluation of the data should first include an
assessment of system performance to determine if
the LTCP resulted in the system meeting the
Presumption or Demonstration Approach upon
which the LTCP was based. Next, the evaluation
should determine if water quality standards are
being met following the construction of controls per
the LTCP. In situations where water quality
standards cannot be met due to other sources in the
receiving water, the permittee should demonstrate
that any remaining CSO discharges do not cause the impairment of water quality standards. Evaluation
of water quality improvements should be based on assessing the trends in the pollutants that the LTCP
identified as contributing to impacts on WQS and designated uses of the receiving water. EPA recognizes
that it is often difficult to identify the specific impacts that individual CSO controls have on receiving
waters; therefore, EPA encourages NPDES authorities to evaluate long-term trends to determine
improvements in water quality. This process retains the NPDES authority's flexibility to apply site-
specific methodology when evaluating the impacts of CSO controls on water quality.
CSO Policy: Small System Considerations
The scope of the long-term CSO control plan
including the characterization, monitoring and
modeling, and evaluation of alternatives
portions of this Policy may be difficult for some
small CSS. At the discretion of the NPDES
authority, jurisdictions with populations under
75,000 may not need to complete each of the
formal steps outlined in Section II. C. of this
Policy, but should be required through their
permits or other enforceable mechanisms to
comply with the nine minimum controls (II. B.),
public participation (II. C.2), and sensitive
areas (II.C.3) portions of the CSO Control
Policy.
In addition, permittees may propose to
implement any of the criteria contained in this
Policy for evaluation of alternatives described
in II.C.4. Following approval of the proposed
plan, such jurisdictions should construct the
control projects and propose a monitoring
program sufficient to determine whether WQS
are attained and designated uses are
protected. In developing long-term CSO control
plan based on the small system considerations
discussed in the preceding paragraph,
permittees are encouraged to discuss the
scope of their long-term CSO control plan with
the WQS authority and the NPDES authority.
These discussions will ensure that the plan
includes sufficient information to enable the
permitting authority to identify the appropriate
CSO controls.
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NPDES authorities are also responsible for coordinating any NPDES permit requirements outside the
LTCP that could affect the post construction compliance monitoring, including any permit requirements
to conduct monitoring or to comply with water quality-based effluent limits. The NPDES authority
should consider integrating the post construction compliance monitoring requirements with any
effluent or ambient monitoring that is required by the permit to reduce redundancy in these efforts.
Water Quality Standards Staff
WQS staff should work with the NPDES authorities to ensure that there is a consistent understanding of
the WQS in the receiving water(s) and to support the NPDES authorities in their review of the post
construction compliance monitoring plan to ensure that it will provide adequate data to evaluate
against the WQS in the receiving water(s). Total Maximum Daily Load (TMDL) studies might be occurring
in CSO communities with impaired waters, in which case, there might be a role for TMDL authorities
during the development and implementation of post construction compliance monitoring plans.
Compliance and Enforcement Authorities
Compliance and enforcement authorities are responsible for working with the NPDES authorities to
ensure that the permittees are complying with their NPDES permit requirements. Specifically, with
respect to the post construction compliance monitoring plan, compliance and enforcement authorities
can work with NPDES authorities to evaluate the data from the post construction compliance monitoring
plan to ensure that it meets LTCP goals. While state NPDES authorities play the primary role in reviewing
post construction compliance monitoring plans and post construction compliance monitoring data in
states with delegated NPDES authority, EPA sometimes retains a strong role in reviewing Post
Construction Monitoring Plans, particularly in instances involving federal enforcement. EPA's role in
reviewing post construction compliance monitoring plans is particularly important in situations where
the plans are used to evaluate LTCP CSO control performance to determine if a federal consent decree
has been satisfied and can be terminated.
Others
Other entities may have responsibilities for, or may contribute to, the development and implementation
of individual post construction compliance monitoring plans. For example, local health department
officials might be able to contribute data on various pollutants (such as bacteria) in the receiving water.
This could help in providing either a baseline for comparison of post construction controls, or it might be
useful in characterizing other locations in the watershed that might or might not be affected by CSOs.
Upstream and downstream dischargers could provide similar data on other pollutants, and it might be
useful to include these dischargers in larger watershed planning efforts. Local stakeholders, such as
watershed groups or local governments, can play a role in shaping the post construction compliance
monitoring plan by providing their input concerning their local needs and interests.
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Section 3. Development of a Post Construction Compliance
Monitoring Plan
Project planning is critical to the development of a successful CSO post construction compliance
monitoring plan. Permittees should develop and implement project planning to ensure the their
understanding of flows, frequency, and duration of wet-weather events and overflow events is reflected
in their plan to verify the adequacy and effectiveness of the design requirements and schedules that
were used to develop the CSS capacity and treatment controls. Further, the monitoring program should
provide data necessary to verify compliance with WQS and protection of designated uses in the
receiving waters. Examples of planning documents that permittees should consider preparing for post
construction compliance monitoring include quality assurance project plans (QAPPs), plans for assessing
CSO controls, field sampling plans and standard operating procedures (SOPs). The project planning
documents should be distributed to the NPDES authority for review and to all staff who will be
performing the work.
The post construction monitoring plan should include the baseline data collected during initial
monitoring, modeling and characterization of the system. The baseline data complements and builds on
the initial flow and wet-weather event characteristics. These data are used to develop the CSO long-
term control plan, and later to monitor the design performance as control measures are implemented
under the LTCP schedule. EPA's guidance document, Guidance on Systematic Planning Using the Data
Quality Objectives Process (2006; http://www.epa.gov/QUALITY/qs-docs/g4-final.pdf), provides a
practical framework for project planning to incorporate the data user's information requirements,
performance objectives, and available resources.
The initial monitoring of the CSOs has more than likely focused heavily on the flows, frequency, and
duration of wet-weather and overflow events, possibly followed by basic water quality assessments for
ambient, stormwater, and overflow events. Because the early monitoring can be iterative, and can result
in more complex flow monitoring requirements to design effective controls and implement sufficient
measures, early efforts of some permittees might have met limited success. Where the early monitoring
efforts might have revealed insufficient understanding of the various inputs to the CSS and any design
limitations in historical and modified control measures, continued efforts in this regard should be
encouraged and integrated into the CSS monitoring program to optimize the effectiveness of control
measures and to reassess the current and future control measures selected, scheduled, and
implemented under the LTCP. It is critical to develop and implement an effective post construction
compliance monitoring plan, it is also critical to maintain awareness of the resources available to the CSS
to monitor, design, and implement the control plan over time.
An effective monitoring plan should have first adequately represented the existing CSS hputs and
capacities in sufficient resolution to ensure selection and implementation of the appropriate design
features and control measures. Once the conceptual plan and schedule have been developed, however,
continued monitoring should support the assessment of controls iplemented throughout their
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implementation in addition to assessment of
receiving waters and the impacts of CSO
overflow events. Thus, while the early
monitoring program targeted the CSS and range
of weather events in the region, the monitoring
program evolves with best management practice
implementation schedules to confirm reduction
in flows, verify performance of control measures,
and to more regularly assess the receiving water
impacts due to CSO events.
Diversion of flow from a combined sewer overflow to a new
treatment plant in the background.
This section should be used as general guide to
developing planning documents for CSO post
construction compliance monitoring. EPA
recognizes that in some situations (e.g., small communities), permittees might streamline the post
construction compliance monitoring plan development process as appropriate.
3.1 The Post Construction Compliance Monitoring Plan and its
Relationship to the Implementation of the NMCs and
Development ofLTCPs
The success of the permittee in achieving the expectation of the CWA and CSO Control Policy through
the implementation of the NMCs and the CSO controls proposed in their LTCP can be evaluated by
evaluating whether the permittee has achieved the goals of the Presumption or the Demonstration
approach, because those goals are selected to develop the CSO long-term control plans with an
expectation of meeting the water quality standards and protecting the designated uses of the
waterbody. Ideally, the permittee has documented whether they are using the Presumption Approach
or the Demonstration Approach in developing their LTCP, and evaluating CSO control can be a
straightforward evaluation of whether the permittee has met the requirements of the approach they
have chosen. For example, if the permittee has chosen the Presumption Approach of no more than four
overflows on average per year, the post construction compliance monitoring plan should be set up to
collect data that allows evaluation of whether the system has achieved, on average, no more than four
overflows per year. Similarly, if the permittee has chosen the Presumption Approach of capture of the
mass of pollutants identified as causing water quality impairment, the post construction compliance
monitoring plan should set up a data collection effort that collects data on the specific pollutants
identified as causing water quality impairments and that allows a mass-balance analysis of the system to
determine whether the controls have achieved capture by mass of those pollutants. The ultimate
responsibility of the permittee is to meet WQs and protect designated uses of the waterbody regardless
of whatever approach is considered in designing the CSO long-term control plan.
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Likewise, the success of the permittee in
achieving water quality goals based on the
implementation of the CSO controls
proposed in the LTCP can be evaluated by
comparing water quality data collected
before implementing the controls to water
quality data collected after implementing
controls. The expectation is that the data
collected after implementing CSO controls
will meet the WQSs. EPA recognizes that it
is often difficult to document the direct
relationship between individual CSO
controls and specific improvements in
water quality, but the comparison of long-
term water quality trends before and after
implementing the LTCP, if the data are
available, can provide a correlation
between CSO controls and improvements
in water quality if other things stay the
same.
Having established that the goal of post
construction compliance monitoring is to
evaluate whether the level of CSO control
proposed in the LTCP (including the
proposed water quality goals) has been
achieved, it is clear that the evaluations
and planning decisions made during the
earliest phases of long-term control
planning have major implications for the
development and implementation of the
post construction compliance monitoring
plan. For example, the methods used for
initial characterization of the CSS, including
the evaluation of the number and location
of overflows, the evaluation of pollutant
loading, and other factors, should be
repeated during measurements of these parameters in the post construction compliance monitoring
step so that the data are comparable. Likewise, the permittee shoud also be consistent in collecting
receiving water data. For example, the permittee should ensure that receiving water data collected
during post construction compliance monitoring is analyzed for the same parameters that were
identified as causing water quality impacts during the receiving water characterization phase of the
CSO Policy: Reopener Clause
A reopener clause authorizing the NPDES authority to
reopen and modify the permit upon determination that
the CSO controls fail to meet WQS or protect designated
uses. Upon such determination, the NPDES authority
should promptly notify the permittee and proceed to
modify or reissue the permit.
The permittee should be required to develop, submit and
implement, as soon as practicable, a revised CSO
control plan which contains additional controls to meet
WQS and designated uses.
If the initial CSO control plan was approved under the
demonstration provision of Section II.C.4.b., the revised
plan, at a minimum, should provide for controls that
satisfy one of the criteria in Section II.C.4.a
(Presumption Approach), unless the permittee
demonstrates that the revised plan is clearly adequate to
meet WQS at a lower cost and it is shown that the
additional controls resulting from the criteria in Section
II.C.4.a. will not result in a greater overall improvement
in water quality.
Unless the permittee can comply with all of the
requirements of the Phase II permit, the NPDES
authority should include, in an enforceable mechanism,
compliance dates on the fastest practicable schedule for
those activities directly related to meeting the
requirements of the CWA.
For major permittees, the compliance schedule should
be placed in a judicial order.
Proper compliance with the schedule for implementing
the controls recommended in the long-term CSO control
plan constitutes compliance with the elements of this
Policy concerning planning and implementation of a long
term CSO remedy.
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LTCP. The data collection procedures used to collect data for pre-construction evaluations should be
retained in the post construction compliance monitoring field sampling plan so that the post
construction data is consistent and comparable with pre-construction data. These procedures should
include monitoring locations, parameters monitored, the frequency at which the monitoring is done, the
frequency of wet- vs. dry-weather monitoring, etc.
The post construction compliance monitoring plan will also depend on the schedule for implementing
the LTCP. For example, the permittee might need to design its post construction compliance monitoring
plan in phases to follow the phased implementation of controls within the system. In a phased
approach,, the monitoring plan is envisioned to follow the implementation of system controls, shifting
from collecting data to assess the effectiveness of controls (wet-weather event frequencies, duration,
flows, CSS capacities), to one that focuses on water quality in the receiving streams and provides data
necessary to demonstrate effectiveness of the LTCP CSO controls.
Post construction compliance monitoring program helps to make necessary adjustment in CSO controls
based on the data collected during the various implementation phases of the CSO long-term control
plan.
3.2 Data Quality Considerations
This section provides an overview of how to ensure that a permittee's post construction compliance
monitoring program incorporates appropriate data quality considerations. EPA provides guidance for
developing QAPPs in the following two documents:
• EPA Requirements for Quality Assurance Project Plans (QA/R-5) - March 2001 (Reissued May
2006), EPA/240/B-01/003. http://www.epa.gov/QUALITY/qs-docs/r5-final.pdf
• Guidance for Quality Assurance Project Plans (G-5) - December 2002, EPA/240/R-02/009.
http://www.epa.gov/quality/qs-docs/g5-final.pdf
For information regarding sampling, refer to:
• Guidance on Choosing a Sampling Design for Environmental Data Collection (G-5S) - December
2002, EPA/240/R-02/005. http://www.epa.gov/qualityl/qs-docs/g5s-final.pdf
In addition, if the permittee is planning to use models to evaluate the effectiveness of CSO controls, the
permittee should refer to:
• Guidance for Quality Assurance Project Plans for Modeling (G-5M) - December 2002, EPA/240/R-
02/007. http://www.epa.gov/QUALITY/qs-docs/g5m-final.pdf
The permittee should use EPA's Quality Assurance Project Plan (QAPP) guidance and all applicable state
or local QAPP guidance to develop a QAPP for post construction monitoring.
QAPPs are prepared to ensure that environmental and related data collected, compiled, or generated
for a project are complete, accurate, and of the type, quantity, and quality required for their intended
use. QAPPs include standardized, recognizable elements that cover the entire project. The four groups
of elements included in a QAPP are (A) Project management; (B) Data generation and acquisition; (C)
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Assessment and oversight; and (D) Data validation and usability. The intent of these four groups is
summarized in EPA's Requirements for Quality Assurance Project Plans (EPA/240/B-01/003 March, 2001;
http://www.epa.gov/QUALITY/qs-docs/r5-final.pdf). A detailed discussion of the content of the four
groups of elements, as it pertains to the development of a CSO post construction monitoring QAPP, is
presented in Appendix A.
3.2.1. Defining the Causes of Water Quality Impairment and Determining
Study Questions
Permittees should determine the causes of water quality impairment by evaluating pertinent
background information about CSO in the receiving waterbody to identify water quality-based factors
and then describe the work that will be done to collect the post construction compliance monitoring
data under the QAPP. An important step in this process is determining data quality objectives and
criteria that describe quality specifications regarding the level of the decision or study question and the
level of the measurements to support the decision or study question. Example study questions that
could be used for a post construction compliance monitoring QAPP include
• Do the number of overflows per year or volume of overflow captured during an average
precipitation year meet the goals of the basic approach selected by the permittee in the LTCP to
verify the effectiveness of CSO control?
• What pollutants and pollutant concentrations are detected at end-of-pipe locations or in
proximity to sensitive areas?
• Does receiving water quality measured immediately downstream of the CSO (or mixing zone, if
applicable) during wet weather meet applicable WQS or criteria?
• Does receiving water quality measured upstream of the CSO during wet or dry weather meet
WQS or criteria for pollutants for which the receiving water is listed as impaired?
• Are concentrations of pollutants detected in the receiving water downstream of the CSO greater
than those detected upstream?
The development of the study questions is the ideal time to determine the sampling design. The
permittee, when developing the sampling design, should try to minimize Type I and Type II decision
errors (false positives and false negatives). A false positive means a problem is found to exist when it in
fact does not. A false negative means a problem is not found when in fact it does exist. Sources of error
or uncertainty include collecting, handling, storing and analyzing samples (USEPA 2002a;
http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf). This section should also describe the types of
environmental data that will be collected for the project and the name(s) of the organization(s)
responsible for their collection.
For more information on documenting sampling design considerations in a CSO control assessment plan
and field sampling plan, see Sections 3.3 and 3.4 below, respectively.
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3.3 CSO Control Assessment Plan
The ideal time to develop the CSO control assessment plan is during development of the CSO control
study questions. The CSO control assessment plan should include a discussion of the basic approach (i.e.,
Presumption Approach, Demonstration Approach) selected by the permittee in the LTCP to verify the
effectiveness of CSO controls. In addition, the CSO control assessment plan should discuss how the
permittee will verify compliance with the selected approach. The CSO control assessment plan should be
submitted to the NPDES authority for review and approval before implementation. Note that there will
be some overlapping topics in the CSO control assessment plan, field sampling plan, and QAPP. To
reduce redundancy, the permittee should reference the applicable discussions in the other document(s)
when possible.
Detailed information on performing monitoring to verify the effectiveness of CSO controls is provided in
Section 4.1 of this guidance document as well as in Section 5 of EPA's (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows Guidance for Monitoring and
Modeling.
3.3.1 Verifying Effectiveness of CSO Controls Using the Presumption Approach
If the Presumption Approach has been selected, the permittee should describe in the CSO control
assessment plan how the specific criterion that the permittee has chosen under the Presumption
Approach will be verified. Note that when the Presumption Approach is selected, the permittee should
define system-wide and annual average conditions in the CSO control assessment plan. Permittees
should discuss the appropriate time frames for evaluating the success of CSO control targets with the
NPDES authority to ensure that adequate data are collected.
Implementing the Presumption Approach requires the permittee to define system-wide and annual
average conditions. System-wide is defined as the baseline condition for the entire CSS. The annual
average has both sewage and runoff components. The annual average sewage volume can be
determined by modeling or metering records. The annual average rainfall component should include
ranking annual rainfall, assessing month-to-month variations, assessing rainfall intensity, and assessing
return frequency.
Evaluating the Effectiveness of CSO Controls Under Criterion i
If the permittee is using Criterion i of the Presumption Approach, the permittee should describe
whether the frequency of CSO events per year will be evaluated through direct monitoring or modeling.
If direct monitoring is chosen, the permittee should describe things like the method that will be used to
determine whether a CSO has occurred; the CSOs that will be monitored, etc. For detailed information
on field monitoring, the permittee might want to reference the field sampling plan (see Section 3.4 of
this guidance document).
If a model is selected to predict the number of overflow events during a continuous simulation period,
the permittee should describe the model that will be used for this purpose and the data that will be
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needed to calibrate and validate the model. The permittee should include a discussion of how they will
collect monitoring data to calibrate or verify the model, including references to the field sampling plan,
as appropriate.
The permittee should discuss how monitored or modeled data will be evaluated on an average annual
basis to verify whether the CSO controls are meeting the frequency goals of the selected approach.
Evaluating the Effectiveness of CSO Controls Under Criterion ii
If the permittee is using Criterion ii of the Presumption Approach, the permittee should describe in the
CSO control assessment plan how flows to the CSS (e.g., flows from satellite communities that
contribute to the CSS, I/I in separate sanitary areas that contribute flow to the CSS) will be identified.
Permittees should have a good idea of the various flows in their system and what they represent from
the system characterization phase of the LTCP. If additional flows to the CSS need to be identified, the
permittee should describe what tools will be used to identify these flows, including additional
monitoring to determine flow contributions from different parts of the system.
After accounting for all the flows to the CSS, the permittee should describe whether the flow and
volume of CSO events per year will be evaluated through direct monitoring or modeling. If direct
monitoring is chosen, the permittee should describe the location(s) at which flow will be measured, and
the flow monitoring equipment. For detailed information on flow monitoring, the permittee might want
to reference the field sampling plan (see Section 3.4 of this guidance document).
If a model is selected to predict the flow and volume of CSO events per year, the permittee should
describe the model that will be used for this purpose and the data that will be needed to calibrate and
validate the model. The permittee should include a discussion of how they will collect monitoring data
to calibrate or verify the model, including references to the field sampling plan, as appropriate. The
permittee should discuss how monitored or modeled data will be evaluated on an average annual basis
to verify whether the CSO controls are meeting the volume goals of the selected approach. Because
percent capture must be evaluated on an annual basis, the permittee should describe how many years
of data (as determined in consultation with the NPDES authority) they will use for this analysis. EPA
recommends the use of long term data, if possible, in order to establish a "typical rainfall year." Many of
these data collection and modeling decisions may have been made during previous phases of LTCP
development (for example, during the system characterization, monitoring and modeling phase). The
permittee should leverage as much of this information as is appropriate for this evaluation to ensure
consistency with previous work and to minimize costs.
Evaluating the Effectiveness of CSO Controls Under Criterion Hi
If the permittee is using Criterion iii of the Presumption Approach, the permittee should describe in the
CSO control assessment plan how the mass of pollutants identified as causing water quality impairment
for the volumes that would be eliminated or captured for treatment under Criterion ii will be eliminated
or removed. For additional information on what pollutants should be selected for evaluation, see
Section 4.2.2 of this guidance document. The permittee should describe in the CSO control assessment
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plan how average pollutant loads will be calculated (using a mass balance approach) to evaluate the
elimination or removal of pollutants.
Average pollutant loads might have been calculated during the characterization, modeling, and
monitoring of the CSS performed during the development of the CSS. If average pollutant loads have not
been previously determined, the permittee should describe what information will be used to assign
them, such as historical NPDES monitoring data from the CSS, treatment plant optimization studies, and
facility plans and designs. In addition, the permittee might need to perform limited sampling at locations
within the CSS and at selected CSO outfalls to obtain recent and reliable characterization data. If
sampling is to be performed, the permittee should describe the CSS locations that will be monitored. For
detailed information on monitoring, the permittee might want to reference the field sampling plan (see
Section 3.4 of this guidance document).
3.3.2 Verifying Effectiveness of CSO Controls Using the Demonstration
Approach
If the Demonstration Approach is selected, the permittee should describe in the CSO control assessment
plan how its key requirements will be demonstrated.
The majority of post construction compliance monitoring for the Demonstration Approach should focus
on receiving water monitoring. Information on developing a field sampling plan for receiving water
monitoring is provided in Section 3.4 of this guidance document. In addition, the permittee should
describe whether a receiving water model will be used to help demonstrate the impact of the CSOs on
the receiving water. If a model will be used, the permittee should describe the model and the data that
will be needed to calibrate and validate the model. Permittees should also include a discussion of how
they will collect monitoring data to calibrate or verify the model, including references to the field
sampling plan, as appropriate.
Permittee needs to realize that ultimate expectation of the CWA and CSO Control Policy is meeting the
WQSs and protecting the designated uses of the waterbody. Presumption and Demonstration
approaches are CSO control design criteria use to develop long-term CSO control plan.
3.3.3 Verifying Effectiveness of Pre-Policy CSO Control Plans
EPA recognizes that extensive work has been done by many Regions, States, and municipalities to abate
CSOs. As such, portions of the CSO Control Policy may already have been addressed by permittees
previous efforts to control CSOs. Therefore, portions of the Policy may not apply, as determined by the
NPDES authority on a case-by-case basis, (see box on next page).
In the case of any ongoing or substantially completed CSO control effort, the NPDES permit or other
enforceable mechanism, as appropriate, should be revised to include all appropriate permit
requirements consistent with Section IV.B. of the CSO Control Policy.
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Communities with pre-policy CSO control plans can also use this guidance for their post construction
compliance monitoring requirements.
3.4 Field Sampling Plan
As described in the discussion at the beginning of the previous Section (3.3), the ideal time to develop
the sampling design is during development of the study questions. The sampling design should be
documented in a field sampling plan and submitted to the NPDES authority for review and approval
before implementation. Note that there will be some overlapping topics in the field sampling plan, CSO
CSO Policy: Effect on Current CSO Control Efforts
EPA recognizes that extensive work has been done by many Regions, States, and municipalities to
abate CSOs. As such, portions of this Policy may already have been addressed by permittee's
previous efforts to control CSOs. Therefore, portions of this Policy may not apply, as determined by the
permitting authority on a case-by-case basis, under the following circumstances:
1. Any permittee that, on the date of publication of this final Policy, has completed or substantially
completed construction of CSO control facilities that are designed to meet WQS and protect
designated uses, and where it has been determined that WQS are being or will be attained, is not
covered by the initial planning and construction provisions in this Policy; however, the operational
plan and post construction monitoring provisions continue to apply. If, after monitoring, it is
determined that WQS are not being attained, the permittee should be required to submit a revised
CSO control plan that, once implemented, will attain WQS.
2. Any permittee that, on the date of publication of this final Policy, has substantially developed or is
implementing a CSO control program pursuant to an existing permit or enforcement order, and
such program is considered by the NPDES authority to be adequate to meet WQS and protect
designated uses and is reasonably equivalent to the treatment objectives of this Policy, should
complete those facilities without further planning activities otherwise expected by this Policy. Such
programs, however, should be reviewed and modified to be consistent with the sensitive area,
financial capability, and post construction monitoring provisions of this Policy.
3. Any permittee that has previously constructed CSO control facilities in an effort to comply with
WQS but has failed to meet such applicable standards or protect designated uses due to
remaining CSOs may receive consideration for such efforts in future permits or enforceable orders
for long-term CSO control planning, design and implementation.
In the case of any ongoing or substantially completed CSO control effort, the NPDES permit or other
enforceable mechanism, as appropriate, should be revised to include all appropriate permit
requirements consistent with Section IV.B. of this Policy.
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control assessment plan and QAPP. Field sampling plans or Sampling and Analysis Plans should generally
be included as appendices to QAPPs, as the QAPP is incomplete without sampling details. To reduce
redundancy, the permittee should reference the applicable discussions in the other document when
possible.
For sampling design considerations and examples, see EPA's Combined Sewer Overflows Guidance for
Monitoring and Modeling (EPA 832 -B-99-002 January 1, 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf). In addition, EPA's Guidance on Choosing a Sampling
Design for Environmental Data Collection (EPA/240/R-02/005 December 2002;
http://www.epa.gov/qualityl/qs-docs/g5s-final.pdf) will be useful for determining the number of
samples needed and how to allocate these samples across space (within the spatial boundaries of the
study) and across time (within the temporal boundaries of the study), to lower uncertainty related to
heterogeneity to the greatest extent possible.
The field sampling plan should address assessment of the CSO controls and both effluent and ambient
monitoring. Ambient monitoring should be conducted at representative CSO locations appropriate to
determine the full range of CSO impacts on the waterbody. The monitoring should be done at CSO
outfalls and outside the area of CSO impact, including areas upstream of CSOs.
The field sampling plan should provide detailed monitoring protocols and associated schedules
(including the duration of different monitoring activities). The monitoring protocols should include the
necessary effluent and ambient monitoring, and, where appropriate, biological assessments, WET
testing, and sediment sampling. These types of monitoring may be appropriate depending on the WQS
in the receiving water. For example, ambient toxicity testing, using samples collected up and
downstream of the CSO outfall during wet weather events might be useful in smaller streams and rivers
to determine compliance with narrative toxicity standards. Alternatively, direct WET testing of CSO
outfall samples during wet weather events can be used to evaluate compliance with the narrative
toxicity standard.
One of the main considerations in determining the frequency, duration and scheduling of monitoring is
identifying the number of storm events needed to provide data for evaluating receiving water impacts.
The National Research Council's (NRC; 2008;
http://www.epa.gov/npdes/pubs/nrc stormwaterreport.pdf) Urban Stormwater Management in the
United States, provides a detailed discussion of the number of data points needed to characterize a set
of conditions. NRC recommends collecting approximately 50 sample pairs (i.e., upstream-downstream
samples during a particular storm condition), with typical sample variabilities, as a reasonable objective
for most stormwater projects to statistically be able to detect a difference of at least 25 percent.
Depending on budgetary constraints, the permitting community could decide to space sampling events
over several years to obtain this number of paired samples. Alternatively, the permitting community
could decide to choose a more judgmental sampling approach for sampling, where fewer samples are
collected and conclusions are based on professional judgment (USEPA 2002c;
http://www.epa.gov/qualityl/qs-docs/g5s-final.pdf).
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EPA's (2002c; http://www.epa.gov/qualityl/qs-docs/g5s-final.pdf) Guidance on Choosing a Sampling
Design for Environmental Data Collection for Use in Developing a Quality Assurance Project Plan
provides guidance on the judgmental sampling approach and more statistically robust sampling designs.
This guidance document notes that when judgmental sampling is used as the sampling design,
quantitative statements about the level of confidence in an estimate (such as confidence intervals)
cannot be made and that conclusions about the target population are limited and depend entirely on
the validity and accuracy of professional judgment. This guidance document also explains how expert
judgment may be used in conjunction with other sampling designs so that more statistically defensible
data can be obtained from sampling.
The post construction monitoring plan should identify the types of pollutants and parameters to be
analyzed for effluent and ambient monitoring. Monitoring may include chemical, physical, or biological
parameters. The permittee should base the decision on what parameters to monitor on site-specific
factors, including the water quality criteria for the specific designated use(s) of the receiving water,
pollutants key to the attainment of designated use(s), and pollutants affected by the CSO controls.
The plan should include appropriate measures of success. In addition, the monitoring should be
coordinated with any ongoing or planned state monitoring programs or programs of other permittees
within the same watershed.
3.4.1 Data Monitoring Needs
As described in EPA's Combined Sewer Overflows Guidance for Monitoring and Modeling (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf). the monitoring effort necessary to address the study
questions will depend on factors such as the layout of the collection system; land uses in the drainage
basin; the quantity, quality and variability of existing historical data; and the available budget. In some
cases, sufficient historical monitoring data might be available so that only limited additional monitoring
might be necessary. The monitoring design should be updated as needed to reflect changes in data
needs.
The field sampling plan should address the following major elements (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf):
• Duration of monitoring program
• Monitoring locations
• Frequency of sampling and number of wet-weather events to be sampled
• Criteria for when samples will be collected (e.g., criteria for both wet weather events and
ambient conditions, i.e., x days/hours from the previous precipitation event)
• greater than x days between events, rainfall events greater than 0.4 inch to be sampled)
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CSO Post Construction Compliance Monitoring Guidance
• Strategy for determining when to initiate
wet-weather monitoring
• Sampling protocols (e.g., sample types,
sample containers, preservation methods
[see also Title 40 of the Code of Federal
Regulations (CFR) Part 136 (Appendix E to
this document)])
• Flow measurement protocols
• Pollutants or parameters to be analyzed or
measured
• Sampling and safety equipment and
personnel
• QA/QC procedures for sampling and
analysis
• Procedures for validating, tracking and
reporting sampling results
Guidance on determining these elements is
provided in this document as well as in Section 4 of
EPA's Combined Sewer Overflows Guidance for
Monitoring and Modeling (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf).
3.4.2 Combined Sewer System and
Receiving Water Quality
Monitoring
Section 4 of this document and Chapters 5 and 6 of
EPA's Combined Sewer Overflows Guidance for
Monitoring and Modeling (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf) provide detailed
guidance on how to perform CSS and receiving water quality monitoring. The permittee should
document its monitoring procedures in the field sampling plan. In many cases, this information is
provided in SOPs attached to the monitoring plan. For guidance on developing SOPs, see Section 3.5.
w A .S;H 1 s i; T u s \
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CSO Monitoring Plan for St. Joseph's Missouri.
3.5 Standard Operating Procedures
An SOP should be prepared for field, laboratory, and database management activities that need to be
performed the same way every time. The permittee should prepare SOPs for activities such as
calibration, use, and maintenance of a flow meter; collecting grab samples from surface waters;
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CSO Post Construction Compliance Monitoring Guidance
collecting field blanks; and measuring turbidity. The permittee should include all applicable SOPs as
attachments to the project QAPP or to the post construction monitoring plan.
For detailed information on developing SOPs, the permittee should see EPA's Guidance for Preparing
Standard Operating Procedures (USEPA 2007a; http://www.epa.gov/quality/qs-docs/g6-final.pdf). As
described in that document, the following general elements should be included in a technical SOP:
1. Title page
2. Table of contents (if needed because of length of document)
3. Procedures
a. Scope and applicability
b. Summary of method
c. Definitions
d. Health and safety warnings
e. Cautions
f. Interferences
g. Personnel qualifications/responsibilities
h. Equipment and supplies
i. Procedure
j. Data and records management
4. Quality assurance and quality control
5. References
The SOP should describe in detail the method for a given procedure. The method should be presented in
sequential steps and should include specific facilities, equipment, materials and methods, QA and QC
procedures, and other factors required to perform the procedure. SOPs should be revised when new
equipment is used, when comments by personnel indicate that the directions are not clear, or when a
problem occurs.
3.6 Example Planning Documents
Some examples of QAPPs, Field Sampling Plans and SOPs that have been prepared for CSO projects
include the following:
• Rouge River National Wet Weather Demonstration Project (2004), including the Rouge River
Watershed Sediment Reconnaissance Survey QAPP http://www.rougeriver.com/
http://www. rougeriver.com/proddata/catalog.cf m?categorv=sampling
• Several Rouge River Field Sampling Plans and SOPs http://www.rougeriver.com/
• Merrimack River Watershed Assessment Study QAPP (USAGE 2003)
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CSO Post Construction Compliance Monitoring Guidance
http://www.nae.usace.army.mil/proiects/ma/merrimack/LMRBqapp.pdf
Merrimack River Watershed Assessment Field Sampling Plan
http://www.nae.usace.army.mil/proiects/ma/merrimack/LMRBfieldsamplingplan.pdf
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CSO Post Construction Compliance Monitoring Guidance
Section 4. Post Construction Compliance Monitoring
This section is intended to show how the questions that were identified in the planning process
described in section 3 can be answered. The questions are some variant of: Are the CSO controls
achieving the level of CSO control they were designed to meet, and are the CSO controls achieving
compliance with WQS, NPDES permit requirements or enforcement actions (orders or decrees)?
This section presents the two components of post construction compliance monitoring in detail: (1) to
collect data for evaluating the effectiveness of CSO controls in meeting their intended purpose, and (2)
to collect ambient data for assessing compliance with WQS. This section also provides general
information on monitoring, discusses the premise that monitoring should be meaningful and enable
verification, and that site-specific conditions will often dictate the extent and adequacy of monitoring.
This section also provides general information on CSS and receiving water monitoring, as well as detailed
information on setting up and conducting post construction compliance monitoring that meets the goals
of the CSO Control Policy.
Goals of Post Construction Compliance Monitoring
As outlined in the CSO Control Policy, post construction compliance monitoring is intended to provide
data that can be used to
• Verify the effectiveness of CSO controls
• Demonstrate compliance with WQS, protection of designated uses and sensitive areas
Individual permittees may set performance standards in their LTCP that can help to define potential
ways to "verify the effectiveness of CSO controls." The CSO Control Policy emphasizes that long-term
CSO control plan to give the highest priority to controlling overflows to sensitive areas, as determined by
the NPDES authority in coordination with State and Federal agencies. The goal of a CSO community's
post construction compliance monitoring program should also give the highest priority to monitor the
overflows to sensitive areas. NPDES authorities should work with individual permittees to ensure that
these performance standards are meaningful and that they contribute to an understanding of the
effectiveness of the CSO control program. The post construction compliance monitoring may also be
linked to specific NPDES permit requirements, such as demonstrating compliance with water quality-
based effluent limits. Because water quality-based effluent limits are required to be based on the
applicable WQS in the receiving water, monitoring data that can be used to evaluate compliance with
water quality-based effluent limits should also meet the requirements for data that can be used to
demonstrate compliance with WQS and protection of designated uses.
Organization of this Section
This section presents detailed discussions of potential methods that permittees can use to verify the
effectiveness of CSO controls and demonstrate compliance with WQS and protection of designated uses.
The section is organized into two major subsections according to the types of monitoring being
conducted. Subsection 4.1 discusses monitoring to "verify the effectiveness of CSO controls." Subsection
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CSO Post Construction Compliance Monitoring Guidance
4.2 discusses ambient monitoring to gather data to be used in assessing compliance with WQS. Each
subsection will focus on the type of monitoring to be done to help define what, where, and when to
monitor.
4.1 Monitoring to Verify the Effectiveness of CSO Controls
Monitoring to verify the effectiveness of CSO controls can take several different forms, which may
include documenting and evaluating implementation milestones, performance measures, or operations
and maintenance requirements. For example, previous EPA guidance describes measures of success for
CSO control in four broad categories, including the following:
• Administrative measures that track programmatic activities;
• End-of-pipe measures that show trends in the discharge of CSS flows to the receiving
waterbody, such as reduction of pollutant loads, the frequency of CSOs, and the duration of
CSOs;
• Receiving waterbody measures that show trends of the conditions in the waterbody to which
the CSO occurs, such as trends in dissolved oxygen levels and sediment oxygen demand; and
• Ecological, human health, and use measures that show trends in conditions relating to the use of
the waterbody, its effect on the health of the population that uses the waterbody, and the
health of the organisms that reside in the waterbody. These might include beach closures,
attainment of designated uses, habitat improvements, and fish consumption advisories. Such
measures would be coordinated on a watershed basis as appropriate.
The third and fourth bullets are primarily measures of the CSO's impact on the receiving water and on local
ecology and human health. These measures will be discussed in detail in Subsection 4.2. This subsection
focuses on the measures in the first and second bullets, with an emphasis on discussing methods to collect
data allowing an evaluation of CSO control effectiveness as defined by end-of-pipe measures.
The CSO Control Policy defines two basic approaches for achieving CSO control through the LTCP: the
Presumption Approach and the Demonstration Approach.
Verifying CSO Control through Verifying Compliance with the Presumption or Demonstration Approach
A straightforward approach to verifying CSO control as described in the CSO Control Policy is to verify
compliance with the approach used in the permittee's LTCP—either the Presumption or the
Demonstration Approach. EPA has laid out very specific requirements for each approach, and verifying
whether the permittee has met the appropriate approach can consist of verifying whether the permittee
has met these requirements. The expectation of the CWA and CSO Control Policy is, the permittee will
ultimately meet WQSs and protect designated uses of the waterbody. Meeting the requirements of any
CSO control approach does not guarantee that the permittee is fulfilling their regulatory requirements.
Post construction compliance monitoring programs determine whether the permittee's regulatory
requirements are met.
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CSO Policy: "Presumption" Approach
A program that meets any of the criteria listed below would be presumed to provide an adequate level of
control to meet the water quality-based requirements of the CWA, provided the permitting authority
determines that such presumption is reasonable in light of the data and analysis conducted in the
characterization, monitoring, and modeling of the system and the consideration of sensitive areas
described in this Policy. These criteria are provided because data and modeling of wet weather events
often do not give a clear picture of the level of CSO controls necessary to protect WQS.
i. No more than an average of four overflow events per year, provided that the permitting authority may
allow up to two additional overflow events per year. For the purpose of this criterion, an overflow
event is one or more overflows from a CSS as the result of a precipitation event that does not
receive the minimum treatment specified below; or
ii. The elimination or the capture for treatment of no less than 85% by volume of the combined sewage
collected in the CSS during precipitation events on a system-wide annual average basis; or
ill. The elimination or removal of no less than the mass of pollutants identified as causing water quality
impairment through the sewer system characterization, monitoring, and modeling efforts for the
volumes that would be eliminated or captured for treatment under paragraph ii above.
Combined sewer flows remaining after implementation of the nine minimum controls and within the
criteria specified at II.CAa.i or ii should receive a minimum of:
• Primary clarification (Removal of floatables and settleable solids may be achieved by any
combination of treatment technologies or methods that are shown to be equivalent to primary
clarification);
• Solids and floatables disposal; and
• Disinfecting effluent, if necessary, to meet WQS, protect designated uses and protect human health,
including removal of harmful disinfection chemical residuals, where necessary.
EPA's Combined Sewer Overflows Guidance for Monitoring and Modeling (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) can be very helpful in establishing programs to verify CSO
controls. Permittees and NPDES authorities should review that guidance as post construction
compliance monitoring plans are developed.
4.1.1 CSO Frequency Control Targets
This document breaks the compliance requirements into two parts; this part deals with the effectiveness
of CSO controls, and this subsection specifically with whether or not CSO frequency targets are being
met. Criterion i of the Presumption Approach states that the permittee will achieve no more than an
average of four overflow events per year (note that the definition states that the NPDES authority may
allow up to two additional overflow events per year, so some permittees may be allowed up to six
overflows per year, on average). This type of CSO control can be evaluated by collecting and studying
CSO frequency data.
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CSO Post Construction Compliance Monitoring Guidance
CSO Policy: "Demonstration" Approach
A permittee may demonstrate that a selected control program, though not meeting the criteria specified
in II.C.4.a. above (Presumption Approach) is adequate to meet the water quality-based requirements of
the CWA. To be a successful demonstration, the permittee should demonstrate each of the following:
i. The planned control program is adequate to meet water quality standards and protect designated
uses, unless water quality standards or uses cannot be met as a result of natural background
conditions or pollution sources other than CSOs;
ii. The CSO discharges remaining after implementing the planned control program will not preclude
attainment of water quality standards or the receiving waters' designated uses or contribute to their
impairment. Where water quality standards and designated uses are not met in part because of
natural background conditions or pollution sources other than CSOs, a total maximum daily load,
including a wasteload allocation and a load allocation, or other means should be used to apportion
pollutant loads;
ill. The planned control program will provide the maximum pollution reduction benefits reasonably
attainable; and
iv. The planned control program is designed to allow cost-effective expansion or cost-effective
retrofitting if additional controls are subsequently determined to be necessary to meet WQS or
designated uses.
The policy defines an overflow event for the purposes of criterion i as one or more untreated overflow
events from anywhere within a particular CSS caused by a precipitation event. The CSS discharge is
considered an untreated overflow if it does not receive the minimum treatment described in Section 4.1
above.
Overflow data should be presented so that they can be evaluated on an average annual basis. Figure 1
below shows the number of untreated overflow events per year after CSO control implementation for a
six-year period (years 2 through 7) compared to an average of pre-control conditions (year 1). It is worth
noting that, although the permittee exceeded four overflows in year 3 (the second year of post control),
the annual average for the six post-control years is less than four overflows per year. This indicates that
the permittee is in compliance with this requirement. Note that the six years of post CSO control data
presented in the figure are for example purposes only; each individual permittee should discuss the
appropriate time frames for evaluating the success of CSO frequency targets with their NPDES authority
to ensure agreement that adequate data are collected.
Permittees should provide data on the number of overflows from the CSS that meet the overflow
definition provided above. These data can either be measured or modeled. In smaller, less complex
systems, it might be most appropriate to monitor the number of overflow events directly. However, in
more complex systems with a large number of outfalls or when CSO outfalls are submerged, it could be
difficult to monitor all the outfalls directly to record overflows. In such cases, it might be more
appropriate to use a model to predict the number of overflows in the reporting period. The number of
overflows could be based on running a properly calibrated and validated model with precipitation data
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CSO Post Construction Compliance Monitoring Guidance
• Overflow
Events
perYear
yri yr2
yr4
yr6 yry
Figure 1. Annual Overflow Events Used to Evaluate Criterion i of the Presumption Approach
collected during the reporting period, or it could be based on modeling a series of design storms used in
developing the LTCP. The following section discusses how to monitor CSO frequency, including discussions
of where and how to monitor, how to use hydrologic and hydraulic models to estimate CSO frequency, and
then provides some examples of monitoring programs designed to collect data on CSO frequency.
4.1.1.1 Direct Monitoring of CSO Frequency
Direct monitoring of CSO frequency consists of recording physical data indicating that CSOs have
occurred. The types of data that can be used to indicate that CSOs have occurred can be direct
monitoring methods, such as meters or monitors that measure CSO discharges as they occur, or simple
"yes/no" methods, such as placing a wood block or other float on a CSO weir and checking after each
storm event to see if it has been dislodged from the weir. Permittees using direct methods for
monitoring CSO frequency should develop a plan that summarizes what method or combination of
methods they will use to determine if CSO discharges have occurred in the CSS (e.g., block method,
direct measurement); which CSOs they will monitor within the system (e.g., every outfall; outfalls
discharging the most frequently on the basis of previous observations; outfalls in sensitive areas); when
and how often they will monitor them (e.g., after every precipitation event delivering a measurable
amount of precipitation; after every precipitation event reaching a certain threshold level of
precipitation); what type of data they will collect from an event (e.g., block present or absent, meter
reading); how that data should be used to determine if a CSO event has occurred (e.g., CSO event has
occurred if the block is absent from the weir or CSO event has occurred if the meter has registered
flow); and, perhaps most importantly, explain how their data are suitably representative of all the CSOs
in the system. It would be expected that permittees with populations more than 75, 000 would utilize
metering or an event monitoring/modeling system.
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CSO Post Construction Compliance Monitoring Guidance
4.1.1.1.1 Methods for Measuring CSO Frequency
There are a number of methods for evaluating whether a CSO has occurred, ranging from the simple to
the sophisticated. This section discusses several of these methods, but individual permittees may devise
other methods for determining whether CSOs have occurred. NPDES authorities should review the
methods proposed by the permittees to ensure that they will measure CSO discharges effectively, and
that the method proposed is appropriate to provide the data needed for the LTCP.
• Visual observation—This is the most direct way to determine if a CSO is occurring is to have field
personnel conduct visual observations at the CSO. There are drawbacks to this method,
including timing, the health and safety of field personnel and the fact that it can be expensive to
mobilize field crews to monitor wet-weather events, and some discharges may also occur below
the water line.
• Block method—In this method, a wood or foam block or some other type of lightweight marker
is placed on top of the weir or hydraulic control at the approximate water level that initiates an
overflow. The block is then checked after each rainfall to determine if it has been dislodged. If
the block has moved or is missing, a CSO discharge is presumed to have occurred. If the block is
still on the weir, no CSO event has occurred.
The block method is simple and low cost. However, it is appropriate only for outfalls that have a
weir system or some suitable type of structure on which the block can be placed. This method
also requires field crews to access the location after each rainfall.
• Chalk board method1—In this method, a chalk board is used as a simple depth-measuring
device, and the occurrence of a CSO is interpreted from the depth of the water at the location of
the chalkboard. The chalkboard is placed at a strategic location in the CSS—typically in a
manhole. A horizontal chalk line is drawn on the board at a height representing the depth of
water needed to cause a CSO discharge. The chalkboard is checked after each rainfall. If the
chalk line is washed away, the water level reached the chalk line, and a CSO discharge is
presumed to have occurred.
The chalk method can be effective if there is a suitable location and space to fasten the
chalkboard. However, this method requires the permittee to know accurately beforehand at
what depth of water in each manhole CSOs will occur.
• Metering—Metering is an excellent way to capture an abundance of data about CSOs, including
whether they have occurred, overflow duration and the volume discharged. However, metering
is expensive because of the capital costs of the meters themselves, costs for meter installation,
operations and maintenance, and potential replacement costs for damaged meters.
• Hydraulic Monitoring Using Remote Sensors—Recent advances in wireless radio network
technology makes it possible for communities to establish a data acquisition system that
uploads flow information collected from various points throughout the CSS to a secure website.
1A variation of the chalk board method is to use pressurized air to blow a coating of chalk dust onto the walls and
bottom of normally dry CSO outfall pipes and observe the coating after each rainfall. When the coating is missing,
a CSO discharge can be inferred.
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This approach avoids the costs associated with creating a centralized database or linking to an
existing SCADA system. Microcomputers embedded within the CSS are connected to flow
sensors that are mounted on the undersides of manhole covers. Remote sensors can also be
used to detect pressure and actuate valves that divert flows to basins for storage or treatment.
4.1.1.1.2 Determining the Outfalls to Evaluate
When identifying the outfalls to evaluate for determining CSO frequency, the permittee can focus on the
worst-case scenario and restrict monitoring to the outfall or outfalls that are known to be most
susceptible to overflows. These outfalls might be known from historical observations, or they can be
determined by hydraulic analysis to identify flow bottlenecks in the sewer system. If historical data or
analysis of the system suggests that different rain events cause different CSOs to overflow, this should
be taken into account when deciding on which outfalls to monitor for results that are adequately
representative of the whole system.
4.1.1.1.3 Determining When and How Often to Monitor
As with determining which outfalls to evaluate, historical observations or analysis of rainfall response
patterns may provide insight into when and how often to monitor the outfalls. These historical data could
show the volume and intensity of precipitation that typically causes overflows, and permittees can track
rain events and then determine which outfalls need to be monitored. Alternatively, if the permittee does
not have a good idea of the rainfall/response relationship, monitoring could consist of the following:
• Choosing a certain number of precipitation events to monitor (e.g., monitor until five storms of
a certain size are evaluated)
• Targeting a certain sized precipitation event (e.g., 3-month, 24-hour storm)
• Monitoring all precipitation events over a representative time period
If the permittee does not choose to monitor all precipitation events, the permittee will have to
extrapolate the number of CSO events from the data collected. Therefore, it is important to choose a
monitoring method that will allow extrapolation of the number of overflows with a reasonable
expectation of accuracy. For example, if the permittee has a good model of the system, it might be
possible to predict overflows at several outfalls by monitoring for overflows at several key outfalls.
4.1.1.1.4 Data Collection
The data collected should allow an evaluation of whether a CSO has occurred. For the simple methods,
such as direct observation of the outfall or evaluation of blocks or chalk lines, a simple yes or no on
whether a CSO has occurred should be sufficient. For other methods of evaluating CSO occurrences,
such as metering, permittees might want to collect other data, such as the volume and duration of
overflow. These data can be used for a calibration of a hydraulic model of the CSS or in other analyses.
Permittees should also collect coincidental precipitation data to define or validate previously-developed
rainfall response relationships.
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4.1.1.1.5 Data Evaluation
For most methods of evaluating whether a CSO has occurred—such as block testing and evaluating chalk
lines—the evaluations should be straightforward. However, for metering data, the permittee might have
to evaluate the data to determine whether a CSO has occurred. If the permittee had previously used
metering data as part of the characterization of the system, the method for interpreting CSO events
might already have been developed. If no metering had been done previously, the permittee should also
discuss the method for interpreting the data and determining whether an overflow has occurred. For
example with continuous metering data, a break in overflow discharge of 72 hours or longer is typically
adopted to determine when one overflow event has ended and a new even has started.
4.1.1.2 Estimating CSO Frequency Using Modeling
Modeling can be a valuable tool for complex CSSs because it allows the permittee to be more confident
in evaluating different circumstances and scenarios after calibration and validation of the model. With
respect to estimating CSO frequencies, models can be especially useful in large or complex systems
where it might be difficult to monitor individual outfalls or where it might be difficult to predict the
response of the CSS to different rainfall events.
Many permittees have developed models of the CSS to evaluate different CSO control scenarios for
evaluating control requirements in the LTCP. If the permittee has used the Presumption Approach of
achieving no more than four overflows, on average annual basis, the model should already be designed to
evaluate the frequency of overflows in the system. In such a case, the permittee should update the model
to reflect the implementation of CSO controls, validate and/or recalibrate the model, and then run the
model in a continuous simulation that is based on a sequence of storms. This accounts for the additive and
antecedent effects of storms occurring close together. A continuous simulation also covers storms with a
range of different characteristics. The permittee should then report the predicted number of overflows
within the simulation period, and the NPDES authority can use these results to evaluate whether the
permittee has achieved acceptable levels of CSO control. Note that such models are typically verified with
some monitoring data (typically metered flow data). Permittees should include a discussion of how they
will collect monitoring data to verify the model in the post construction compliance monitoring phase.
4.1.2 CSO Volume Control Targets
Criterion ii of the Presumption Approach states that the permittee will achieve the elimination or
capture for treatment of no less than 85 percent by volume of the combined sewage collected in the CSS
during precipitation events on an annual average basis. This type of CSO control can be evaluated by
collecting and studying CSO volume data.
Many permittees will have completed flow monitoring during the characterization phase of their LTCP,
and therefore the permittee may already have good information to use to evaluate CSO volume targets.
Permittees are encouraged to use any existing data in their evaluations, and to use the data in this
section to supplement their data collection efforts to ensure that the data is adequate to evaluate CSO
volume control targets.
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Communities that use modeling should integrate the results of their Post Construction
Compliance Monitoring
CSS communities should assess whether their specific performance criteria have been achieved by
verifying that the remaining CSO discharges are in compliance with the water quality goals of the CWA.
In most cases, bacteria will be the pollutant of concern, and this will need to be quantified by the
determination of the number of residual untreated overflows for a predefined "typical year." For a
community that has used a model to assist in the determination of the final alternative of the LTCP, the
following steps would typically need to occur after LTCP implementation is complete to determine
whether performance criteria have been achieved:
1. During precipitation events, the following data would be collected for each event: rainfall data;
overflow volumes and frequency and duration at each CSO location; predefined water quality
sampling in the receiving water (for predefined parameters and at predefined locations);
2. Run the hydraulic model (if applicable) to see if, using the rainfall data experienced during the
monitoring period, the model is predicting the same number and magnitude of overflows as
actually observed during the monitoring period;
3. Modify the model, if necessary, so it is again accurately calibrated so that it predicts what has
been observed during the post construction monitoring program sampling. Note that this will be
the first time the model will be verified with the design/measures specified in the LTCP, NPDES
permit, consent decree or order implemented and the model might need to be adjusted until it is
calibrated/validated to predict the same CSO activation frequency, duration, and volume as
observed in the sampling results;
4. When the model has been verified to be accurately calibrated to the "actual future sewer
hydraulic design" that was basis of the LTCP, NPDES permit, consent decree or order, then the
model should be run again on the predefined "typical year" to see how many overflows are
predicted to occur;
5. If the model simulation predicts, using the "typical year" rainfall data, that the number of
overflows meets the specified performance of the LTCP, NPDES permit, consent decree or
order (e.g., < 4 overflows in a typical year), then the performance criteria are deemed to be met;
6. Lastly, the residual overflows need to be evaluated if sampling has indicated the water quality
goals of the CWA are still not being met. This will require coordination with state and federal
regulators to determine if any additional work may be warranted or how otherwise to resolve the
issues.
Since it is highly unlikely that the post construction compliance monitoring period in the future will
experience the same rain event data as the predefined typical year, steps 2-5 (above) should be
conducted to allow a properly calibrated/validated model to predict performance for the typical year after
there may have been 10-15 years of modifications to the sewer system since the LTCP was finalized.
EPA recognizes that the scope of an LTCP, including the characterization, monitoring and modeling,
and evaluation of alternatives may be difficult for some small CSSs. At the discretion of the NPDES
authority, jurisdictions with populations under 75,000 may not need to complete each of the formal steps
outlined in Section II. C. of the CSO Control Policy (Long-Term CSO Control Plan). Permittees are
encouraged to discuss the scope of their LTCP with their WQS authority and NPDES authority to ensure
that their plan includes sufficient information to enable the permitting authority to identify the appropriate
CSO controls.
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CSO Post Construction Compliance Monitoring Guidance
4.1.2.1 Identifying Flows to the CSS
Permittees should ensure that the flow values used to evaluate compliance with CSO volume control
targets include appropriate contributions of the various parts of the CSS and that the remaining CSO
volumes are calculated correctly. For example, permittees should be sure to account for flows from
upstream from separated areas, plus any infiltration and inflow that can be expected during critical
periods (e.g., during rainfall events). Examples of the types of flows that should be accounted for to
ensure that the flow volumes represent the CSS and all its contributing areas include the following:
• Flows from satellite communities that contribute to the CSS
• Separate sanitary flow to the CSS from non-CSS areas
• Infiltration and inflow in separate sanitary areas that contribute flow to the CSS
• Flow in key interceptors in the CSS
• Flow at key hydraulic control points (i.e., pump stations) in the CSS
• Flow at treatment facilities within the CSS
• Flow at the headworks of the publicly owned treatment works wastewater treatment plant
(POTWWWTP)
• Flow at POTW WWTP outfalls, including allowable CSO-related bypasses
• Flow at CSO outfalls
4.1.2.2 Measuring Flows in the CSS
As discussed in the previous section, to evaluate compliance with criterion ii of the Presumption
Approach, permittees should provide supporting data and calculations for the volume of combined
sewage in the CSS during precipitation events. Once the permittee is sure that all flows are accounted
for, a specific location or locations for measuring flow or for calculating flow with the CSS model should be
identified. In a simple system, this could be at the influent wet well at the headworks of the WWTP
where all the captured flow from the system is consolidated. In more complex systems, permittees
might opt to evaluate the 85 percent control level by sewershed, so the permittee should choose a
location that includes all the flows into that sewershed.
Once the correct locations for the evaluation of flow are identified, the permittee should evaluate the
flow at that location. In an ideal situation, the permittee would monitor flow in the CSS in the location
where all the flows have already entered the system, so as to account for the entire flow. However, in
other cases, it might be necessary to determine the flow through the CSS model or by estimating the
different flow components from monitoring results and adding them together to get a total flow of
combined sewage in the CSS during precipitation events. Estimating the combined sewage in the CSS
during precipitation events by adding the different flow components based on monitoring requires a full
understanding of what flows each monitoring point represents. Permittees should have a good idea of
the various flows in their system and what they represent from the system characterization phase of the
LTCP. However, in situations where a permittee installs additional flow meters to collect monitoring data
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to determine flow contributions from different parts of the system, the permittee should be sure to
position the flow meters so as to be able to isolate the various significant flow components.
Flow measurements are generally made using automatic devices that can be installed in channels, storm
drains, or CSO structures. These devices use a variety of sensor types, including pressure/depth sensors
and acoustic measurements of stage height or Doppler effects from flow velocity. Data are stored in a
computer chip that can be accessed and downloaded by a portable computer. Data are processed
according to the appropriate pipe, flume, or weir hydraulic equations. Field calibration of such equations
is important because these types of data can be influenced by surcharging, backwater, tidal flows, and
other complex hydraulic conditions typical of wet-weather flows.
4.1.2.3 Modeling Flows in the CSS
Permittees could also use hydraulic modeling to evaluate flows in the CSS. Different hydraulic models
may be appropriate for different purposes. Several types of models are summarized below:
• Models based on the kinetic wave approximation of the full hydrodynamic equations. These
models can predict flow depths, and therefore flow and discharge volumes, in systems that are
not subject to surcharging or backups (backwater effects). These models require the user to
input hydrographs from runoff model results (the TRANSPORT block of SWMM is an example).
• Complex hydrodynamic models based on the full hydrodynamic equations. They simulate
surcharging, backwater effects, or looped systems and represent all pertinent hydraulic
processes. These models require the user to input hydrographs from runoff model results (the
EXTRAN block of SWMM is an example).
EPA does not recommend using landside runoff models for determining flow volumes in the CSS. While
many permittees have used runoff models in developing the LTCP, they are not appropriate for
determining volume in the CSS. Runoff models are based on Soil Conservation Service runoff curve
numbers, runoff coefficients, or other similar methods for the generation of flow. These models can
estimate runoff flows delivered to the sewer system, and, to a lesser degree, flows at different points in
the system. Runoff models generally do not by themselves adequately simulate flow within the system.
EPA's Combined Sewer Overflows Guidance for Monitoring and Modeling (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) provides a full discussion of monitoring approaches to
determine flow volumes in the CSS. For more information on flow monitoring, permittees should refer
to that document.
4.1.2.4 Definitions and Calculations for CSO Volume Control Requirements
Criterion ii for the Presumption Approach requires the capture of 85 percent of combined sewage in the
CSS during precipitation events on an annual average basis. This means that the permitte is to determine
the flows in the CSS during precipitation events and then to conduct a volume balance to determine the
volume of overflows from the system during these precipitation events. The requirement that this
percent capture must be evaluated annually indicates that the permittee should use multiple years of
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CSO Post Construction Compliance Monitoring Guidance
annual percent capture data in this analysis. The specific parameters that must be defined for the CSS to
evaluate criterion ii are defined below.
4.1.2.4.1 Volume of Combined Sewage in the CSS during Precipitation Events
The "combined sewage in the CSS during precipitation events" is the sum of runoff plus sanitary sewage
entering the CSS (or dry-weather flow). Runoff should either be modeled or calculated as the combined
sewage entering the CSS during precipitation events. Sanitary sewage should either be metered or
apportioned from the sanitary sewage in CSS during precipitation events. Delineating what should be included
in sanitary sewage should be negotiated between the permittee and the NPDES authority. For example, NPDES
authorities may expect systems with high I/I to reduce baseline sanitary sewage flow levels to account for excessive I/I.
The determination of combined sewage "during precipitation events" should include the time frame of
the precipitation event that is producing runoff, plus some additional time period for the CSS to drain.
Options for determining the period required for the CSS to drain might include the following:
• The observed time for runoff to pass through CSS
• The time until flow in sewer returns to normal (i.e., time required until the CSS reaches
approximately 110 to 120 percent of dry-weather flow)
It should be noted that different NPDES authorities might define the term "return to normal flow"
differently and 110 to 120 percent of dry weather flow is provided as an example only. Some systems
might experience increased I/I for several days after rainfall events, in which case NPDES authorities may
require some other determinant of returning to "normal flows" other than 110-120 percent of dry
weather flow. In all cases, the permittee and the NPDES authority should agree on a methodology for
determining when a system has returned to "normal" flows.
Figure 2 shows a typical diurnal flow pattern in a CSS. Figure 3 shows the flow generated by a
precipitation event. Figure 4 shows the flow in the CSS generated by the precipitation event
superimposed on the baseline flow. The shaded areas under the curve represent the volume of
combined sewage in the CSS during precipitation events. The actual combined sewage volume can be
calculated through integrating the area under the curve between the two points representing the
beginning and the end of the precipitation events.
Permittees can then add the volume of combined sewage in the CSS during individual precipitation events
to get an annual total combined sewage in the CSS during precipitation events. For example, in Figure 4
above, if the first storm had 3 million gallons (MG) of flow, the second storm had 1 MG of flow, and the
third storm had 4 MG of flow, the total for this period is 3 + 1 + 4 = 8 MG of combined sewage in the CSS
during precipitation events over this 96-hour period. Permittees would repeat this procedure as needed to
determine the volume of combined sewage in the CSS during precipitation events for the entire year.
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12
10
I8
B
Note: MGD = million gallons per day.
Figure 2. Sanitary flow in CSS overtime.
12
10
S" 8
O
~ 6
2
0
A
0 12 24 36 48 60
Time (hours)
0 12 24 36 48 60 72 84 96
Time (hours)
72 84 96
Figure 3. Runoff into the CSS overtime caused by rainfall.
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CSO Post Construction Compliance Monitoring Guidance
12
10
§8
0 12 24 36 48 60 72 84 96;
Time (hours)
Figure 4. Sum of sanitary runoff flows in the CSS overtime.
(Shaded areas indicate wet weather volumes used in assessing percent capture.)
Note that individual NPDES authorities can choose to set criteria or some sort of threshold for rainfall
events that are counted with respect to quantifying "combined sewage in the CSS during precipitation
events." This might have the effect of eliminating small rainfall events as being counted towards the
percent capture requirements. NPDEs authorities can set these criteria through their own policies or
through negotiation with permittees, but in all cases, the requirements should be clear so that the
permittees know how to calculate these values. It is important to remember that any precipitation event
creating an overflow within the CSS should be counted (i.e., it is not the size but presence of an overflow
from the CSS that triggers the counting).
4.1.2.4.2 Volume of Combined Sewage Captured or Treated
To determine the percentage of combined sewage volume captured or treated in the CSS, the permittee
must quantify the volume of combined sewage that is captured or treated. This includes the sum of all
combined sewage that is treated through the WWTP during precipitation events, plus all combined
sewage that is detained, stored, treated to acceptable levels, or otherwise captured and not discharged
as CSOs during precipitation events. One method for determining this volume is to add together all the
combined sewage flows to individual CSO controls, plus the peak flow of the WWTP effluent during
precipitation events. This can be done through monitoring data, or through estimating flows with
models, as described in previous sections. Another option is to measure the remaining CSO volumes
after implementing CSO controls. Several examples of these types of calculations are provided below.
Example 1
The most straightforward method for calculating the volume of combined sewage in the CSS during
precipitation events that is captured or treated is to determine the total CSO discharge volume for the
year (either by monitoring or modeling) and subtract it from the total combined sewage flow in the CSS
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during precipitation events for the year. The difference is the volume of combined sewage in the CSS
during precipitation events that is captured or treated. For example:
Total combined sewage flow in the CSS during precipitation events for the year = 600 MG
Total CSO discharge volume for the year = 40 MG
Total CSO volume captured for treatment for the year = 600 - 40 = 540 MG
Total percent capture = 100 x (540/600) = 90%. Therefore this meets the 85 percent capture
threshold for the Presumption Approach.
Example 2
A second method for determining the volume of combined sewage in the CSS during precipitation
events that is captured or treated is to calculate a flow balance that sums the flows through each CSO
control facility. For example, if the WWTP treated 50 MG of combined sewage during precipitation
events for the year and an off-line storage facility received 30 MG of combined sewage during
precipitation events for the year, the total volume of combined sewage in the CSS during precipitation
events that is captured or treated is 50 MG + 30 MG = 80 MG. This calculation is shown below.
WWTP flow during precipitation events (includes baseline and wet-weather flows) = 50 MG
(metered over the year)
Off-line storage = 30 MG (metered over the year)
Total CSO volume captured for treatment = 50 + 30 = 80 MG
This flow balance can become difficult to determine for some types of CSO controls. For example, in-line
storage is difficult to measure directly. Therefore, modeling might be appropriate to determine the
volumes of combined sewage in the CSS during precipitation events that are captured or treated.
4.1.2.4.3 Calculating a Volume Balance
The most straightforward method for evaluating whether a permittee has achieved 85 percent capture
is to calculate a volume balance of combined sewage flow in the CSS after implementation of CSO
controls. For example, one method of calculating the volume balance is:
Percent capture = 100 x (sum of volume delivered to acceptable treatment divided by the sum
of inflow volumes to the CSS [sanitary+ runoff]) over a representative time frame
A second option is:
Percent capture = 100 x (i - [overflow volume divided by the sum of runoff and sanitary
volume]) over a representative time frame
As described in Subsection 4.1.2.1 above, the permittee must take into account all appropriate flows
when determining the average volume of combined sewage in the CSS during precipitation events. For
example, Figure 5 below shows the flows being collected in the CSS on a particular day that significant
rainfall has occurred. The figure shows an upstream combined area discharging an average of 100 MGD
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to a CSS. This CSS also collects an average of 25 MGD from an upstream separate sewer area and
receives an average of 10 MGD in infiltration and inflow. Therefore, the total flow in the CSS is
100 MGD + 25 MGD + 10 MGD = 135 MGD
Once a permittee has collected data on the flows in the CSS during precipitation events on an annual
basis, the permittee can use a mass balance approach to provide data on whether they are meeting 85
percent capture. This can be a simple calculation of the ratio of the annual flow volume in the CSS during
precipitation events divided by the volume of combined sewage treated or captured. Table 1 provides
an example of calculating the percentage of combined sewage captured or treated in the CSS before and
after implementing CSO controls.
Upstream
Separate
Sower Area
25 MG
Upstream Combined
Flow 100 MG
Total combined sewage in CSS - 100 + 25 +
10=135MG
Infiltration and
Inflow 10 MG
Figure 5. Flows to the CSS during a particular 24-hour precipitation event.
Table 1. Example calculation for percentage of combined sewage captured and/or treated
in CSS
Total volume of combined sewage collected in the CSS during
precipitation events (MG)
Volume of combined sewage that is captured and/or sufficiently
treated before discharge
Percentage of combined sewage captured and/or sufficiently
treated before discharge
Volume of remaining untreated CSOs
Percentage of remaining untreated CSOs
No CSO control
1,220
756
62%
464
38%
LTCP
(CSO retention
basins)
1,220
1,037
85%
183
15%
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In this example, there is an average of 1,220 MG of combined sewage in the CSS during precipitation
events during one of the years analyzed. Before implementing CSO controls, approximately 756 MG of
this flow, or 62 percent, is diverted to the WWTP for treatment. The remaining 38 percent of the flow,
or 464 MG, overflows as CSOs. However, after implementing CSO control measures (in this case, CSO
retention basins) through the LTCP, 1,037 MG of combined sewage (85 percent of the total) is treated or
captured. Thus, the implementation of this LTCP can be considered adequate to meet criterion ii of the
Presumption Approach.
4.1.2.4.4 Calculation of Annual Average Capture Volume
Criterion ii of the Presumption Approach states that the permittee will capture no less than 85 percent
by volume of the combined sewage collected in the CSS during precipitation events on an annual
average basis. Therefore, the permittee should present several years' worth of data on percent capture
to allow an evaluation of compliance with this Approach. The permittee has calculated an annual
percent capture for several years' worth of data, calculated the annual average over a several-year
period for use in evaluating criterion ii of the Presumption Approach, and then would average these
annual flow volumes to produce an annual average of flow in the CSS during precipitation events.
Table 2 provides an example of calculating the annual average percentage of combined sewage
captured or treated in the CSS over a time frame of 4 years.
In this example, the average annual percentage of combined sewage captured or treated is 87 percent.
It is worth noting that in Year 2, the percentage of combined sewage captured or treated is 82 percent,
which is below the threshold set under criterion ii of the Presumption Approach. However, the
permittee still meets the criterion because the average annual percentage of combined sewage
captured or treated over the 4- year period is above 85 percent.
To determine an appropriate period over which to calculate the annual average flow in the CSS during
precipitation events, permittees should confer with the regulatory authorities. In general, the period
chosen for determining the annual average should be representative of the same precipitation
conditions for which the permittee planned in the LTCP so that the permittee can be reasonably sure
that the LTCP is achieving the planned level of CSO control with respect to percent capture of flows.
Table 2. Example calculation for annual average of percentage of combined sewage
captured or treated in an example CSS
Year
YeaM
Year 2
YearS
Year 4
Annual average
Volume of combined sewage
collected in the CSS during
precipitation events (MG)
680
856
598
760
724
Volume of sewage that was
captured or adequately
treated (MG)
600
702
520
684
627
Percentage of combined
sewage considered
captured or treated
88%
82%
87%
90%
87%
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4.1.3 Pollutant Mass Removal Control Targets
Criterion iii of the Presumption Approach states that the permittee will achieve the elimination or
removal of no less than the mass of pollutants identified as causing water quality impairment through
the sewer system characterization, monitoring, and modeling efforts for the volumes that would be
eliminated or captured for treatment under criterion ii. Another way of stating this criterion is that the
permittee will achieve the elimination or removal of 85 percent of the mass of pollutants in the CSS
during precipitation events. Note that this criterion applies to pollutants "causing water quality
impairment;" therefore, it should be applied only to the pollutants identified as being pollutants of
concern during the characterization, monitoring, and modeling stage of LTCP development. For
example, in many CSS systems, bacteria, sediment, and biochemical oxygen demand are the primary
pollutants of concern.
In using this Approach, the permittee should use the mass-balance approach to determining flows in the
CSS described under Section 4.1.2 above, and then add a corresponding pollutant load to evaluate the
elimination or removal of pollutants. Derivation of average pollutant loads might have been completed
during the characterization, modeling and monitoring of the CSS done during the development of the
LTCP. If average pollutant loads have not been previously determined, permittees can use several
different methods to assign them, including reviewing historical data from the CSS (including NPDES
monitoring data, if it includes monitoring of specific pollutants) or other sources. Other sources of data
might include the following:
• General treatment plant influent concentrations and operating data
• Treatment plant optimization studies
• Special studies done as a part of an NPDES permit application
• Pretreatment program data
• Collection system data gathered during NMC implementation
• Existing wet-weather CSS sampling and analysis
• Facility plans and designs
The permittee can potentially use national or regional stormwater data (e.g., Nationwide Urban Runoff
Program [NURP data, USEPA 1983], National Stormwater Quality Database [NSQD data available from
http://rpitt.eng.ua.edu/Research/ms4/mainms4.shtml1) to supplement its available data, although more
recent localized data are preferred.
To obtain recent and reliable characterization data, the permittee might need to conduct limited
sampling at locations in the CSS and at selected CSO outfalls. To be effective for characterizing pollutant
mass removal control targets, this monitoring should include monitoring before and after implementation
of CSO controls.
EPA's Combined Sewer Overflows Guidance for Monitoring and Modeling (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) and Guidance for Long-Term Control Plan (1995b;
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http://www.epa.gov/npdes/pubs/owm0272.pdf) documents provide good information on developing
and conducting a monitoring program, and on supplementing the monitoring data with modeling.
These documents also discuss data analysis to evaluate pollutant loads. Multiplying the flow
measurements discussed in Section 4.1.2.2 above by pollutant concentration values gives an estimate of
the total pollutant load handled by the CSS. If pollutant loads are estimated for several outfalls, they
may be normalized to account for differences in rainfall and land area, and then these concentrations
may be applied to other areas of the CSS that might not have been monitored.
Pollutant removal could be evaluated in several different ways. For example, if CSO control involves a
flow-through treatment technology that removes pollutants, the permittee can use monitoring data
from the CSO outfall, or perhaps design performance standards, to determine the pollutant
concentrations or removals that should be applied to the discharge to calculate pollutant loads. For
example, if a high-rate ballasted flocculation treatment system treats 150 MG of CSO flows in its first
year of operation, and it starts from a raw TSS concentration of 414 mg/L and provides 90 percent
removal, it would remove 466,122 Ibs of TSS (150 MG x 414 mg/L x 8.34 x 0.9 = 466,122). Applying the
high rate treatment system that treats 150 MG of flow to an illustrative LTCP example, the mass balance
is:
Mass balance before LTCP implementation
Mass of TSS in CSS during precipitation events = 1,220 MG x 414 mg/L TSS x 8.34 (conversion
factor) = 4,212,367 Ibs TSS
Mass of TSS discharged from WWTP after treatment = 756 MG x 30 mg/L x 8.34 = 189,151 Ibs
TSS
Mass of TSS in the untreated discharge = 464 MG x 414 mg/L TSS x 8.34 = 1,602,080 Ibs TSS
Total TSS discharged = 189,151 + 1,602,080 = 1,791,231
Total TSS captured or treated = 4,212,367-1,791,231 = 2,421,136
Percent of TSS captured or treated before LTCP implementation = (2,421,136/4,212,367) =
57.5%
Mass balance after implementing LTCP (includes retention basins and high rate treatment)
Mass of TSS in CSS during precipitation events = 4,212,367 Ibs TSS (same as before LTCP
implementation)
Mass of TSS discharged from WWTP after treatment = 1,037 MG x 30 mg/L x 8.34 = 259,457 Ibs
TSS (note change in volume treated from 756 MG to 1,037 MG due to implementation of
retention basins in LTCP)
Mass of TSS treated through high-rate treatment = 150 MG x 414 mg/L TSS x 8.34 x 0.1 = 51,791
Ibs TSS
Mass of TSS untreated = 33 MG x 414 mg/L TSS x 8.34 = 113,941 Ibs TSS
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Total TSS discharged = 259,457 + 51,791 + 113,941 = 425,189 Ibs TSS
TSS captured or treated = 4,212,367 - 425,189 = 3,787,178
Total TSS removed from system = (3,787,178/4,212,367) = 90%
This illustrative example shows that the implementation of CSO retention basins and high rate
treatment would allow the permittee to meet the criterion of 85 percent capture of TSS.
4.1.4 Water Quality-Based Targets
While the Presumption Approach focuses on achieving certain end-of-pipe goals (e.g., number of
overflows, percent capture of volume or pollutants), the CSO Control Policy also allows permittees to
comply using water quality-based criteria under the Demonstration Approach. Under the Demonstration
Approach, condcting appropriate post construction compliance monitoring involves collection of information
sufficient to demonstrate each of the four criteria in the in the CSO Policy by the permittee (see box at page 27).
This approach focuses on the in-stream water quality in the receiving water; therefore, the majority of
post construction compliance monitoring for the Demonstration Approach should focus on receiving
water monitoring. Receiving water monitoring is discussed in Section 4.2. However, collecting receiving
water monitoring data might not be sufficient to allow evaluation of compliance with the Demonstration
Approach. For example, criterion ii discusses the situation in which CSOs for which WQS and designated
uses are not met in part because of natural background conditions or pollution sources other than CSOs.
The permittee may use a receiving water model to help demonstrate the impact of its CSOs on the
receiving water, and the post construction compliance monitoring plan may include using post
construction monitoring data to model the receiving water after implementing CSO controls to
demonstrate that remaining CSOs would not preclude attainment of WQS if upstream water quality met
WQS.
4.1.5 Treatment Requirements
CSO permittees may have requirements to achieve specific levels of treatment of their CSO discharges.
These may be expressed as numeric or narrative water quality-based effluent limits in NPDES permits, or
they may be treatment requirements or performance standards negotiated with the NPDES authority
and incorporated into an LTCP. For example, the CSO Control Policy also defines an overflow event for
the purposes of criterion i of the Presumption Approach as one or more overflows from a CSS as the
result of a precipitation event that does not receive the following minimum treatment:
• Primary clarification (Removal of floatables and settleable solids may be achieved by any
combination of treatment technologies or methods that are shown to be equivalent to primary
clarification);
• Solids and floatables disposal; and
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• Disinfection of effluent, if necessary, to meet water quality standards, protect designated uses
and protect human health, including removal of harmful disinfection chemical residuals, where
necessary.
Therefore, to define the number of CSO events that have occurred at a facility, the permittee should
evaluate whether flows have been treated to the levels defined above. If the flows have not been
treated to the levels defined above, they are considered as CSOs and are counted in the number of
CSOs in the system. The permittee's post construction monitoring plan should provide data to
demonstrate that any flows that are not considered CSOs have achieved this level of treatment.
Permittees may also have treatment requirements associated with the specific control technologies they
have implemented as part of their LTCPs. For example, a permittee that installed high-rate treatment
may have performance or treatment requirements for that specific piece of equipment. As with the
treatment requirements described above for criterion i of the Presumption Approach, the permittee
should include monitoring to collect data for these performance or treatment requirements as part of its
post construction compliance monitoring plan.
Providing data that allows the regulatory authority to evaluate compliance with treatment or
performance requirements, or both, might be more straightforward than the data collection required
under other parts of the post construction compliance monitoring plan because treatment or
performance requirements are typically end-of-pipe measurements. Therefore, collecting data for these
requirements can be as straightforward as collecting water samples at the end of the pipe and analyzing
them for the pollutant to see if they have achieved the requirement.
Note that the requirements for achieving performance levels or treatment requirements should have
been defined before developing and implementing the post construction compliance monitoring plan. It
is critical that the permittee and the permit writer define and agree on performance standards or
treatment requirements and the conditions under which they are to apply. Both permittee and the
permit writer should take into account the design standards of the CSO control equipment that they are
installing to ensure that the design standards can be achieved under the flow conditions expected
during CSO events. For example, it would not make sense to the regulatory authority to require
achievement of secondary treatment standards if the control technology is designed to achieve only
secondary treatment as an average load under continuous flow conditions.
It might also be necessary for the permit writer and the permittee to ensure that the treatment
requirements or performance standards can be compared to the WQS in the receiving water. For
example, if the NPDES authority has required a permittee to achieve a treatment requirement related to
the geometric mean of bacteria, is the permittee capable of demonstrating compliance with this
requirement through collecting treatment data from storm events that will occur at unpredictable
intervals?
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4.1.6 Other CSO Control Targets
While the CSO Control Policy focuses on the Presumption and Demonstration Approaches for controlling
CSOs and achieving CWA goals, there are other potential methods for achieving these goals, such as full
sewer separation not developed under a traditional LTCP, or other levels of control under the
Demonstration Approach. This section discusses several of these types of alternatives for complying
with the CSO Control Policy and discusses several potential options for conducting post construction
compliance monitoring for these alternatives.
4.1.6.1 Sewer Separation
Separation is the conversion of a CSS into separate stormwater and sanitary sewage collection systems.
This method has historically been used by many communities as a way to eliminate CSOs and their
effects altogether. Separation has been reconsidered in recent years because it typically results in
increased loads of stormwater runoff pollutants (e.g., sediments, bacteria, metals, oils) being discharged
to the receiving waters, is relatively expensive, and can disrupt traffic and other community activities
during construction. Sewer separation is a positive means of eliminating CSOs and preventing sanitary
flow from entering the receiving waters during wet-weather periods, however, and might still be
applicable and cost-effective. It can also be considered in conjunction with the evaluation of sensitive
areas in accordance with the CSO Control Policy, although storm drain discharges likely will still remain.
In some cases, municipalities that separate their combined sewers might be required to file for NPDES
stormwater permit coverage.
Note that this is a different approach than partial sewer separation, which some permittees use in
certain parts of their CSS as part of a larger CSO control effort. In such situations, partial sewer
separation should be evaluated in terms of the larger CSO control approach because it is used in
conjunction with other control methods. It is only in cases of complete sewer separation that CSO
control efforts should be evaluated based solely on the success of the separation in eliminating CSOs
altogether. The goal of a complete sewer separation is the complete elimination of CSOs. This may be
required to meet a water quality goal of meeting existing WQS at all times.
Post construction compliance monitoring for a permittee that has completely separated its sewer
system should focus on the confirmation of the separation through collection system analysis than on
receiving water monitoring. The goal of post construction monitoring is to ensure that there are no
remaining sanitary connections to the storm system or storm connections to the sanitary system
(investigations similar to municipal separate storm sewer system requirements to conduct an illicit
discharge detection and elimination program). The permit writer might also wish to wrap any CSO post
construction compliance monitoring requirements together with any municipal separate storm sewer
system permit monitoring requirements to reduce potential redundancy and maximize the relevant data
for the stormwater program.
The permit writer may also require modeling or monitoring of the newly separated system to
demonstrate that the system no longer has CSOs. This could include monitoring the former CSO outfalls.
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4.1.6.2 Other CSO Control Efforts
Because the CSO Control Policy was developed and implemented after CSO control efforts were already
underway for some permittees, there might be permittees that have implemented only parts of the
policy's recommendations to use either the Presumption or the Demonstration Approach to control
CSOs; therefore, they could have different requirements for CSO planning and CSO control
implementation than those typically formalized in LTCPs. EPA's previous guidance for CSO permit writers
recognized that some permittees might have already undertaken planning efforts before the CSO
Control Policy. The previous guidance states that the permit writer should consider the following efforts
that a permittee might have taken before implementing NPDES permits that include CSO requirements,
including the following:
1. Substantial completion of CSO controls that appear to provide for attainment of WQS
2. CSO control programs substantially developed or implemented pursuant to existing permits or
enforcement orders
3. Previous construction of CSO facilities designed to provide for attainment of WQS but where
WQS have not been attained because of remaining CSOs
The guidance goes on to state that, if the permittee has substantially completed construction of projects
designed to provide for attainment of WQS, the permit conditions for LTCP development may be
modified to reflect these efforts. The permit writer may choose not to require the initial planning and
construction provisions of the LTCP. The permittee, however, should be required to complete the
relevant components of the LTCP that might not have been addressed by the permittee's previous
efforts or that represent ongoing commitments, including development of an operations and
maintenance program and post construction compliance monitoring plan. If the permittee has
substantially developed or is developing a CSO control program pursuant to an existing permit or
enforcement order but has not completed construction of the selected CSO controls, and the control
program is expected to provide for attainment of WQS and is consistent with the objectives of the CSO
Control Policy, the permit writer should modify the permit to require evaluation of sensitive areas and
financial capabilities, as well as development of a post construction monitoring plan.
This guidance makes it clear that all permittees should develop and implement a post construction
compliance monitoring plan, no matter how their CSO program was developed. A post construction
compliance monitoring plan developed for CSO control planning begun before implementing the CSO
Control Policy should have the same goals as any post construction compliance monitoring program
developed consistently with the Presumption or Demonstration Approach outlined in the CSO Control
Policy, although the specific details of the plan could be different. These plans should still generate data
that allow permit writers to verify the effectiveness of CSO controls and demonstrate compliance with
WQS and protection of designated uses.
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4.2 Ambient Monitoring for Assessing Compliance with Water
Quality Standards
This monitoring requires an understanding of the water quality benefits expected to be realized by
implementing the LTCP. Ideally, the ambient monitoring would build on monitoring carried out to
characterize CSO impacts and the condition of receiving waters. Coordination with other state and local
monitoring efforts is encouraged.
4.2.1 Who Should Conduct the Monitoring?
As described in EPA's CSO Control Policy, a permittee should develop and implement a post construction
water quality monitoring plan adequate to verify compliance with WQS and protection of designated
uses, as well as to ascertain the effectiveness of CSO controls. Each permittee should develop its plan in
consultation with the NPDES authority. The post construction monitoring plan should detail the
monitoring protocols to be followed, including the necessary effluent and ambient monitoring and,
where appropriate, other monitoring protocols such as biological assessments, WET testing, and
sediment sampling. To support their post construction compliance monitoring program the permittee
may collect their own data, or if available, use monitoring data from other sources (e.g. federal and/or
state agencies). Permittees need to make sure the secondary data used from other sources are quality
data.
4.2.1.1 NPDES Watershed Framework
To help permittees reduce some of the costs involved in carrying out post construction compliance
monitoring, it might be advantageous for the permitting community to apply the NPDES Watershed
Framework (USEPA 2007b; http://www.epa.gov/npdes/pubs/watershed techguidance entire.pdf).
where all interested parties are involved in designing and implementing watershed goals. It is also
important to note that eliminating CSO discharges will not always ensure that WQS will be met because
other pollution sources (e.g., sanitary sewer overflows, stormwater, pollution from upstream sources,
concentrated animal feeding operations) can affect the receiving waterbody (DIG 2002;
http://epa.gov/oigearth/reports/2002/csofinal.pdf). It is often necessary to limit all sources of pollutants
to the watershed to ensure that WQS will be met.
As described in EPA's (2007b; http://www.epa.gov/npdes/pubs/watershed techguidance entire.pdf)
Watershed-based NPDES Permitting Technical Guidance, the NPDES Watershed Framework includes a
geographic focus, sound management techniques based on strong science and data, and
partnerships/stakeholder involvement. Watershed teams might include representatives from all levels
of government, public interest groups, industry, academic institutions, private landowners, concerned
citizens, and others.
Integrating NPDES permits and the NPDES program into a watershed approach means developing and
using a watershed-based analysis as part of the permitting process and using that analysis to identify a
range of NPDES implementation options, and potentially other program options to achieve watershed
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goals. This approach explicitly considers the impact of multiple pollutant sources and stressors, including
nonpoint source contributions, when developing point source permits (USEPA 2007b;
http://www.epa.gov/npdes/pubs/watershed techguidance entire.pdf).
EPA's (2007b; http://www.epa.gov/npdes/pubs/watershed techguidance entire.pdf) Watershed-based
NPDES Permitting Technical Guidance provides descriptions of several potential NPDES implementation
options. In cases where treatment plants, stormwater, CSOs and other municipally controlled point
source activities are each under single ownership, the NPDES authority could consider one permit that
covers and integrates all NPDES requirements. This would reduce the administrative burden for the
permittee and NPDES authority and allow the NPDES authority to develop permit conditions (limitations
and monitoring requirements) that specifically address existing watershed goals and watershed
management plans. A watershed permitting approach accounts for upstream pollutant contributions
and promotes early and continuous involvement of parties responsible for upstream sources.
A group using a coordinated, cooperative approach to collecting water quality data is referred to as a
monitoring consortium. EPA has developed guidance on establishing monitoring consortiums within
watersheds titled Monitoring Consortiums: A Cost-Effective Means to Enhancing Watershed Data
Collection and Analysis (USEPA 1997;
http://www.epa.gov/owow/watershed/wacademy/its03/mon cons.pdf). A consortium offers a
watershed-based method of implementing many monitoring needs (e.g., TMDL development, water
quality trading, watershed-bounded multi-source permit development). In addition, monitoring
consortiums help participants pool funds and share expertise while collecting data to identify trends,
evaluate attainment of WQS, develop management strategies, and improve data consistency and
comprehensiveness. NPDES authorities should consider whether a cooperative data collection effort by
sources within the watershed would help permittees reduce their overall monitoring costs.
4.2.1.2 Watershed Teams
Most communities with CSSs (and therefore with CSOs) are in the Northeast and Great Lakes regions,
and the Pacific Northwest. Several CSO communities have used a watershed approach to address water
quality issues and associated receiving water quality monitoring, including the following:
• The Rouge River Gateway Partnership: As described on the Rouge River Project's Web site
(http://www.rougeriver.com/geninfo/new/gateway.html), this partnership includes
representatives from three counties, 48 Metro-Detroit communities and numerous stakeholders
in Michigan.
• The Merrimack CSO Coalition
(http://www.nae.usace.armv.mil/proiects/ma/merrimack/merrimack.htm) includes
Massachusetts and New Hampshire communities along the Merrimack River, with assistance
from the U.S. Army Corps of Engineers.
• The 3 Rivers Wet Weather Demonstration Program (http://www.3riverswetweather.org/) is
made up of representatives from three geographically defined planning basins (Eastern,
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Northern, and Southern) in Allegheny County, Pennsylvania, in a partnership with the Allegheny
County Sanitary Authority and the Allegheny County Health Department.
• The Maumee River Basin Partnership (http://www.mrbplg.org/) includes several municipalities
on the Maumee River in Indiana, Ohio, and Michigan, as well as watershed management groups,
and the regional community. Several local watershed groups
(http://www.mrbplg.org/locwsgroups.html) perform monitoring in this watershed.
• The City of Omaha's CSO Program (http://www.omahacso.com/) includes a CSO monitoring
project, as described in the CSO Monitoring Plan for Omaha
(http://ne.water.usgs.gov/proiects/cso.html). The U.S. Geological Survey (USGS) Nebraska
Water Science Center, in cooperation with the City of Omaha, will participate in the CSO
monitoring project.
• Northeast Ohio Regional Sewer District Mill Creek Watershed CSO Monitoring
(http://pubs.usgs.gov/of/2007/1171/): USGS, in cooperation with the Northeast Ohio Regional
Sewer District performed Escherichia coli monitoring in the Mill Creek Watershed before and
during sewer modifications implemented to eliminate or control (by reducing the number of
overflows) all the CSOs in the Mill Creek watershed.
• Ohio River Valley Water Sanitation Commission (ORSANCO) Wet Weather Studies
(http://www.orsanco.org): Several ORSANCO studies are being conducted to help government
agencies better understand the local effects of CSOs and the development of effective bacteria
reduction strategies. Study participants include EPA, states, and municipalities.
In many cases, CSO watershed team monitoring is partially funded through partnerships with federal or
state agencies. A searchable catalog of federal funding sources (grants, loans, cost-sharing) for
watershed protection, including monitoring, is on EPA's Web site at http://cfpub.epa.gov/fedfund/.
Permittees might be able to obtain assistance with monitoring from state, interstate, or tribal agencies.
The six congressionally authorized interstate organizations are New England Interstate Water Pollution
Control Commission, ORSANCO, Interstate Environmental Commission, Interstate Commission of the
Potomac River Basin, Delaware River Basin Commission and Susquehanna River Basin Commission. If a
state, interstate, or tribal agency is already conducting ongoing studies of the CSO receiving waterbody
to be evaluated, the agency might be able to provide historical monitoring data to the permitting
community, or if funding allows, include additional parameters or sample points in its upcoming
monitoring plans to help evaluate the permittee's compliance with WQS and protection of designated
uses.
Many academic institutions and volunteer community organizations also support CSO receiving water
monitoring programs. Monitoring data from academic institutions and volunteer groups can have a high
degree of credibility, particularly where quality assurance and quality control procedures are
documented (USEPA 1997; http://www.epa.gov/owow/watershed/wacademy/its03/mon cons.pdf).
Additional guidance on funding CSO monitoring programs is in EPA's Combined Sewer Overflows
Guidance for Funding Options (USEPA 1995a; http://www.epa.gov/npdes/pubs/owm0249.pdf) and the
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Office of Inspector General's (2002; http://epa.gov/oigearth/reports/2002/csofinal.pdf) Wastewater
Management Controlling and Abating Combined Sewer Overflows.
4.2.2 What Should be Monitored?
The permittee, in consultation with the NPDES authority, should select the pollutants to be included in
the post construction water quality monitoring program. The permittee should document these
pollutants and the rationale for their selection in the facility's field sampling plan. The pollutants that
should be selected (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf) include those that are
• Suspected to be present in the combined sewage
• Discharging to a sensitive area
• Causing impairment of receiving waterbody designated uses
• Causing exceedances of receiving WQS
• Discharged by industrial users in quantities that are expected to adversely affect receiving water
quality
The permittee, in consultation with the NPDES authority, should determine what EPA, state, and local
water quality criteria or standards applicable to the specific designated use(s) of the receiving water are
available for these pollutants. Information on designated uses and use attainability analyses is available
from EPA's Designated Uses Web site (http://www.epa.gov/waterscience/standards/uses). In addition,
links to state, tribal, and territorial WQS are at
http://www.epa.gov/waterscience/standards/wqslibrary/links.html.
When determining the specific designated use(s) of the receiving water, permittees should consult with
the NPDES authority to determine whether CSOs are discharged into sensitive areas. Sensitive areas are
determined by the NPDES authority in coordination with state and federal agencies. As described in
EPA's CSO Control Policy, sensitive areas include Outstanding National Resource Waters, National
Marine Sanctuaries, waters with threatened or endangered species and their designated critical habitat,
waters with primary contact recreation, public drinking water intakes or their designated protection
areas and shellfish beds.
The permittee should also discuss with the NPDES authority the sampling protocols and analytical
methods acceptable for analysis of pollutants in receiving waters. The permittee's field sampling plan
should follow the sampling and analytical procedures in Title 40 of the Code of Federal Regulations (CFR)
Part 136 (Appendix E), including the use of appropriate sample containers, sample preservation
methods, maximum allowable holding times, described in Table II of Part 136.3, and analytical methods
approved for NPDES compliance monitoring detailed in Tables IA - IH of Part 136.3. In addition, a
discussion of how monitoring should be performed is presented in Section 4.2.5 and in EPA's (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows Guidance for Monitoring and
Modeling. Appendix C of this guidance also provides a basic framework for addressing the technical
issues associated with purchasing laboratory services for field sampling.
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4.2.2.1 Pollutants Suspected to Be Present in the Combined Discharge
In-stream ambient water quality is typically affected by pathogens, oxygen demanding substances,
nutrients, oils, floatables and solids from CSO discharges. In general, these parameters or their
indicators should be included in the CSO post construction compliance monitoring program because
they are suspected to be present in the combined sewage, and they could adversely affect the receiving
waterbody.
4.2.2.2 Pollutants Causing Impairment of Waterbody Designated Uses/Pollutants
Causing Exceedances of Receiving Water Quality Standards
The permittee, in consultation with the NPDES authority, should review applicable state CWA section
303(d) or 305(b) reports or lists to determine the parameters causing impairment in receiving and
downstream waterbodies. In addition, permittees should evaluate any previous water quality
monitoring performed on the receiving water during preparation of the LTCP. All parameters for which
the waterbody is impaired or those exceeding WQS should be selected for field sampling.
4.2.2.3 Pollutants Discharged by Industrial Users in Quantities That Are Expected to
Adversely Affect Receiving Water Quality
Permittees should review all available industrial pretreatment program data to determine what
pollutants discharged by industrial users could adversely affect receiving water quality (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf).
4.2.2.4 Potential Receiving Water Monitoring Parameters
CSOs contain a variety of pollutants from domestic and industrial wastewater as well as from
stormwater. As described in Section 4.1 of EPA's (2004b;
http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm) Report to Congress on the Impacts and
Control of CSOs and SSOs, pollutants in CSOs come from a variety of sources. Domestic wastewater
contains microbial pathogens, oxygen demanding substances, suspended solids, and nutrients.
Wastewater from industrial facilities, commercial establishments, and institutions can contribute
additional pollutants such as oil and grease, toxic metals, and synthetic organic compounds. Although
the concentration of pollutants in stormwater is generally more dilute than in wastewater, it can contain
significant amounts of microbial pathogens, oxygen demanding substances, suspended solids, toxic
metals, pesticides, nutrients, and floatables.
CSO pollutant concentrations vary within a given event as well as from event to event and community to
community (USEPA 2004b; http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm). Depending on
industrial pretreatment discharges and receiving waterbody and downstream designated uses and
water quality impairments, post construction compliance monitoring parameters could include one or
more of the following:
• Bacterial indicators (e.g., enterococcus, E. coli, fecal coliform bacteria)
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• Dissolved oxygen
• Biochemical oxygen demand
• Nutrients
• Floatables
• Dissolved solids
• Suspended (or settleable) solids
• Oil and grease
• Flow (velocity)
• Temperature
• pH
• Turbidity
• Conductivity
• Toxic metals
• Pesticides
• Any anticipated CSO parameter subject to a TMDL wasteload allocation for CSOs or under a
CWA section 303(d) listing
• Any other parameter that could affect public health or aquatic life
Bacterial Indicators
Fecal bacteria have been used as an indicator of the possible presence of pathogens in surface waters
and the risk of disease, on the basis of epidemiological evidence of gastrointestinal disorders from
ingesting contaminated surface water or raw shellfish. Contact with contaminated water can lead to ear
or skin infections, and inhaling contaminated water can cause respiratory diseases. The pathogens
responsible for these diseases can be bacteria, viruses, protozoans, fungi, or parasites that live in the
gastrointestinal tract and are shed in the feces of warm-blooded animals (USEPA 2008;
http://www.epa.gov/waterscience/beaches/sanitarysurvev/pdf/user-manual.pdf). Examples of
pathogenic bacteria associated with untreated wastewater, CSOs, and SSOs include Campylobacter,
Salmonella, Shigella, Vibrio cholerae, and Yersinia (USEPA 2004b;
http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm).
Enterococci and E. co//are used as the primary indicators of fecal contamination and are recommended
as the basis for bacterial WQS in EPA's 1986 Ambient Water Quality Criteria for Bacteria
(http://www.epa.gov/waterscience/beaches/files/1986crit.pdf) document (both for fresh waters,
enterococci for marine waters). The standards are defined as a concentration of the indicator above
which the health risk from waterborne disease is unacceptably high.
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Dissolved Oxygen and Biochemical Oxygen Demand
Dissolved oxygen is an important measure of the quantity of oxygen available to aquatic organisms in
the receiving stream. Biochemical oxygen demand (measured as BOD5 the amount of dissolved oxygen
consumed within 5 days by biological processes breaking down organic matter) is widely used as a
measure of the amount of oxygen-demanding organic matter in water. The organic matter in sewage
includes human excreta, kitchen waste, and industrial waste (USEPA 2004b;
http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm). Oxygen depletion that results from the
discharge of CSOs containing oxygen-demanding substances can harm or kill fish and benthic
invertebrates in streams and rivers.
Nutrients
Nitrogen in its ammonia/ammonium or nitrate/nitrite forms is a nutrient for aquatic vegetation.
Nitrogen also is a limiting nutrient to algal production in marine and estuarine systems. Phosphorus is
the limiting nutrient for growth of aquatic vegetation in freshwater rivers and lakes and, when
discharged in high concentrations, can lead to eutrophication in waterbodies. Limiting the loading of
nitrogen and phosphorus into receiving streams is critical to alleviating eutrophication in downstream
coastal waters.
Floatables and Solids
Floatable debris causes problems because it can easily come into contact with aquatic animals, people,
boats, fishing nets, and other objects. Communities also lose money when beaches must be closed or
cleaned up, and the fishing industry and recreational and commercial boaters spend thousands of
dollars every year to repair vessels damaged by floatable debris (USEPA 2002d;
http://www.epa.gov/owow/oceans/debris/floatingdebris/debris-final.pdf). Floatable debris also can be
a source of bacterial contamination to bathing beaches. Types of floatables present in water include
street litter (e.g., cigarette butts, filters); medical items (e.g., syringes); resin pellets; food packaging;
beverage containers; sewage-related items; pieces of wood and siding from construction projects;
fishing equipment (e.g., nets, lures, lines); household trash; plastic bags and sheeting; and beverage
yokes (six-pack rings for beverage containers) (USEPA 2002d;
http://www.epa.gov/owow/oceans/debris/floatingdebris/debris-final.pdf).
TSS can injure or kill fish, shellfish, and other aquatic organisms in receiving waters by causing abrasions
and by clogging gills. Indirectly, solids can screen out light and can contribute to the development of
noxious conditions through oxygen depletion. Some nutrients bind to solids, and solids often include
oxygen-demanding organic material. Solids also have the potential to settle on the bottom of the
receiving waterbody and smother spawning beds or other habitats. Also, the presence of solids in
receiving waters used as drinking water source waters can increase the cost of drinking water
treatment.
Oil and Grease
Excessive oil and grease concentrations can be associated with high biochemical oxygen demand in a
waterbody, and they can present other nuisance problems.
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Flow, Temperature, pH, Turbidity, and Conductivity
Stream or river discharge is sometimes called flow. A discharge measurement is a combination of a
velocity measurement and a cross-sectional area measurement. The units in these two measurements
are as follows: velocity = length per unit time, and cross-sectional area = width x depth of the stream
(units are length squared). When these two values are multiplied together, the resulting units are length
cubed, or volume per unit time. Flow is generally measured in units of cubic feet per second or MGD.
For a complete reference on measuring stream discharge, see USGS Water Supply Paper 2175 (USGS
1982; http://pubs.usgs.gov/wsp/wsp2175). Flow or discharge measurements are essential to most
pollution management and control activities. High flows due to CSOs may cause stream bank erosion.
Water temperature is routinely measured for use in taking temperature-dependent measurements such
as pH. Water temperature can also be important in assessing the quality of potential habitat for aquatic
species and for some less-desirable pathogenic organisms.
The field parameter, pH, is a measure of the acidity (hydrogen/hydroxide ion concentration) of water in
sampling locations identified for characterization and assessment. Most aquatic organisms have a
preferred range of pH, usually pH 6 to 9. Beyond that range aquatic organisms begin to suffer stress,
which can lead to death. High pH values also force dissolved ammonia into its toxic, un-ionized form,
which can further stress fish and other organisms.
Turbidity is a measure of water cloudiness. Turbidity is not specific to the types of particles in the water.
These particles can be suspended or colloidal matter, and they can be inorganic, organic, or biological.
Waters that are unnaturally turbid can be harmful to fish and other aquatic life by clogging respiratory
organs and impairing visual-based predators.
Conductivity is highly correlated with the concentration of dissolved solids in the water column. Aquatic
organisms require a relatively constant concentration of the major dissolved ions in the water. Levels
too high or too low can limit survival, growth, or reproduction. Also, salinity of a waterbody can be
estimated by measuring conductivity because electric current passes much more easily through water
with a higher salt content (USEPA 2008;
http://www.epa.gov/waterscience/beaches/sanitarysurvev/pdf/user-manual.pdf).
Toxic Metals and Pesticides
Many metals are toxic to algae, aquatic invertebrates, and fish. The metals most commonly identified in
wastewater include cadmium, chromium, copper, lead, mercury, nickel, silver, and zinc. Stormwater in
CSSs can also contribute metals such as arsenic, cadmium, chromium, copper, lead, nickel, and zinc to
receiving waters (USEPA 2004b; http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm).
Although pesticides and herbicides can serve useful purposes in backyard applications, some of these
chemicals are bioaccumulative and retain their toxicity after they are discharged into receiving waters.
Pesticide loading to receiving streams should be monitored to prevent impairment of downstream uses
such as drinking water, wildlife habitat, and recreation. Chronic effects on aquatic communities from
exposure to toxic metals and pesticides include lower productivity and biomass and reduced biological
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diversity. Acute effects can be observed as immediate fish kills or severely reduced biological diversity
(USEPA 2004b; http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm).
Additional Parameters or Assessments
The permittee, in consultation with the NPDES authority, should determine whether any additional
parameters or field monitoring should be selected for post construction compliance monitoring. These
could included any anticipated CSO parameter subject to a TMDL wasteload allocation for CSOs or under
a CWA section 303(d) listing or any other parameter that could affect public health or aquatic life.
Additional assessments could include biological assessments (Barbour et al. 1999;
http://www.epa.gov/owow/monitoring/rbp/index.html), sediment monitoring (e.g., see EPA's
Suspended and Bedded Sediments Web page at http://www.epa.gov/waterscience/criteria/sediment/)
and WET testing (http://www.epa.gov/waterscience/methods/wet/).
Biological assessments can include a survey of the macroinvertebrate or fish community both up and
downstream of the CSO. Comparison of pollution-sensitive metrics such as the number of certain taxa,
life stages offish present and the abundance of juvenile fish, species richness, and species diversity
could indicate a significant difference between upstream and downstream communities. Biological
impairment downstream of a CSO can indicate that the CSO is a potential source of pollutants that are
causing the impairment and are not being measured. Another potential issue to consider is that
differences in hydrological conditions (e.g., flow or velocity) between up and downstream of the CSO,
rather than water quality impacts, could be responsible for differences observed in biological condition.
Typical biological assessments include the collection, identification, and assessment of
macroinvertebrates, fish, or periphyton. Impairment to one or more types of biological communities
could narrow the focus of source identification. For example, certain benthic invertebrate species (e.g.,
mayflies) are more sensitive to metals than most fish species, while certain fish species (e.g., trout,
bluegill) are generally more sensitive to ammonia than invertebrates. Thus changes in one or more
communities could aid in determining the specific cause of impairment.
If siltation carries significant levels of pathogens or chemical pollutants, it might preclude harvesting of
shellfish for consumption. In inland receiving waters, siltation and sedimentation impair benthic habitats
for fish and invertebrates, potentially limiting the presence of certain species or life stages. Evaluation of
available habitat is often effectively conducted as part of EPA's Rapid Bioassessment Protocols (RBPs)
(Barbour et al. 1999; http://www.epa.gov/owow/monitoring/rbp/index.html). The RBPs include visual-
based assessment of a variety of characteristics of the prevailing habitat conditions among which is
imbeddedness of the substrate critical to spawning and rearing of aquatic species. Because of the
variety and comprehensiveness of habitat characteristics evaluated in the RBPs, they provide a cost-
effective screening tool indicating the abundance and viability of habitats requisite to a number of
designated uses and can assist in focusing investigations on areas of nonattainment or potentially at-risk
habitats.
In addition to physical habitat quality impacts due to sediments, sediments can accumulate pollutants,
particularly those that are less water soluble such as petroleum products, many pesticides, and PCBs.
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This is especially the case in receiving waterbodies having fine particle sized sediments, such as silts and
clays. The presence of toxic pollutants in sediments from a point source can be evaluated using whole
sediment toxicity test protocols developed by EPA and ASTM. Samples of sediment up and downstream
of a CSO outfall can be collected during base flow conditions and tested to evaluate potential pollutant
effects of a CSO. Such monitoring might also help inform results of a bioassessment. However,
pollutants accumulated in sediment may originate from many sources other than the CSO of interest
and therefore interpretation of sediment toxicity results should be done with care. An important aspect of
such testing is having a known reference site in the waterbody to characterize background conditions, in
addition to an upstream site, which can then be compared to the CSO site results. Sediment toxicity
testing of CSOs is probably best used in fairly small waterbodies where the source of sediment
pollutants can be reasonably known.
Because the types and concentrations of chemical pollutants can vary, and they are often incompletely
known, WET should also be considered as a monitoring parameter where aquatic life use protection is
needed. WET has the advantage of providing a standardized measure of toxicity that takes into account
all pollutants in the sample as well as the interactions between them. In addition, WET provides a direct
measure of pollutant (e.g., metal) bioavailability because it includes the water quality characteristics
(e.g., hardness, pH) of the sample.
The permitting community should also determine whether any additional measurements are required to
calculate values for pollutants selected for post construction compliance monitoring for comparison to
applicable WQS or criteria (e.g., hardness for calculating applicable criteria for several metals, pH for
calculating applicable ammonia criteria).
Examples of parameters for which NPDES authorities might require CSO post construction monitoring
are provided in Table 3.
Table 3. Example Parameters for which NPDES Authorities Might Require Post
Construction Monitoring
Waterbody or CSO attribute
Waterbody on 303(d) list for dissolved oxygen
impairment
Waterbody on 303(d) list for sedimentation
Waterbody designated uses include primary contact
recreation
Waterbody zinc concentrations exceeding WQS
Fish kills reported in waterbody
CSS within a coastal system
Example parameters to be monitored
nutrients, BOD5, dissolved oxygen
settleable solids, turbidity, sediment survey
bacterial indicators
dissolved zinc, hardness3
dissolved oxygen, BOD5, oil and grease, pH, toxic
metals, hardness, pesticides
sodium, chloride, total dissolved solids or conductivity13
3 Note that several metal criteria are hardness-dependent; therefore, it is required that samples analyzed for metals
also be analyzed for hardness.
b In coastal systems, these measurements can be used to detect the presence of sea water in the CSS, which might
be the result of intrusion through failed tide gates (USEPA 1999 ; http://www.epa.gov/npdes/pubs/sewer.pdf).
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4.2.3 Where Should Monitoring Be Performed?
When choosing sampling locations, the permittee should consider the following receiving water
characteristics:
• Locations of sensitive areas
• Upstream and downstream of CSO outfalls
• Location and impacts of other sources of pollutant loadings; when possible, the permittee
should select monitoring locations that have limited or known effects from other pollutant
sources
• Location of historical monitoring locations used to initially characterize CSO impacts
• Size of the waterbody
• Horizontal and vertical variability in the waterbody
• Degree of resolution necessary to assess attainment of WQS
• Data needed to populate or validate water quality models
• Physical logistics (accessibility, whether water is navigable, if bridges are available from which to
sample)
• Crew safety (see Section 4.2.5, How Should Monitoring Be Conducted?)
Potential receiving water sampling designs (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf)
include the following:
• Reference site samples collected at separate locations for comparison with the CSO study site to
determine relative changes between the locations.
• Near-field studies to sample and assess receiving waters within the immediate mixing zone of
CSOs. These studies can examine possible short-term toxicity impacts or long-term habitat
alterations near the CSO.
• Far-field studies to sample and assess receiving waters outside the immediate vicinity of the
CSO. These studies typically examine delayed impacts, including oxygen demand, nutrient-
induced eutrophication, and changes in macroinvertebrate assemblages.
• Assessing WQS for recreation, where the NPDES authority could require determination of a
maximum or geometric mean bacterial indicator concentration at point of discharge into river or
mixing zone boundary.
The location of sampling points should be dependent on the type of waterbody receiving CSO
discharges. In EPA's (2004b; http://cfpub.epa.gov/npdes/cso/cpolicy report2004.cfm) Report to
Congress on the Impacts and Control of CSOs and SSOs, EPA identified the types of waterbodies
receiving CSO discharges by associating CSO outfall locations with USGS's National Hydrography Dataset
(NHD) indexed waters.
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Chapter 4 of EPA's (1999) Combined Sewer Overflows Guidance for Monitoring and Modeling (USEPA
1999; http://www.epa.gov/npdes/pubs/sewer.pdf) provides detailed information on determining
sampling locations for rivers, streams, creeks, and similar waterbodies. The permitting community
should select a reference site or sites (e.g., upstream of the CSO location, an adjacent reach) for
comparison with water samples collected downstream of the CSO to evaluate relative changes between
the locations. The permitting community should also determine whether mixing zones are applicable to
the CSO discharges, and if so, whether monitoring locations should be selected both within the mixing
zone to evaluate acute toxicity as well as outside the mixing zone to evaluate compliance with chronic
water quality criteria. EPA has determined that mixing zones are not appropriate for pathogenic
pollutants.
If the CSO permittee decides to take the watershed approach (see Section 4.2.1 of this guidance), in
which NPDES authorities require other point sources in the watershed to perform reference site and
downstream monitoring to assess the effect of other sources of pollution. This information could be
used to compare relative pollutant contributions from each source. The permitting community should
also consider making cooperative sampling arrangements when pollutants from multiple sources are
discharged into a receiving water or when several agencies share the cost of the collection system and
the POTW. The identification of new monitoring locations should account for sites that might already be
part of an existing monitoring system used by local or state government agencies or research
organizations (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf).
The permitting community should consider where samples will be collected at each sampling location.
To obtain a sample from a well-mixed portion of a river or stream, it is generally recommended that the
samples be obtained at mid-depth (avoiding collection of sediment from the bottom and any scum at
the top) at the midpoint of the waterbody. In cases where there are sensitive areas of concern (e.g.,
drinking water source, primary contact recreation,), the NPDES authority should consider the users at
risk (USEPA 2002e; http://www.epa.gov/waterscience/beaches/technical.html.). More details on
identifying sample locations for recreational waters are provided below.
Ideally, previous monitoring has been performed under the Phase I permit requirement to implement
the NMCs to characterize baseline CSO impacts and the condition of receiving waters before CSO
controls were implemented. In such cases, it is recommended that the permittee conduct monitoring at
both the same and different sample locations used to initially the characterize CSO impacts and the
condition of receiving waters to test the accuracy of the assumptions used in modeling.
EPA recognizes that in many situations, budgetary constraints will affect the number of samples that can
be collected and analyzed. Because variability is usually greater from storm to storm than site to site, it
is generally preferable to select a set of representative locations at which samples can be collected
during several storms and dry-weather events than it is to rotate between several receiving water
locations. If only a few monitoring locations can be monitored, the permitting community should choose
sampling locations that represent the worst-case scenario (areas that receive overflows most frequently
or have the largest pollutant loading or flow volume, sensitive areas) (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf).
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Recreational Waters
In many cases, monitoring at recreational waterbodies is
already performed under the Beaches Environmental
Assessment and Coastal Health (BEACH) Act. The BEACH Act
was passed on October 10, 2000, and amended the CWA by
adding section 406. The BEACH Act addresses pathogens and
pathogen indicators in coastal recreation waters (USEPA
2002e). A complete copy of the BEACH Act is at
http://www.epa.gov/waterscience/beaches/technical.html.
EPA recommends that the permittee coordinate CSO
receiving water monitoring for primary and secondary
No swimming at Any Time
Sewer Overflows
CSO Signage, installed at outfall locations
contact recreation areas with existing water quality monitoring performed under the BEACH Act.
Chapter 4 and Appendices H and J of EPA's (2002e;
http//www.epa.gov/waterscience/beaches/technical.html) National Beach Guidance and Required
Performance Criteria for Grants provides detailed information on monitoring at bathing beaches. When
selecting monitoring locations at recreational waters, the permitting community should, at a minimum,
consider selecting monitoring locations near the CSO outfall and typical bathing areas.
When determining the depth of sampling at recreational waters, the primary factor is identifying the
users at risk (USEPA 2002e; http://www.epa.gov/waterscience/beaches/technical.html). Samples of
ankle- or knee-depth water might be more appropriate for children and infants, whereas waist- or chest-
depth samples might be more appropriate for adults. Sampling from boats is usually inadequate for
beach monitoring because water depths would exceed those common to beach-related recreational
activities, especially for young children (CADHS 1999). It might also be desirable to select monitoring
locations away from the shore in areas where surfing, windsurfing, jet skiing, or other activities occur.
Areas Designated for the Protection of Fish, Shellfish, and Wildlife
Areas designated for protection of fish propagation and shellfish could require assessment of channel
morphology because sediment loading and siltation can significantly affect fish spawning and rearing
areas. Bedded substrates from siltation can prove to be unsuitable as spawning grounds for resident
fishes or sensitive species.
Samples for WET testing should be collected from the CSO outfall if possible so as to evaluate the
potential effects of the discharge on waterbody aquatic life. Another approach that could be used to
evaluate CSO discharges is ambient toxicity testing using samples collected up and downstream of the
CSO outfall. These WET tests are typically conducted as screening tests, with no dilution of samples.
Note that it might not be possible to accurately assess the toxicity of the CSO discharge under high-flow
conditions because there could be many other sources of pollutants between the up and downstream
site. Also, as noted previously, upstream samples could be toxic in themselves because of influences
further upstream; this would make toxicity comparisons between up and downstream samples
problematic. In general it might be analytically more appropriate to evaluate the toxicity of wet-weather
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CSO discharges using laboratory-based WET testing of the outfall rather than ambient testing using up
and downstream samples.
Most biological and sediment assessments are designed as upstream vs. downstream or downstream vs.
some known reference condition for the region. Therefore, if the original assessment was an upstream
vs. downstream assessment, sampling should be completed in the same locations if feasible after
implementing CSO controls. If the original assessment was conducted as a downstream assessment
compared to a known reference condition for the region, downstream sampling in the same general
vicinity would be necessary to demonstrate improvement with the implementation of the CSO controls.
The downstream sampling location should be selected with care so that the biota or sediment being
sampled is in fact exposed to the CSO plume during the flow condition being monitored, which could
imply that the downstream location represents a certain degree of mixing of the CSO discharge with the
receiving system. However, the location should not be so far downstream from the CSO outfall such that
the biota or sediment is likely to be affected by other sources of pollutants (e.g., other point sources).
Such monitoring would make it difficult to interpret CSO compliance. If there are many CSOs in a
relatively small area or stretch of stream, it might be more feasible and more useful to monitor up and
downstream of the group of CSOs in question. While this sampling design would not enable one to
distinguish effects from specific CSO discharges, it provides a more useful assessment of the cumulative
impacts of the group of CSOs. WET testing and pollutant monitoring of the individual CSO discharges
could be used to distinguish relative impacts of the different CSOs and therefore relative contributions
to cumulative impacts on biota or sediment.
Areas Designated for Public Water Supply
CSO discharges to waters designated for public water supply should be evaluated adjacent to intakes to
ensure that any potential pollutants posing human health risk do not exceed treatment capacity of the
distribution system. Discharges in such sensitive waters require exhaustive monitoring because of the
potential for residential and agricultural pesticides and fertilizers in stormwater runoff. Further, heavy
metals and trace organics might be present in runoff from roads and parking lots, which could require
more advanced treatment than routine disinfection of sanitary discharges.
Rainfall Gage and Stream Gage Locations
It is recommended that rainfall be measured using rain gages throughout the CSS drainage area to
evaluate local rainfall conditions and the impact of CSOs on receiving waters. The post construction
monitoring plan should identify locations where rain gages will be placed to provide data representative
of the entire CSS drainage area. The permittee should space gages closely enough to reduce variation in
storm tracking and storm intensity measurements within the CSS area. As described in EPA's (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows Guidance for Monitoring and
Modeling, rain gages are often spaced 6 to 8 kilometers apart; however, gages might need to be spaced
more closely than that to provide sufficient data for analysis. Rain gages can provide valuable
information and are usually relatively inexpensive.
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Proposed Monitoring Locations
The City of Omaha requested that the U.S.
Geological Survey (USGS) participate in a CSO
monitoring project. The USGS Nebraska Water
Science Center will monitor the water quality and
quantity at 11 CSO-monitoring locations and will
collect streamflow data at the stream and river
locations and water-quality data at all of these
locations. This CSO monitoring project will:
• Provide water quality data that can be used
as part of the City of Omaha's Long Term
Control Plan, specifically in the evaluation of
control alternatives
• Measure hydrologic and water-quality data
on an ongoing basis to determine the effects
of the CSO controls
• Assess the attainment of water-quality
standards for pollutants of concern
• Characterize the baseline conditions of the
streams during wet and dry weather
conditions
Streamflow data will be transmitted on a near real-
time basis to the world-wide web via satellite for the
11 stream and three river locations, and selected water quality parameters (water temperature, dissolved
oxygen, specific conductivity, pH, and turbidity) will also be transmitted in near real-time for three sites on
the Missouri River basin and four sites in the Papillion Creek basin. Two sets of water-quality samples will
be collected monthly: once on a scheduled date (at the stream and river locations) and once during
storm-induced CSO overflow events (at all 27 locations). At all but the three Missouri River locations,
automatic samplers will be used to collect water-quality samples. Samples from the Missouri River will be
collected manually by USGS personnel. These data will be used to characterize the effect that CSO
discharges presently have on water quality in their receiving streams. In the future, a private contractor for
the City of Omaha will use these data to model the potential benefits that future control options may offer.
The post construction monitoring plan should also provide locations of stream gage stations. Historical
stream flow data is very useful in planning when samples should be collected. Also, stream flow data
collected during receiving water sample collection can be used to evaluate CSO controls and receiving
water quality. The NPDES authority should determine whether automated flow meters should be
installed at locations upstream and downstream of the CSO. In addition, the permitting community
should determine whether streamflow conditions from USGS gaging stations (at
http://waterdata.usgs.gov/nwis/rt) can be used to help determine receiving water flow. Additional
information on determining flow is provided in Section 4.1.2 of this guidance document.
4.2.4 When Should Monitoring Be Performed?
The permittee should document when sampling will be performed in the post construction monitoring
plan. CSO frequency and duration are dependent on factors including rainfall pattern, preceding dry
period, type of receiving water and circulation pattern or flow, ambient tide or state of river or stream
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and diurnal flow to the treatment plant (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf).
When possible, the permitting community should be sure that most receiving water monitoring is
performed during those seasons, flow regimes, and other critical conditions during which it is expected
that CSOs would have the greatest potential for effects.
In addition to identifying the number of storm events needed to provide data for evaluating receiving
water impacts, the permitting community should consider the following factors when determining the
frequency, duration, and schedule of monitoring:
• WQS appropriate for the prevailing uses
• Classification of the waterbody
• Location of CSO outfalls
• Wet- and dry-weather monitoring needs
• Climate and season
• Duration and frequency of CSO discharges
• The need to maintain and apply water quality models (refer to Section 4.1 of this guidance
document for additional information on when models might be applied)
Water Quality Standards
The permitting community should identify what water quality criteria or standards (see Appendix A of
this guidance) are applicable to the parameters selected for monitoring (see Section 4.2.2 of this
guidance) and designated use(s) of the receiving water. In general, it might be appropriate to more
frequently monitor CSO discharges to sensitive areas or high-quality areas (e.g., drinking water intakes,
primary or secondary contact recreational areas) (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf).
When one of the designated uses of the receiving waterbody is recreation, the permittee will need to
collect and analyze samples for E. coli or enterococci during the recreational season (generally the end
of May through the beginning of September). Note that EPA's criteria for full body contact recreation at
recreational waters is based on a geometric mean of a statistically sufficient number of samples
(generally not less than five samples equally spaced over a 30-day period) (USEPA 1986;
http://www.epa.gov/waterscience/beaches/rules/bacteria-rule.htm). If the permitting community is
interested in using a single sample maximum value to assess whether receiving water quality meets
bacteria criteria, readers should refer to EPA's Web site on Using Single Sample Maximum Values in
State Water Quality Standards, at http://www.epa.gov/waterscience/beaches/rules/singe-sample-
maximum-factsheet.htm.
Wet- and Dry-Weather Monitoring Needs
To provide data for evaluating receiving water impacts and effectiveness of CSO controls, the
permittee should consider collecting samples during the following conditions.
• Dry-weather events
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• Wet-weather events during which a CSO is not expected to occur
• Wet-weather events during which a CSO is expected to occur
Monitoring during both dry-weather events as well as wet-weather events during which a CSO is not
expected to occur should provide background data on conditions in the receiving waters and help the
permitting community determine whether water quality criteria are being met or exceeded during dry-
weather and wet-weather non-CSO events, respectively. In addition, monitoring during wet-weather
events during which a CSO event is not expected to occur will provide data indicating whether CSO
controls are working as designed.
In cases where the facility is using the Presumption Approach (CSO Control Policy Section II.CAa.i and ii,
the permittee should consider collecting samples during dry-weather and wet-weather events during
which a CSO is expected to occur.
Most monitoring should be targeted for wet-weather events during which a CSO event is expected to
occur, so that the potential greatest impacts from CSOs on receiving water quality can be evaluated.
These data can be used to characterize the effectiveness of technologies used to treat CSOs remaining
after implementing the NMCs and within the criteria specified in Sections II.CAa.i or ii of the CSO
Control Policy. These treatment technologies, as described in Section II.CAa.iii of the CSO Control
Policy, include primary clarification (or equivalent method); solids and floatables disposal; and
disinfection of effluent (if necessary) to meet WQS, protect designated uses, and protect human health,
including removal of harmful disinfection residuals where necessary.
The permittee should also consider monitoring storms of varying intensity with a variety of pre-storm
conditions (e.g., varying number of days since the last storm, varying intensity of the previous storms)
and preceding dry days to represent a range of conditions experienced by the CSS (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf).
Climate and Season
As described earlier in this section of the guidance document, depending on the designated uses of the
receiving waterbody, the NPDES authority might require seasonal monitoring (e.g., late spring-summer
recreational season) to evaluate the effectiveness of CSO controls and receiving water quality. The
permitting community should evaluate local historical weather data to determine the seasons when
most high-intensity rain storms or stormwater runoff/snow melt events are likely to occur, so that
monitoring can be targeted during this time.
Duration and Frequency of CSO Discharge
In most cases, CSO discharge will start after a rainfall event has begun and might continue for some time
after rainfall has ceased. Many in-stream samples collected during a wet-weather event represent times
either before or after the CSO slug has passed (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf). Because receiving waterbody hydrographs generally
correspond only to the duration and intensity of rainfall in the watershed, the permittee will need
additional information to more accurately predict when CSO sampling should begin and the duration
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and frequency of sampling. Ideally this additional information should include the actual CSO discharge
start and stop times and estimations of how long it will take for a CSO slug, once discharged, to reach
the monitoring location(s).
It is expected that permittees will know when a CSO event begins and ends on the basis of flow
measurements at the CSO outfalls (refer to Section 4.1.2 of this guidance document for additional
information on determining flows). To identify when receiving water monitoring locations are affected
by CSO discharges (so that samples can be collected during these times) the permittee could perform a
time travel analysis (Langrangian analysis) (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf).
The Rouge River National Wet Weather Demonstration Project performed several time-of-travel dye
studies (using Rhodamine WT dye) for reaches of the Rouge River to evaluate how quickly a slug of dye
introduced to the receiving water near a CSO outfall would take to reach the monitoring stations (Rouge
River National Wet Weather Demonstration Project 2004;
http://www.rougeriver.com/pdfs/sampling/RPO-WMGT-TR55.pdf).
Permittees could plan the frequency and duration of monitoring at a CSO event using information from
the receiving water hydrographs, time travel analyses, and knowledge of when the CSO event begins
and ends. For example, during a storm event, the permittee could collect a sample from the upstream
and downstream receiving water locations before the CSO discharges, when the leading edge of CSO
slug is expected to reach the downstream receiving water location, the expected mid-point of the CSO
event, and when the trailing edge of the CSO slug is expected to reach the downstream receiving water
location.
If performing a time travel study is not feasible because of budgetary constraints, it might be
appropriate for the permittee to collect samples more frequently (e.g., collect samples every hour for
the duration of CSO discharge and several hours after CSO discharge has ceased) throughout the first
few wet-weather events during which a CSO is expected to occur, so that a CSO discharge pollutograph
can be estimated. The information from the pollutograph could then be used to estimate when the
leading edge of CSO slug is expected to reach the downstream receiving water location, the expected
midpoint of the CSO event, and when the trailing edge of the CSO slug is expected to reach the
downstream receiving water location for future sampling events. More information on pollutographs is
provided in EPA's (1999; http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows
Guidance for Monitoring and Modeling.
Evaluation of CSO controls using WET testing would include multiple wet-weather events of differing
magnitude when there was an overflow. WET testing of wet-weather events over the course of a year
would help determine if wet-weather event magnitude, duration, or seasonality affects water quality of
the overflow from the CSO. Likewise, screening acute WET tests could be conducted on samples
collected at different times during a wet-weather event to determine the relative toxicity of first flush
versus later stages of the wet-weather event. Such monitoring might help inform CSO controls.
For bioassessments, samples should be collected during the state's index period for the assemblage of
interest (e.g., fish, macroinvertebrates). Generally, bioassessment sampling is neither effective nor safe
during periods of high flows. Sampling is typically conducted under base- or low-flow conditions. Ideally,
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biological sampling should be conducted pre- and post-CSO control implementation so that an accurate
baseline is established for biological expectations at the site. If pre-CSO control implementation data do
not exist, post-CSO control implementation biological assessments should rely on site-specific reference
site as well as perhaps ecoregional reference site biological data. The latter are often available from the
state/tribe biological monitoring programs. Site-specific reference biological data would be collected at
the same time as the downstream CSO biological data to assess effects of the CSO. Because some local
impacts on downstream biota are likely after any project's construction, it is useful to conduct
bioassessments periodically (annually or biannually) over a few (3-5) years, depending on the size of the
receiving system relative to the CSO discharge, to determine whether CSO controls are not affecting
biota and to track recovery of biota post construction. CSOs on small stream systems should be
monitored more frequently (i.e., annually for 3-5 years) than those on larger systems because impacts
are likely to be greater and recovery slower in the former situation.
Sediment monitoring, like bioassessments, should be conducted during periods of base flow because
that is when sampling methods are most efficient, and sediment effects are likely to be greatest on
biota. However, if certain aquatic life uses are designated such as anadromous fish spawning, sediment
sampling should be associated with that season as well because sediments have profound effects on
spawning behavior and egg survival. In instances where there are multiple aquatic life uses that can be
affected by sediment from CSOs, multiple samplings in a given year might be desirable.
4.2.5 How Should Monitoring Be Conducted?
The permittee should document its monitoring procedures in the post construction water quality
monitoring plan, QAPP, and SOPs (for more details on how to prepare these documents, see Sections
3.1 through 3.5). The permitting community should use the information in this section of the document
and refer to discussions of who should monitor, what pollutants should be monitored and where and
when to monitor, also provided in Section 4.2 of this document. In addition, for additional information
on how to effectively perform post construction compliance receiving water quality monitoring, the
permitting community should see Chapters 4 and 6 of EPA's Combined Sewer Overflows Guidance for
Monitoring and Modeling (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf).
Permittees should consider the following elements when determining how samples will be collected
from the chosen receiving water monitoring stations:
• Health and safety concerns
• Criteria for when samples will be collected (e.g., greater than x days between events, rainfall
events greater than 0.4 inches to be sampled)
• Strategy for determining when to initiate wet-weather monitoring
• Stream velocity measurement considerations
• Sampling techniques
• Sampling personnel and equipment
• QA/QC procedures for sampling and analysis
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The permittee should provide copies of the post construction water quality monitoring plan, QAPP, and
SOPs to each field sampling team before initiating the sampling program. The field sampling team
members should be sure to bring these documents into the field for each sampling event, so that they
can refer to them as needed.
Health and Safety Concerns
The permittee should consider health and safety concerns when selecting sample locations and
determining the schedule for collection. Ideally, sampling should be conducted in teams of two (buddy
system) to ensure that additional personnel are available to initiate critical emergency communication
and appropriate response in case of emergencies. The two-person team should include one person
sampling and one person maintaining a line of sight from a safe distance from the banks during all
sampling operations.
When selecting monitoring locations, the permittee should consider physical logistics (e.g., whether the
water is navigable, if bridges are available from which to sample, the accessibility of the receiving waters
and potential biological hazards [e.g., irritant poisonous plants, hazardous wildlife]) and crew safety
(USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf). The permittee should perform field
observations before, during, and after wet-weather events at locations considered wadeable before
sampling locations are finalized to determine whether flows of excessive velocity will prohibit field staff
from safely wading into and out of the receiving water to collect samples. Note also the footing on or
near the banks of the proposed sampling locations, and the degree of incision of the stream channel.
Observe the riparian zones for indication of torrent, and evaluate the receiving water's banks for
bankfull height indicators (Strahler 1957; Rosgen 1996
http://www.chelanpud.org/relicense/comm/meet2000/4854 l.pdf) and bank angles to ensure safe
entry and escape from the waters under flashy storm conditions. This is of particular concern for rain
events in urban and suburban watersheds (due to proportion of impervious surfaces) and in high
gradient streams, as conditions can change from safe to unsafe in a matter of minutes. In case of
uncertainty, err on the side of caution and ensure that sampling crews are appropriately staffed and
equipped with personal floatation devices (life vest) where streams may be subject to sudden change.
Loss of footing while wading can pose a serious hazard even in smaller streams, when the slip and fall
hazard is combined with the potential for waders to fill and further impede recovery. In cases of large
(nonwadeable) rivers, it would be best to find a bridge from which to sample or to collect samples by
boat. In cases of extreme high flow events in smaller streams, it might be best to collect samples using a
sampling pole or some other device that allows for safe deployment and retrieval without entering the
stream. Samplers should be aware that strong stream velocities can cause sampling poles to pull
suddenly and become awkward to hold and retrieve. Even in bank sampling operations it may be
advisable to don a personal floatation device as a preventive measure in case of deeply incised stream
channels or poor footing.
When manual sampling is to be performed, it is recommended that receiving water samples be collected
only during daylight hours due to health and safety concern. This should especially be a consideration
when planning sampling events and determining when the next sampling event should occur according
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to local weather forecast information. If it is forecasted that most of the rainfall and subsequent CSO
discharge (from time travel analysis or earlier hydrograph or pollutograph results as described in Section
4.2.4 of this document) will occur primarily during non-daylight hours, it is recommended that manual
sampling be rescheduled during a different storm event. Manual sampling during lightning events
should also be avoided. If using only automated samplers to collect samples in cases where no grab
sampling is required (e.g., no bacteria samples and no oil and grease samples need to be collected),
sampling during non-daylight hours would not be considered a health and safety concern.
The rainfall, darkness, and cold temperatures that often accompany wet-weather field sampling events
can make even small tasks difficult and sometimes unsafe. Contingency planning and extensive
preparation can, however, minimize mishaps and help ensure safety. As described in EPA's Combined
Sewer Overflows Guidance for Monitoring and Modeling (USE PA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf), before field sampling, the permittee should ensure that
• Sampling personnel are well trained and familiar with their responsibilities, as defined in the
post construction water quality monitoring plan
• Personnel use appropriate safety procedures and equipment
• A health and safety plan or section in the post construction water quality management plan
identifies the necessary emergency procedures, safety equipment, and nearby hospitals and
emergency medical services
• Sample containers are clean and assembled, and bottle labels are filled out to the extent
possible
• All necessary equipment is inventoried, and inspected, i.e., field monitoring equipment is calibrated
and tested, and equipment such as boats, motors, automobiles, and batteries are checked
• Boat crews are used when landside and bridge sampling are infeasible or unsafe
It is recommended that a training session covering field monitoring equipment and safety concerns be
held at the beginning of the project for all parties involved in sampling. In addition, the permittee should
verify that field personnel are trained in first aid, cardiopulmonary resuscitation (CPR), and are current
on their vaccinations (e.g., Hepatitis A or Hepatitis A and B combination vaccination) (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf). Additional good health and safety field practices include
the following:
• Field personnel should work in pairs at all times.
• Field personnel should wear appropriate clothing such as rubber boots, waders, rubber gloves,
and clothing to protect arms and legs.
• Field staff members should ensure that charged cellular phones are with them at all times.
• Persons working with acid preservatives will wear eye protection and nitrile or latex gloves. Any
spilled acid will be neutralized with sodium bicarbonate and diluted with water until it is no
longer hazardous.
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• Insect repellant and sunscreen should be worn during the spring and summer months, although in a manner
that insures that samples will not become contaminated (e.g.,pestide, oil and grease, volatileorganics).
Criteria for When Samples Will Be Collected
The permittee should evaluate and determine the types of conditions under which samples will be
collected (i.e., dry-weather events, wet-weather events during which a CSO is not expected to occur,
wet-weather events during which a CSO is expected to occur). In general, dry-weather events are
characterized as being preceded by a 72-hour period with no measurable rainfall (less than 0.1 inch
rainfall). Wet-weather events are generally characterized as storm events that are greater than 0.1 inch
and at least 72 hours from the previously measurable (greater than 0.1 inch rainfall) storm event (USEPA
1992; http://www.epa.gov/npdes/pubs/owm0093.pdf). For more information on planning the
frequency, duration and scheduling of monitoring events, see Section 4.2.4 of this guidance document.
The wet-weather conditions under which a CSO is not expected to occur, as well as the wet-weather
conditions for which a CSO is expected to occur, can be determined using storm hydrograph data and
CSO control design specifications. For example, the permitting community could target rainfall events of
different sizes under which a CSO is not expected to occur (e.g., small [0.35 to 0.49 inch] to medium [0.5
to 0.99 inch]) as well as rainfall events for which a CSO is expected to occur (large [> 1.0 inch]). It is
recommended that the permitting community evaluate these examples to determine whether they are
appropriate or whether they should be slightly modified for the receiving water to be monitored.
Note that there might be special circumstances such as large rainfalls on days preceding an overflow
with less than 0.1 inch rainfall that could be the cause of a CSO. As described in the Frequently Asked
Questions About CSO DMRs file available from the Indiana Department of Environmental Management
Permitting Web site (http://www.in.gov/idem/4897.htm), the duration of an overflow after rainfall has
ceased is a factor that the NPDES authority should evaluate when defining a dry-weather event.
Strategy for Determining When to Initiate Wet-Weather Monitoring
After determining when and where monitoring should be performed and the criteria for when samples
should be collected, key elements to consider in determining whether to initiate sampling for a wet-
weather event (ORSANCO 1998; http://www.epa.gov/npdes/pubs/owm0093.pdf) include the following:
• Identify local site conditions (e.g., characterize stream conditions, historical climatic patterns)
• Identify local rain gage networks (airports, municipalities)
• Identify monitoring contact personnel (laboratory managers, field leaders)
• Identify weather sources (local meteorologist, National Weather Service, cable TV, Internet
sites, local airports)
• Storm tracking (monitoring leader tracks weather and stream conditions; monitoring leader
notifies personnel of potential events)
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By developing a strategy for determining which storm events are most appropriate for wet-weather
monitoring, the permittee can collect the needed data while limiting the number of times the field staff
is mobilized and the number of sampling events. This can result in significant savings in personnel,
equipment, and laboratory costs. It is recommended that the permittee develop a decision flow chart or
checklist for initiating a wet-weather event. An example flow chart is provided in Exhibit 4-3 of EPA's
(1999; http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows Guidance for
Monitoring and Modeling.
Stream Velocity Measurement Considerations
As described in Section 4.2.3 of this guidance, the permittee should determine whether automated flow
meters could be installed at locations upstream and downstream of the CSO. In addition, the permitting
community should determine whether stream flow conditions from USGS gaging stations (accessible at
http://waterdata.usgs.gov/nwis/rt) can be used to help determine receiving water flow.
When determining whether portable or installed automated stream velocity meters should be used for
CSO post construction monitoring, the permittee should consider the following advantages and
disadvantages of using each type of meter:
• Portable velocity meters are less expensive than automated velocity meters.
• Portable velocity meters generally do not provide print-outs of the storm hydrograph; storm
hydrographs, when used in conjunction with information about the CSO discharge travel time,
are useful for planning when samples should be collected.
• Automated velocity meters require installation and consideration of power sources.
• When using a portable velocity meter, a member of the field staff must read each velocity
measurement from the display and record it on a field data sheet.
• When using a portable velocity meter, there is potential for data recording errors.
• When properly installed and maintained, automated velocity meters will provide constant,
accurate velocity data.
• Portable velocity meters can be used to provide velocity data for the sampling event only.
• If desired, many automated velocity meters can be purchased as part of an automated field
sampler that has the capability of collecting composite samples when triggered by a certain pre-
set velocity rate (note that samples required to be collected as grab samples cannot be collected
using an automated sampler).
For detailed information on receiving water hydraulic monitoring techniques, see Section 6.2 of EPA's
(1999; http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows Guidance for
Monitoring and Modeling.
Sampling Personnel and Equipment
After determining where and when samples will be collected, for what parameters the samples will be
analyzed, the laboratory that will perform the analyses (refer to Appendix C of this document), the
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permittee will deermine the personnel and sampling equipment needs for performing post
construction receiving water quality monitoring. As described above, it is recommended that field
personnel work in pairs at all times, for safety reasons. If grab samples are being collected at upstream
and downstream locations simultaneously, at least four sampling staff mebers are needed to perform the
monitoring. Additional staff might be needed for recording flow measurements if portable flow meters are
used and for delivering bacteria samples to the laboratory within holding times.
Field staff should follow the sampling protocols documented in the post construction water quality
monitoring plan, QAPP, CSO control assessment plan, field sampling plan and SOPs, as described in
Sections 3.1 through 3.5 of this document. The post construction water quality monitoring plan should
include the following information to assist field staff in performing monitoring efficiently and correctly:
• Map of the watershed and the sampling locations.
• Names and phone numbers of the field sampling staff and laboratory personnel involved in the
project.
• The number of samples and quality control samples (see discussion in the following section) to
be analyzed for each parameter during each sampling event.
• The study target analytes and corresponding EPA analytical method or Standard Method.
• Types of sample bottles, preservatives, and holding times required as specified by the EPA
analytical method or Standard Method; bacteria samples must be delivered to the analytical
laboratory within 6 hours of collection.
• SOPs for calibration, setup and maintenance of equipment and for collection of samples.
On the basis of the analytical methods that will be used and field measurements (e.g., velocity,
temperature, pH, rainfall) that will be collected, the permittee should determine what the equipment
needs of the study are. For example, the permittee might determine that a probe should be purchased
for measuring pH and specific conductance at the upstream and downstream monitoring locations.
Equipment that might need to be purchased for a sampling event includes the following:
• Automated velocity meters or samplers
• Portable velocity meters
• Field probes and calibration standards
• Sample pole(s)
• Gloves (latex, nitrile)
• Boots
• Waders
• Certified clean sample bottles (note that these could be provided by the analytical laboratory)
• Sample preservatives required by analytical method (e.g., sulfuric acid, nitric acid)
• Coolers and ice/blue ice for storing samples on-site before delivery to laboratory
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• Rain gages
• All-weather writing paper
Sampling Techniques
As described earlier in the document, both automated and grab sampling techniques can be used for
post construction compliance receiving water monitoring. For each sampling event, the field staff should
be sure to label all sample bottles and complete a chain-of-custody form, recording each of the samples
for each sample location and stage of the CSO discharge, date and time of collection, type of
preservative and analyses to be conducted. In addition, the field staff should coordinate with the
laboratory throughout the sampling process, to ensure the laboratory will know when to expect samples
to be delivered or shipped.
Field staff should ensure that one rain gage is placed at each monitoring station and that overall, a
minimum of three rain gages be used in the watershed. In addition, flow monitoring should be
performed at each sampling location. This information will be very useful in interpreting the analytical
results (NRC 2008; http://www.epa.gov/npdes/pubs/nrc stormwaterreport.pdf).
Automated Sampling
If automated samplers are used, the permittee should be sure to follow the manufacturer's instructions
for installing, configuring and programming the units. After this has been accomplished, very little needs
to be done to start the sampling process. One field staff member will need to make sure the samplers
are turned on and that the flow meter plotters are turned on before the storm event. In addition, the
field staff member will need to be sure that clean bottles have been loaded into the sampler before the
storm event.
After the monitoring is complete, the staff member should review the hydrograph printout or portable
flow meter readings, along with any information on the CSO slug travel time, to determine what bottles
should be analyzed by the laboratory. As described in Section 4.2.4, it might be desirable to have the
laboratory analyze samples representing receiving water conditions before the CSO discharges, when
the leading edge of CSO slug is expected to reach the downstream receiving water location, the
expected mid-point of the CSO event, and when the trailing edge of the CSO slug is expected to reach
the downstream receiving water location.
Manual Collection of Samples
For manual collection of samples, the field staff will need to be sure their hands are clean (no lotions or
sunscreens applied) and put on a pair of clean, powder-free gloves before collecting samples at each
station. In addition, it might be appropriate for field staff to wear elbow-length gloves underneath the
clean, powder-free gloves for health protection, but the permittee should check with the laboratory
before sampling begins to determine whether the elbow-length gloves would contaminate samples for
the analytes to be studied. Field staff should label each bottle or container with a label and permanent
marker. Information that should be included on each label includes project name, sampling location,
date, time, analyte(s), and whether it is preserved with acid or other chemical.
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To determine when manual samples should be collected during a sampling event, a staff member should
review the hydrograph printout or portable flow meter readings, along with any information on the CSO
slug travel time. Field staff should collect sample(s) into the appropriate bottle(s). In cases where a
sampling pole is needed, a field staff member should attach a clean bottle to the sampling pole, remove
the cap and walk to a location of the receiving stream where there is adequate flow. If the stream level
is too high, the field staff member should collected the sample(s) from a bridge over the middle of the
channel. The sampling pole length can be extended as necessary to collect samples.
In cases where no preservatives are needed, the sample can be collected directly into the bottle to be
delivered to the laboratory for analysis. In cases where preservatives are needed, the sample should be
collected into a clean collection bottle from which the sample can be poured into the pre-preserved
bottles to be delivered to the laboratory for analysis.
The field staff member should face upstream and tip the bottle into the water, allowing the water to
flow into the bottle. The field staff member should rapidly submerge the bottle to the desired depth
(refer to Section 4.2.3) and turn the bottle to an upward 45-degree angle until it is filled with water. The
field staff member should raise the bottle straight up out of the water.
Biological Assessments
For bioassessments, grab samples are typically collected using various field collection devices depending
on the assemblage being sampled and the physical characteristics of the waterbody (e.g., see Barbour et
al. 1999 [http://www.epa.gOV/owow/monitoring/rbp/1; ASTM field sampling methods). Wadeable
streams have perhaps the most researched biological methods for macroinvertebrates and fish, and
many states and tribes have their own sampling protocols, which include sampling and sample process
methods. For stream macroinvertebrates, sampling devices include fixed area net devices, such as
Surber and Hess samplers, that rely on physically disturbing the sediments causing invertebrates to
passively flow directly downstream into the net sampler. Fish are generally captured by netting,
traveling seine, or electrofishing. The type of gear used is often specific to the types of habitat being
sampled and the characteristics of the receiving waterbody. Backpack electrofishing, for example is a
fairly efficient sampling technique in wadeable streams but is inappropriate in beatable rivers and lakes.
In general, sampling should be conducted such that subsequent sampling locations are not disturbed or
otherwise affected by sampling. In streams, this usually entails sampling from downstream to upstream
locations to ensure that sites sampled later in the day are not affected by earlier sampling.
The permitting community should consult appropriate state/tribe protocols before monitoring. By using
standardized methods of collection, processing, and enumeration, the precision, accuracy, and
comparability of biological data are improved. Biological sampling requires knowledge and experience
using particular sampling equipment. Therefore, staff trained in the use of such samplers is necessary to
obtain reliable data.
Sediment Sampling
Sediment sampling, where required, is conducted by manual collection of surface sediment using care to
retrieve the sample without resuspending fine solids at the sediment/water interface. Samples can be
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collected by hand or using specialized sampling devices developed specifically for sediment collection
(see USEPA 2001b; http://www.epa.gov/waterscience/cs/library/collection.html).
In wadeable streams, manual samples can be collected using a stainless steel scoop or large stainless
steel spoon in areas of sediment deposition. Surficial sediment is scooped off of the streambed and
carefully raised through the water column being careful not to resuspend any of the fine sediments from
the sample.
In larger streams, lakes, and marine environments, sediment samples are best collected using grab
samplers such as a petite ponar or Van Veen sampling device. These devices are routinely deployed by
winch and activated by gravity or by use of a weighted messenger to close the clam-shell jaws. Again,
the device is slowly raised through the water column to avoid resuspension of fine solids in the sampling
device and to prevent loss of the fine sediments from the sample. The permittee should use EPA's
Methods for Collection, Storage, and Manipulation of Sediments for Chemical and Toxicological
Analyses: Technical Manual (USEPA 2001b;
http://www.epa.gov/waterscience/cs/library/collection.html) to help select an appropriate sediment
sampling device and to identify proper ways to ensure that high-quality samples are collected.
WET Testing
Samples for WET testing should be collected from the CSO outfall if possible so as to evaluate the
potential effects of the discharge on waterbody aquatic life. As described in Section 4.2.3 of this
document, it might be analytically more appropriate to evaluate the toxicity of wet-weather CSO
discharges using laboratory-based WET testing of the outfall rather than ambient testing using up and
downstream samples.
Depending on state implementation procedures, WET tests are often conducted using multiple dilutions
of the sample (including the undiluted sample itself). By testing multiple dilutions at the same time, it is
possible to derive toxicity endpoints that can then be compared with actual flow/dilution conditions as
well as other flow conditions of concern (e.g., 7Q10). However, multiple dilution WET tests are relatively
more costly than bacterial or inorganic pollutant analyses, particularly chronic WET tests, which can
affect the number of CSO or CSO outfalls that can be monitored for WET.
Some states conduct stormwater and CSO sampling using a screening WET approach that does not
require sample dilution. In this approach, only two treatments are conducted: a laboratory water
control and the undiluted CSO sample. This type of WET testing yields a pass-fail result. Such testing has
the advantage of being cheaper and easier to conduct, which can allow more frequent testing of a CSO
discharge or testing of more outfalls. However, screening tests cannot indicate the concentration of CSO
discharge that would not be toxic.
The dilution water used for testing of CSOs could be EPA-approved laboratory water (i.e., reconstituted
water or dilute mineral water) or upstream water. Using upstream water might be a more realistic
approach for testing the toxicity of a CSO discharge because it already incorporates the prevailing
background water quality conditions (e.g., hardness, pH, various ions), which, as explained in Section
4.2.2 of this document, affect certain water quality criteria as well as the toxicity of certain pollutants
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(e.g., many priority pollutant metals). However, the upstream water itself could be toxic because of
factors other than CSOs, which would make it a poor diluent in WET testing. Laboratory water, on the
other hand, has the advantage of being a known, standardized diluent for WET testing, which enables
one to obtain a definitive answer regarding toxicity of the CSO sample. However, laboratory water is not
typically site-specific in composition and therefore, could under- or over-estimate toxicity of the CSO
sample. One compromise might be to identify an upstream reference site that is known to be relatively
free of anthropogenic influences, yet represents the natural background water quality condition. It is a
good idea to subject water from such a site to WET testing before conducting CSO monitoring to confirm
that it is a useful diluent for WET testing. Another compromise is to analyze several water samples
during wet- and dry-weather events to characterize key water quality characteristics such as hardness,
alkalinity, pH, and major ion concentrations (e.g., potassium, magnesium, calcium, sodium). Laboratory
water can then be adjusted to match those characteristics as closely as possible.
QA/QC Procedures for Sampling and Analysis
The permittee should contact the laboratory before the start of the sampling event (24 hours is ideal) to
notify them when samples might be arriving at the laboratory and to determine whether additional
volumes of samples need to be collected for QCanalyses in the laboratory. If a sampling trip is canceled,
the permittee should notify the laboratory immediately.
The permittee should discuss with the analytical laboratory how often duplicate samples and blanks
should be collected for analysis. Duplicate samples provide a check for precision in sampling equipment
and techniques (USEPA 1999; http://www.epa.gov/npdes/pubs/sewer.pdf). When duplicate grab
samples are required, the duplicate should be collected at the same time as the sample by holding both
bottles under water side by side, whenever possible. Field blanks, trip blanks and field duplicates should
also be collected as specified by the laboratory.
Field blanks are samples that are collected to check for cross-contamination between samples. Cross-
contamination can occur either during sample collection, during shipment, or during processing in the
laboratory. When sampling for inorganic compounds, deionized or distilled water should be used to
prepare the field blank. When sampling for organic compounds, field blanks should be prepared from
high-performance liquid chromatography (HPLC)-grade water.
Trip blanks are samples that are collected to check for contamination that might occur during shipping
between the field and the laboratory for samples to be analyzed for volatile organic contaminants.
HPLC-grade water should be used to prepare trip blanks.
Equipment blanks are samples that are collected to check field equipment decontamination procedures.
It is important to collect equipment blanks when sample collection equipment or sample collection
vessels (e.g., bailers, clean bottles) are re-used for taking samples at different times or locations. When
sampling for inorganic compounds, deionized or distilled water should be used to prepare the
equipment blank. When sampling for organic compounds, equipment blanks should be prepared from
HPLC-grade water. After field equipment is decontaminated, the field staff should rinse the equipment
with the appropriate grade of water and collect the rinsing water in the sample containers.
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Field staff should prevent contamination of samples by wearing clean, powder-free gloves and by
making sure hands are clean. Field staff should also be sure to clean the sampling pole after each event
and use only certified pre-cleaned bottles for sample collection. Also, field staff should wash hands
thoroughly or use hand sanitizer after handling samples, especially before eating or drinking.
A second field staff member of each team should act as the QC officer by checking all records and forms
to be sure they are complete and correct and that all samples have been taken and preserved correctly
before leaving each sampling site.
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References
APHA (American Public Health Association). 1998. Standard Methods for the Examination of Water and
Wastewater. 20th ed. American Public Health Association, Washington, DC.
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Barbour, M.T., J. Gerritsen, B.D. Snyder, and J.B. Stribling. 1999. Rapid Bioassessment Protocols for Use
in Streams and Wadeable Rivers: Periphyton, Benthic Macroinvertebrates and Fish, Second
Edition. EPA 841-B-99-002. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. .
CADHS. 1998. Beach Sanitation Guidance for Saltwater Beaches. California Department of Health
Services. .
NRC (National Research Council). 2008. Urban Stormwater Management in the United States. National
Research Council of the National Academies, National Academies Press, Washington, DC.
.
ORSANCO (Ohio River Valley Water Sanitation Commission). 1998. Fax Memorandum on wet weather
monitoring from Jim Gibson, ORSANCO, to Tim Dwyer, EPA. March 4, 1998, as cited in USEPA
(U.S. Environmental Protection Agency). 1992. NPDES Storm Water Sampling Guidance
Document. EPA 833-B-92-001. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. .
Rosgen, D.L and H.L. Silvey. 1996. Applied River Morphology. Wildland Hydrology Books, Fort Collins,
CO. .
Strahler, A. N. 1957. Quantitative analysis of watershed geomorphology. Am. Geophys. Union Trans.
38:913-920.
USAGE (U.S. Army Corps of Engineers, New England District). 2003. Merrimack River Watershed
Assessment Study - Quality Assurance Project Plan (QAPP). Prepared for sponsor communities:
Manchester, NH; Nashua, NH; Lowell, MA; Greater Lawrence Sanitary District, MA; Haverhill,
MA by COM Cambridge, MA.
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USEPA (U.S. Environmental Protection Agency). 1983. Results of the Nationwide Urban Runoff Program,
Volume I, Final Report. NTIS PB84-185552. U.S. Environmental Protection Agency Water
Planning Division, Washington, DC.
USEPA (U.S. Environmental Protection Agency). 1986. Ambient Water Quality Criteria for Bacteria 1986.
EPA 440/5-84-002. U.S. Environmental Protection Agency, Office of Research and Development,
Microbiology and Toxicology Division and Office of Water Regulations and Standards, Criteria
and Standards Division, Washington, DC.
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USEPA (U.S. Environmental Protection Agency). 1992. NPDES Storm Water Sampling Guidance
Document. EPA833-B-92-001. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. .
USEPA (U.S. Environmental Protection Agency). 1995a. Combined Sewer Overflows Guidance for Funding
Options. EPA 832-B-95-007. U.S. Environmental Protection Agency, Office of Wastewater
Management Municipal Support Division, Washington. DC.
.
USEPA (U.S. Environmental Protection Agency). 1995b. Guidance for Long-Term Control Plan. EPA 832-B-
95-002. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 1995c. Guidance for Permit Writers. EPA 832-B-95-008.
U.S. Environmental Protection Agency, Office of Wastewater Management, Washington, DC.
Available from .
USEPA (U.S. Environmental Protection Agency). 1995d. Guidance for Nine Minimum Controls. EPA 832-B-
95-003. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 1997. Monitoring Consortiums: A Cost-Effective Means
to Enhancing Watershed Data Collection and Analysis. EPA 841-R-97-006. U.S. Environmental
Protection Agency, Office of Wetlands, Oceans and Watersheds, Assessment and Watershed
Protection Division, Washington, DC.
.
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USEPA (U.S. Environmental Protection Agency). 2000. Guidance on Technical Audits and Related
Assessments for Environmental Data Operations, EPA QA/G-7. EPA 600-R-99-080. U.S.
Environmental Protection Agency, Office of Environmental Information, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2001a (Reissued May 2006). Requirements for Quality
Assurance Project Plans, EPA QA/R-5. EPA 240-B-01-003. U.S. Environmental Protection Agency,
Office of Environmental Information, Washington, DC.
.
USEPA. 2001b. Methods for Collection, Storage, and Manipulation of Sediments for Chemical and
Toxicological Analyses: Technical Manual. EPA-823-B-01-002. U.S. Environmental Protection
Agency, Office of Water, Washington, D.C.
.
USEPA (U.S. Environmental Protection Agency). 2002a. Guidance for Quality Assurance Project Plans,
EPA QA/G-5. EPA 240-R-02-009. U.S. Environmental Protection Agency, Office of Environmental
Information, Washington, DC. .
USEPA (U.S. Environmental Protection Agency). 2002b. Guidance for Quality Assurance Project Plans for
Modeling, EPA QA/G-5M. EPA-240-R-02-007. U.S. Environmental Protection Agency, Office of
Environmental Information, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2002c. Guidance on Choosing a Sampling Design for
Environmental Data Collection. EPA 240-R-02-005. U.S. Environmental Protection Agency, Office
of Environmental Information, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2002d. Assessing and Monitoring Floating Debris.
U.S. Environmental Protection Agency, Office of Water, Office of Wetlands, Oceans, and
Watersheds, Oceans and Coastal Protection Division, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2002e. National Beach Guidance and Required
Performance Criteria for Grants. EPA 823-B-02-004. U.S. Environmental Protection Agency,
Office of Water, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2004a. EPA's NPDES Inspection Manual. U.S.
Environmental Protection Agency, Office of Compliance, Office of Enforcement and Compliance
Assurance, Washington, DC.
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CSO Post Construction Compliance Monitoring Guidance
USEPA (U.S. Environmental Protection Agency). 2004b. Report to Congress on the Impacts and Control of
CSOs andSSOs. EPA 833-R-04-001. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. .
USEPA (U.S. Environmental Protection Agency). 2006. Guidance on Systematic Planning Using the Data
Quality Objectives Process. EPA QA/G-4. EPA 240-B-06-001. U.S. Environmental Protection
Agency, Office of Environmental Information, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2007a. Guidance for Preparing Standard Operating
Procedures, EPA QA/G-6. EPA 600-B-07-001. U.S. Environmental Protection Agency, Office of
Environmental Information, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2007b. Watershed-based NPDES Permitting Technical
Guidance. EPA 833-B-07-004. U.S. Environmental Protection Agency, Office of Wastewater
Management Water Permits Division, Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2008. Great Lakes Beach Sanitary Survey User Manual.
EPA 823-B-06-001. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
.
USGS (U.S. Geological Survey). 1982. Measurement and Computation of Stream flow: Volume 1.
Measurement of Stage and Discharge, Volume 2 Computation of Discharge. Water Supply Paper
2175 .
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Appendix A - Supplemental QAPP Information
A QAPP is prepared to ensure that environmental and related data collected, compiled, or generated for
a project are complete, accurate, and of the type, quantity, and quality required for their intended use.
QAPPs are composed of standardized, recognizable elements covering the entire project from planning,
through implementation, to assessment. The four groups of elements and their intent, as summarized in
EPA's Requirements for Quality Assurance Project Plans (USEPA 2001a;
http://www.epa.gov/QUALITY/qs-docs/r5-final.pdf) are as follows:
A - Project Management
B - Data Generation and Acquisition
C - Assessment and Oversight
D - Data Validation and Usability
Group A - Project Management
Addressing the elements in the Project Management group ensures that the project has a defined goal,
that the participants understand the goal and the approach to be used, and that the planning outputs
have been documented. The nine elements in this group are described below.
Al Title and Approval Sheet: The permittee, in consultation with the NPDES authority, should
determine who will be responsible for reviewing and approving the QAPP. Usually, the project manager
and QA officer from each entity involved in the project (e.g., permittee, NPDES authority, laboratory
responsible for analyzing samples, volunteer monitoring organizations) will need to approve the QAPP.
The permittee should include the names and titles of persons who will be responsible for reviewing and
approving the QAPP and other pertinent information (e.g., project title, date of preparation, version
control number, organization preparing the QAPP) on the title and approval sheet.
A2 Table of Contents: The permittee should develop a table of contents for the document to enable
document reviewers and project participants to easily locate pertinent information in the QAPP.
A3 Distribution List: The permittee should include the names and corresponding contact information for
each person who is involved with post construction compliance monitoring. This should include project
managers, QA officers, and representatives of all groups involved in the project who should receive a
copy of the QAPP.
A4 Project/Task Organization: The permittee should include in this section a brief description of the
post construction compliance monitoring project. In addition, the permittee should include a description
of the key project management and QA staff names, titles, and responsibilities. This information should
be illustrated using a project organization chart (see the example organization chart in Figure A-l).
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Permitting Authority
Project Manager
fNamej
Permitting Authority
QA Officer
[Name]
Other Monitoring Organization
Director
[Name)
Other Technical Staft
Permittee
Project Manager
[Name]
Analytical Laboratory
Project Manager
[Name]
Permittee
QA Officer
[Name]
Permittee
Field Leader
[Name]
Modeling Leader
[Name]
Database Manager
jName]
Other Technical Staff
Permittee
Held QC Officer
(Name]
Modeling QC Officer
[Name)
Database QC Officer
[Name]
Othtr OA/QC Staff
Analytical Laboratory
QA Officer
(Name)
Project Management Auuionty
~^^~ QA Program Authority
- - — Lines of Communication
Figure A-1. Example QAPP organization chart.
A5 Problem Definition/Background: Here, the permittee should provide any pertinent background
information about the history of the CSO problems in the receiving waterbody. A map of the study area
can be included. Also, the permittee should identify the intended use (e.g., ascertaining the
effectiveness of CSO controls, verifying compliance with WQS and protection of designated uses) of the
post construction compliance monitoring data to be collected under the QAPP. Virtually all the sections
of the QAPP that follow will contain information consistent with the information stated in this section
(USEPA 2002a; http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf).
A6 Project/Task Description: The permittee should provide an overall description of the work to be
performed for the project. Examples of tasks that could be included in this section are describing the
basic approach (i.e., Presumption Approach, Demonstration Approach) selected by the permittee in the
LTCP to verify the effectiveness of CSO controls, preparing a CSO control assessment plan, preparing a
field sampling plan, identifying whether some flows or pollutant loads will be modeled and what models
will be used, identifying sample locations, obtaining sampling equipment and supplies, performing
sampling, supporting analysis of samples and preparing sample reports and analyses. A description of
the records and reports required for each task should be included. It is also recommended that a project
schedule showing the dates by which major tasks will be performed is included in this section.
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A7 Quality Objectives and Criteria: The purpose of this element (USEPA 2002a;
http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf) is to describe quality specifications at
(1) the level of the decision or study question; and
(2) the level of the measurements to support the decision or study question.
(1) Decision or Study Level Question Level
The outputs from EPA's data quality objectives process will help address "(1) the level of the decision or
study question." Detailed guidance on the data quality objectives process is available from EPA's
Guidance on Systematic Planning Using the Data Quality Objectives Process (USEPA 2006;
http://www.epa.gov/QUALITY/qs-docs/g4-final.pdf).
(2) Measurements to Support the Decision or Study Question Level
The section of the QAPP addressing "(2) the level of the measurements to support the decision or study
question/' should discuss the measurement performance criteria in terms of the expected level of
uncertainty in data that will be used to address the study question or support the decision (USEPA
2002a; http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf). When possible, it is desirable to state
measurement performance criteria in quantitative terms, such as limits for field measurement and
analytical laboratory precision, bias, and completeness. The permittee should determine in conjunction
with the NPDES authority whether there are any performance criteria requirements for CSO post
construction compliance monitoring.
It is a good idea for the permittee to check the operating manual for the equipment used to take field
measurements (e.g., flow meter, turbidity meter, thermometer) and to check with the NPDES
authority's and laboratory's QA officers to ensure that the results will be of quality adequate to answer
the study questions. Some example measurement performance criteria for a CSO post construction
compliance monitoring program are presented in Table A-l.
If a model will be used to predict the number of overflow events per year, the flow and volume of CSO
events per year, or to evaluate reductions in pollutant loads, the permittee should address evaluating
the quality of the data used for the model and assessing the results of the model application. The
permittee should provide a list of data sources that will be used to populate, calibrate, and validate the
model. The permittee should also describe the acceptance criteria against which data will be judged
before being used as input to the modeling effort. For example, data might be checked for
reasonableness (e.g., dates will be checked through queries to ensure that no mistyped dates are
included [e.g., 8/24/1900]) and representativeness (e.g., sampling station data will be checked through
queries and mapping to ensure that no mistyped geospatial data are used [e.g., locations outside the
sewershed in question].
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Table A-1. Example performance criteria for a CSO post construction compliance
monitoring program
Measurement parameter
Precision
Accuracy and bias
Completeness
Field parameters
Time
Flow
water temperature
PH
Turbidity
specific conductance
± 5 minutes
± 30%
± 1 °C
± 0.2 units
±2%
±2%
> 90%
Analytical laboratory parameters
Total suspended solids
Ammonia as nitrogen
Nitrate + nitrite
Total phosphorus
Dissolved phosphorus
Hardness
Enterococci using EPA Method 1600
RPD<15
30%
> 90%
The permittee should use a systematic planning process to determine the type and quality of output
needed from modeling projects. This should begin with a modeling needs and requirements analysis,
which includes the following components:
• Assess the need(s) of the modeling project
• Define the purpose and objectives of the model and the model output specifications
• Define the quality objectives to be associated with model outputs
The permittee should describe model calibration and validation procedures, what data will be used for
calibration and validation, how sensitivity analyses will be performed, and general percent error
calibration/validation targets for the model(s) to be used. Also, the permittee should include a
description of how the model will be verified through testing the model code, including program
debugging, to ensure that the model implementation has been done correctly. For the purposes of
assessing model outputs and usability, the permittee should describe how staff will review model
predictions for reasonableness, relevance, and consistency with the requirements of the model
development process.
For additional information on developing a modeling QAPP, the permittee should refer to EPA's (2002b;
http://www.epa.gov/QUALITY/qs-docs/g5m-final.pdf) Guidance for Quality Assurance Project Plans for
Modeling.
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A8 Special Training/Certifications: In this section of the QAPP, the permittee should discuss training
requirements, including any training sessions that will be held. For example, a training session covering
field monitoring equipment and safety concerns might be held at the beginning of the project for all
parties involved in sampling.
A9 Documentation and Records: The permittee should provide in this section of the QAPP a description
of how field sampling collection and handling activities will be documented. For example, general
observations and weather conditions could be documented in a field log notebook. It might be desirable
to record flow information and specific sample parameters (e.g., pH, temperature, grab samples) on
special field data forms. Also, the permittee will want to describe what information will be included on
the sample identification labels (e.g., sample point, date and time of collection) and on the chain-of-
custody forms. Example chain-of-custody forms, field data sheets and sample identification labels are
generally referenced in this section as attachments to the QAPP.
An example EPA Chain-of-Custody form is available from EPA's NPDES Inspection Manual (USEPA 2004a)
Web site at http://www.epa.gov/oecaerth/resources/publications/monitoring/cwa/inspections/
npdesinspect/npdesinspectappm.pdf. As described in EPA's (1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) Combined Sewer Overflows Guidance for Monitoring and
Modeling, chain-of-custody forms typically contain the following information:
• Name of project and sampling locations
• Date and time that each sample was collected
• Names of sampling personnel
• Sample identification names and numbers
• Types of sample containers
• Analyses to be performed on each sample
• Additional comments on each sample
• Names of all personnel transporting the samples
The sample label/field form(s) could include information (USEPA 1999;
http://www.epa.gov/npdes/pubs/sewer.pdf) such as
• Name of project
• Date and time of sample collection
• Sample location
• Name or initials of sampler
• Analysis to be performed
• Sample identification (ID) number
• Preservative used
• Type of sample (grab, composite)
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If modeling will be performed to evaluate the effectiveness of CSO controls, the permittee should
describe how the modeling will be performed and documented, including quality control tests and how
tracking of version control will be performed.
Group B - Data Generation and Acquisition
The elements in this group address all aspects of project design and implementation. Implementation of
these elements ensures that appropriate methods for sampling, measurement and analysis, data
collection or generation, data handling, and QC activities are employed and are properly documented.
The ten elements in this group are described below.
Bl Sampling Process Design (Experimental Design): This section should discuss the strategy and
procedures that will be used to collect flow, water quality and other data. The permittee should also
describe who will perform the sampling, how many sampling events are planned, when the sampling
events will be performed and the parameters that will be monitored. A brief discussion or table (see
example provided in Table A-2) of the sampling methods used (e.g., grab, composite, continuous
monitoring), sample points, and analytical tests to be performed (e.g., EPA methods, Standard Methods)
and number of samples to be analyzed for each parameter per event should also be included in this
section.
Table A-2. Example sample collection and analyses at each sampling location
Sample point
Upstream 1
Upstream 2
CSO Outfall
Downstream
Sample point description
Upstream of study area
Mouth of tributary upstream
of study
CSO effluent (end-of-pipe)
Downstream of CSO
Total samples per field sampling event
Escherichia
CO//
5+ 1QC
5+ 1QC
5+ 1QC
5+ 1QC
20 + 4QC
TSS
5+ 1QC
5+ 1QC
5+ 1QC
5+ 1QC
20 + 4QC
BOD5
5+ 1QC
5+ 1QC
5+ 1QC
5+ 1QC
20 + 4QC
B2 Sampling Methods: For methods of collecting samples, the permittee should refer to specific SOPs.
For example, they might want to include SOPs for flow measurement; use of turbidity meter; sampling
during CSO events; collection of field blanks, trip blanks, and equipment blanks; and equipment
decontamination. Additional guidance on preparing SOPs was provided in Section 4.5 of this guidance.
B3 Sample Handling and Custody: The permittee should include a discussion of how samples will be
packed (e.g., in boxes secured with packing tape) and shipped or delivered to the analytical laboratory
with corresponding chain-of-custody forms, ensuring samples will be received by laboratory for analysis
of samples within holding time requirements. This section should include a list or table of sample
volumes and bottles that will be used for sample collection purposes. In addition, the permittee should
include a table of sample handling requirements (see example Table A-3) in this section of the QAPP.
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Table A-3. Example sample handling requirements for samples to be analyzed by the
laboratory
Parameter
TSS
BOD5
Enterococci or E. coif
Maximum holding time
7 days
2 days
< 6 hours between collection and initiation of
analyses; processing (filtration and plating) will be
completed no later than 8 hours after collection
Preservation required
cool, 1-4°C
cool, 1-4°C
cool, 1-4°C
a EPA (1986; http://www.epa.gov/waterscience/beaches/files/1986crit.pdf) recommends use of £. coli or enterococci
as indicators of fecal contamination for freshwater and enterococci as an indicator of fecal contamination for marine
water.
B4 Analytical Methods: The permittee should include a list or table of target analytes and corresponding
analytical methods (e.g., E. coli by EPA Method 1603; enterococci by EPA Method 1600) in this section of
the QAPP. In addition, the permittee should discuss or reference the sample processing and analytical
methods and method-specific criteria to be met for analysis; in most cases, this information can be
found in the analytical laboratory's QAPP. In many cases, it will be desirable to use a certified
environmental laboratory to perform the analyses (for more information on contracting laboratory
services, see Appendix C).
B5 Quality Control: This section should describe the checks that will be performed to estimate the
variability for each measurement activity (USEPA 2002a; http://www.epa.gov/QUAUTY/qs-docs/g5-
final.pdf). Analysis of QC samples such as field blanks and duplicate samples can be used to perform
these checks. Some example QC checks that could be used for samples analyzed for microbiological
parameters are provided below.
• Duplicate sample: A second aliquot of a field sample that is prepared or analyzed exactly like a
field sample. One duplicate will be prepared and analyzed for every 10 field samples for all
parameters.
• Positive/negative controls: Positive and negative controls refer to control cultures that, when
analyzed exactly like field samples, will produce a known positive or a known negative result for
a given type of media. One media-specific positive control and one media-specific negative
control will be prepared and analyzed for every 10 field samples, or one per sample set,
whichever is more frequent. In addition, one positive control and one negative control will be
prepared and analyzed with every confirmation test. Each control will be carried through the
entire procedure and must exhibit the expected positive or negative result.
• Media check: Before use of newly prepared media, a representative portion of 5 percent of each
media batch will be checked for correct response to positive and negative controls. Positive and
negative controls will be analyzed exactly like field samples.
• Incubator/waterbath temperatures: Incubator or waterbath temperatures will be taken two
times per day. Temperatures will be taken no less than 4 hours apart and will be within ± 0.5 °C
of the desired temperature.
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In addition, it is recommended that the permittee discuss completeness objectives and how the
permittee plans to meet these objectives. Completeness is defined as the percentage of measurements
made that are judged to be valid according to specific criteria and entered into the data management
system. For example, it might be desirable to set a 90 percent completeness goal. A permittee might
take measures such as storing and transporting samples in unbreakable (plastic) containers whenever
possible or wrapping glass containers in bubble wrap for shipping.
B6 Instrument/Equipment Testing, Inspection, and Maintenance: The permittee should discuss how
often equipment and instruments will be inspected to ensure their satisfactory performance. The
permittee should also describe how maintenance activities will be performed (e.g., replacing internal
desiccant and batteries in flow meters; replacing internal desiccant, replacing peristaltic pump tubing
and calibrating the aliquot volume in autosamplers) and reference appropriate SOPs or user manuals. In
addition, the permittee should describe whether backup equipment will be used in cases where
equipment breaks or malfunctions.
B7 Instrument/Equipment Calibration and Frequency: This section should include the procedures and
frequency of calibration and standards or apparatus to be used for instruments that need to be
calibrated. The permittee should check the instrument user manuals to determine how often
calibrations should be performed. For example, an autosampler might need to be calibrated several
times a year, while a dissolved oxygen meter might need to be calibrated before each day it is used.
Flow meters are usually factory-calibrated but should be tested (e.g., spin test to check condition of
meter bearings) to ensure that they are working properly before use.
B8 Inspection/Acceptance of Supplies and Consumables: The permittee should describe what supplies
and consumables will be checked before use and who will be responsible for checking them. For
example, a field leader might ensure that only certified clean containers for bacterial analyses are used
for sample collection and that only certified standard solutions that have not expired are used for
turbidity probe calibration.
B9 Non-direct Measurements: The permittee should describe whether data previously collected for a
purpose other than post construction compliance monitoring or collected by an organization not under
the direction of the NPDES authority will be used. For example, the permittee might determine that the
nondirect data in question will meet the data indicator requirements in the QAPP and be able to use the
information to populate models to help evaluate CSO control effectiveness or to help evaluate receiving
water quality. Alternatively, the permittee might determine that the nondirect data in question will not
meet the data indicator requirements in the QAPP and decide to use the information for qualitative
assessment purposes only.
BIO Data Management: In this section of the QAPP, the permittee should discuss how data generated
from the project will be managed (USEPA 2002a; http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf).
For example, the permittee might document samples by using sample identification labels and chain-of-
custody forms. It is recommended that the permittee discuss where hard copies for chain-of-custody
forms and field data sheets will be stored and where electronic project spreadsheets, reports and
laboratory files will be stored and backed up.
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Group C - Assessment and Oversight
The elements in this group address the activities for assessing the effectiveness of the implementation
of the project and associated QA and QC activities. The purpose of assessment is to ensure that the
QAPP is implemented as approved (conformance/nonconformance), to increase confidence in the
information obtained, and ultimately to determine whether the information may be used for their
intended purpose (USEPA 2002a; http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf). The two
elements in this group are described below.
Cl Assessments and Response Actions: This element gives information concerning how a project's
activities will be assessed during the project to ensure that the QAPP is being implemented as approved.
A wide variety of internal (self) and external (independent) assessments can be conducted during a
project (USEPA 2002a; http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf). Detailed information on
different types of assessments can be found in Appendix B of EPA's (2002a;
http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf) Guidance for Quality Assurance Project Plans and
EPA's Guidance on Technical Audits and Related Assessments (G-7) (USEPA 2000;
http://www.epa.gov/QUALITY/qs-docs/g7-final.pdf). An example of an internal assessment is the
permittee's project manager periodically assessing field data collection efforts, field notes and
laboratory data as part of the project to ensure that the data collected are usable for the purpose of the
study.
For assessing field collection efforts, the permittee's project manager might check proper calibration of
field equipment, consistent recording of data, accurate sample methodology, and appropriate
distribution of samples to the laboratory. For review of field data, the permittee's project manager
might review the field measurements to ensure that they are within the accepted range for each
parameter (e.g., ± 1 °C for water temperature). A response to detecting inconsistencies in field
procedures or measurements could be discussing field instrument calibration and data collection with
field personnel to define potential causes. In the final data reports, the project manager will need to
appropriately flag the questionable data, with discussion as to the nature and extent of the limiting
observations.
For review of laboratory results, the permittee's project manager might verify that all the values are
within the laboratories' acceptable ranges for each parameter. These ranges should be specified in the
laboratory's Quality Management Plan or SOPs before sampling. Response actions could include
discussing any discrepancies with the laboratory project manager to assess the need to re-test the
sample. The laboratory should report outlier data in the data report and describe potential sources of
error.
For review of model results, the modeling staff could generally check results to those obtained by other
models or by comparing them to hand calculations. In addition, model calculations should be compared
to field data. If the modeling staff determines that adjustments should be made to model parameters to
obtain a fit to the data, the modeling staff should provide an explanation and justification that agree
with scientific knowledge and fit within reasonable ranges of process rates as found in the literature.
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C2 Reports to Management: After completing field sampling, laboratory and if necessary, modeling
activities, the permittee should prepare and submit a draft report to the NPDES authority for review.
The report should list all participants, sampling locations, samples collected, models used, and data used
to populate, calibrate, and validate the models. In addition, the report should include results and
conclude whether the CSO controls meet the compliance goals of the selected approach and whether
the sampled receiving water quality at each measurement location was compliant with WQS and
protection of designated uses.
Group D - Data Validation and Usability
The elements in this group address the QA activities that occur after the data collection or generation
phase of the project is completed. These final checks are performed to check whether the data obtained
from the project will conform to the project's objectives and to estimate the effect of any deviations
(USEPA 2002a; http://www.epa.gov/QUALITY/qs-docs/g5-final.pdf). The three elements in this group
are described below.
Dl Data Review, Verification, and Validation: This section of the QAPP should provide an overview of
the final checks that will be performed. This could include reviewing data entries for completeness and
correctness and checking results against performance criteria specified in the QAPP (see the description
of A7 Quality Objectives and Criteria above). On the basis of the results of the final checks, the
permittee should determine whether to accept, reject, or qualify the data.
D2 Verification and Validation Methods: This section of the QAPP should provide the processes that will
be used to verify and validate the data generated, including the actual checks that will be performed and
the person(s) responsible for performing them. For example, it could be stated that the "data collected
in the field will be validated and verified by the permittee project manager." It generally is the
laboratory's responsibility to validate and verify the analytical results (for more information on
laboratory contracting considerations, see Appendix D). The permittee project manager should review
the data verification and validation report(s) prepared by the laboratories to determine whether any
data should be rejected or qualified.
D3 Reconciliation with User Requirements: This assessment represents the final determination of
whether the data collected are of the correct type, quantity, and quality to support their intended use
for the project. Any problems encountered in meeting the performance criteria (or uncertainties and
limitations in the use of the data) should be discussed with the NPDES authority and reconciled, if
possible.
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Appendix B. Recommended Reporting Requirements
The permittee, in consultation with the NPDES authority, should determine how frequently post
construction compliance monitoring reports should be prepared and submitted to the NPDES authority
and other interested parties (e.g., federal agencies, regional commissions, volunteer groups). Monthly or
quarterly reporting might be sufficient in cases where monitoring is performed several times each year
for several years. In cases where modeling is performed to evaluate the effectiveness of CSO controls, it
might be more appropriate for the permittee to submit one report documenting the modeling results
when they are available.
The reports should include a discussion of whether the CSO controls are meeting the goals (e.g.,
frequency, volume) of the approach (i.e., Presumption Approach, Demonstration Approach) selected by
the permittee in the LTCP to verify the effectiveness of CSO controls. The report should also assess
whether CSO receiving water quality complies with WQS. The NPDES authority should consult with EPA
to determine whether results should be entered into national databases (e.g., (PCS/ICIS, STORET).
The permitting community should consider including the following recommended data elements in the
post construction compliance monitoring report for determining the effectiveness of CSO controls:
• Facility name and city
• Submittal mailing address, contact name
• Name of wastewater treatment facility normally receiving sewage
• NPDES permit number
• Monitoring period
• Duration of monitoring program
• Surface water(s) affected by the discharge(s)
• Identification of basic approach (i.e., Presumption Approach, Demonstration Approach) and
identification of the criteria under the Presumption Approach (if selected) by the permittee in
the LTCP to verify the effectiveness of CSO controls
• Description of method(s) used to evaluate the effectiveness of CSO controls
• The CSOs and areas within the CSS that were monitored (e.g., outfall identification number,
location in CSS that includes all flows into a sewershed) and rationale for their selection (e.g.,
outfalls discharging the most frequently from previous observations, outfalls in sensitive areas,
simple or complex system)
• Identifying representative overflows
• Event duration for each outfall for each day
• POTW WWTP influent flow for each day at a designated monitoring point in MGD
• Operational problems that reduced the capabilities of the POTW or the delivery/treatment
system including natural or man-made disasters, power outages, equipment breakdown or
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malfunction, biological problems, inadequate capacity because of antecedent conditions
(previous rainfall, snowmelt, elevated groundwater and so on).
• Peak influent flow rate entering the POTW WWTP at a designated monitoring point in MG
• Peak influent design flow
• Chlorine residuals (max chlorine dose, chlorine residual in final effluent)
• Event discharge from each overflow or approved representative overflow in MG and as
metered/measured or estimated
• If models were used, a description of the model(s) selected for the project and the data that
were used to calibrate and validate the model(s)
• If the Presumption Approach, Criterion i was selected, a presentation of overflow data allowing
for evaluation on an average annual basis (for additional information, see Section 4.1.1 of this
guidance document) to evaluate whether no more than an average of four overflow events
occurred per year (provided that the NPDES authority may allow up to two additional overflow
events per year)
• If the Presumption Approach, Criterion ii was selected, flows in CSS during precipitation events,
volume of overflows from the system during the precipitation events, and calculation of percent
capture on an annual basis to evaluate whether 85 percent of combined sewage in the CSS
during precipitation events is captured on an annual basis (for additional information, see
Section 4.1.2 of this guidance document)
• If the Presumption Approach, Criterion iii was selected, calculation of average pollutant load
removal (for examples, see Section 4.1.3 of this guidance) to show that the permittee will
achieve the elimination or removal of no less than the mass of pollutants identified as causing
water quality impairment through the sewer system characterization, monitoring, and modeling
efforts for the volumes that would be eliminated or captured for treatment under the
Presumption Approach, Criterion ii.
• If the Demonstration Approach was selected, methods used to demonstrate the impact of CSOs
on the receiving water, such as receiving water model and water quality monitoring
In addition to the above data elements for evaluating the effectiveness of CSO controls, the permitting
community should consider including the following recommended data elements in the post
construction compliance monitoring report for assessing whether CSO receiving water quality complies
with WQS:
• Monitoring locations
• Day of month, day of week
• Frequency of sampling and number of wet weather events sampled.
• Criteria for when samples were collected (e.g., greater than x days between events, rainfall
events greater than 0.4 inch to be sampled)
• Description of flow measurement, rainfall measurement and sampling methods used
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General weather conditions (e.g., temperature)
Precipitation in inches, measured to the closest 0.10-inch of precipitation event over a 1-day
period
Precipitation type
Storm duration
Flow measurements
Time discharge begins
Pollutant concentrations
Compliance status of the municipality (e.g., overflow number out of allowable number of
overflows per year)
Statement confirming that reported CSO discharge and the level of treatment provided was in
full compliance with final performance criteria in permit, order, or other enforceable document
issued between the NPDES authority and the permittee, or by court action
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Appendix C. Resources Relevant to Applicable Water Quality
Standards
As described earlier in this document, characterizing CSO impacts implicitly requires the permittee to
identify the WQS of the receiving water and to evaluate how the CSO discharges are affecting the
receiving waters with respect to such standards. The permitting community should determine what
water quality criteria or standards applicable to the specific designated use(s) of the receiving water are
available for the pollutants selected for analysis.
The WQS program, as envisioned in section 303(c) of the CWA, is a joint effort between the states and
EPA. The CWA requires EPA to publish water quality criteria recommendations, and it requires states to
adopt protective criteria into their standards. States can do this in one of three ways:
• Adopt EPA's recommended criteria
• Modify EPA's recommended criteria to reflect site-specific conditions
• Adopt criteria that are as protective as EPA's recommendation based on scientifically defensible
methods
States adopt WQS to protect public health or welfare, enhance the quality of water, and protect
biological integrity. EPA oversees states' activities to ensure that state-adopted standards are consistent
with the requirements of the CWA and that WQS regulations (40 CFR Part 131) are met. Monitoring,
assessments, and compliance determinations must also consider the applicable water quality criteria
and standards adopted by the state, tribe or territory, and approved by EPA for the given location of the
CSO project."
Environmental stressors can be chemical, physical or biological in nature, and likewise can impact the
chemical, physical, and biological characteristics of an aquatic ecosystem. The interactions among
chemical, physical, and biological stressors and their compounding impacts emphasize the need to
directly detect and assess actual water quality impairments of the biota.
C.I Indicators of Bacterial Contamination
C.I.I Recreational Waters
Before the 1986 revision to EPA's national criterion for bacteria, EPA's 1976 recommended criteria for
bathing waters was based on fecal coliform bacteria. In EPA's 1976 Quality Criteria for Water
(http://www.epa.gov/waterscience/criteria/library/redbook.pdf), it was recommended that, based on a
minimum of five samples taken over a 30-day period, "fecal coliform bacterial level should not exceed a
log mean of 200 per 100 milliliters (ml), nor should more than 10 percent of the total samples taken
during any 30-day period exceed 400 per 100 ml."
On the basis of results of studies EPA performed in the late 1970s and early 1980s, it was determined
that enterococci and E. coli had a greater degree of association with outbreaks of certain diseases than
fecal coliform bacteria. EPA, in its 1986 Ambient Water Quality Criteria for Bacteria
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(http://www.epa.gov/waterscience/beaches/files/1986crit.pdf, recommended enterococci and E. coli as
the basis for bacterial WQS. EPA's (1986; http://www.epa.gov/waterscience/beaches/files/1986crit.pdf)
recommended criteria for bacteria for bathing waters are as follows:
• Freshwater: On the basis of a statistically sufficient number of samples (generally not less than
five samples equally spaced over a 30-day period), the geometric mean of the indicated
bacterial densities should not exceed one or the other of the following:
- E. coli 126 per 100 ml
- Enterococci 33 per 100 ml
No sample should exceed a one-sided confidence limit (C.L) calculated using the following as a
guidance:
Designated bathing beach 75% C.L.
Moderate use for bathing 82% C.L.
Light use for bathing 90% C.L.
Infrequent use for bathing 95% C.L.
On the basis of a site-specific log standard deviation, or if site data are insufficient to establish a
log standard deviation, using 0.4 as the log standard deviation for both indicators.
• Marine water: On the basis of a statistically sufficient number of samples (generally not less
than five samples equally spaced over a 30-day period), the geometric mean of the enterococci
densities should not exceed 35 per 100 mL.
No sample should exceed a one-sided C.L. using the following as guidance:
Designated bathing beach 75% C.L.
Moderate use for bathing 82% C.L.
Light use for bathing 90% C.L.
Infrequent use for bathing 95% C.L.
On the basis of a site-specific log standard deviation, or if site data are insufficient to establish a
log standard deviation, using 0.7 as the log standard deviation.
Under the CWA, EPA is required to approve state-adopted standards for waters of the United States,
evaluate adherence to the standards, and oversee enforcement of standards compliance. As of the year
2000, many states had not adopted EPA's recommended bacteria criteria (USEPA 1986;
http://www.epa.gov/waterscience/beaches/files/1986crit.pdf) or an as protective as alternative into
their standards for coastal recreational waters. In response, Congress passed the Beaches Environmental
Assessment and Coastal Health Act of 2000 (BEACH Act; USEPA 2000
[http://www.epa.gov/waterscience/beaches/files/beachbill.pdfD. that required states to adopt
protective bacteria criteria into their state standards by April 2004.
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Through the BEACH Act, EPA established federal standards for those states and territories with coastal
recreation waters that had not yet adopted bacteria criteria as protective of health as EPA's 1986
criteria into their WQS. The BEACH Act Rule (see 40 CFR 131.41) states that these standards apply to E.
coli or enterococci regardless of origin unless a sanitary survey shows that sources of the indicator
bacteria are non-human and an epidemiological study shows that the indicator densities are not
indicative of a human health risk. For additional information on the status of standards development for
coastal recreational waters, see EPA's Final Nationwide Bacterial Standards Fact Sheet at
http://www.epa.gov/waterscience/beaches/rules/bacteria-rule-final-fs.htm.
C.l.1.1 Single Sample Maximum Values
EPA provides recommendations for those interested in using a single sample maximum (SSM) value to
assess receiving water quality at http://www.epa.gov/waterscience/beaches/rules/singe-sample-
maximum-factsheet.htmffposition. The geometric mean is generally more relevant than the SSM
because it is usually a more reliable measure of long-term water quality, being less subject to random
variation, and more directly linked to the underlying studies on which the 1986 bacteria criteria were
based. However, using an SSM is especially important for beaches and other recreational waters that are
prone to short-term spikes in bacteria concentrations from CSO discharges or waters that are
infrequently monitored.
It should be emphasized that SSM values in EPA's 1986 Ambient Water duality Criteria for Bacteria
(http://www.epa.gov/waterscience/beaches/files/1986crit.pdf) were not developed as acute criteria;
rather, they were developed as statistical constructs to allow decision makers to make informed
decisions to open or close beaches on the basis of small data sets. Treating the SSM as equivalent to
acute criteria (i.e., with a specified duration of exposure of just one second) could impart a level of
protection much more stringent than intended by the 1986 bacteria criteria document.
Therefore, EPA intends that states and territories covered by the BEACH Act Rule retain the discretion to
use SSM values as they deem appropriate in the context of CWA implementation programs other than
beach notification and closure, consistent with the CWA and its implementing regulations.
The BEACH Act Rule (see 40 CFR 131.41) provides calculated SSM values based on the 75, 82, 90, and 95
percent confidence levels in EPA's 1986 Ambient Water duality Criteria for Bacteria
(http://www.epa.gov/waterscience/beaches/files/1986crit.pdf). EPA recognizes that the log standard
deviations observed in EPA's epidemiological studies might not coincide with that for a particular
waterbody. If a state or territory is interested in calculating site-specific SSM values, the BEACH Act Rule
requires the collection of at least 30 bacterial samples in a single recreation season (see 40 CFR
131.41(c)(3)) to capture the variability inherent in bacteria concentrations at a site over the period of a
single season without introducing additional variability from extreme weather conditions such as
drought or El Nino conditions.
EPA considers that for calculating site-specific SSM values, as specified in 40 CFR 131.41(c)(3), it provides
enough detail on the calculation that states included in the BEACH Act Rule can implement this provision
of the rule without needing to adopt it as a site-specific water quality criterion. As a result, states
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included in the BEACH Act Rule do not need EPA review and approval under 40 CFR Part 131 in their
application of 40 CFR 131.41(c)(3).
C.I. 1.2 Future Recreational Water Standards
EPA's current (1986; http://www.epa.gov/waterscience/beaches/files/1986crit.pdf) criteria
recommendations use indicator bacteria. Most strains of E. coli and enterococci do not cause human
illness (that is, they are not human pathogens); rather, they indicate fecal contamination, and the
assumption is that pathogens co-occur with incidences of fecal contamination (USEPA 2007a;
http://www.epa.gov/waterscience/criteria/recreation/experts/expertsWorkshop.pdf).
Since publication of the 1986 criteria, many states have expressed concern that the current fecal
indicator/illness rate relationships identified in the epidemiology studies leading up to the 1986 criteria
are not appropriate or representative of all U.S. waters. For example, states have concerns that the
most appropriate indicator in tropical waters could be different than in temperate waters, and that
appropriate levels of indicators could be different in waters where human fecal waste predominates
animal waste (USEPA 2007a;
http://www.epa.gov/waterscience/criteria/recreation/experts/expertsWorkshop.pdf).
Since EPA issued its recreational criteria more than 20 years ago, there have been significant scientific
advances, particularly in the areas of molecular biology, microbiology, and analytical chemistry. As
described in EPA's (2007a;
http://www.epa.gov/waterscience/criteria/recreation/experts/expertsWorkshop.pdf) Report of the
Experts Scientific Workshop on Critical Research Needs for the Development of New or Revised
Recreational Water Criteria, EPA believes that these new scientific and technical advances need to be
factored into the development of new or revised CWA 304(a) criteria for recreation. To this end, EPA has
been conducting research and assessing relevant scientific and technical information to provide the
scientific foundation for developing new or revised criteria. The BEACH Act of 2000 requires EPA to
conduct new studies and issue new or revised criteria, specifically for Great Lakes and coastal marine
waters.
EPA's Critical Path Science Plan (USEPA 2007b;
http://www.epa.gov/waterscience/criteria/recreation/plan/index.html) describes the high-priority
research and science that EPA intends to conduct to establish the scientific foundation for developing
new or revised recreational water quality criteria recommendations. EPA's Critical Path Science Plan
(http://water.epa.gov/scitech/swguidance/waterquality/standards/criteria/health/recreation/plan inde
x.cfm ) describes the overall research goals, key science questions associated with data gaps in the
existing science, and the studies that EPA intends to conduct or support to develop new or revised water
quality criteria for pathogens and pathogen indicators by the end of 2012.
Detailed information on the development of EPA's new or revised recreational water quality criteria is
on EPA's Recreational Water Quality Criteria Web site:
http://www.epa.gov/waterscience/criteria/recreation/.
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C.l.1.3 Non-coastal or Inland Recreational Waters
Note that the BEACH Act Rule (see 40 CFR 131.41) is applicable to only coastal recreational waters.
Section 502(21) of the CWA explicitly excludes from the definition of coastal recreation waters "inland
waters; or water upstream of the mouth of a river or stream having an unimpaired natural connection
with the open sea."
EPA will approve pathogen standards for inland waters if the standards submitted by states to EPA for
approval are found to be scientifically defensible for protecting the uses of these waterbodies. Parts of
states with only inland waters are not subject to the BEACH Act requirements, as described on EPA's
Frequent Questions - Final Water Quality Standards for Coastal and Great Lakes Recreation Waters Web
site, at http://www.epa.gov/waterscience/beaches/rules/bacteria-rule-questions.htmtfinland.
C.2 Shellfish Harvesting Waters
EPA's (1986; http://www.epa.gov/waterscience/beaches/files/1986crit.pdf) recommended criteria for
bacteria for shellfish harvesting waters is
The median fecal coliform bacterial concentration should not exceed 14 MPN per 100 ml with
not more than 10 percent of samples exceeding 43 MPN per 100 ml for the taking of shellfish.
In cases where CSOs are discharged into shellfish harvesting waters, it is expected that the NPDES
authority will require the permittee to collect and analyze samples for fecal coliform bacteria for
comparison to applicable state standards. If the receiving water also is classified as a coastal recreational
water, it is expected that the NPDES authority will require the permittee to monitor for both fecal
coliform bacteria (to evaluate compliance with shellfish harvesting WQS) and E. coli or enterococci to
meet BEACH Act requirements.
C.3 Other Applicable Water Quality Criteria
A compilation of all EPA's current recommended ambient water quality criteria for the protection of
aquatic life and human health (USEPA 2005) are provided on EPA's National Recommended Water
Quality Criteria Table Web site (http://www.epa.gov/waterscience/criteria/wqctable/). In 2002 EPA
published revisions to many of the ambient water quality criteria for human health as the National
Recommended Water Quality Criteria: 2002 (http://www.epa.gov/waterscience/pc/revcom.pdf). In 2003
EPA published an additional 15 revised human health criteria. The current National Recommended
Water Quality Criteria Table (USEPA 2005;
http://water.epa.gov/scitech/swguidance/waterquality/standards/current/index.cfm) reflects the
compilation of the updated information already published by EPA in 2002 and 2003.
Great Lakes Requirements
Great Lakes regulatory requirements, known as the Great Lakes Initiative, or GLI, apply to all the
streams, rivers, lakes and other bodies of water within the U.S. portion of the Great Lakes drainage
basin. For those waters, a state or authorized tribe must adopt requirements (including water quality
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criteria) that are consistent with (as protective as) regulations EPA promulgated on March 23, 1995. See
60 FR 15366 and 40 CFR 132.l(b) and 132.4.
State, Tribal, and Territorial Water Quality Standards
Because each state has its own WQS, individual post construction compliance monitoring plans will have
to be designed to provide data to allow evaluation of CSO controls in achieving the specific WQS in the
receiving water. In post construction monitoring plans, permittees should show a direct link between
the WQS in the receiving water and the data they are collecting in the post construction compliance
monitoring program. This can be straightforward in the case of waterbodies that have clearly identified
water quality criteria, such as TSS, but it can be more challenging in the case of other standards, such as
geometric means for bacteria.
State, tribal, and territorial WQS are available from EPA's state, tribal and territorial standards Web site
(http://www.epa.gov/waterscience/standards/wqslibrary/links.html). Some state criteria are
nonnumeric, qualitative guidelines that describe a desired water quality goal.
Data collection is potentially challenging for receiving waters that have narrative criteria related to
biological communities or sediment quality. In such cases, as part of its post construction compliance
monitoring plan, the permittee may be required to design and implement studies that provide data that
allow the NPDES authority to assess the attainment of designated uses. Addressing narrative criteria can
be an important aspect of any monitoring plan because effects on designated uses cannot always be
accurately assessed using the relatively few pollutant-specific criteria available (e.g., metals, pH). For
example, narrative criteria, such as "no toxics in toxic amounts," are written to account for any
constituents not specifically measured. WET testing is able to determine compliance with such narrative
criteria by testing the discharge as a whole. Often, constituents that are not specifically measured, or a
combination of constituents, can cause toxicity and would not have been accounted for if not for WET
testing. Similarly, bioassessment integrates effects of all pollutants associated with an effluent as well as
hydrological impacts that could impair aquatic life habitats. Evaluating more holistic environmental
parameters, such as bioassessment, WET, and sediments, addresses narrative criteria designed to
protect and maintain designated uses. The methodology used in these studies should be consistent with
any studies done before implementing CSO controls, during the characterization of the receiving water
so that the data collected are consistent with, and comparable to, prior data, therefore allowing a
comparison of pre-and post-CSO control implementation, to provide information on attainment of
water quality goals.
C.3.1 Biocriteria
Sections 303 and 304 of the CWA require states to protect biological integrity as part of their WQS. This
can be accomplished, in part, through the development and use of biological criteria. As part of a state
or tribal WQS program, biological criteria can provide scientifically sound and detailed descriptions of
the designated aquatic life use for a specific waterbody or segment. They fulfill an important assessment
function in water quality-based programs by establishing the biological benchmarks for (1) directly
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measuring the condition of the aquatic biota, (2) determining water quality goals and setting priorities,
and (3) evaluating the effectiveness of implemented controls and management actions.
Additional information on EPA's bioassessment and biocriteria programs is available at
http://www.epa.gov/waterscience/biocriteria/.
C.3.2 Sediment criteria
In 1976, EPA published a water quality criteria recommendation for solids and turbidity that is based on
light reduction. This criterion is summarized in the 1986 EPA Quality Criteria for Water as
Solids (Suspended, Settleable) and Turbidity—Freshwater fish and other aquatic life: Settleable
and suspended solids should not reduce the depth of the compensation point for
photosynthetic activity by more than 10 percent from the seasonally established norm for
aquatic life.
The criterion and a brief description of the rationale are at
http://www.epa.gov/waterscience/criteria/goldbook.pdf. These criteria have not been frequently
adopted or used by states. Many states have different criteria for different stream channel substrate
types. When they are differentiated, states typically have more stringent criteria for streams with hard
substrates (gravel, cobble, bedrock) and less stringent criteria for streams with soft substrates (sand, silt,
clay). Cold water fisheries typically have more rigorous criteria than do warm water fisheries in states
that differentiate between the two uses. A few states use biocriteria (e.g., biotic indices), and at least
one uses soil loss as a criterion. Several states provide criteria for an averaging period (e.g., 30 days) as
well as an allowed daily maximum concentration. Some states set an absolute value while others set a
value over a background level.
Most states with numerical criteria use turbidity as a surrogate measure. Some use exceedances over
background (e.g., "Not greater than 50 NTU over background," or "not more than 10 percent above
background" or "no more than 5 NTUs above background"), while some use absolute values (e.g., "Not
greater than 100 NTU"). Some states have established numeric standards that are basin-specific, while
others vary with the presence of salmonids. In general, most states are concerned with the effects of
water clarity and light scattering on aquatic life. The majority of states use EPA method 180.1 to
measure turbidity and method 160.2 to measure TSS. Most states use optical backscatter or optical
transmission technology for turbidity either by measuring in situ or in the lab after collecting grab or
single point samples. Very few, if any states, attempt to correlate turbidity with TSS or biological
impacts, and only a few states measure suspended sediment concentration. Very few states measure
particle size distribution or bedload.
Only a few states use suspended solids as a criterion. Suspended solids criterion values vary from 30
mg/L up to 158 mg/L At least one state uses transparency (> 90 percent of background) as a standard. A
number of states have criteria based on sediment deposited over a period or during a storm event.
Values are typically 5 mm during an individual event (e.g., during the 24 hours following a heavy
rainstorm) for streams with hard substrates bottoms and 10 mm for streams with soft bottoms.
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Additional information on sediment criteria is available from EPA's suspended and bedded sediments
Web site (http://www.epa.gov/waterscience/criteria/sediment/).
C.3.3 WET Testing
At present, EPA has no national criteria developed under CWA section 304(a) for acute and chronic WET.
In the absence of such criteria, according to EPA's (1991;
http://www.epa.gov/npdes/pubs/owm0264.pdf) Technical Support Document for Water Quality-Based
Toxics Control (TSD), recommended magnitudes for WET are for acute protection, the Criterion
Maximum Concentration should be set at 0.3 acute toxic units (TUa) to the most sensitive of at least two
test species, where a TUa = 100/LC50 (concentration that is lethal to 50 percent of the test organisms).
For chronic protection, the criteria continuous concentration (CCC) should be set at 1.0 chronic toxic
units (TUc) to the most sensitive of at least three test species, where a TUc = either 100/NOEC (where
NOEC = the no observed effect concentration of a given sample) or 100/IC25 (where IC25 = the
concentration at which the response of test organisms is 25 percent below that observed in the control).
Some states have their own numeric WET criteria that are usually consistent with the level of protection
afforded by the criteria expressions above.
Depending on state implementation procedures, for CSO wet-weather evaluations, acute WET criteria
are typically more relevant than chronic WET criteria because the water quality event is often short in
duration (e.g., < 48 hours). In such cases, acute WET tests (which are between 48 and 96 hours in
duration) might be more appropriate than chronic tests (which are typically conducted over a 6-8 day
period for most EPA-approved chronic test methods). However, some studies have reported latent
toxicity effects of stormwater discharges (i.e., effects observed when continuing the test past the
required acute test duration), which might not be identified using short duration acute WET tests. The
decision to use acute versus chronic WET tests should rest in part on the magnitude and duration of the
CSO event: high magnitude or long duration CSO events might warrant chronic WET testing. This
decision could also depend on the relative dilution of the CSO flow in the receiving waterbody. If dilution
is very high (e.g., > 100), chronic testing would probably not be appropriate: EPA's TSD notes that
chronic WET testing is advisable when effluent dilution is > 1 percent of the receiving waterbody flow on
the basis of the flow condition of concern. If chronic testing is conducted, test exposure concentrations
should be renewed using fresh samples collected during the event rather than using the same sample
for renewals during the 6-8 day period (i.e., using the first flush sample for the entire 6-8 day test
duration). Using fresh samples collected throughout the wet-weather CSO event ensures that test
organisms are exposed in a manner similar to the aquatic life in the receiving waterbody.
For dry-weather CSO samples, chronic WET criteria and chronic WET testing might be more appropriate
than acute testing depending on the CSO dilution as noted above. If there is, indeed, dry-weather and
lower waterbody flows, discharge from a CSO outfall during that condition might be expected to have
the potential for water quality effects on aquatic life, suggesting the need for sensitive chronic WET
testing.
Additional information on EPA's WET testing is available at
http://www.epa.gov/waterscience/methods/wet/.
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C4 TMDLs
In receiving waters where bacterial TMDLs in coastal recreational waters have been based on fecal
coliform bacteria standards, it is expected that the NPDES authority will require the permittee to
monitor for both fecal coliform bacteria (to meet TMDL requirements) and E. coli or enterococci to meet
BEACH Act requirements.
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References Appendix C
USEPA (U.S. Environmental Protection Agency). 1976. Quality Criteria for Water. EPA 440/9-76-023. U.S.
Environmental Protection Agency, Washington, DC.
USEPA (U.S. Environmental Protection Agency). 1986. Ambient Water Quality Criteria for Bacteria 1986.
EPA 440/5-84-002. U.S. Environmental Protection Agency, Office of Research and Development,
Microbiology and Toxicology Division and Office of Water Regulations and Standards, Criteria
and Standards Division, Washington, DC.
USEPA (U.S. Environmental Protection Agency). 1991. Technical Support Document for Water Quality-
based Toxics Control. EPA-505-2-90-001. U.S. Environmental Protection Agency, Office of Water,
Washington, DC. .
USEPA (U.S. Environmental Protection Agency). 2000. Beaches Environmental Assessment and Coastal
Health Act of 2000. Public Law 106-284 106th Congress —OCT. 10, 2000.
USEPA (U.S. Environmental Protection Agency). 2002. National Recommended Water Quality Criteria.
EPA-822-R-02-047. U.S. Environmental Protection Agency, Office of Science and Technology,
Washington, DC.
USEPA (U.S. Environmental Protection Agency). 2005. National Recommended Water Quality Criteria
Table: Poster and Brochure. EPA-822-H-04-001 and EPA-822-F-04-010, respectively. U.S.
Environmental Protection Agency, Office of Science and Technology, Washington, DC.
USEPA (U.S. Environmental Protection Agency). 2007a. Report of the Experts Scientific Workshop on
Critical Research Needs for the Development of New or Revised Recreational Water Quality
Criteria. U.S. Environmental Protection Agency, Office of Research and Development,
Washington, DC.
.
USEPA (U.S. Environmental Protection Agency). 2007b. Critical Path Science Plan for the Development of
New or Revised Recreational Water Quality Criteria. U.S. Environmental Protection Agency,
Office of Research and Development, Washington, DC.
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Appendix D. CSS Contracting for Laboratory Services
Although many municipalities have established procedures and policies governing the purchase of
services and supplies, these procedures might not lend themselves readily to the purchase of analytical
services. This appendix provides a basic framework for municipal permittees to use in addressing the
technical and contractual issues associated with purchasing laboratory services to support a compliance
monitoring program, awarding contracts, and working with contract laboratories. In some cases,
separate laboratories might be necessary for chemistry, toxicity (WET testing), and microbial indicators,
depending on the accessibility and capabilities of qualified laboratory service providers.
Many laboratory service providers focus on chemical analysis alone, and can retain relationships with
microbiological and WET laboratories to support programs that require those measurements. Further
certification and accreditation of chemical and microbiological laboratories may be administered under
different programs by different accrediting agencies. Microbiological laboratories have historically been
accredited by local departments of health, while environmental chemistry and toxicity laboratories are
accredited by local environmental offices or water agencies, or can take part in national accreditation
programs. WET laboratories may be accredited or certified by the state in some cases or accredited by
the National Environmental Laboratory Accreditation Conference (NELAC) in those states that
participate in the NELAC program. Therefore solicitation, prequalification, and selection of best-value
providers call for a more robust procurement process than many other commercially available services.
Further, because CSO compliance monitoring in particular must, by design, include assessment of
precipitation-triggered discharges, close coordination with the selected provider(s) after award is critical
to the collection of valid data and the overall success of the monitoring program.
Successfully contracting for laboratory services for compliance monitoring relies on the following steps:
Step 1: Define the scope of your analytical requirements (analytical indicators, and measurement
parameters including applicable WQS based on designated uses of the receiving waters) to
develop a detailed contract
Step 2: Develop a standardized bid sheet/cost estimate
Step 3: Identify and solicit approved/certified laboratories
Step 4: Evaluate bidder qualifications and award contracts to a primary laboratory(ies) and a
backup laboratory(ies)
Step 5: Work closely with your laboratory(ies) before monitoring begins and maintain
communication throughout monitoring
These general steps, and details on the activities associated with each, are discussed in Sections D.I
through D.5. Whether you contract with one laboratory for both microbiological and chemical analyses
or separate laboratories, the same general procedures apply.
Remember: you must use an approved laboratory for compliance monitoring, as described in Section D.
3 below, and as described in the provisions of the CWA.
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D.I Defining Your Needs and Developing a Contract
The first step in developing an analytical services contract for analyses is identifying the who, what,
where, when, of the project for your system (the why is the CSO Control Policy and requirement for post
construction compliance monitoring), and the how will be defined through collaboration with your
analytical services provider(s). A well-written contract will address minimally the who (is authorized to
contact the laboratory and to collect and submit samples) and when (samples will be submitted for
analysis) as well as the administrative issues, such as laboratory payments and adjustments. When and
where samples will be collected are critical to identifying the number of overall number of samples that
will be submitted for analysis in a given period of performance, and what parameters will be measured
as necessary to develop the overall scope of the monitoring program to allow the potential bidders to
more closely evaluate the analytical requirements and offer any potential volume discount schedules
that could apply. Because of the nature of CSO post construction compliance monitoring and its focus on
dry- and wet-weather monitoring, it will be necessary to identify the number of dry-weather (ambient)
sampling events proposed and the conditions that will qualify an ambient sampling (i.e., 72 hours since
last measureable rainfall). It is also necessary to identify the number of targeted wet-weather sampling
events that will be proposed, and project within the wet-weather events how many additional CSO
overflow samples might be submitted. During procurement, the variability of prevailing weather
conditions could dictate the need for qualifying the bid sheet as the maximum number of events that
will be sampled, but it should be clear in your solicitation that the actual number of sampling events rely
on predictable weather events.
The best way to ensure that you get the data you need for compliance monitoring in the required period
is to specify your requirements in detail in the contract. A well-written contract can minimize or
eliminate many common problems in procuring analytical services and enable you to collect reliable and
timely results. Recommendations on the factors to consider in defining the scope of the services you
need, and the information you should be sure to include in your contract, are provided below.
D.I.I Client Information
Who defines your CSS to the laboratories that you would like to submit bids for the project, and who will
be collecting the samples (if you would like a bid on sampling services). After award, who will include
your sampling coordination contact(s) for the program.
D.I.2 Sample Information
What describes the samples to be analyzed. As noted in Sections D.I. through D.5, this encompasses a
variety of factors, each of which should be evaluated and defined before you develop the contract.
However, one of the easiest descriptions to overlook is the required analytical sensitivity. Your CSO
monitoring program will include assessment of ambient water quality. In conventional monitoring
programs ambient water quality is assessed during dry-weather or base-flow sampling events, and it
includes a direct comparison of analytical results from grab samples to prevailing WQS. Because a
variety of WQS are available based on selected designated uses from outstanding natural resource
waters and public drinking water supply to secondary contact recreation, analytical sensitivity
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requirements can vary widely. In watershed-wide monitoring programs or in waterbodies or reaches
with multiple designated uses, it is advantageous to select the most stringent WQS as your program
goals. By selecting the most stringent standards there is less likelihood that there will be confusion at
the laboratory as to the analytical objectives, thereby returning the application of the correct standards
back to the user in the ultimate use of the data. Analytical interferences should be less prevalent in
higher grade waters or those that are designated for enhanced water quality. Therefore, where a
laboratory might be required to effect a dilution to render a meaningful measurement on a more
complex sample, it will generally be on a sample from a lesser use designation, and should not affect the
final assessment of attainment of standards.
D. 1.2.1 Number of Samples
What is the total number of samples the laboratory(ies) will need to analyze during a sampling event,
how many events are planned or proposed, and how many will be required during a contract period? If
you are collecting primarily unit rates, and wish to award blanket purchase agreements or purchase
orders, the extended numbers of samples are strictly for projecting the potential sample volume to the
laboratory for volume consideration. Alternatively, if you are awarding a contract for a single permit
period or some other period in accordance with purchasing policies, the laboratory should define your
extended sample numbers.
Will your program include monitoring once per month or twice or more per month? This total includes
not only routine monitoring samples (field [monitoring] samples) but also any field blanks, duplicates
and project-specific quality control (QC; spiked matrix spike and matrix spiked duplicate [MS/MSD])
samples. Field (monitoring) samples and unique, field-generated, project-specific QC samples are
generally considered billable samples (sample analyses for which the laboratory will be paid its per-
sample cost). Some laboratories might offer MS/MSD analyses as value added services (at no cost),
provided MS/MSD data are not expected to exceed 1 in 20 samples. Laboratories often offer a batch QC
option that allows the laboratory to select the sample that they spike and report as MS/MSD for each
batch; however, this could require additional tracking to ensure that your samples receive sufficient
(1/20) site-specific QC samples to assess your data. This should be clear in your request and in your final
contract, as well as in the bids received.
Internal laboratory QC samples, such as method blanks and ongoing precision and recovery (OPR),
laboratory control samples (LCS) or certified standard reference materials (SRM) analyses should be
considered unbillable samples—sample analyses that are required by the method but apply to multiple
clients. Rather than charging clients for these samples directly, laboratories typically will distribute the
costs of these samples across billable samples.
If a sample is collected and sent to the laboratory but cannot be submitted because of a problem
unrelated to laboratory performance (such as shipping delays that violate the sample holding time), the
CSS might be required to repeat the entire sampling event, because all measurements should be
reported for parameters of interest on the same samples (representing the same site conditions, and
spatial and temporal distributions). It is inappropriate to recollect a single parameter for analysis during
a wet-weather event, because the final data requirement could be for multiple sites and multiple
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parameters to gain a complete understanding of conditions during the event. In such cases, all samples
should be cancelled, and another event should be scheduled to ensure a valid and representative
assessment.
D. 1.2.2 Sample Types
Two types of samples can be collected under a monitoring program—grab samples or composite
samples.
D.I.2.2.1 Grab Samples
Grab samples are samples that are collected instantaneously (as rapidly as is practicable) directly from a
discharge or from below the surface of a receiving stream directly into sample containers or into a larger
device or container for dispensing into individual sample containers. Certain parameters (microbiological
indicators, oil and grease, volatile constituents, and so on) must be collected directly into the containers
to be submitted for analysis to preserve their integrity. Other parameters can be collected
simultaneously in a large container or a sampling device and dispensed into multiple sample containers
for shipment. Table 1060:1 in Standard Methods for the Examination of Water and Wastewater.
Twentieth Edition (APHA 1998; http://www.umass.edu/tei/mwwp/acrobat/sm2320b.PDF) or later
include sample types allowable for compliance monitoring by parameter or indicator.
D.l.2.2.2 Composite Samples
Composite samples are either time-weighted or flow-weighted composites collected over a period of
time to represent total pollutant discharge over time (for constant discharge rates), or total pollutant
loading relative to flow. Composite samples are routinely collected automatically with automatic
sampling devices triggered by some change in stage or by rain gage, or by change in pressure in the
event of in-line pressure transducers.
Sample parameters not amenable to composite sampling (e.g., pathogens, oil and grease, and
orthophosphate) are generally collected as individual manual grabs distributed throughout a discharge
event. Grab sampling throughout a discharge event could include analysis of only three to four sample
aliquots representing a first flush, rise, peak, and fall of the receiving water hydrograph, or they can be
collected throughout the discharge event and analyzed to produce a pollutograph where the stream
hydrograph and stage discharge relationship can be used to determine loading associated with each
sample analyzed. Alternatively, composite sampling can be performed to proportionally sample or
proportionally combine sample aliquots in accordance with average precipitation events or through use
of the hydrograph to prepare a composite representative of the entire storm event. These sample
composites can be submitted as a single stormwater sample whose result reflects an event mean
concentration for estimating loads during a wet-weather event.
D. 1.2.3 Required Sample Volume
On the basis of the full suite of measurements required at each sampling site, your sample volume
requirements could vary. While it is not as critical at the time of solicitation what volumes will be
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collected at each sampling station, solicitation might be a good time to request sample volume
requirements from your potential providers. Laboratories generally prefer to describe which
measurement parameters can share bottles, and they could specify additional volumes to ensure that
sufficient sample volume is available for any required reanalyses. Regardless of the overall program
scope, some samples (e.g., microbiological samples) always require grab sampling and will require
separate containers. They will also dictate the shortest required holding time for laboratory analysis
with a maximum 6-hour transit time to the analytical laboratory; thus, multiple deliveries can be
anticipated in longer wet-weather events.
In addition, if your monitoring scope includes toxicity testing, the volume of sample required is greater
than that required for all other chemical and microbiological indicators parameters in a monitoring
event, and holding times for toxicity testing generally do not exceed 24 hours.
D.l.2.4 Extra Services
Will any additional services be required of the laboratory in addition to sample analyses? Possible
services include the following:
• Sampling kit pre-preserved bottleware; filters, rental or purchase of on-site filtration equipment,
if necessary
• Sample shipping containers
• Courier services (especially for microbiological samples)
• Training for sample collection personnel
Some laboratories might include these services in the sample analysis cost. Defining the specific services
your program will need, and specifying these services clearly in the contract will enable the laboratories
to better assess whether the requested services are included in the routine costs or are extra, and
respond accordingly.
Clearly specify in your contract any services required in addition to routine sample analysis.
D.I.3 Sampling Schedules
CSO monitoring is difficult to schedule because of the need to capture variable weather and flow
conditions (dry, wet-weather non-overflow, and wet-weather overflow events). However, your program
should include some initial targets for its dry- and wet-weather sampling events, if only identified by the
number of each per month, quarter, or year.
Indicate in your bid sheets and subcontract the month that you plan to begin monitoring and how
frequently you will monitor. If possible, do not specify actual sample collection dates and days during
the week, but work with the awarded laboratory to establish a schedule that meets your needs and
does not present additional potential risk to sample integrity. Wet-weather sampling is obviously much
less predictable, so planning for those events more within your control should reflect optimal
consideration of routine delivery and workday schedules.
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D.I.4 Analytical Methodologies
How describes the analytical method that the laboratory will use. All compliance monitoring must be
conducted in accordance with methods prescribed at 40 CFR Part 136 in accordance with NPDES
requirements (see Appendix E). Unless significant historical data exist and methodologies have been
preselected for a program, your solicitation should include a place for providers to indicate what
methods they routinely use in their various measurements. Because of the flexibility to use multiple
methods, laboratories select those methods most applicable to support their clients' implementation of
their respective monitoring plans. This allows multiple permittees' samples to be processed together,
reduces laboratory operating costs, and generally manifests itself in lower costs to the clients. An online
source to verify acceptance of the laboratory's proposed methods is available at:
http://ecfr.gpoaccess.gov/. (Note that the referenced site includes a disclaimer: that eCFR "is not an
official legal edition of the CFR. The e-CFR is an editorial compilation of CFR material and Federal
Register amendments produced by the National Archives and Records Administration's Office of the
Federal Register (OFR) and the Government Printing Office/')
D. 1.4.2 Container Types, Preservatives and Holding Times
Composition of sample containers for a specific laboratory measurement parameter can be an
important part of preserving sample integrity. Just as analytical methods options are presented in Tables
IA-IH of 40 CFR Part 136, container types, preservatives, and holding times are specified in Table II of
Part 136. A similar resource for container type, preservation, and holding time can be found in Table
1060:1 of Standard Methods as referenced in Section D.I.2.2.1. Container types and preservatives are
generally specific to a measurement parameter; however, they are often linked to the specific method
of measurement and the associated equipment. Some chemical preservation might not be amenable to
some sample handling equipment or measurement systems, but the physical preservation (refrigeration
to < 10 °C or < 6 °C) and the prescribed holding times are not variable. Thus, it is important to work with
your selected laboratory regarding the container types and preservatives suitable to their preferred
methods and measurement equipment.
D. 1.4.3 Quality Control Requirements
Although most methods approved at Part 136 specify the QC requirements that must be met during
performance of the method, your contract should reiterate that all QC requirements for the method
must be met at the required frequency during processing and analysis of your samples, and that method
compliance is a minimum performance standard for acceptance. As noted earlier in Section D.I.2.1, the
costs for the method blank, OPR, LCS, or SRM analyses should be distributed by the laboratory across
the cost of sample analysis and should not be considered billable. On the other hand, you can expect to
pay for unique field QC samples that are submitted with the monitoring samples (blanks and duplicates),
minimally. You might also expect some negotiation to take place regarding MS/MSD samples, if you
require that they be batch-specific. Your laboratory could indicate that if you require MS/MSD on one of
your monitoring stations with every event (regardless of the number of stations), they would be
considered billable, but if you accept batch QC of only 1 spiked sample pair per 20 field samples, they
might wave those additional costs. Different laboratories treat MS/MSD samples differently, and you
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should make sure that you communicate your requirements and request that bids clearly specify how
such QC samples are treated.
Reiterate in the contract that method blanks, ongoing precision and recovery tests, and staining controls
must be performed at the frequency required in the method and that all holding times must be met.
D.I.6 Data Deliverables and Other Contract Issues
In addition to the who, what, when, and how questions that the contract should address, you should
also provide details on data delivery, adjustments for lateness, and sample reanalysis cost issues. These
issues are discussed in Sections D.I.6.1 through D.I.6.5.
D. 1.6.1 Data Submission
The laboratory, at a minimum, should submit the results for each monitoring sample to you
electronically and in hard copy form to ensure that there have been no transcription errors in transfer of
data to final reporting formats, or for use in future analysis by the CSS.
Clearly indicate in your contract that the laboratory is required to submit data electronically and in hard
copy. Specify that all laboratory data must be recorded on in laboratory logs and appropriate laboratory
bench sheets and that all associated QC data and that an authorized data release be signed and
submitted for separate, independent verification.
D. 1.6.2 Hard Copy Data Deliverables
To demonstrate some due diligence and to ensure sufficient information to verify the analytical data
provided electronically, your data deliverables should include results for all your monitoring (field)
samples, field QC samples, and method QC samples. It is also helpful to request a statement of
verification and validity and a data release signed by the laboratory QA manager or their designee
indicating that the data have been reviewed and verified as being compliant with the requirements of
the method and or any project QA guidance or QAPP.
Note: If you do not intend to review all the raw data generated by the laboratory, this section is not
relevant and can be ignored.
If your project team intends to review all the raw data associated with your monitoring program
samples, you should request copies of the forms used by the laboratory to record sample
measurements, sample processing times, and sample examination results in addition to the information
on the QC samples associated with your monitoring sample. (Original data forms should stay at the
laboratory; copies can be submitted for further review by the project team. If bench sheets and raw
data, and such, are requested on a batch basis or more frequently monthly basis, the CSS could expect
additional charges from the laboratory). If your contract seeks to collect fully validatable data request
the following:
• Monitoring sample identification information.
• Monitoring sample results, by parameter, in appropriate units defined in the contract, including
quantitation and method detection limits.
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Laboratory quality control batch associated with the samples.
ID number and result for the blanks, OPRs, LCSs, or SRMs analyzed for the batch.
Preparation logs or bench sheets for all samples processed in the batch.
Data system printouts or forms of calibration data, sample analyses, and results including
appropriate evaluations of curve linearity and daily calibration verification, sample
concentrations, QC results, and acceptance criteria.
Laboratory comments describing any noteworthy observations made during analysis including
description of any departures from standard procedures or method protocols, the rationale for
those departures, and their overall effect on data quality or usability. If the laboratory provided
comments on the sample analyses or results that require follow-up, contact the laboratory to
discuss, if necessary. Comments could include any applicable data qualifiers. The following is a
list of potential data qualification descriptions:
- The recovery for the associated OPR sample did not meet method requirements (could
indicate a measurement bias)
- Analyte detected in the method or field blank
- Positive and negative staining controls were not acceptable or not examined
- Method holding times were not met.
- Sample arrived at the laboratory in unacceptable condition
If you want the laboratory to submit full raw data with your hard copy results (this should not be
requested unless you intend to validate all the raw data), clearly indicate in your contract the materials
that are required. You can also choose to request a hard copy of only the sample and QC summary
results (often referred to as a level 2 package).
D.l.6.3 Data Turnaround Requirements
In your contract, make sure that expectations for data delivery are clear. If your permit or other program
requirements dictate specific data reporting or filing deadlines (perhaps during refinement of control
measures), use those requirements to back-calculate how long will be needed to verify laboratory
results, and, in turn when the laboratory should complete analyses and transmit results. The turnaround
requirement for the laboratory should be short enough to provide the CSS project team time to review
the data and request any necessary clarification before required submittal deadlines to the NPDES
authority. The required data turnaround should be stated clearly in the contract. This turnaround time
should be expressed in calendar days (not working days), and should start from the sample collection
date. The data turnaround time calculations should consider the day that the sample is delivered day
zero, and the following day as day one. (Data turnaround times in analytical contracts typically start
from the receipt of the sample at the laboratory, but the laboratory must calculate analytical holding
times from sample collection time.)
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As a general rule, the data turnaround time should be less than 15 days. Using the 15 days allows for
most sample analyses by the appropriate methods within their holding times (plus additional time to
compile the data package and mail the results, if hard copies are required) as the shortest realistic
turnaround time, determine when you will actually need the results. It might be advisable to request
acceleration premiums (generally expressed as a percentage surcharge for a batch) in case some
samples require expedited delivery to evaluate a specific control measure; are part of a corrective action
investigation; or were collected to investigate an unusual or unexpected discharge event. Collection of
accelerator premiums allows you to include those options in your contract without modification should
those services be necessary. In most cases, the same turnaround time can be specified for both
submission of electronic data and receipt of hard copy materials.
D. 1.6.4 Liquidated Damages and Penalties
You should consider including penalty or damage clauses in your contract as incentives to preclude
laboratories from submitting data late or performing analyses improperly. Because of the nature of the
services provided, assessing actual damages caused by improperly performed analyses is often difficult.
Liquidated damages often are used in analytical services contracts in lieu of actual damages. Liquidated
damages typically specify that, if the laboratory fails to deliver the data specified in the deliverables
section of the contract or fails to perform the services within the specified data turnaround time, the
laboratory will pay a fixed, negotiated price to compensate the organization to whom the services
should have been delivered. For example, some EPA contracts for analytical services specify that the
laboratory will pay, as fixed, agreed, and liquidated damages, 2 percent of the analysis price per
calendar day of delay, to a maximum reduction of 50 percent of the analysis price.
If liquidated damages or penalties are involved, they should
(1) be based in terms of cost by each late day or in increments,
(2) be strong enough to discourage late delivery, and
(3) be reasonable enough that they will not discourage laboratories from bidding.
The contract should specify that the laboratory will not be charged with liquidated damages when the
delay in delivery or performance arises out of causes beyond the control and without the fault or
negligence of the laboratory. It also might be necessary to limit damages to a certain dollar value or
scope.
Other types of damages that should be considered and can be included in the contract include costs for
resampling and administrative costs associated with the evaluation and processing of unacceptable data
(data that do not meet the requirements specified in the contract or the QC requirements specified in
the analytical method).
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Clearly indicate in your contract whether liquidated damages will be applied to late data or other
problems, how these liquidated damages are calculated, and the limits and conditions associated with
the damages. However, instituting penalties over a laboratory for late delivery remains at your
discretion, and communication should be a consideration in the use of liquidated damages for late
data. It is more important that you are able to plan for and project delivery of late data than to levy
fines against a valued service provider. Also keep in mind that a portion of CSO monitoring includes
wet-weather events, and working closely and cooperatively with the selected laboratory is key to
successful data collection. There will be times beyond anyone's control that the program requires
expedited laboratory support (from delivery of sampling kits to capture a storm event to additional
staffing to initiate time-critical analysis) to ensure success.
D.l.6.5 Reanalysis Costs
Every laboratory periodically produces data that are associated with unacceptable QC data or are invalid
for other reasons. The contract should stipulate that the laboratory will reanalyze samples at no cost if
the problems are due to laboratory error. If the problems are due to an error outside of the laboratory's
control (such as the laboratory's rejection of samples received at > 20°C that results in resampling), the
laboratory should contact sampling personnel for direction before incurring costs, and they should not
be responsible for the additional costs that could result.
Clearly indicate in your contract when the laboratory would be required to bear the costs of sample
reanalysis and when these costs will be covered under the contract.
The contract also should state that you have the right to inspect the results, and if they do not meet the
requirements in the contract, you have the right to reject the data, returning them to the laboratory
without payment. Rejection of data should be based on sound technical review of the results. It also
obligates you to make no use of those results without making some payment to the laboratory.
D.2 Developing a Bid Sheet
After all project requirements have been established, you should develop a bid sheet to accompany the
analytical requirements summary during the solicitation. The bid sheet allows laboratories to submit
bids in the same format, making bid evaluations easier, and helps to clarify the project. Development
and use of a bid sheet is recommended regardless of whether you solicit the project competitively to
multiple laboratories, or is simply requesting a quote from a laboratory you already know you will be
using, because it provides a very clear vehicle for submitting and evaluating costs.
Clearly indicate in your contract that you have the right to inspect results and reject the results if they
do not meet contract requirements.
The bid sheet format should include the following information in a formatted header:
• Project identifier (e.g. "CSO Compliance Monitoring Sample Analyses for [CSS name or facility
name and permit number]").
• Space for laboratory identification and contact information (for when they submit the bid).
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• Day, date, and time (including time zone) of the bid deadline.
• Procurement contact information (contact and mailing address, fax number, phone number, and
email address).
• Estimated award date.
• Laboratory period of performance (includes the period of time during which the laboratory is
obliged to resolve issues associated with analysis of the samples—generally 6 months after
shipment of the last sample).
• Data turnaround times and surcharges (time from sample receipt to reporting results) 15 day
(standard); surcharge (%) for 10 day; surcharge (%) for 5 day; surcharge (%) for 3 day.
• Bid validity period (period of time during which bid prices are considered valid—generally 45
days after the bid deadline; if the project is awarded after the period you specify, you must
contact bidding laboratories to determine whether their bid is still valid, or needs to be revised).
Actual bid sheets for analytical services typically are formatted as a table, with descriptions of services
and supplies identified in a single column down one side to define a row header; a column for requested
or planned number of units; a column for required (WQS) or requested quantitation limits (where no
apparent standards exist); and blank columns for laboratory input and responses.
Laboratory input should be requested for the following:
• Preferred methods (e.g., E. coli by Standard Methods 9223B or 755 by SM 2540D)
• Laboratory quantitation limits (next to the target limit for easy evaluation)
• Laboratory method detection limits (MDLs, as defined and required under 40 CFR Part 136
Appendix B), if applicable;
• Laboratory-defined acceptance criteria (for OPR, LCS, etc.);
• Unit rates
• Extended costs
The following are two examples of a bid sheet for nine stations with 25 dry-weather and 25 wet-weather
events with field QC at the prescribed frequency:
Parameter
Stations
Events
Field Dups
(1/20)
Blanks 1/20 or
one per event
TSS
Sample kits
#
9
50
23
50
523
50
Laboratory
method
SM 2540D
NA
Requested
limit (WQS)
20
NA
Lab
quant
limit
5
NA
MDL
2
NA
Acceptance
90-110
NA
Unit
rate
Incl. in
total
Incl. in
total
20
N/C
Extended
cost
10,460.00
0.00
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The above table assumes standard turnaround time of 15 calendar days, all method-required quality
control data, and a type 2 report.
Parameter
TSS
Sample kits
Other
(describe)
MS/MSD 1 set
per 20
Totals
#
523
50
46
Laboratory
method
SM 2540D
NA
SM 2540D
Requested
limit (WQS)
20
NA
20
Lab
quant
limit
5
NA
5
MDL
2
NA
2
Acceptance
90-110
NA
90-110
Unit
rate
20
N/C
20
Extended
cost
10,460.00
0.00
920.00
11,380.00
The above table includes analysis of samples collected from nine sampling station in 50 individual
sampling events with 5 percent field duplicates (1 sample per 20 field samples; or 23 field duplicates),
and project-specific MS and MSD (or MS and laboratory DUP, depending on method requirements) will
be required at the same frequency as the field duplicates, while there will be an additional requirement
for one field blank per 20 samples or one per event, whichever is more frequent (50).
D.3 Soliciting the Contract
Procedures for soliciting and awarding contracts to perform analytical services can vary, depending on
the scope of the project and purchasing requirements within the organization that is issuing the
contract. At one end of the spectrum are contracts that are awarded after placing a single phone call
and obtaining a quote from a single laboratory. The opposite end of the spectrum are contracts awarded
after a competitive solicitation and bidding process involving the distribution of a detailed project
description and a formal bid sheet via fax or mail.
D.3.1 Approved Laboratories
Regardless of whether you will be soliciting the project to multiple laboratories or working with a single
laboratory (although a backup laboratory is strongly recommended—see below), you must limit your
laboratories to only those participating in the EPA Discharge Monitoring Report QA (DMR-QA) program
for chemical analysis. National accreditation is offered through the National Environmental Laboratory
Accreditation Program (NELAP) for most chemical analysis, but a local provider might not be interested
in servicing clients from outside the state; therefore, they might not pursue the broad accreditation.
However, you can find a list of NELAP-accredited labs at http://www.nelac-institute.org/accred-
labs.php, which can be sorted by state for ease in finding a local laboratory. NELAP-accredited labs will
have indication that they are approved for NP (nonpotable) water programs. To complete a good first
screen of laboratories, you should check with your state water or environmental agency's laboratory
certification specialist or list of approved laboratories on the Web. Both sources should include a phone
number at minimum if not a contact name and number for initial inquiry. You will want to inquire as to
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the laboratory's participation in DMR-QA and its ability to conduct microbiological analysis, because
E. coli and enterococcus are likely to be a large part of your CSO monitoring program.
For WET testing, many states do not have accreditation or certification for WET laboratories. In such
states, it is advisable to inquire about the WET laboratory's experience with the types of tests needed,
their quality management program, and historic quality control data (e.g., reference toxicant test quality
control charts) for the types of tests required. In addition, because WET testing is relatively labor
intensive compared to chemical or microbiological analyses, it is wise to inquire about personnel
training and experience performing the types of WET tests required. A review of the laboratory's
personnel, equipment, and quality control can also help indicate the number of WET tests the
laboratory can perform simultaneously while meeting the required project quality criteria. For more
information about contracting WET laboratories, see EPA's WET test method manuals (e.g., Methods for
Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms,
5th ed (USEPA 2002; http://www.epa.gov/waterscience/methods/wet/disk2/atx.pdf).
Microbiological laboratories might be approved through a local department of health, depending on the
breadth of their offerings. Regardless, at the time of your initial discussion request a copy of certification
or accreditation letters as part of your prequalification for the solicitation. EPA offers approval for
microbiological assessment of drinking waters, which is at
http://www.epa.gov/safewater/disinfection/lt2/lab home.html. While drinking water certification is
not required for CSO compliance monitoring, approved laboratories might also offer services to CSOs
and other NPDES permittees as part of their routine business practice.
D.3.2 Primary and Backup Laboratory Contracts
Because a laboratory's approval status could change during the monitoring period, you should consider
awarding a primary contract and a backup contract. If no performance problems or other problems are
encountered during the monitoring period by the laboratory awarded the primary contract, that
laboratory would provide uninterrupted sample analysis support for the entire monitoring period.
However, if the laboratory encountered performance problems, was disapproved, or was otherwise
unable to meet contract requirements, your CSS could switch sample analyses to the backup laboratory
under the contract you established with the laboratory before monitoring began. You can discuss the
award of primary and backup contracts with the laboratories in the contract solicitation.
D.4 Evaluating Bids
After the laboratories have received the solicitation and submitted their bids, you should evaluate the
bids to identify the laboratory that will be awarded the analytical services contract. Specific procedures
for evaluating bids can vary, depending on the requirements of your organization, but the bid evaluation
process generally entails evaluation and comparison of each laboratory's proposed cost and capability to
meet the analysis requirements.
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D.4.1 Identifying Responsive Bidders
You should consult your legal or purchasing departments to identify any applicable requirements for
evaluating competitive bids. Review all bids and recalculate subtotals and totals to ensure that the
bidding laboratories did not make any mathematical errors. In addition, you might want to verify that
there are no unacceptable contingencies associated with any of the bids. Either eliminate from
consideration bids from laboratories that bid with contingencies or contact the laboratory(ies) to discuss
the bid and verify that the laboratory cannot perform the specified services.
Of the remaining (responsive) bids, identify the lowest bidder (or the laboratory that best meets your
requirements) to award the primary contract and a second bidder to award the backup contract. If
additional assessments of a laboratory's performance or responsibility are needed, you might want to
contact references.
D.4.2 References
If you have not worked with a particular laboratory before and would like to verify that it will meet your
needs throughout the monitoring period, you can ask the laboratory to provide contacts and phone
numbers of utility or government clients for whom the laboratory has performed services.
• Did the laboratory provide data by the required due date?
• Were the data provided by the laboratory of acceptable quality and compliant with contract
requirements and in an easy to understand format?
• Were laboratory personnel easy to work with when problems arose during all phases of the
project, including sample scheduling, sample analysis, and data review? If problems were noted
during data review, was the laboratory prompt and responsive in addressing your concerns?
• Do you have any reservations in recommending this laboratory?
D.5 Communicating with the Laboratory
After the analytical services contract is awarded, request laboratory contact information for the
following roles, and provide the laboratory with CSS contacts for the same roles:
• A technical contact for analytical questions or problems
• A sample control contact for shipping delays on the sampling end and sample receipt problems
on the laboratory end
• An administrative contact for invoicing and payment
Maintaining communications with the laboratory is critical to identifying and resolving problems quickly
and minimizing the need for resampling and reshipments. At a minimum, notify the laboratory of
sample shipments the day you ship and confirm that the laboratory received the sample on time and in
acceptable condition. You can alternatively request that the laboratory send a copy of the executed
chain-of-custody form via fax to confirm sample receipt. You can also consider contacting the laboratory
each week before you sample to verify that they know to expect samples.
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Although most communications are typically conducted over the phone, these communications also can
be conducted via e-mail, which has the added benefit of providing you and the laboratory with a written
record of sample receipt confirmations, problem notifications, and problem resolutions.
References Appendix D.
APHA. 1998. Standard Methods for the Examination of Water and Wastewater. 20th ed. American Public
Health Association, Washington, DC.
USEPA (U.S. Environmental Protection Agency). 2002. Methods for Measuring the Acute Toxicity of
Effluents and Receiving Waters to Freshwater and Marine Organisms. 5th ed.
U.S. Environmental Protection Agency, Washington, DC.
.
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Appendix E. 40 CFR - SUBCHAPTER D - Part 136
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SUBCHAPTER D—WATER PROGRAMS (CONTINUED)
PART 136—GUIDELINES ESTAB-
LISHING TEST PROCEDURES FOR
THE ANALYSIS OF POLLUTANTS
Sec.
136.1 Applicability.
136.2 Definitions.
136.3 Identification of test procedures.
136.4 Application for alternate test proce-
dures.
136.5 Approval of alternate test procedures.
136.6 Method modifications and analytical
requirements.
APPENDIX A TO PART 136—METHODS FOR OR-
GANIC CHEMICAL ANALYSIS OF MUNICIPAL
AND INDUSTRIAL WASTEWATER
APPENDIX B TO PART 136—DEFINITION AND
PROCEDURE FOR THE DETERMINATION OF
THE METHOD DETECTION LIMIT—REVISION
1.11
APPENDIX C TO PART 136—INDUCTIVELY COU-
PLED PLASMA—ATOMIC EMISSION SPEC-
TROMETRIC METHOD FOR TRACE ELEMENT
ANALYSIS OF WATER AND WASTES METHOD
200.7
APPENDIX D TO PART 136—PRECISION AND RE-
COVERY STATEMENTS FOR METHODS FOR
MEASURING METALS
AUTHORITY: Sees. 301, 304(h), 307 and 501(a),
Pub. L. 95-217, 91 Stat. 1566, et seg. (33 U.S.C.
1251, et seg.) (the Federal Water Pollution
Control Act Amendments of 1972 as amended
by the Clean Water Act of 1977).
§ 136.1 Applicability.
(a) The procedures prescribed herein
shall, except as noted in §136.5, be used
to perform the measurements indicated
whenever the waste constituent speci-
fied is required to be measured for:
(1) An application submitted to the
Administrator, or to a State having an
approved NPDES program for a permit
under section 402 of the Clean Water
Act of 1977, as amended (CWA), and/or
to reports required to be submitted
under NPDES permits or other re-
quests for quantitative or qualitative
effluent data under parts 122 to 125 of
title 40, and,
(2) Reports required to be submitted
by dischargers under the NPDES estab-
lished by parts 124 and 125 of this chap-
ter, and,
(3) Certifications issued by States
pursuant to section 401 of the CWA, as
amended.
(b) The procedure prescribed herein
and in part 503 of title 40 shall be used
to perform the measurements required
for an application submitted to the Ad-
ministrator or to a State for a sewage
sludge permit under section 405(f) of
the Clean Water Act and for record-
keeping and reporting requirements
under part 503 of title 40.
[72 PR 14224, Mar. 26, 2007]
§ 136.2 Definitions.
As used in this part, the term:
(a) Act means the Clean Water Act of
1977, Pub. L. 95-217, 91 Stat. 1566, et seg.
(33 U.S.C. 1251 et seg.) (The Federal
Water Pollution Control Act Amend-
ments of 1972 as amended by the Clean
Water Act of 1977).
(b) Administrator means the Adminis-
trator of the U.S. Environmental Pro-
tection Agency.
(c) Regional Administrator means one
of the EPA Regional Administrators.
(d) Director means the Director of the
State Agency authorized to carry out
an approved National Pollutant Dis-
charge Elimination System Program
under section 402 of the Act.
(e) National Pollutant Discharge Elimi-
nation System (NPDES) means the na-
tional system for the issuance of per-
mits under section 402 of the Act and
includes any State or interstate pro-
gram which has been approved by the
Administrator, in whole or in part,
pursuant to section 402 of the Act.
(f) Detection limit means the minimum
concentration of an analyte (sub-
stance) that can be measured and re-
ported with a 99% confidence that the
analyte concentration is greater than
zero as determined by the procedure
set forth at appendix B of this part.
[38 PR 28758, Oct. 16, 1973, as amended at 49
PR 43250, Oct. 26, 1984]
§ 136.3 Identification of test proce-
dures.
(a) Parameters or pollutants, for
which methods are approved, are listed
together with test procedure descrip-
tions and references in Tables IA, IB,
1C, ID, IE, IF, IG, and IH. In the event
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§136.3
of a conflict between the reporting re-
quirements of 40 CFR Parts 122 and 125
and any reporting requirements associ-
ated with the methods listed in these
tables, the provisions of 40 CFR Parts
122 and 125 are controlling and will de-
termine a permittee's reporting re-
quirements. The full text of the ref-
erenced test procedures are incor-
porated by reference into Tables IA, IB,
1C, ID, IE, IF, IG, and IH. The incorpo-
ration by reference of these documents,
as specified in paragraph (b) of this sec-
tion, was approved by the Director of
the Federal Register in accordance
with 5 U.S.C. 552(a) and 1 CFR part 51.
Copies of the documents may be ob-
tained from the sources listed in para-
graph (b) of this section. Documents
may be inspected at EPA's Water
Docket, EPA West, 1301 Constitution
Avenue, NW., Room B102, Washington,
DC (Telephone: 202-566-2426); or at the
National Archives and Records Admin-
40 CFR Ch. I (7-1-10 Edition)
istration (NARA). For information on
the availability of this material at
NARA, call 202-741-6030, or go to: http://
www.archives.gov/federal register/
code of_federal regulations/
ibr locations.html. These test proce-
dures are incorporated as they exist on
the day of approval and a notice of any
change in these test procedures will be
published in the FEDERAL REGISTER.
The discharge parameter values for
which reports are required must be de-
termined by one of the standard ana-
lytical test procedures incorporated by
reference and described in Tables IA,
IB, 1C, ID, IE, IF, IG, and IH or by any
alternate test procedure which has
been approved by the Administrator
under the provisions of paragraph (d) of
this section and §§136.4 and 136.5. Under
certain circumstances paragraph (c) of
this section, §136.5(a) through (d) or 40
CFR 401.13, other additional or alter-
nate test procedures may be used.
124
April 2011
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TABLE IA—LIST OF APPROVED BIOLOGICAL METHODS FOR WASTEWATER AND SEWAGE SLUDGE
Parameter and units
Bacteria:
1. Coliform (fecal), num-
weight.
2. Coliform (fecal) in
presence of chlorine,
number per 100 mL.
3. Coliform (total), num-
ber per 100 mL.
4. Coliform (total), in
presence of chlorine,
number per 100 mL.
100 mL20.
6. Fecal streptococci,
number per 100 mL.
per 100 mL20.
per gram dry weight12.
Aquatic Toxicity:
9. Toxicity, acute, fresh
water organisms,
LCso, percent effluent.
Method 1
Most Probable Number (MPN),5
step.
MPN, 5 tube, 3 dilution, or
MF2, single step
MPN, 5 tube, 3 dilution, or
MPN, 5 tube, 3 dilution, or
MPN 7.8.15 multiple tube/multiple
well.
MF2A 7,8,9 single step
MPN, 5 tube 3 dilution
MF2 or
Plate count
MPN7-9 multiple tube/multiple
well.
MF2-6- 7,8,9 single step
MPN multiple tube
Ceriodaphnia dubia acute
Daphnia pup/ex and Daphnia
magna acute.
Fathead Minnow, Pimephales
promelas, and Bannerfin
shiner, Cyprinella feeds/,
acute.
Rainbow Trout, Oncorhynchus
mykiss, and brook trout,
Salvelinus fontinalis, acute.
EPA
p. 1323
168012-14
1681 12-19
p 1243
p. 1323
p. 1243
p. 1143
p 1083
p. 1143
p 111 3
1 603 21
p. 1393
p 1363
p. 1433
160024
1 682 22
2002.0 25.
2021. 02=.
2000.0 25.
201 9.0 25.
Standard methods
18th, 19th, 20th ed.
9221 C E
9222 D
9221 C E
9222 D
9221 B
9222 B
9221 B
9222 (B+B 5c)
9223 B13
9230 B
9230 C
Standard methods on-
line
9221 C E-99.
9222 D-97
9221 C E-99.
9222 D-97.
9221 B-99.
9222 B-97
9221 B-99.
9222 (B+B5c)-97
9223 B-9713
9230 B-93.
9230 C-93
AOAC, ASTM,
USGS
B-0050-85 5
B-0025-8 5
991 15"
B-0055-85 5
D6503-9910
Other
Colilert*13'17
ColNerHS*13-16-17
mColiBlue-24*18
Enterolert*13-23
(D
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6
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TABLE IA—LIST OF APPROVED BIOLOGICAL METHODS FOR WASTEWATER AND SEWAGE SLUDGE—Continued
un
Parameter and units
10. Toxicity, acute, estu-
arine and marine orga-
nisms of the Atlantic
Ocean and Gulf of
Mexico, LCso, percent
effluent.
11. Toxicity, chronic,
fresh water organisms,
NOEC or IC2s, percent
effluent.
12. Toxicity, chronic, es-
tuarine and marine or-
ganisms of the Atlantic
Ocean and Gulf of
Mexico, NOEC or IC2s,
percent effluent.
Method 1
Mysid, Mysidopsis bahia, acute
Sheepshead Minnow,
Cyprinodon variegatus, acute.
Silverside, Menidia beryllina,
Menidia menidia, and
Menidia peninsulas, acute.
Fathead minnow, Pimephales
promelas, larval survival and
growth.
Fathead minnow, Pimephales
promelas, embryo-larval sur-
vival and teratogenicity.
Daphnia, Ceriodaphnia dubia,
survival and reproduction.
G reen alga, Selenastrum
capricornutum, growth.
Sheepshead minnow,
Cyprinodon variegatus, larval
survival and growth.
Sheepshed minnow,
Cyprinodon variegatus, em-
bryo-larval survival and
teratogenicity.
Inland silverside, Menidia
beryllina, larval survival and
growth.
Mysid, Mysidopsis bahia, sur-
vival, growth, and fecundity.
Sea urchin, Arbacia punctulata,
fertilization.
EPA
2007.0 25.
2004.0 25.
2006.0 25.
1 000.0 26.
1001.026.
1 002.0 26.
1 003.0 26.
1 004.0 27.
1 005.0 27.
1 006.0 27.
1 007.0 27.
1 008.0 27.
Standard methods
18th, 19th, 20th ed.
Standard methods on-
line
AOAC, ASTM,
USGS
Other
o
-n
X3
O
o
m
Q.
o
1 The method must be specified when results are reported.
2 A 0.45 ^im membrane filter (MF) or other pore size certified by the manufacturer to fully retain organisms to be cultivated and to be free of extractables which could interfere with their
growth.
3USEPA. 1978. Microbiological Methods for Monitoring the Environment, Water, and Wastes. Environmental Monitoring and Support Laboratory, U.S. Environmental Protection Agency,
Cincinnati, OH, EPA/600/8-78/017.
4 [Reserved]
NJ
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5USGS. 1989. U.S. Geological Survey Techniques of Water-Resource Investigations, Book 5, Laboratory Analysis, Chapter A4, Methods for Collection and Analysis of Aquatic Biological
and Microbiological Samples, U.S. Geological Survey, U.S. Department of the Interior, Reston, VA.
6 Because the MF technique usually yields low and variable recovery from chlorinated wastewaters, the Most Probable Number method will be required to resolve any controversies.
7Tests must be conducted to provide organism enumeration (density). Select the appropriate configuration of tubes/filtrations and dilutions/volumes to account for the quality, character,
consistency, and anticipated organism density of the water sample.
8When the MF method has been used previously to test waters with high turbidity, large numbers of noncoliform bacteria, or samples that may contain organisms stressed by chlorine, a
parallel test should be conducted with a multiple-tube technique to demonstrate applicability and comparability of results.
9To assess the comparability of results obtained with individual methods, it is suggested that side-by-side tests be conducted across seasons of the year with the water samples routinely
tested in accordance with the most current Standard Methods for the Examination of Water and Wastewater or EPA alternate test procedure (ATP) guidelines.
10ASTM. 2000, 1999, 1996. Annual Book of ASTM Standards—Water and Environmental Technology. Section 11.02. ASTM International. 100 Barr Harbor Drive, West Conshohocken,
PA 19428.
11 AOAC. 1995. Official Methods of Analysis of AOAC International, 16th Edition, Volume I, Chapter 17. Association of Official Analytical Chemists International. 481 North Frederick Ave-
nue, Suite 500, Gaithersburg, MD 20877-2417.
12 Recommended for enumeration of target organism in sewage sludge.
13These tests are collectively known as defined enzyme substrate tests, where, for example, a substrate is used to detect the enzyme ^-glucuronidase produced by E. coli.
14 USEPA. July 2006. Method 1680: Fecal Coliforms in Sewage Sludge (Biosolids) by Multiple-Tube Fermentation Using Lauryl-Tryptose Broth (LTB) and EC Medium. US Environmental
Protection Agency, Office of Water, Washington, DC EPA-821-R-06-012.
15Samples shall be enumerated by the multiple-tube or multiple-well procedure. Using multiple-tube procedures, employ an appropriate tube and dilution configuration of the sample as
needed and report the Most Probable Number (MPN). Samples tested with Colilert® may be enumerated with the multiple-well procedures, Quanti-Tray® Quanti-Tray® 2000, and the MPN
calculated from the table provided by the manufacturer.
16Colilert-18® is an optimized formulation of the Colilert® for the determination of total coliforms and E. co//that provides results within 18 h of incubation at 35 °C rather than the 24 h re-
quired for the Colilert® test and is recommended for marine water samples.
17 Descriptions of the Colilert®, Colilert-18®, Quanti-Tray®, and Quanti-Tray®/2000 may be obtained from IDEXX Laboratories, Inc., 1 IDEXX Drive, Westbrook, ME 04092.
18 A description of the mColiBlue24® test, Total Coliforms and £ coli, is available from Hach Company, 100 Dayton Ave., Ames, IA 50010.
19USEPA. July 2006. Method 1681: Fecal Coliforms in Sewage Sludge (Biosolids) by Multiple-Tube Fermentation using A-1 Medium. U.S. Environmental Protection Agency, Office of
Water, Washington, DC EPA-821-R-06-013.
20 Recommended for enumeration of target organism in wastewater effluent.
21 USEPA. July 2006. Method 1603: Escherichia coli (E. coli) in Water by Membrane Filtration Using Modified membrane-Thermotolerant Escherichia coli Agar (modified mTEC). U.S. En-
vironmental Protection Agency, Office of Water, Washington, DC EPA-821-R-06-011.
22USEPA. July 2006. Method 1682: Salmonella in Sewage Sludge (Biosolids) by Modified Semisolid Rappaport-Vassiliadis (MSRV) Medium. U.S. Environmental Protection Agency, Office
of Water, Washington, DC EPA-821-R-06-014.
23 A description of the Enterolert® test may be obtained from IDEXX Laboratories, Inc., 1 IDEXX Drive, Westbrook, ME 04092.
24USEPA. July 2006. Method 1600: Enterococci in Water by Membrane Filtration Using membrane-Enterococcus lndoxyl-|}-D-Glucoside Agar (mEI). U.S. Environmental Protection Agen-
cy, Office of Water, Washington, DC EPA-821-R-06-009.
25 USEPA. October 2002. Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms. Fifth Edition. U.S. Environmental Protection
Agency, Office of Water, Washington, DC EPA/821/R-02/012.
26 USEPA. October 2002. Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms. Fourth Edition, U.S. Environmental Protec-
tion Agency, Office of Water, Washington, DC EPA/821/R-02/013.
27 USEPA. October 2002. Short-term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organisms. Third Edition. U.S. Environmental
Protection Agency, Office of Water, Washington, DC EPA/821/R-02/014.
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES
Parameter
1 Acidity as CaCO3 mg/
L.
Methodology58
Electrometric end-
point or phenol-
phthalein endpoint.
EPA35,52
Standard meth-
ods
(18th, 19th)
2310 B(4a)
Reference (metho
Standard meth-
ods
(20th)
2310 B(4a)
d number or page)
Standard meth-
ods
online
2310 B(4a)-97
ASTM
D1 067-92 02
USGS/AOAC/
other
1-1 020-85 2
3
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NJ
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NJ
oo
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
Parameter
2. Alkalinity, as CaCO3,
mg/L.
3. Aluminum — Total,4 mg/
L.
4. Ammonia (as N), mg/L
Methodology58
Electrometric or Col-
orimetric titration
to pH 4.5, manual,
or
automatic
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
STGFAA
ICP/AES36
ICP/MS
Direct Current Plas-
ma (DCP) 36.
Colori metric
(Eriochrome
cyanine R).
Manual, distillation
(at pH 9.5) 6 fol-
lowed by:
Nesslerization
Titration
Electrode
Reference (method number or page)
EPA35,52
310 2 (Rev
1974)1.
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200 8 Rev 5 4
(1994).
350.1, Rev. 2.0
(1993).
Standard meth-
ods
(18th, 19th)
2320 B
3111 D
3113 B
3120 B
3500-AI D
4500-NH B3 ....
4500-NH3 C
(18th only).
4500-NH3 C
(19th) and
4500-NH3 E
(18th).
4500-NH3 D or
E (19th) and
4500-NH3 F
orG (18th).
Standard meth-
ods
(20th)
2320 B
3120 B
3500-AI B
4500-NH3 B ....
4500-NH3C ....
4500-NH3 D or
E.
Standard meth-
ods
online
2320 B-97
3111 D-99
3113 B-99.
3120 B-99
3500-AI B-01 .
4500-NH3 B-97
4500-NH3 C-97.
4500-NH3 D or
E-97.
ASTM
D1 067-92, 02
D56 73-03
04190-94,99
D1426-98, 03
(A).
D1426-98, 03
(B).
USGS/AOAC/
other
973.4S3, I-
1030-85 2
I-2030-852
1-3051-85 2
1-4471-9750
993. 143
See footnote 34
973.493
97S.493, I-
3520-85 2
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
5. Antimony—Total,4 mg/
L.
6. Arsenic—Total, 4 mg/L
7. Barium—Total,4 mg/L ..
8. Beryllium—Total,4 mg/L
Automated phenate,
or.
Automated electrode
Ion Chromatography
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
STGFAA
ICP/AES36
ICP/MS
Digestion 4 followed
by.
AA gaseous hydride
AA furnace
STGFAA
ICP/AES 36
ICP/MS
Colorimetric (SDDC)
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
ICP/AES36
ICP/MS
DCP36
Digestion 4 followed
by:
350.1 60, Rev.
2.0 (1993).
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200 8 Rev 5 4
(1994).
206.5 (Issued
1978)1.
200 9 Rev 2 2
(1994).
200 7 Rev 4 4
(1994).
200.8, Rev. 5.4
(1994).
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
4500-NH3 G
(19th) and
4500-NH3 H
(18th).
3111 B
3113 B
3120 B
3114 B 4.d
3113 B
3120 B
3500-As C
3111 D
3113 B
3120 B
4500-NH3 G ...
3120 B
3120 B
3500-As B
3120 B
4500-NH3 G-97
3111 B-99.
3113 B-99.
3120 B-99.
3114 B 4.d-97 ...
3113 B-99
3120 B-99
3500-As B-97 ...
3111 D-99
3113 B-99
3120 B-99.
D69 19-03
D56 73-03
D2972-97, 03
(B).
D2972-97, 03
(C).
D5673-03
D2972-97, 03
(A).
D4382-95, 02.
D5673-03
I-4523-852
See footnote 7
993.143
I-3062-852
I-4063-9849
993.143
I-3060-85
I-3084-852
993.143
See footnote 34
(D
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(D
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(JO
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TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
Parameter
9. Biochemical oxygen de-
mand (BOD6), mg/L.
10. Boron— Total,37 mg/L
1 1 Bromide mg/L
12. Cadmium — Total,4 mg/
L.
Methodology58
AA direct aspiration
AA furnace
STGFAA
ICP/AES
ICP/MS
DCP, or
Colori metric
(aluminon).
Dissolved Oxygen
Depletion.
Colorimetric (cur-
cumin).
ICP/AES or
DCP
Titrimetric
Ion Chromatography
CIE/UV
Digestion 4 followed
by:
AA direct aspira-
tion36.
Reference (method number or page)
EPA35,52
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
200.7, Rev. 4.4
(1994).
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
Standard meth-
ods
(18th, 19th)
3111 D
3113 B
3120 B
3500-Be D.
5210 B
4500-B B
3120 B
4110 B
3111 B orC ....
Standard meth-
ods
(20th)
3120 B
5210 B
4500-B B
3120 B
4110 B
Standard meth-
ods
online
3111 D-99
3113 B-99
3120 B-99
5210 B-01
4500-B B-00
3120 B99
4110 B-00
3111 BorC-99
ASTM
D3645-93 (88),
03 (A).
D3645-93 (88),
03 (B).
D5673-03
04190-94,99
04190-94,99
D1246-95, 99
(C).
04327-97, 03
D3557-95, 02
(A or B).
USGS/AOAC/
other
I-3095-852
|_4471_9750
993. 143
See footnote 34
97S.44,3 p.
17.9, 1-1578-
78s
1-3112-852
|_4471_9750
See footnote 34
p. S44.10
1-1 125-85 2
993. 30 3
06508, Rev.
254
974.27,3 p.
37. 9, 1-3135-
85 2 or I-
31 36-85 2
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
13. Calcium—Total,4 mg/L
CO
14. Carbonaceous bio-
chemical oxygen de-
mand (CBOD6), mg/L12.
15. Chemical oxygen de-
mand (COD), mg/L.
16. Chloride, mg/L .
AA furnace
STGFAA
ICP/AES36
ICP/MS
DCP36
Voltametry 1 1 or
Colorimetric (Dithi-
zone).
Digestion 4 followed
by:
AA direct aspiration
ICP/AES
DCP or
Titrimetric (EDTA) ....
Ion Chromatography
Dissolved Oxygen
Depletion with ni-
trification inhibitor.
Titrimetric
Spectrophotometric
manual or auto-
matic.
Titrimetric: (silver ni-
trate) or.
(Mercuric nitrate)
Colorimetric: manual
or.
Automated (Ferricya-
nide).
Potentiometric Titra-
tion.
Ion Selective Elec-
trode.
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
200 7 Rev 4 4
(1994).
410 3 (Rev
1978)1.
410 4 Rev 2 0
(1993).
3113 B
3120 B
3500-Cd D
3111 B
3120 B
3500-Ca D
5210 B
5220 C
5220 D
4500-CI-B
4500-CI-C
4500-CI-E
4500-CI-D
3120 B
3120 B
3500-Ca B
5210 B
5220 C
5220 D
4500-CI-B
4500-CI-C
4500-CI-E
4500-CI-D
3113 B-99
3120 B-99
3111 B-99
3120 B-99
3500-Ca B-97 ...
5210 B-01
5220 C-97
5220 D-97
4500-CI-B-97 ...
4500-CI-C-97 ...
4500-CI-E-97 ...
4500-CI-D-97.
D3557-95, 02
(D).
D5673-03
D41 90-94, 99
D3557-95 02
(C).
D511-93 03 (B)
D511-93, 03 (A)
D69 19-03
D1 252-95 00
(A).
D1 252-95 00
(B).
0512-89(99)
(B).
D5 12-89 (99)
(A).
D512-
89(99)(C).
1-4138-89 51
l-1472-852or
1-4471-97 50
993.143
See footnote 34
1-3152-852
|_4471_9750
See footnote 34
97S.463, p. 179
I-3560-852
See foot-
notes13'14. I-
3561-852
1-1183-85 2
973.51 3, I-
1184-852
1-1187-85 2
1-2187-85 2
(D
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(JO
NJ
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
Parameter
17. Chlorine — Total resid-
ual, mg/L; Titrimetric.
18. Chromium VI dis-
solved, mg/L.
19. Chromium — Total,4
mg/L.
Methodology58
Ion Chromatography
CIE/UV
Amperometric direct,
or.
Amperometric direct
(low level).
lodometric direct
Back titration ether
end-point15 or.
DPD-FAS
Spectrophotometric,
DPD or.
Electrode
0.45-micron Filtra-
tion followed by:
AA chelation-extrac-
tion or.
Ion Chromatography
Colorimetric (Di-
phenyl-carbazide).
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA chelation-extrac-
tion.
AA furnace
STGFAA
Reference (method number or page)
EPA35,52
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
218.6, Rev. 3.3
(1994).
200.9, Rev. 2.2
(1994).
Standard meth-
ods
(18th, 19th)
4110 B
4500-CI D
4500-CI E
4500-CI B
4500-CI C
4500-CI F
4500-CI G
3111 C
3500-CrE
3500-CrD
3111 B
3111 C
3113 B
Standard meth-
ods
(20th)
4110 B
4500-CI D
4500-CI E
4500-CI B
4500-CI C
4500-CI F
4500-CI G
3500-CrC
3500-CrB
Standard meth-
ods
online
4110 B-00
4500-CI D-00 ....
4500-CI E-00.
4500-CI B-00.
4500-CI C-00.
4500-CI F-00.
4500-CI G-00.
3111 C-99
3500-CrC-01 ...
3500-CrB-01 ...
3111 B-99
3111 C-99.
3113 B-99
ASTM
D4327-97, 03
D1253-86 (96),
03.
D5257-97
D1 687-92, 02
(A).
D1 687-92, 02
(B).
D1 687-92, 02
(C).
USGS/AOAC/
other
993. 30 3
D6508, Rev.
254
See footnote 1e
1-1232-85
993.23
1-1230-85
974.273, |_
3236-85 2
I-3233-9346
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
20. Cobalt—Total,4 mg/L
21. Color, platinum cobalt
h-1 units or dominant wave-
<~n length, hue, luminance
purity.
22. Copper—Total,4 mg/L
ICP/AES36
ICP/MS
DCP,36or
Colorimetric (Di-
phenyl-carbazide).
Digestion 4 followed
by:
AA direct aspiration
AA furnace
STGFAA
ICP/AES
ICP/MS
DCP
Colorimetric (ADMI)
or.
(Platinum cobalt), or
Spectrophotometric
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
STGFAA
ICP/AES 3S
ICP/MS
DCP36 or
Colorimetric
(Neocuproine) or.
(Bicinchoninatel
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
200.9, Rev. 2.2
(1994).
200 7 Rev 4 4
(1994).
200.8, Rev. 5.4
(1994).
200 9 Rev 2 2
(1994).
200 7 Rev 4 4
(1994).
200.8, Rev. 5.4
(1994).
3120 B
3500-Cr D
3111 B orC ....
3113 B
3120 B
2120 E
2120 B
2120 C
3111 B orC ....
3113 B
3120 B
3500-Cu D
3500-Cu E
3120 B
3500-Cr B
3120 B
2120 E
2120 B
2120 C
3120 B
3500-Cu B
3500-Cu C
3120 B-99.
3500-Cr B-01 .
3111 B or C-99
3113 B-99
3120 B-99
2120 B-01
3111 B or C-99
3113 B-99
3120 B-99
3500-Cu B-99
3500-Cu C-99 ..
D5673-03
D41 90-94, 99
D3558-94, 03
(A or B).
D3558-94, 03
(C).
D5673-03
D41 90-94, 99
D1688-95, 02
(A or B).
D1 688-95 02
(C).
D5673-03
D41 90-94, 99
993.143
See footnote 34
p. 37 9, I-3239-
85 2
I-42 43-89 51
|_4471_9750
993.143
See footnote 34
See footnote1S
1-1250-85 2
974.273 p. 379
I-3270-852
or 1-3271-
852
I-42 74-89 51
|_4471_9750
993.143
See footnote 34
See footnote19
(D
(D
O
Ufi
(JO
(JO
-------
(JO
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
Parameter
23. Cyanide — Total, mg/L
24. Available Cyanide,
mg/L.
25. Fluoride — Total, mg/L
Methodology58
Automated Distilla-
tion and Colorim-
etry, or.
Manual distillation
with MgCI2 fol-
lowed by:
Titrimetric or
Spectrophotometric,
manual or.
Automated 20 or
Ion Selective Elec-
trode.
Cyanide Amenable
to Chlorination
(CATC); Manual
distillation with
MgCI2 followed by
Titrimetric or
Spectrophotometri-
c.
Flow injection and
ligand exchange,
followed by amper-
ometry61.
Automated Distilla-
tion and Colorim-
etry.
Manual distillation6
followed by:
Electrode, manual or
Automated
Colori metric,
(SPADNS) or.
Reference (method number or page)
EPA35,52
335.4, Rev. 1.0
(1993)57.
335 4 Rev 1 0
(1993)57.
Standard meth-
ods
(18th, 19th)
4500-CN-C
4500-CN-D
4500-CN-E
4500-CN-F
4500-CN-G
4500-F-B
4500-F-B
4500-F-D
Standard meth-
ods
(20th)
4500-CN-C
4500-CN-D
4500-CN-E
4500-CN-F
4500-CN-G
4500-F-B
4500-F-B
4500-F-D
Standard meth-
ods
online
4500-CN-D-99
4500-CN-E-99 ..
4500-CN-F-99 ..
4500-CN-G-99
4500-F-B-97.
4500-F-C-97
4500-F-D-97
ASTM
D2036-98(A) ...
D2036-98(A) ...
D2036-98(A).
D2036-98(B).
D6888-04
01179-93,99
(B).
01179-93,99
(A).
USGS/AOAC/
other
Kelada-01 55
10-204-00-1-
X56
p. 22 9
I-3300-85
10-204-00-1-
X56, I-4302-
85 2
OIA-167744
Kelada-01 55
I-4327-852
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
26. Gold—Total,4 mg/L ....
27. Hardness—Total, as
CaCO3, mg/L.
28. Hydrogen ion (pH), pH
units.
29. Iridium—Total,4 mg/L
30. Iron—Total,4 mg/L
Automated
complexone.
Ion Chromatography
CIE/UV
Digestion 4 followed
by:
AA direct aspiration,
or.
AA furnace, or
DCP
Automated colori-
metric,.
Titrimetric (EDTA) or
Ca plus Mg as their
carbonates, by in-
ductively coupled
plasma or AA di-
rect aspiration.
(See Parameters
13 and 33)..
Electrometric meas-
urement or.
Automated electrode
Digestion 4 followed
by:
AA direct aspiration
or.
AA furnace
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
STGFAA
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
231 .2 (Rev.
1978)1.
130.1 (Issued
1971)1.
150.2 (Dec.
1982)1.
235 2 (Issued
1978)1.
200.9, Rev. 2.2
(1994).
4500-F-E
4110 B
3111 B
2340 B orC ....
4500-H+ B
3111 B
3111 B orC
3113 B
4500-F-E
4110 B
2340 B or C ....
4500-H+ B
4500-F-E-97.
4110 B-00
3111 B-99.
2340 B or C-97
4500-H+ B-00 ..
3111 B-99.
3111 B or C-99
3113 B-99
04327-97,03 ...
01126-86(92),
02.
01 293-84 (90),
99 (A or B).
01 068-96 03
(A or B).
01 068-96 03
(C).
993.30 3
D6508, Rev.
254
See footnote 34
973.5 2B3, I-
1338-852
973.41.3, I-
1586-852
See footnote21,
I-2587-852
974.273, I-
3381-852
(D
-o
O
I
6
(D
O
Ufi
(JO
U1
-------
(JO
Ol
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
Parameter
31 . Kjeldahl Nitrogen 5—
Total, (as N), mg/L.
32. Lead— Total,4 mg/L ....
Methodology58
ICP/AES 3S
DCP36or
Colorimetric (Phe-
nanthroline).
Digestion and dis-
tillation followed
by: 20
Titration or
Nesslerization or
Electrode
Automated phenate
colorimetric.
Semi-automated
block digester col-
orimetric.
Manual or block
digester potentio-
metric.
Block digester, fol-
lowed by Auto dis-
tillation and Titra-
tion, or.
Nesslerization, or
Flow injection gas
diffusion.
Digestion 4 followed
by:
Reference (method number or page)
EPA35,52
200.7, Rev. 4.4
(1994).
351.1 (Rev.
1978)1.
351.2, Rev. 2.0
(1993).
Standard meth-
ods
(18th, 19th)
3120 B
3500-Fe D
4500-Norg B or
C and 4500-
NH3B.
4500-NH3 C
(19th) and
4500-NH 3 E
(18th).
4500-NH3 C
(18th Only).
4500-NH3 F or
G (18th) and
4500-NH3 D
or E (19th).
Standard meth-
ods
(20th)
3120 B
3500-Fe B
4500-Norg B or
C and 4500-
NH3B.
4500-NH3C ....
4500-NH3 D or
E.
Standard meth-
ods
online
3120 B-99
3500-Fe B-97 ...
4500-Norg B or
C-97 and
4500-NH3 B-
97.
4500-NH3 C-97
4500-NH3 D or
E-97.
ASTM
04190-94,99
D1068-96, 03
(D).
D3590-89, 02
(A).
D3590-89, 02
(A).
D3590-89, 02
(A).
D3590-89, 02
(B).
D3590-89, 02
(A).
USGS/AOAC/
other
|_4471_97so
See footnote 34
See footnote 22
973. 48 3
1-4551-788
1-451 5-9 145
See footnote 39
See footnote 40
See footnote 41
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
33. Magnesium—Total,4
mg/L.
34. Manganese—Total,4
mg/L.
35. Mercury—Total4, mg/
L.
AA direct aspira-
tion36.
AA furnace
STGFAA
ICP/AES36
ICP/MS
DCP36
Voltametry 1 1 or
Colorimetric (Dithi-
zone).
Digestion 4 followed
by:
AA direct aspiration
ICP/AES
DCP or
Gravimetric
Ion Chromatography
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
STGFAA
ICP/AES 36
ICP/MS
DCP36 or
Colorimetric
(Persulfate), or.
(Periodate)
Cold vapor manual
or.
Automated
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200 8 Rev 5 4
(1994).
200 7 Rev 4 4
(1994).
200 9 Rev 2 2
(1994).
200 7 Rev 4 4
(1994).
200 8 Rev 5 4
(1994).
245 1 Rev 3 0
(1994).
245.2 (Issued
1974).
3111 B orC ....
3113 B
3120 B
3500-Pb D
3111 B
3120 B
3500-Mg D.
3111 B
3113 B
3120 B
3500— Mn D ...
3112 B
3120 B
3500-Pb B
3120 B
3120 B
3500-Mn B
3111 B or C-99
3113 B-99
3120 B-99
3500-Pb B-97.
3111 B-99
3120 B-99
3111 B-99
3113 B-99
3120 B-99
3500-Mn B-99 ..
3112 B-99
D3559-96, 03
(A or B).
D3559-96, 03
(D).
D56 73-03
D41 90-94 99
D3559-96, 03
(C).
D511-93 03 (B)
D69 19-03
D858-95, 02 (A
or B).
D858-95, 02
(C).
D56 73-03
D41 90-94 99
D3223-97 02
974.273, I-
3399-852
I-4403-8951
1-4471-97 50
993.143
See footnote 34
974.273, I-
3447-852
|_4471_9750
See footnote 34
974.273, I-
3454-852
|_4471_9750
993.143
See footnote 34
920.203 3
See footnote 23
977.22 3, I-
3462-8S2
(D
O
I
6
(D
O
Ufi
-------
(JO
oo
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
Ufi
to
o
Parameter
36. Molybdenum — Total 4,
mg/L.
37. Nickel— Total,4 mg/L ..
38. Nitrate (as N), mg/L ...
Methodology58
Cold vapor atomic
fluorescence spec-
trometry (CVAFS).
Purge and Trap
CVAFS.
Digestion 4 followed
by:
AA direct aspiration
AA furnace
ICP/AES
ICP/MS
DCP
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
STGFAA
ICP/AES 3S
ICP/MS
DCP36, or
Colori metric
(heptoxime).
Ion Chromatography
CIE/UV
Reference (method number or page)
EPA35,52
245.7 Rev. 2.0
(2005) 59.
1631E43.
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
Standard meth-
ods
(18th, 19th)
3111 D
3113 B
3120 B
3111 B orC ....
3113 B
3120 B
3500-Ni D
(17th Edition).
4110 B
Standard meth-
ods
(20th)
3120 B
3120 B
4110 B
Standard meth-
ods
online
3111 D-99
3113 B-99
3120 B-99
3111 BorC-99
3113 B-99
3120 B-99
4110 B-00
ASTM
D5673-03
D1886-90, 94
(98) (A or B).
D1886-90, 94
(98) (C).
D5673-03
04190-94,99
D4327-97, 03
USGS/AOAC/
other
I-3490-852
I-3492-9647
1-4471-97 50
993. 143
See footnote 34
I-3499-852
I-4503-8951
|_4471_9750
993. 143
See footnote 34
993. 30 3
D6508, Rev.
254
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
39. Nitrate-nitrite (as N),
mg/L.
40. Nitrite (as N), mg/L ....
41. Oil and grease—Total
recoverable, mg/L.
Ion Selective Elec-
trode.
Colorimetric (Brucine
sulfate), or.
Nitrate-nitrite N
minus Nitrite N
(See parameters
39 and 40)..
Cadmium reduction,
manual or.
Automated or
Automated hydrazine
Ion Chromatography
CIE/UV
Spectrophotometric:
Manual or.
Automated
(Diazotization).
Automated ("bypass
cadmium reduc-
tion).
Manual (*bypass
cadmium reduc-
tion).
Ion Chromatography
CIE/UV
Hexane extractable
material (HEM): n-
Hexane extraction
and gravimetry.
Silica gel treated
HEM (SGT-HEM):
Silica gel treat-
ment and gravim-
etry..
352.1 1
353 2 Rev 2 0
(1993).
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
353.2, Rev. 2.0
(1993).
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
1664A42
1664A42.
4500-NO3-D ..
4500-NO3-E ...
4500-NO3-F
4500-NO3-H
4110 B
4500-NO2-B ...
4500-NO3-F ....
4500-NO3-E
4110 B
4500-NO3 -D ..
4500-NO3-E ...
4500-NO3-F
4500-NO3-H
4110 B
4500-NO2-B ...
4500-NO3-F ....
4500-NO3-E
4110 B
5520 B 3B
4500-NO3 -D-00.
4500-NO3-E-00
4500-NO3-F-00
4500-NO3-H-00
4110 B-00
4500-NO2-B-00
4500-NO3-F-00
4500-NO3-E-00
4110 B-00
5520 B-01 3S
D3867-99(B).
D3867-99(A)
D4327-97
D3867-99(A) ...
D3867-99(B)
D4327-97, 03
973.50 3,
419D1'7, p.
28 9
I-4545-852
993.30 3
D6508, Rev.
254
See footnote 25
I-4540-852
I-4545-852
993.30 3
D6508, Rev.2 54
(D
(D
O
Ufi
(JO
ID
-------
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
to
to
Parameter
42. Organic carbon — Total
(TOC), mg/L.
43. Organic nitrogen (as
N), mg/L.
44. Orthophosphate (as
P), mg/L.
45. Osmium — Total4, mg/
L.
46. Oxygen, dissolved,
mg/L.
47. Palladium— Total,4
mg/L.
Methodology58
Combustion or oxi-
dation.
Total Kjeldahl N (Pa-
rameter 31) minus
ammonia N (Pa-
rameter 4).
Ascorbic acid meth-
od:.
Automated, or
Manual single rea-
gent.
Manual two reagent
Ion Chromatography
CIE/UV
Digestion 4 followed
by:
AA direct aspiration,
or.
AA furnace
Winkler (Azide modi-
fication), or.
Electrode
Digestion 4 followed
by:
AA direct aspiration,
or.
AA furnace
Reference (method number or page)
EPA35,52
365.1, Rev. 2.0
(1993).
365.3 (Issued
1978)1.
300.0, Rev 2.1
(1993) and
300.1, Rev
1.0 (1997).
252.2 (Issued
1978)1.
253.2 1 (Issued
1978).
Standard meth-
ods
(18th, 19th)
5310 B, C, orD
4500-P F
4500-P E
4110 B
3111 D
4500-OC
4500-OG
3111 B
Standard meth-
ods
(20th)
5310 B, C, or D
4500-P F
4500-P E
4110 B
4500-OC
4500-OG
Standard meth-
ods
online
5310 B, C, or D-
00.
4110 B-00
3111 D-99.
4500-O C-01 ....
4500-OG-01 ....
3111 B-99
ASTM
D2579-93 (A or
B).
D515-88(A)
D4327-97, 03
D888-92, 03
(A).
D888-92, 03
(B).
USGS/AOAC/
other
97S.47,3 p.
1424
973.56 3, I-
4601-85 2
973.553
993. 30 3
D6508, Rev.
254
973.4 SB3, I-
1 575-78 8
1-1 576-78 8
p. 3271°
p. 3281°
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
48. Phenols, mg/L
to
CO
49. Phosphorus (ele-
mental), mg/L.
50. Phosphorus—Total,
mg/L.
51. Platinum—Total,4 mg/
L.
52. Potassium—Total,4
mg/L.
53. Residue—Total, mg/L
54. Residue—filterable,
mg/L.
55. Residue—non-filter-
able (TSS), mg/L.
56. Residue—settleable,
mg/L.
57. Residue—Volatile, mg/
L.
DCP
Manual distillation26
Followed by:
Colorimetric (4AAP)
manual, or.
Automated
Gas-liquid chroma-
tog raphy.
Persulfate digestion
followed by: 20
Manual or
Automated ascorbic
acid reduction.
Semi-automated
block digester.
Digestion 4 followed
by:
AA direct aspiration
AA furnace
DCP
Digestion 4 followed
by:
AA direct aspiration
ICP/AES
Flame photometric,
or.
Colorimetric
Ion Chromatography
Gravimetric, 103—
105°.
Gravimetric, 180°
Gravimetric, 103—
105 °C post wash-
ing of residue.
Volumetric, (Imhoff
cone), or
gravimetric.
Gravimetric, 550 °C
420 1 1 (Rev
1978).
420 1 1 (Rev
1978).
420.4 Rev. 1.0
(1993).
365.3 1 (Issued
1978).
365.1 Rev. 2.0
(1993).
365.4 1 (Issued
1974).
255 2 1
200.7, Rev. 4.4
(1994).
160.41
4500-P B.5
4500-P E
4500-P F
3111 B
3111 B
3120 B
3500-K D
2540 B
2540 C
2540 D
2540 F
4500-P B.5
4500-P E
4500-P F
3120 B
3500-K B
2540 B
2540 C
2540 D
2540 F
3111 B-99.
3111 B-99
3120 B-99.
3500-K B-97.
2540 B-97
2540 C-97
2540 D-97
2540 F-97.
D515-88(A).
D515-88(B)
D69 19-03
See footnote 34
See footnote 27
See footnote 27
See footnote 2a
973.55 3
973.563, I-
4600-852
1-4610-9148
See footnote 34
973.533, I-
3630-852
317 B17
I-3750-852
1-1750-852
I-3765-852
I-3753-85 2
(D
(D
O
Ufi
-------
NJ
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
un
Parameter
58. Rhodium — Total,4 mg/
L.
59. Ruthenium — Total,4
mg/L.
60. Selenium — Total,4 mg/
L.
61. Silica — Dissolved,37
mg/L.
62. Silver— Total,4- 31 mg/
L.
Methodology58
Digestion 4 followed
by:
AA direct aspiration,
or.
AA furnace
Digestion 4 followed
by:
AA direct aspiration,
or.
AA furnace
Digestion 4 followed
by:
AA furnace
STGFAA
ICP/AES36
ICP/MS
AA gaseous hydride
0.45 micron filtration
followed by:
Colorimetric, Manual
or.
Automated
(Molybdosilicate),
or.
ICP/AES
Digestion 4- 2!> fol-
lowed by:
AA direct aspiration
Reference (method number or page)
EPA35,52
265.21.
267.2 1.
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200 8 Rev 5 4
(1994).
200.7, Rev. 4.4
(1994).
Standard meth-
ods
(18th, 19th)
3111 B
3111 B
3113 B
3120 B
3114 B
4500-Si D
3120 B
3111 B orC
Standard meth-
ods
(20th)
3120 B
4500-SiO2 C ...
3120 B
Standard meth-
ods
online
3111 B-99.
3111 B-99.
3113 B-99
3120 B-99.
3114 B-97
4500-SiO2C-97
3120 B-99
3111 BorC-99
ASTM
D3859-98, 03
(B).
D56 73-03
D3859-98, 03
(A).
D859-94, 00 ...
USGS/AOAC/
other
I-4668-9849
993. 143
I-3667-852
1-1 700-85 2
I-2700-852
1-4471-97 50
974.27 3, p.
379, I-3720-
85 2
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
to
01
63. Sodium—Total,4 mg/L
64. Specific conductance,
micromhos/cm at 25 °C.
65. Sulfate (as SO4), mg/L
66. Sulfide (as S), mg/L ...
67. Sulfite (as SO3), mg/L
68. Surfactants, mg/L
69. Temperature, °C
70. Thallium—Total,4 mg/
L.
AA furnace
STGFAA
ICP/AES
ICP/MS
DCP
Digestion 4 followed
by:
AA direct aspiration
ICP/AES
DCP or
Flame photometric
Ion Chromatography
Wheatstone bridge
Automated colori-
metric.
Gravimetric
Turbidimetric
Ion Chromatography
CIE/UV
Titrimetric (iodine), or
Colorimetric (meth-
ylene blue).
Ion Selective Elec-
trode.
Titrimetric (iodine-
iodate).
Colorimetric (meth-
ylene blue).
Thermometric
Digestion 4 followed
by:
200 9 Rev 2 2
(1994).
200 7 Rev 4 4
(1994).
200.8, Rev. 5.4
(1994).
200.7, Rev. 4.4
(1994).
120 1 1 (Rev
1982).
375.2, Rev. 2.0
(1993).
300 0 Rev 2 1
(1993) and
300.1, Rev
1.0 (1997).
3113 B
3120 B
3111 B
3120 B
3500-Na D
2510 B
4500-SO42-C
or D.
4110 B
4500-S 2-F
(19th) 4500-
S2~E (18th).
4500-S 2-D
4500-S 2-G
4500-SO32-B ..
5540 C
2550 B
3120 B
3120 B
3500-Na B
2510 B
4500-SO42-C
or D.
4110 B
4500-S 2-F
4500-S 2-D
4500-S 2-G
4500-SO32-B ..
5540 C
2550 B
3113 B-99
3120 B-99
3111 B-99
3120 B-99
3500-Na B-97
2510 B-97
4110 B-00
4500-S 2-F-OO ...
4500-S 2-D-OO.
4500-S 2-G-OO ..
4500-SO32-B-
00.
5540 C-00
2550 B-00
D5673-03
D 6919-03.
D1 125-95 (99)
(A).
D516-90, 02 ...
D4327-97 03
D4658-03.
D2330-88, 02.
|_4724-89 51
|_4471_9750
993. 143
See footnote
973.S43, I-
3735-8S2
|_4471_9750
See footnote
973 40 3 I-
2781-85 2
925. 54 3
426C30
993 30 3
D6508, Rev.
2 54
I-3840-85 2
See footnote
(D
(D
O
Ufi
(JO
-------
TABLE IB—LIST OF APPROVED INORGANIC TEST PROCEDURES—Continued
Ufi
to
Oi
Parameter
71. Tin— Total,4 mg/L
72. Titanium — Total,4 mg/
L.
73. Turbidity, NTU53
74. Vanadium — Total,4
mg/L.
Methodology58
AA direct aspiration
AA furnace
STGFAA
ICP/AES
ICP/MS
Digestion 4 followed
by:
AA direct aspiration
AA furnace or
STGFAA
ICP/AES
Digestion 4 followed
by:
AA direct aspiration
AA furnace
DCP
Nephelometric
Digestion 4 followed
by:
AA direct aspiration
AA furnace
ICP/AES
ICP/MS
DCP or
Colorimetric (Gallic
Acid).
Reference (method number or page)
EPA35,52
279.2 1 (Issued
1978).
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
200.9, Rev. 2.2
(1994).
200.7, Rev. 4.4
(1994).
283.2 1 (Issued
1978).
180.1, Rev. 2.0
(1993).
200.7, Rev. 4.4
(1994).
200.8, Rev. 5.4
(1994).
Standard meth-
ods
(18th, 19th)
3111 B
3120 B
3111 B
3113 B
3111 D
2130 B
3111 D
3120 B
3500-V D
Standard meth-
ods
(20th)
3120 B
2130 B
3120 B
3500-V B
Standard meth-
ods
online
3111 B-99.
3120 B-99.
3111 B-99
3113 B-99.
3111 D-99.
2130 B-01
3111 D-99.
3120 B-99
3500-V B-97.
ASTM
D5673-03
D1889-94, 00
D3373-93, 03.
D5673-03
04190-94,99
USGS/AOAC/
other
993.143
I-3850-78 8
See footnote 34
I-3860-852
1-4471-97 50
993.143
See footnote 34
o
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75. Zinc -Total4, mg/L
Digestion 4 followed
by:
AA direct aspira-
tion36.
AA furnace
ICP/AES 3S
ICP/MS
DCP 3e or
Colorimetric (Dithi-
zone) or.
(Zinconl
289.2 1 (Issued
1978).
200 7 Rev 4 4
(1994).
200 8 Rev 5 4
(1994).
3111 B orC ....
3120 B
3500-Zn E
3500-Zn F
3120 B
3500-Zn B
3111 B or C-99
3120 B-9959
3500-Zn B-97 ...
D1691-95, 02
(A or B).
D56 73-03
D41 90-94 99
974.27 3 p
37 9, I-3900-
85 2
|_4471_9750
993 143
See footnote 34
See footnote 33
Table 1B Notes:
1 "Methods for Chemical Analysis of Water and Wastes," Environmental Protection Agency, Environmental Monitoring Systems Laboratory-Cincinnati (EMSL-
Cl), EPA-600/4-79-020 (NTIS PB 84-128677), Revised March 1983 and 1979 where applicable.
2Fishman, M. J., ef a/. "Methods for Analysis of Inorganic Substances in Water and Fluvial Sediments," U.S. Department of the Interior, Techniques of Water-
Resource Investigations of the U.S. Geological Survey, Denver, CO, Revised 1989, unless otherwise stated.
3"Official Methods of Analysis of the Association of Official Analytical Chemists," Methods Manual, Sixteenth Edition, 4th Revision, 1998.
4For the determination of total metals (which are equivalent to total recoverable metals) the sample is not filtered before processing. A digestion procedure is
required to solubilize analytes in suspended material and to break down organic-metal complexes (to convert the analyte to a detectable form for colorimetric
analysis). For non-platform graphite furnace atomic absorption determinations a digestion using nitric acid (as specified in Section 4.1.3 of Methods for the Chem-
ical Analysis of Water and Wastes) is required prior to analysis. The procedure used should subject the sample to gentle, acid refluxing and at no time should the
sample be taken to dryness. For direct aspiration flame atomic absorption determinations (FLAA) a combination acid (nitric and hydrochloric acids) digestion is
preferred prior to analysis. The approved total recoverable digestion is described as Method 200.2 in Supplement I of "Methods for the Determination of Metals in
Environmental Samples" EPA/600R-94/111, May, 1994, and is reproduced in EPA Methods 200.7, 200.8, and 200.9 from the same Supplement. However, when
using the gaseous hydride technique or for the determination of certain elements such as antimony, arsenic, selenium, silver, and tin by non-EPA graphite fur-
nace atomic absorption methods, mercury by cold vapor atomic absorption, the noble metals and titanium by FLAA, a specific or modified sample digestion proce-
dure may be required and in all cases the referenced method write-up should be consulted for specific instruction and/or cautions. For analyses using inductively
coupled plasma-atomic emission spectrometry (ICP-AES), the direct current plasma (DCP) technique or the EPA spectrochemical techniques (platform furnace
AA, ICP-AES, and ICP-MS) use EPA Method 200.2 or an approved alternate procedure (e.g., CEM microwave digestion, which may be used with certain
analytes as indicated in Table IB); the total recoverable digestion procedures in EPA Methods 200.7, 200.8, and 200.9 may be used for those respective methods.
Regardless of the digestion procedure, the results of the analysis after digestion procedure are reported as "total" metals.
5 Copper sulfate may be used in place of mercuric sulfate.
6Manual distillation is not required if comparability data on representative effluent samples are on file to show that this preliminary distillation step is not nec-
essary: however, manual distillation will be required to resolve any controversies.
7Ammonia, Automated Electrode Method, Industrial Method Number 379-75 WE, dated February 19, 1976, Bran & Luebbe (Technicon) Auto Analyzer II, Bran
& Luebbe Analyzing Technologies, Inc., Elmsford, NY 10523.
8The approved method is that cited in "Methods for Determination of Inorganic Substances in Water and Fluvial Sediments", USGS TWRI, Book 5, Chapter A1
(1979).
9American National Standard on Photographic Processing Effluents, April 2, 1975. Available from ANSI, 25 West 43rd St., New York, NY 10036.
10"Selected Analytical Methods Approved and Cited by the United States Environmental Protection Agency," Supplement to the Fifteenth Edition of Standard
Methods for the Examination of Water and Wastewater (1981).
11 The use of normal and differential pulse voltage ramps to increase sensitivity and resolution is acceptable.
(D
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Ol
12Carbonaceous biochemical oxygen demand (CBOD6) must not be confused with the traditional BOD6 test method which measures "total BOD." The addition ^
of the nitrification inhibitor is not a procedural option, but must be included to report the CBOD6 parameter. A discharger whose permit requires reporting the tradi- JJ^
tional BODs may not use a nitrification inhibitor in the procedure for reporting the results. Only when a discharger's permit specifically states CBODs is required O>
can the permittee report data using a nitrification inhibitor. '<&
13OIC Chemical Oxygen Demand Method, Oceanography International Corporation, 1978, 512 West Loop, P.O. Box 2980, College Station, TX 77840.
"Chemical Oxygen Demand, Method 8000, Hach Handbook of Water Analysis, 1979, Hach Chemical Company, P.O. Box 389, Loveland, CO 80537.
15The back titration method will be used to resolve controversy.
16Orion Research Instruction Manual, Residual Chlorine Electrode Model 97-70, 1977, Orion Research Incorporated, 840 Memorial Drive, Cambridge, MA
02138. The calibration graph for the Orion residual chlorine method must be derived using a reagent blank and three standard solutions, containing 0.2, 1.0, and
5.0 mL 0.00281 N potassium iodate/100 mL solution, respectively.
17The approved method is that cited in Standard Methods for the Examination of Water and Wastewater, 14th Edition, 1976.
18National Council of the Paper Industry for Air and Stream Improvement, Inc., Technical Bulletin 253, December 1971.
19Copper, Biocinchoinate Method, Method 8506, Hach Handbook of Water Analysis, 1979, Hach Chemical Company, P.O. Box 389, Loveland, CO 80537.
20When using a method with block digestion, this treatment is not required.
21 Hydrogen ion (pH) Automated Electrode Method, Industrial Method Number 378-75WA, October 1976, Bran & Luebbe (Technicon) Autoanalyzer II. Bran &
Luebbe Analyzing Technologies, Inc., Elmsford, NY 10523.
22lron, 1,10-Phenanthroline Method, Method 8008, 1980, Hach Chemical Company, P.O. Box 389, Loveland, CO 80537.
23Manganese, Periodate Oxidation Method, Method 8034, Hach Handbook of Wastewater Analysis, 1979, pages 2-113 and 2-117, Hach Chemical Company,
Loveland, CO 80537.
24Wershaw, R. L.,ef a/., "Methods for Analysis of Organic Substances in Water," Techniques of Water-Resources Investigation of the U.S. Geological Survey,
Book 5, Chapter A3, (1972 Revised 1987) p. 14.
25Nitrogen, Nitrite, Method 8507, Hach Chemical Company, P.O. Box 389, Loveland, CO 80537.
26Just prior to distillation, adjust the sulfuric-acid-preserved sample to pH 4 with 1+9 NaOH.
27The approved method is cited in Standard Methods for the Examination of Water and Wastewater, 14th Edition. The colorimetric reaction is conducted at a
to pH of 10.0±0.2. The approved methods are given on pp 576-81 of the 14th Edition: Method 510A for distillation, Method 510B for the manual colorimetric proce-
03 dure, or Method 51OC for the manual spectrometric procedure.
28R.F. Addison and R. G. Ackman, "Direct Determination of Elemental Phosphorus by Gas-Liquid Chromatography," Journal of Chromatography, Vol. 47,
No.3, pp. 421-426, 1970.
29Approved methods for the analysis of silver in industrial wastewaters at concentrations of 1 mg/L and above are inadequate where silver exists as an inor-
ganic halide. Silver halides such as the bromide and chloride are relatively insoluble in reagents such as nitric acid but are readily soluble in an aqueous buffer of
sodium thiosulfate and sodium hydroxide to pH of 12. Therefore, for levels of silver above 1 mg/L, 20 mL of sample should be diluted to 100 mL by adding 40 mL
each of 2 M Na2S2O3 and NaOH. Standards should be prepared in the same manner. For levels of silver below 1 mg/L the approved method is satisfactory.
30The approved method is that cited in Standard Methods for the Examination of Water and Wastewater, 15th Edition. 4^
31 For samples known or suspected to contain high levels of silver (e.g., in excess of 4 mg/L), cyanogen iodide should be used to keep the silver in solution for °
analysis. Prepare a cyanogen iodide solution by adding 4.0 mL of concentrated NH4OH, 6.5 g of KCN, and 5.0 mL of a 1.0 N solution of I2 to 50 mL of reagent (~)
water in a volumetric flask and dilute to 100.0 mL. After digestion of the sample, adjust the pH of the digestate to >7 to prevent the formation of HCN under acidic I"
conditions. Add 1 mL of the cyanogen iodide solution to the sample digestate and adjust the volume to 100 mL with reagent water (NOT acid). If cyanogen iodide
is added to sample digestates, then silver standards must be prepared that contain cyanogen iodide as well. Prepare working standards by diluting a small vol- O
ume of a silver stock solution with water and adjusting the pH>7 with NH4OH. Add 1 mL of the cyanogen iodide solution and let stand 1 hour. Transfer to a 100- P"
mL volumetric flask and dilute to volume with water. —
32Stevens, H.H., Ficke, J. F., and Smoot, G. F., "Water Temperature—Influential Factors, Field Measurement and Data Presentation," Techniques of Water- -Q
Resources Investigations of the U.S. Geological Survey, Book 1, Chapter D1, 1975. I
33Zinc, Zincon Method, Method 8009, Hach Handbook of Water Analysis, 1979, pages 2-231 and 2-333, Hach Chemical Company, Loveland, CO 80537. -j-
34"Direct Current Plasma (DCP) Optical Emission Spectrometric Method for Trace Elemental Analysis of Water and Wastes, Method AES0029," 1986—Re- .L
vised 1991, Thermo Jarrell Ash Corporation, 27 Forge Parkway, Franklin, MA 02038 O
35Precision and recovery statements for the atomic absorption direct aspiration and graphite furnace methods, and for the spectrophotometric SDDC method m
for arsenic are provided in Appendix D of this part titled, "Precision and Recovery Statements for Methods for Measuring Metals." Q
36Microwave-assisted digestion may be employed for this metal, when analyzed by this methodology. "Closed Vessel Microwave Digestion of Wastewater ~
Samples for Determination of Metals", CEM Corporation, P.O. Box 200, Matthews, NC 28106-0200, April 16, 1992. Available from the CEM Corporation. §
37When determining boron and silica, only plastic, PTFE, or quartz laboratory ware may be used from start until completion of analysis. ^
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38Only use n-hexane extraction solvent when determining Oil and Grease parameters—Hexane Extractable Material (HEM), or Silica Gel Treated HEM (analo- [J1
gous to EPA Method 1664A). Use of other extraction solvents (e.g., those in the 18th and 19th editions) is prohibited. <
39Nitrogen, Total Kjeldahl, Method PAI-DK01 (Block Digestion, Steam Distillation, Titrimetric Detection), revised 12/22/94, Ol Analytical/ALPKEM, P.O. Box =;'
9010, College Station, TX 77842. §
40Nitrogen, Total Kjeldahl, Method PAI-DK02 (Block Digestion, Steam Distillation, Colorimetric Detection), revised 12/22/94, Ol Analytical/ALPKEM, P.O. Box 3
9010, College Station, TX 77842. 3
41 Nitrogen, Total Kjeldahl, Method PAI-DK03 (Block Digestion, Automated FIA Gas Diffusion), revised 12/22/94, Ol Analytical/ALPKEM, P.O. Box 9010, Col- 5
lege Station, TX 77842. Jf
42Method 1664, Revision A "n-Hexane Extractable Material (HEM; Oil and Grease) and Silica Gel Treated n-Hexane Extractable Material (SGT-HEM; Non- —
polar Material) by Extraction and Gravimetry" EPA-821-R-98-002, February 1999. Available at NTIS, PB-121949, U.S. Department of Commerce, 5285 Port -o
Royal, Springfield, VA 22161. O
43USEPA. 2001. Method 1631, Revision E, "Mercury in Water by Oxidation, Purge and Trap, and Cold Vapor Atomic Fluorescence Spectrometry" September jjT
2002, Office of Water, U.S. Environmental Protection Agency (EPA-821-R-02-024). The application of clean techniques described in EPA's draft Method 1669: o
Sampling Ambient Water for Trace Metals at EPA Water Quality Criteria Levels (EPA-821-R-96-011) are recommended to preclude contamination at low-level, a:
trace metal determinations. §
44Available Cyanide, Method OIA-1677, "Available Cyanide by Flow Injection, Ligand Exchange, and Amperometry," ALPKEM, A Division of Ol Analytical, P.O.
Box 9010, College Station, TX 77842-9010. >
45"Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Ammonia Plus Organic Nitrogen by a Kjeldahl Di- *§
gestion Method," Open File Report (OFR) 00-170. §
46"Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Chromium in Water by Graphite Furnace Atomic o
Absorption Spectrophotometry," Open File Report (OFR) 93-449. •<
47"Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Molybdenum by Graphite Furnace Atomic Absorp-
tion Spectrophotometry," Open File Report (OFR) 97-198.
48"Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Total Phosphorus by Kjeldahl Digestion Method
and an Automated Colorimetric Finish That Includes Dialysis" Open File Report (OFR) 92-146.
49"Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Arsenic and Selenium in Water and Sediment by
Graphite Furnace-Atomic Absorption Spectrometry" Open File Report (OFR) 98-639.
50"Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Elements in Whole-water Digests Using Inductively
Coupled Plasma-Optical Emission Spectrometry and Inductively Coupled Plasma-Mass Spectrometry," Open File Report (OFR) 98-165.
51 "Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Inorganic and Organic Constituents in Water and
Fluvial Sediment," Open File Report (OFR) 93-125.
52AII EPA methods, excluding EPA Method 300.1, are published in "Methods for the Determination of Metals in Environmental Samples," Supplement I, Na-
tional Exposure Risk Laboratory-Cincinnati (NERL-CI), EPA/600/R-94/111, May 1994; and "Methods for the Determination of Inorganic Substances in Environ-
mental Samples," NERL-CI, EPA/600/R-93/100, August, 1993. EPA Method 300.1 is available from http://www.epa.gov/safewater/methods/pdfs/met300.pdf.
53Styrene divinyl benzene beads (e.g., AMCO-AEPA-1 or equivalent) and stabilized formazin (e.g., Hach StablCal™ or equivalent) are acceptable substitutes
for formazin.
54Method D6508, Rev. 2, "Test Method for Determination of Dissolved Inorganic Anions in Aqueous Matrices Using Capillary Ion Electrophoresis and Chromate
Electrolyte," available from Waters Corp, 34 Maple St., Milford, MA, 01757, Telephone: 508/482-2131, Fax: 508/482-3625.
55Kelada-01, "Kelada Automated Test Methods for Total Cyanide, Acid Dissociable Cyanide, and Thiocyanate," EPA 821-B-01-009, Revision 1.2, August
2001, National Technical Information Service (NTIS), 5285 Port Royal Road, Springfield, VA 22161 [Order Number PB 2001-108275]. The toll free telephone
number is: 800-553-6847. Note: A 450-W UV lamp may be used in this method instead of the 550-W lamp specified if it provides performance within the quality
control (QC) acceptance criteria of the method in a given instrument. Similarly, modified flow cell configurations and flow conditions may be used in the method,
provided that the QC acceptance criteria are met.
56QuikChem Method 10-204-00-1-X, "Digestion and Distillation of Total Cyanide in Drinking and Wastewaters using MICRO DIST and Determination of Cya-
nide by Flow Injection Analysis" is available from Lachat Instruments 6645 W. Mill Road, Milwaukee, Wl 53218, Telephone: 414-358-4200.
57When using sulfide removal test procedures described in Method 335.4, reconstitute particulate that is filtered with the sample prior to distillation. ^
58 Unless otherwise stated, if the language of this table specifies a sample digestion and/or distillation "followed by" analysis with a method, approved digestion _
and/or distillation are required prior to analysis. GJ
59Method 245.7, Rev. 2.0, "Mercury in Water by Cold Vapor Atomic Fluorescence Spectrometry," February 2005, EPA-821-R-05-001, available from the U.S. j>
EPA Sample Control Center (operated by CSC), 6101 Stevenson Avenue, Alexandria, VA 22304, Telephone: 703-461-2100, Fax: 703-461-8056. W
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oo
60The use of EDTA may decrease method sensitivity in some samples. Analysts may omit EDTA provided that all method specified quality control acceptance
criteria are met.
61 Samples analyzed for available cyanide using Methods OIA-1677 or D6888-04 that contain particulate matter may be filtered only after the ligand exchange
reagents have been added to the samples, because the ligand exchange process converts complexes containing available cyanide to free cyanide, which is not
removed by filtration. Analysts are further cautioned to limit the time between the addition of the ligand exchange reagents and sample analysis to no more than
30 minutes to preclude settling of materials in samples.
Ufi
TABLE 1C—LIST OF APPROVED TEST PROCEDURES FOR NON-PESTICIDE ORGANIC COMPOUNDS
CO
o
Parameter 1
1 Acenaphthene
2 Acenaphthylene
3 Acrolein
4. Acrylonitrile
5. Anthracene
6. Benzene
7 Benzidine
8. Benzo(a)anthracene ...
9. Benzo(a)pyrene
10. Benzo(b)fluoranthene
11. Benzo(g,h,i) perylene
12. Benzo(k) fluoranthene
13. Benzyl chloride
14. Benzyl butyl phthalate
EPA method number2'7
GC
610
610
603
603
610
602
610
610
610
610
610
606
GC/MS
625, 1625B
625, 1625B
6244, 1624B.
6244, 1624B.
625, 1625B
624, 1624B
6255, 1625B ..
625, 1625B
625, 1625B
625, 1625B
625, 1625B
625, 1625B
625, 1625B
HPLC
610
610
610
605
610
610
610
610
610
Other approved methods
Standard Methods
[Edition(s)]
6440 B [18th, 19th,
20th].
6410 B, 6440 B,
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6200 B [20th] and
621 OB
[18th, 19th], 6200
C [20th] and
6220 B
[18th, 19th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
Standard Methods
Online
6410 B-00
6410 B-00
6200 B and C-97.
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
ASTM
D4657-92 (99)
D4657-92 (99)
D4657-92 (99)
D4657-92 (99)
D4657-92 (99)
D4657-92 (99)
D4657-92 (99)
D4657-92 (99)
Other
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote3, p.1
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote3, p.
130: See foot-
note6, p. S102
See footnote9, p.
27
o
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15. Bis(2-chloroethoxy)
methane.
16. Bis(2-chloroethyl)
ether.
17. Bis(2-ethylhexyl)
phthalate.
18. Bromodichloro-meth-
ane.
19. Bromoform
20. Bromomethane
21. 4-Bromophenyl
phenyl ether.
22. Carbon tetrachloride
23. 4-Chloro-3-methyl
phenol.
24. Chlorobenzene
25. Chloroethane
611
611
606
601
601
601
611
601
604
601 , 602
601
625, 1625B
625, 1625B
625, 1625B
624, 1624B
624, 1624B
624, 1624B
625, 1625B
624, 1624B
625, 1625B
624, 1624B
624, 1624B
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6200 C [20th] and
6230 B [18th,
19th], 6200 B
[20th] and 6210
B [18th, 19th].
6200 C [20th] and
6230 B [18th,
19th], 6200 B
[20th] and 6210
B [18th, 19th].
6200 C [20th] and
6230 B [18th,
19th], 6200 B
[20th] and 6210
B [18th, 19th].
6410 B [18th, 19th,
20th].
6200 C [20th] and
6230 B [18th,
19th].
6410 B, 6420 B
[18th, 19th, 20th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6220
B [18th, 19th],
6200 C [20th]
and 6230 B
[18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6410 B-00
6410 B-00
6410 B-00
6200 B and C-97.
6200 B and C-97.
6200 B and C-97.
6410 B-00
6200 C-97
6410 B-00, 6420
B-00.
6200 B and C-97
6200 B and C-97.
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote3, p.
130
See footnote9, p.
27
See footnote3, p.
130
(D
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TABLE 1C—LIST OF APPROVED TEST PROCEDURES FOR NON-PESTICIDE ORGANIC COMPOUNDS—Continued
Ufi
Parameter 1
26. 2-Chloroethylvinyl
ether.
27 Chloroform
28 Chloromethane
29. 2-Chloronaph-thalene
30 2-Chlorophenol
31. 4-Chlorophenyl
phenyl ether.
32 Chrysene
33. Dibenzo(a,h)an-
thracene.
34. Dibromochloro-meth-
ane.
35. 1,2-Dichloro-benzene
EPA method number2'7
GC
601
601
601
612
604
611
610
610
601
601 , 602
GC/MS
624 1624B
624 1624B
624 1624B
625 1625B
625 1625B
625 1625B
625, 1625B
625, 1625B
624 1624B
624 1625B
HPLC
610
610
Other approved methods
Standard Methods
[Edition(s)]
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th] 6200 C
[20th] and 6230
B [18th, 19th].
6410 B [18th, 19th,
20th].
6410 B, 6420 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6200 B [20th] and
6210 B [18th,
19th] 6200 C
[20th] and 6230
B [18th, 19th].
6200 C [20th] and
6220 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
Standard Methods
Online
6200 B and C-97.
6200 B and C-97
6200 B and C-97.
6410 B-00
6410 B(00, 6420
B-00.
6410 B-00
6410 B-00
6410 B-00
6200 B and C-97.
6200 C-97
ASTM
D4657-92 (99)
D4657-92 (99)
Other
See footnote3, p.
130
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
o
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00
36. 1 ,3-Dichloro-benzene
37. 1 ,4-Dichloro-benzene
38. 3,3-Dichloro-benzi-
dine.
39. Dichlorodifluoro-meth-
ane.
40 1 1-Dichloroethane
41 1 2-Dichloroethane
42 1 1-Dichloroethene
43 trans-1 2-Dichloro-
ethene.
44. 2,4-Dichlorophenol ....
45. 1 ,2-Dichloro-propane
601 , 602
601 , 602
601
601
601
601
601
604
601
624, 1625B
624, 1625B
625, 1625B
624 1624B
624 1624B
624 1624B
624 1624B
625, 1625B
624, 1624B
605
6200 C [20th] and
6220 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 C [20th] and
6220 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6410 B [18th, 19th,
20th].
6200 C [20th] and
6230 B [18th,
19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6410 B, 6420 B
[18th, 19th, 20th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 C-97
6200 C-97
6410 B-00.
6200 C-97.
6200 B and C 97
6200 B and C 97
6200 B and C 97
6200 B and C 97
6410 B-00, 6420
B-00.
6200 B and C-97.
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
(D
-o
O
I
6
(D
O
Ufi
-------
U1
NJ
TABLE 1C—LIST OF APPROVED TEST PROCEDURES FOR NON-PESTICIDE ORGANIC COMPOUNDS—Continued
un
Parameter 1
46. cis-1 ,3-Dichloro-
propene.
47. trans-1 ,3-Dichloro-
propene.
48. Diethyl phthalate
49. 2,4-Dimethylphenol ...
50. Dimethyl phthalate ....
51. Di-n-butyl phthalate ...
52. Di-n-octyl phthalate ...
53. 2,3-Dinitrophenol
54. 2,4-Dinitrotoluene
55. 2,6-Dinitrotoluene
56. Epichlorohydrin
57. Ethylbenzene
58. Fluoranthene
EPA method number2'7
GC
601
601
606
604
606
606
606
604
609
609
602
610
GC/MS
624, 1624B
624, 1624B
625 1625B
625, 1625B
625 1625B
625, 1625B
625 1625B
625 1625B
625, 1625B
625 1625B
624, 1624B
625, 1625B
HPLC
610
Other approved methods
Standard Methods
[Edition(s)]
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6410 B [18th, 19th,
20th].
6410 B, 6420 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B, 6420 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6220
B [18th, 19th].
6410 B, 6440 B
[18th, 19th, 20th].
Standard Methods
Online
6200 B and C-97.
6200 B and C-97.
6410 B-00
6410 B-00, 6420
B-00.
6410 B-00
6410 B-00
6410 B-00
6410 B-00, 6420
B-00.
6410 B-00
6410 B-00
6200 B and C-97
6410 B-00
ASTM
D4657-92 (99)
Other
See footnote9, p.
27
See footnote 9, p.
27
See footnote 9, p.
27
See footnote 9, p.
27
See footnote 9, p.
27
See footnote 9, p.
27
See footnote 9, p.
27
See footnote 3, p.
130; See foot-
note 6, p. S102
See footnote 9, p.
27
o
-n
*J
O
O
m
Q.
o
NJ
O
-------
NJ
O
59. Fluorene
60. 1,2,3,4,6,7,8-
Heptachloro-
dibenzofuran.
61. 1,2,3,4,7,8,9-
Heptachloro-
dibenzofuran.
62. 1,2,3,4,6,7,8-
Heptachlorodibenzo-p-
dioxin.
63 Hexachlorobenzene
64 Hexachloro-butadiene
65 Hexachlorocyclo-
pentadiene.
66 123478-
Hexachlorodibenzofura-
n.
67. 1,2,3,6,7,8-
Hexachlorodibenzofura-
n.
68 123789-
Hexachlorodibenzofura-
n.
69. 2,3,4,6,7,8-
Hexachlorodibenzofura-
n.
70. 1,2,3,4,7,8-
Hexachlorodibenzo-p-
dioxin.
71 123678-
Hexachlorodibenzo-p-
dioxin.
72. 1,2,3,7,8,9-
Hexachlorodibenzo-p-
dioxin 1613B10.
73 Hexachloroethane
74 ldeno(1 2 3-cd) py-
rene.
75. Isophorone
610
612
612
612
612
610
609
625, 1625B
1613B10.
1613B10.
1613B10.
625 1625B
625 1625B
625 5 1625B
1613B10
1613B10.
1613B10
1613B10.
1613B10.
1613B10
1613B10.
625 1625B
625 1625B
625, 1625B
610
610
6410 B, 6440 B
[18th, 19th, 20th].
6410 B [18th 19th
20th].
6410 B [18th 19th
20th].
6410 B [18th 19th
20th].
6410 B [18th 19th
20th].
6410 B 6440 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
D4657-92 (99)
D4657-92 (99)
See footnote 9, p. [J1
27 <.
(D
O
$
See footnote 9 p L{-
27 0
See footnote 9 p ^
27 >
See footnote 9 p *Q
27 5
O
See footnote9 p
27
See footnote9 p ur>
27 w
See footnote9, p. O>
27 0>
(JO
-------
U1
TABLE 1C—LIST OF APPROVED TEST PROCEDURES FOR NON-PESTICIDE ORGANIC COMPOUNDS—Continued
un
CO
Oi
Parameter 1
76. Methylene chloride ....
77. 2-Methyl-4,6-
dinitrophenol.
78 Naphthalene
79. Nitrobenzene
80. 2-Nitrophenol
81 4-Nitrophenol
82. N-
Nitrosodimethylamine.
83. N-Nitrosodi-n-propyl-
amine.
84. N-
Nitrosodiphenylamine.
85.
Octachlorodibenzofuran.
86. Octachlorodibenzo-p-
dioxin.
87. 2,2'-Oxybis(2-
chloropropane) [also
known as bis(2-
chloroisopropyl) ether].
88. PCB-1016
89 PCB-1221
90 PCB-1232
EPA method number2'7
GC
601
604
610
609
604
604
607
607
607
611
608
608
608
GC/MS
624, 1624B
625, 1625B
625, 1625B
625, 1625B
625, 1625B
625 1625B
6255, 1625B ...
6255 1625B
6255 1625B
1613B10*.
161361°.
625 1625B
625
625
625
HPLC
610
Other approved methods
Standard Methods
[Edition(s)]
6200 C [20th] and
6230 B [18th,
19th].
6410 B, 6420 B
[18th, 19th, 20th].
6410 B, 6440 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
6410 B, 6420 B
[18th, 19th, 20th].
6410 B, 6420 B
[18th, 19th, 20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
Standard Methods
Online
6200 C-97
6410 B-00, 6420
B-00.
6410 B-00
6410 B-00
6410 B-00, 6420
B-00.
6410 B-00, 6420
B-00.
6410 B-00
6410 B-00
6410 B-00
6410 B-00.
6410 B-00
6410 B-00
6410 B-00
ASTM
D4657-92 (99)
Other
See footnote3, p.
130
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote9, p.
27
See footnote3, p.
43; See foot-
note8
See footnote3, p.
43; See foot-
note8
See footnote3, p.
43; See foot-
note8
o
-n
X3
O
o
m
Q.
o
NJ
O
-------
NJ
O
91. PCB-1242
92. PCB-1248
93. PCB-1254
94. PCB-1260
95 1237 8-Pentachloro-
dibenzofuran .
96 2347 8-Pentachloro-
dibenzofuran .
97 12378-
Pentachlorodibenzo-p-
dioxin.
98. Pentachlorophenol ....
CO 99 Phenanthrene
-q
100 Phenol
101 Pyrene
102 23 78-Tetra-
chlorodibenzofuran.
103 23 78-Tetra-
chlorodibenzo-p-dioxin.
104 112 2-Tetra-chloro
ethane .
105 Tetrachloroethene
608
608
608
608
604
610
604
610
601
601
625
625.
625
625
1613B10
1613B10
1613B10
625, 1625B
625 1625B
625 1625B
625 1625B
1613B10
613 6255s>
1613B10.
624 1624B
624 1624B
610
610
6410 B [18th, 19th,
20th].
6410 B [18th, 19th,
20th].
6410 B, 6630 B
[18th, 19th, 20th].
6410 B, 6630 B
[18th, 19th, 20th].
6410 B 6440 B
[18th, 19th, 20th].
6410 B 6420 B
[18th, 19th, 20th].
6410 B 6440 B
[18th, 19th, 20th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00 6420
B-00.
6410 B-00
6200 B and C 97
6200 B and C 97
D4657-92 (99)
D4657-92 (99)
See footnote3, p. [J1
43; See footnote <
3
See footnote 3, p. 3
43; See footnote •§
Q
See footnote 3, p.
43; See footnote J
I
o1
>
U1
U1
-------
U1
Ol
TABLE 1C—LIST OF APPROVED TEST PROCEDURES FOR NON-PESTICIDE ORGANIC COMPOUNDS—Continued
Ufi
CO
CO
Parameter 1
106 Toluene
107. 1,2,4-Trichloro-ben-
zene.
108. 1,1,1-Trichloro-eth-
ane.
109. 1,1,2-Trichloro-eth-
ane.
110. Trichloroethene
111. Trichlorofluoro-meth-
ane.
112. 2,4,6-
Trichlorophenol.
EPA method number2'7
GC
602
612
601
601
601
601
604
GC/MS
624 1624B
625 1625B
624 1624B
624, 1624B
624, 1624B
624
625, 1625B
HPLC
6200 B [20th]
and 6210 B
[18th, 19th],
6200 C [20th]
and 6230 B
[18th, 19th]
Other approved methods
Standard Methods
[Edition(s)]
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6220
B [18th, 19th].
6410 B [18th, 19th,
20th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B and C-97
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6200 B [20th] and
6210 B [18th,
19th], 6200 C
[20th] and 6230
B [18th, 19th].
6410 B, 6420 B
[18th, 19th, 20th].
Standard Methods
Online
6200 B and C-97.
6410 B-00
6200 B and C-97.
6200 B and C-97.
6200 B and C-97.
6410 B-00, 6420
B-00.
ASTM
See footnote3, p.
130.
Other
See footnote 3, p.
130; See foot-
note 9, p. 27
See footnote9, p.
27
o
-n
*J
O
o
m
Q.
O
NJ
O
-------
NJ
O
113. Vinyl chloride
CO
CD
601 624, 1624B
6200 B [20th] and
6210 B [18th,
19th], <6200 C
[20th] and 6230
B [18th, 19th].
6200 B and C-97.
1 All parameters are expressed in micrograms per liter (ng/L) except for Method 1613B in which the parameters are expressed in picograms per liter (pg/L).
2The full text of Methods 601-613, 624, 625, 1624B, and 1625B, are given at Appendix A, "Test Procedures for Analysis of Organic Pollutants," of this part
136. The full text of Method 1613B is incorporated by reference into this part 136 and is available from the National Technical Information Services as stock num-
ber PB95-104774. The standardized test procedure to be used to determine the method detection limit (MDL) for these test procedures is given at Appendix B,
"Definition and Procedure for the Determination of the Method Detection Limit," of this part 136.
3"Methods for Benzidine: Chlorinated Organic Compounds, Pentachlorophenol and Pesticides in Water and Wastewater," U.S. Environmental Protection Agen-
cy, September, 1978.
4Method 624 may be extended to screen samples for Acrolein and Acrylonitrile. However, when they are known to be present, the preferred method for these
two compounds is Method 603 or Method 1624B.
5Method 625 may be extended to include benzidine, hexachlorocyclopentadiene, N-nitrosodimethylamine, and N-nitrosodiphenylamine. However, when they are
known to be present, Methods 605, 607, and 612, or Method 1625B, are preferred methods for these compounds.
5a625, screening only.
6"Selected Analytical Methods Approved and Cited by the United States Environmental Protection Agency," Supplement to the Fifteenth Edition of Standard
Methods for the Examination of Water and Wastewater (1981).
7Each analyst must make an initial, one-time demonstration of their ability to generate acceptable precision and accuracy with Methods 601-603, 624, 625,
1624B, and 1625B (See appendix A of this part 136) in accordance with procedures each in Section 8.2 of each of these methods. Additionally, each laboratory,
on an on-going basis must spike and analyze 10% (5% for methods 624 and 625 and 100% for methods 1624B and 1625B) of all samples to monitor and evalu-
ate laboratory data quality in accordance with Sections 8.3 and 8.4 of these methods. When the recovery of any parameter falls outside the warning limits, the an-
alytical results for that parameter in the unspiked sample are suspect. The results should be reported, but cannot be used to demonstrate regulatory compliance.
These quality control requirements also apply to the Standard Methods, ASTM Methods, and other methods cited.
8"Organochlorine Pesticides and PCBs in Wastewater Using Empore™ Disk" 3M Corporation Revised 10/28/94.
9USGS Method 0-3116-87 from "Methods of Analysis by U.S. Geological Survey National Water Quality Laboratory—Determination of Inorganic and Organic
Constituents in Water and Fluvial Sediments," U.S. Geological Survey, Open File Report 93-125.
10Analysts may use Fluid Management Systems, Inc. PowerPrep system in place of manual cleanup provided that the analysis meet the requirements of Meth-
od 1613B (as specified in Section 9 of the method) and permitting authorities.
TABLE ID—LIST OF APPROVED TEST PROCEDURES FOR PESTICIDES 1
Parameter
1 Aldrin
2. Ametryn
3 Aminocarb
4. Atraton
Method
GC
GC/MS
GC
TLC
GC
EPA2-7
608
625
Standard Methods
18th, 19th, 20th Ed.
6630 B & C
6410 B
Standard Methods
Online
6410 B-00.
ASTM
D3086-90
D5812-96 (2002) ..
Other
See footnote3 p 7' See footnote4 p
27; See footnote8
See footnote3, p. 83; See footnote6,
pS68
See footnote3 p 94' See footnote6
p. S16
See footnote3, p. 83; See footnote6,
p. S68
(D
-o
O
I
6
(D
O
Ufi
-------
U1
oo
TABLE ID—LIST OF APPROVED TEST PROCEDURES FOR PESTICIDES 1—Continued
Ufi
Parameter
5 Atrazine
6 Azinphos methyl
7 Barban
8. a-BHC
9 p-BHC
10. 5-BHC
11. y-BHC (Lindane) ....
12 Captan
13 Carbaryl
14 Carbo-phenothion
15 Chlordane
16. Chloro-propham
17 24-0
18 44'-DDD
19. 4,4'-DDE
Method
GC
GC
TLC
GC
GC/MS
GC
GC/MS
GC
GC/MS
GC
GC/MS
GC
TLC
GC
GC
GC/MS
TLC
GC
GC
GC/MS
GC
GC/MS
EPA2-7
608
625s
608
625s
608
625s
608
625
608
625
608
625
608
625
Standard Methods
18th, 19th, 20th Ed.
6630 B & C
6410 B
6630 C
6410 B
6630 C
6410 B
6630 B & C
6410 B
6630 B
6630 B & C
6410 B
6640 B
6630 B & C
6410 B
6630 B & C
6410 B
Standard Methods
Online
6410 B-00.
6410 B-00
6410 B-00
6410 B-00.
6410 B-00
6410 B-00
6410 B-00.
ASTM
D3086-90
05812-96(02)
D3086-90
05812-96(02)
D3086-90
05812-96(02)
03086-90
05812-96(02)
03086-90
05812-96(02)
03086-90
05812-96(02)
03086-90
05812-96(02)
03086-90
05812-96(02)
Other
See footnote3 p 83' See footnote6
p. S68; See footnote9
See footnote3 p 25' See footnote6
p. S51
See footnote3 p 104' See footnote6
p. S64
See footnote3, p. 7; See footnote8
See footnote8
See footnote8
See footnote3, p. 7; See footnote4, p.
27; See footnote8
See footnote3 p 7
See footnote3 p 94 See footnote6
p. S60
See footnote4 p 27' See footnote6
p. S73
See footnote3 p 7' See footnote4 p
27; See footnote8
See footnote3, p. 104; See footnote6,
p. S64.
See footnote3 p 115' See footnote4
p. 40
See footnote3 p 7' See footnote4 p
27; See footnote8
See footnote3, p. 7; See footnote4, p.
27; See footnote8
o
-n
*J
O
o
m
Q.
o
NJ
O
-------
NJ
O
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
4,4'-DDT
Demeton-O
Demeton-S
Diazinon
Dicamba
Dichlofen-thion
Dichloran
Dicofol
Dieldrin
Dioxathion
Disulfoton
Diuron
Endosulfan I
Endosulfan II
Endosulfan Sulfate
Endrin
Endrin aldehyde
Ethion
Fenuron
Fenuron-TCA
GC
GC/MS
GC
GC
GC
GC
GC
GC
GC
GC
GC/MS
GC
GC
TLC
GC
GC/MS
GC
GC/MS
GC
GC/MS
GC
GC/MS
GC
GC/MS
GC
TLC
TLC
608
625
608
625
608
625s
608
625s
608
625
608
625s
608
625
6630 B & C
6410 B
6630 B & C
6630 B & C
6410 B
6630 B & C
6410 B
6630 B & C
6410 B
6630 C
6410 B
6630 B & C
6410 B
6410 B-00.
6410 B-00
6410 B-00
6410 B-00
6410 B-00
6410 B-00
D3086-90
05812-96(02)
D3086-90
05812-96(02).
D3086-90
05812-96(02)
03086-90
05812-96(02)
03086-90
05812-96(02)
See footnote3, p. 7; See footnote4, p.
27; See footnote8
See footnote3, p. 25; See footnote6,
p. S51
See footnote3, p. 25; See footnote6,
p. S51
See footnote3, p. 25; See footnote4,
p. 27; See footnote6, p. S51
See footnote3, p. 115
See footnote4, p. 27; See footnote6,
p. S73
See footnote3, p. 7
See footnote3, p. 7; See footnote4, p.
27; See footnote8
See footnote4, p. 27; See footnote6,
p. S73
See footnote3, p. 25; See footnote6,
p. S51
See footnote3, p. 104; See footnote6,
p. S64
See footnote3, p. 7; See footnote4, p.
27; See footnote8
See footnote3, p. 7; See footnote8
See footnote8
See footnote3, p. 7; See footnote4, p.
27; See footnote8
See footnote8
See footnote4, p. 27; See footnote6,
p. S73
See footnote3, p. 104; See footnote6,
p. S64
See footnote3, p. 104; See footnote6,
p. S64
(D
-o
O
(D
O
Ufi
-------
Ol
o
TABLE ID—LIST OF APPROVED TEST PROCEDURES FOR PESTICIDES 1—Continued
Ufi
Parameter
40 Heptachlor
41. Heptachlor epoxide
42. Isodrin
43 Linuron
44 Malathion
45 Methiocarb
46. Methoxy-chlor
47. Mexacar-bate
48. Mirex
49 Monuron
50 Monuron-TCA
51 Nuburon
52. Parathion methyl ....
53. Parathion ethyl
54. PCNB
55 Perthane
56. Prometon
57. Prometryn
58. Propazine
Method
GC
GC/MS
GC
GC/MS
GC
GC
GC
TLC
GC
TLC
GC
TLC
TLC
TLC
GC
GC
GC
GC
GC
GC
GC
EPA2-7
608
625
608
625
Standard Methods
18th, 19th, 20th Ed.
6630 B & C
6410 B
6630 B & C
6410 B
6630 C
6630 B & C
6630 B & C
6630 C
6630 C
6630 B & C
Standard Methods
Online
6410 B-00
6410 B-00
ASTM
D3086-90
05812-96(02)
D3086-90
05812-96(02)
D3086-90,
05812-96(02).
03086-90
05812-96(02).
Other
See footnote3 p 7' See footnote4 p
27' See footnote8
See footnote3, p. 7; See footnote4, p.
27' See footnote6 p S73' See
footnote 8
See footnote4, p. 27; See footnote6,
p. S73
See footnote3 p 104' See footnote6
p. S64
See footnote3 p 25' See footnote4
p. 27; See footnote6, p. S51
See footnote3 p 94' See footnote6
p. S60
See footnote3, p. 7; See footnote4, p.
27; See footnote8
See footnote3, p. 94; See footnote6,
p. S60
See footnote3, p. 7; See footnote4, p.
27
See footnote3 p 104' See footnote6
p. S64
See footnote3 p 104' See footnote6
p. S64
See footnote3 p 104' See footnote6
p. S64
See footnote3, p. 25; See footnote4,
p. 27
See footnote3, p. 25; See footnote4,
p. 27
See footnote3, p. 7
See footnote4 p 27
See footnote3, p. 83; See footnote6,
p. S68; See footnote9
See footnote3, p. 83; See footnote6,
p. S68; See footnote9
See footnote3, p. 83; See footnote6,
p. S68; See footnote9
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59. Propham
60. Propoxur
61 . Secbumeton
62. Siduron
63. Simazine
64. Strobane
65 Swep
66 2 4 5-T
67 2 4 5-TP (Silvex)
68 Terbuthylazine
69 Toxaphene
70. Trifluralin
TLC
TLC
TLC
TLC
GC
GC
TLC
GC
GC
GC
GC
GC/MS
GC
608
625
6630 B & C
6640 B
6640 B
6630 B & C
6410 B
6630 B
6410 B-00
D3086-90
05812-96(02).
See footnote3, p. 104; See footnote6,
p. S64
See footnote3, p. 94; See footnote6,
p. S60
See footnote3, p. 83; See footnote6,
p. S68
See footnote3, p. 104; See footnote6,
p. S64
See footnote3, p. 83; See footnote6,
p. S68; See footnote9
See footnote3, p. 7
See footnote3 p 104' See footnote6
p. S64
See footnote3 p 115' See footnote4
p. 40
See footnote3 p 115' See footnote4
p. 40
See footnote3 p 83' See footnote6
p. S68
See footnote3 p 7' See footnote4 p
27; See footnote8
See footnote3. D. 7: See footnote9
1 Pesticides are listed in this table by common name for the convenience of the reader. Additional pesticides may be found under Table 1C, where entries are listed by chemical name.
2The full text of Methods 608 and 625 are given at Appendix A, "Test Procedures for Analysis of Organic Pollutants," of this part 136. The standardized test procedure to be used to
determine the method detection limit (MDL) for these test procedures is given at Appendix B, "Definition and Procedure for the Determination of the Method Detection Limit," of this part
136.
3 "Methods for Benzidine, Chlorinated Organic Compounds, Pentachlorophenol and Pesticides in Water and Wastewater," U.S. Environmental Protection Agency, September 1978. This
EPA publication includes thin-layer chromatography (TLC) methods.
4"Methods for Analysis of Organic Substances in Water and Fluvial Sediments," Techniques of Water-Resources Investigations of the U.S. Geological Survey, Book 5, Chapter A3
(1987).
5The method may be extended to include a-BHC, y-BHC, endosulfan I, endosulfan II, and endrin. However, when they are known to exist, Method 608 is the preferred method.
6 "Selected Analytical Methods Approved and Cited by the United States Environmental Protection Agency." Supplement to the Fifteenth Edition of Standard Methods for the Examina-
tion of Water and Wastewater (1981).
7 Each analyst must make an initial, one-time, demonstration of their ability to generate acceptable precision and accuracy with Methods 608 and 625 (See appendix A of this part 136)
in accordance with procedures given in Section 8.2 of each of these methods. Additionally, each laboratory, on an on-going basis, must spike and analyze 10% of all samples analyzed
with Method 608 or 5% of all samples analyzed with Method 625 to monitor and evaluate laboratory data quality in accordance with Sections 8.3 and 8.4 of these methods. When the re-
covery of any parameter falls outside the warning limits, the analytical results for that parameter in the unspiked sample are suspect. The results should be reported, but cannot be used
to demonstrate regulatory compliance. These quality control requirements also apply to the Standard Methods, ASTM Methods, and other methods cited.
8"Organochlorine Pesticides and PCBs in Wastewater Using Empore™ Disk", 3M Corporation, Revised 10/28/94.
9USGS Method 0-3106-93 from "Methods of Analysis by the U.S. Geological Survey National Water Quality Laboratory—Determination of Triazine and Other Nitrogen-containing
Compounds by Gas Chromatography with Nitrogen Phosphorus Detectors" U.S. Geological Survey Open File Report 94-37.
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TABLE IE—LIST OF APPROVED RADIOLOGIC TEST TEST PROCEDURES
un
Parameter and units
1. Alpha-Total, pCi per liter ....
2. Alpha-Counting error, pCi
per liter.
3 Beta-Total pCi per liter
4. Beta-Counting error, pCi ....
5. (a) Radium Total pCi per
liter.
Method
Proportional or scintillation
counter.
Proportional or scintillation
counter.
Proportional counter
Scintillation counter
Reference (method number or page)
EPA1
9000
Appendix B
9000
Appendix B
9030
903.1
Standard Methods
18th, 19th, 20th Ed.
7110 B
7110 B
7110 B
7110 B
7500- Ra B
7500-RaC
Standard Methods On-
line
71 1 0 B-00
71 1 0 B-00
71 1 0 B-00
7110 B-00
7500-Ra B-01
7500-Ra C-01
ASTM
D1 943-90 96
D1 943-90 96
D1 890-90 96
D1890-90, 96
D2460-90 97
D3454-91, 97
USGS2
pp. 75 and 78 3
p. 79
pp. 75 and 78 3
p. 79
p. 81
1 Prescribed Procedures for Measurement of Radioactivity in Drinking Water, EPA-600/4-80-032 (1980), U.S. Environmental Protection Agency, August 1980.
2Fishman, M. J. and Brown, Eugene, "Selected Methods of the U.S. Geological Survey of Analysis of Wastewaters," U.S. Geological Survey, Open-File Report 76-177 (1976).
3The method found on p. 75 measures only the dissolved portion while the method on p. 78 measures only the suspended portion. Therefore, the two results must be added to obtain the
"total."
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Environmental Protection Agency
§136.3
TABLE IF—LIST OF APPROVED METHODS FOR PHARMACEUTICAL POLLUTANTS
Pharmaceuticals pollutants
aceton itri le
n-amyl acetate
tert-butyl alcohol
chloroform
o-dichlorobenzene
diethylamine
ethyl acetate
n-hexane
isobutyraldehyde
isopropyl acetate
Methyl Cellosolve A
methyl formate
4-methyl-2-pentanone (MIBK)
n-propanol
toluene
xylenes
CAS registry No.
75-05-8
628-63-7
71-41-0
71-43-2
1 23-86-4
75-65-0
1 08-90-7
67-66-3
95-50-1
1 07-06-2
109-89-7
67-68-5
64-1 7-5
141-78-6
1 42-82-5
110-54-3
78-84-2
67-63-0
108-21-4
1 08-20-3
67-56-1
109-86-4
75-09-2
107-31-3
108-10-1
1 08-95-2
71-23-8
67-64-1
1 09-99-9
108-88-3
121^14-8
(Note 1)
Analytical method number
1666/1 671 /D3371/D3695.
1666/D3695.
1 666/D3695
D4763/D3695/502 2/524 2
1 666/D3695
1666.
502 2/524 2
502.2/524.2/551.
1625C/502.2/524.2.
D3695/502 2/524 2
1666/1671.
1 666/1 671
1666/1 671 /D3695
1666/D3695.
1 666/D3695
1666/D3695.
1666/1667.
1 666/D3695
1666/D3695.
1 666/D3695
1666/1 671 /D3695
1666/1671
502 2/524 2
1666.
1 624C/1 666/D3695/D4763/524.2.
D4763
1666/1 671 /D3695.
D3695/D4763/524 2
1 666/524 2
D3695/D4763/502.2/524.2.
1 666/1 671
1624C/1666.
TABLE 1F NOTE:
1. 1624C: m-xylene 108-38-3, o,p-xylene E-14095 (Not a CAS number; this is the number provided in the Environmental
Monitoring Methods Index (EMMI) database.); 1666: m,p-xylene 136777-61-2, o-xylene 95-47-6.
TABLE IG—TEST METHODS FOR PESTICIDE ACTIVE INGREDIENTS
EPA Survey
Code
8
12
16
17
22
25
26
27
30
31
35
39
41
45
52
Pesticide name
Triadimefon
Dichlorvos
2 4-D- 2 4-D Salts and Esters
[2 ,4-Dichloro-phenoxyacetic
acid].
2 4-DB- 2 4-DB Salts and Esters
[2 ,4-Dichlorophenoxybutyric
acid].
Mevinphos
Cyanazine
Propach lor
MCPA- MCPA Salts and Esters
[2-Methyl-4-
chlorophenoxyacetic acid].
Dichlorprop' Dichlorprop Salts
and Esters [2-(2,4-
Dichlorophenoxy) propionic
acid].
MCPP; MCPP Salts and Esters
[2-(2-Methyl-4-chlorophenoxy)
propionic acid].
TCMTB [2-(Thiocyanomethylthio)
benzo-thiazole].
Pronamide
Propanil
Metribuzin
Aceohate
CAS No.
43121-43-3
62-73-7
94_75_7
94-82-6
7786-34-7
21725-46-2
1918-16-7
94_74_6
120-36-5
93-65-2
21564-17-0
23950-58-5
709-98-8
21087-64-9
30560-19-1
EPA Analytical Method No.(s)
507/633/525 1/1656
1657/507/622/525.1
1658/515 1/615/515 2/555
1658/515 1/615/515 2/555
1657/507/622/525.1
629/507
1656/508/608.1/525.1
1658/615/555
1658/515 1/615/515 2/555
1658/615/555
637
525 1/507/633 1
632.1/1656
507/633/525 1/1656
1656/1657
45
April 2011
163
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§ 136.3 40 CFR Ch. I (7-1-10 Edition)
TABLE IG—TEST METHODS FOR PESTICIDE ACTIVE INGREDIENTS—Continued
EPA Survey
Code
53
54
55
58
60
62
68
69
69
70
73
75
76
80
82
84
86
90
103
107
110
112
113
118
119
123
124
125
126
127
132
133
138
140
144
148
150
154
156
158
172
173
175
178
182
183
185
186
192
197
203
204
205
206
208
212
218
Pesticide name
Acifluorfen
Alachlor
Aldicarb
Ametryn
Atrazine
Benomyl
Bromacil; Bromacil Salts and
Esters.
Bromoxynil
Bromoxynil octanoate
Butachlor
Captafol
Carbaryl [Sevin]
Carbof u ra n
Chloroneb
Chlorothalonil
Stirofos
Chlorpyrifos
Fenvalerate
Diazinon
Parathion methyl
DCPA [Dimethyl 2,3,5,6-tetra-
chloro-terephthalate].
Dinoseb
Dioxathion
Nabonate [Disodium cyanodithio-
imidocarbonate].
Diuron
Endothall
Endrin
Ethaltluralin
Ethion
Ethoprop
Fenarimol
Fenthion
Glyphosate [N(Phosphonomethyl)
glycine].
Heptachlor
Isopropalin
Linuron
Malathion
Methamidophos
Methomyl
Methoxychlor
Nabam
Naled
Norflurazon
Bentluralin
Fensulfothion
Disulfoton
Phosmet
Azinphos Methyl
Organo-tin pesticides
Bolstar
Parathion
Pendimethalin
Pentachloronitrobenzene
Pentachlorophenol
Permethrin
Phorate
Busan 85 [Potassium
dimethyldithiocarbamate].
CAS No.
50594-66-6
15972-60-8
116-06-3
834-12-8
1912-24-9
17804-35-2
314-40-9
1689-84-5
1689-99-2
23184-66-9
2425-06-1
63-25-2
1563-66-2
2675-77-6
1897-45-6
961-11-5
2921-88-2
51630-58-1
333-41-5
298-00-0
1861-32-1
88-85-7
78-34-2
138-93-2
330-54-1
145_73_3
72-20-8
55283-68-6
563-12-2
13194-48-4
60168-88-9
55-38-9
1071-83-6
76-44-8
33820-53-0
330-55-2
121-75-5
10265-92-6
16752-77-5
72-43-5
142-59-6
300-76-5
27314-13-2
1861-40-1
115-90-2
298-04-4
732-11-6
86-50-0
12379-54-3
35400-43-2
56-38-2
40487-42-1
82-68-8
87-86-5
52645-53-1
298-02-2
128-03-0
EPA Analytical Method No.(s)
515.1/515.2/555
505/507/645/525.1/1656
531.1
507/619/525.1
505/507/619/525.1/1656
631
507/633/525.1/1656
1625/1661
1656
507/645/525.1/1656
1656
531.1/632/553
531.1/632
1656/508/608.1/525.1
508/608.2/525.1/1656
1657/507/622/525.1
1657/508/622
1660
1657/507/614/622/525.1
1657/614/622
508/608.2/525.1/515.1/515.2/1656
1658/515.1/615/515.2/555
1657/614.1
630.1
632/553
548/548.1
1656/505/508/608/617/525.1
1656/627 See footnote 1
1657/614/614.1
1657/507/622/525.1
507/633.1/525.1/1656
1657/622
547
1656/505/508/608/617/525.1
1656/627
553/632
1657/614
1657
531.1/632
1656/505/508/608.2/617/525.1
630/630.1
1657/622
507/645/525.1/1656
11656/1627
1657/622
1657/507/614/622/525.1
1657/622.1
1657/614/622
lnd-01/200.7/200.9
1657/622
1657/614
1656
1656/608.1/617
625/1625/515.2/555/515.1/ 525.1
608.2/508/525.1/1656/1660
1657/622
630/630.1
46
164
April 2011
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Environmental Protection Agency § 136.3
TABLE IG—TEST METHODS FOR PESTICIDE ACTIVE INGREDIENTS—Continued
EPA Survey
Code
219
220
223
224
226
230
232
236
239
241
243
252
254
255
256
257
259
262
263
264
268
Pesticide name
Busan 40 [Potassium N-
hydroxymethyl-N-
methyldithiocarbamate].
KN Methyl [Potassium N-methyl-
dithiocarbamate].
Prometon
Prometryn
Propazine
Pyrethrin I
Pyrethrin II
DEF [S S S-Tributyl
phosphorotrithioate].
Simazine
Carbam-S [Sodium
dimethyldithiocarbanate].
Vapam [Sodium
methyldithiocarbamate].
Tebuthiuron
Terbacil
Terbufos
Terbuthylazine
Terbutryn
Dazomet
Toxaphene
Merphos [Tributyl
phosphorotrithioate].
Trifluralin
Ziram [Zinc
dimethyldithiocarbamate].
CAS No.
51026-28-9
137_41_7
1610-18-0
7287-19-6
139-40-2
121-21-1
121-29-9
78-48-8
122-34-9
128-04-1
137-42-8
34014-18-1
5902-51-2
13071-79-9
5915_41_3
886-50-0
533_74_4
8001-35-2
150-50-5
1582-09-8
137-30-4
EPA Analytical Method No.(s)
630/630.1
630/630.1
507/619/525 1
507/619/525.1
507/619/525 1/1656
1660
1660
1657
505/507/619/525.1/1656
630/630 1
630/630.1
507/525 1
507/633/525.1/1656
1657/507/614 1/525 1
619/1656
507/619/525.1
630/630 1/1659
1656/505/508/608/617/525 1
1657/507/525.1/622
1656/508/617/627/525 1
630/630.1
1 Monitor and report as total Trifluralin.
47
April 2011
165
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TABLE IH—LIST OF APPROVED MICROBIOLOGICAL METHODS FOR AMBIENT WATER
CO)
Parameter and units
Bacteria:
1. E. coli, number per
100 mL.
per 100 mL.
Protozoa:
4. Giardia
Method 1
MPN 6,8,14 multiple tube,
Multiple tube/multiple well,
MF 2,5,6, 7,8 two step, or
Single step
MPN e,8 multiple tube
MF 2,5,6, 7,8 (wo step
Single step, or
Filtration/I MS/FA
Filtration/IMS/FA
EPA
1103.1"
160320, 160421
1106.1 23
160024.
p 1433
162225,162326
162326.
Standard
methods 18th, 19th,
20th Ed.
9221 B.1/9221 F".«
9223 B«
9222 B/9222 G ™
9213 D.
9230 B
9230 C
Standard methods
online
9221 B. 1-99/9221
F 11,13
9223 B-97'2
9222 B-97/9222Q18
9230 B-93
9230 C-93
AOAC, ASTM, USGS
991.1510
D5392-939.
D6503-99 9
D5259-929.
Other
Colilert* 12,16 Colilert-
18® 1 2, 1 5, 1 e
mColiBlue-24®17.
Enterolert®12,22
1 The method must be specified when results are reported.
2 A 0.45 |im membrane filter (MF) or other pore size certified by the manufacturer to fully retain organisms to be cultivated and to be free of extractables which could interfere with their
growth.
3USEPA. 1978. Microbiological Methods for Monitoring the Environment, Water, and Wastes. Environmental Monitoring and Support Laboratory, U.S. Environmental Protection Agency,
Cincinnati, OH. EPA/600/8-78/017.
4 [Reserved]
5 Bec
Because the MF technique usually yields low and variable recovery from chlorinated wastewaters, the Most Probable Number method will be required to resolve any controversies.
6Tests must be conducted to provide organism enumeration (density). Select the appropriate configuration of tubes/filtrations and dilutions/volumes to account for the quality, character,
consistency, and anticipated organism density of the water sample.
7When the MF method has not been used previously to test waters with high turbidity, large number of noncoliform bacteria, or samples that may contain organisms stressed by chlorine,
a parallel test should be conducted with a multiple-tube technique to demonstrate applicability and comparability of results.
8To assess the comparability of results obtained with individual methods, it is suggested that side-by-side tests be conducted across seasons of the year with the water samples routinely
tested in accordance with the most current Standard Methods for the Examination of Water and Wastewater or EPA alternate test procedure (ATP) guidelines.
9ASTM. 2000, 1999, 1996. Annual Book of ASTM Standards— Water and Environmental Technology. Section 11.02. ASTM International. 100 Barr Harbor Drive, West Conshohocken, PA
19428.
10AOAC. 1995. Official Methods of Analysis of AOAC International, 16th Edition, Volume I, Chapter 17. Association of Official Analytical Chemists International. 481 North Frederick Ave-
nue, Suite 500, Gaithersburg, MD 20877-2417.
11 The multiple-tube fermentation test is used in 9221 B.1. Lactose broth may be used in lieu of lauryl tryptose broth (LTB), if at least 25 parallel tests are conducted between this broth and
LTB using the water samples normally tested, and this comparison demonstrates that the false- positive rate and false-negative rate for total coliform using lactose broth is less than 10 per-
cent. No requirement exists to run the completed phase on 10 percent of all total coliform-positive tubes on a seasonal basis.
12These tests are collectively known as defined enzyme substrate tests, where, for example, a substrate is used to detect the enzyme ^-glucuronidase produced by E. coli.
13After prior enrichment in a presumptive medium for total coliform using 9221B.1, all presumptive tubes or bottles showing any amount of gas, growth or acidity within 48 h ± 3 h of incu-
bation shall be submitted to 9221 F. Commercially available EC-MUG media or EC media supplemented in the laboratory with 50 |ig/mL of MUG may be used.
14 Samples shall be enumerated by the multiple-tube or multiple-well procedure. Using multiple-tube procedures, employ an appropriate tube and dilution configuration of the sample as
needed and report the Most Probable Number (MPN). Samples tested with Colilert® may be enumerated with the multiple-well procedures, Quanti-Tray® or Quanti-Tray® 2000, and the
MPN calculated from the table provided by the manufacturer.
15Colilert-18® is an optimized formulation of the Colilert® for the determination of total coliforms and E. coli that provides results within 18 h of incubation at 35 °C rather than the 24 h re-
quired for the Colilert® test and is recommended for marine water samples.
^Descriptions of the Colilert®, Colilert-18®, Quanti-Tray®, and Quanti-Tray®/2000 may be obtained from IDEXX Laboratories, Inc., 1 IDEXX Drive, Westbrook, ME 04092.
17 A description of the mColiBlue24® test, Total Coliforms and E. coli, is available from Hach Company, 100 Dayton Ave., Ames, IA 50010.
18Subject total coliform positive samples determined by 9222B or other membrane filter procedure to 9222G using NA-MUG media.
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19USEPA. July 2006. Method 1103.1: Escherlchla col! (E. coif) in Water by Membrane Filtration Using membrane-Thermotolerant Escherichia coll Agar (mTEC). U.S. Environmental Pro- E3J1
tection Agency, Office of Water, Washington, DC EPA-821-R-06-010. 5
20USEPA. July 2006. Method 1603: Escherichia coli (E. coif) in Water by Membrane Filtration Using Modified membrane-Thermotolerant Escherichia coli Agar (Modified mTEC). U.S. En- ^'
vironmental Protection Agency, Office of Water, Washington, DC EPA-821-R-06-011. O
21 Preparation and use of Ml agar with a standard membrane filter procedure is set forth in the article, Brenner et al. 1993. "New Medium for the Simultaneous Detection of Total Coliform D
and Escherichia coli in Water." Appl. Environ. Microbiol. 59:3534-3544 and in USEPA. September 2002.: Method 1604: Total Coliforms and Escherichia coli (E. coli) in Water by Membrane D
Filtration by Using a Simultaneous Detection Technique (Ml Medium). U.S. Environmental Protection Agency, Office of Water, Washington, DC EPA 821-R-02-024. ~
22 A description of the Enterolert* test may be obtained from IDEXX Laboratories, Inc., 1 IDEXX Drive, Westbrook, ME 04092. J-J
23USEPA. July 2006. Method 1106.1: Enterococci in Water by Membrane Filtration Using membrane-Enterococcus-Esculin Iron Agar (mE-EIA). U.S. Environmental Protection Agency, —i-
Office of Water, Washington, DC EPA-821-R-06-008. Q.
24USEPA. July 2006. Method 1600: Enterococci in Water by Membrane Filtration Using membrane-Enterococcus Indoxyl-fi-D-Glucoside Agar (mEI). U.S. Environmental Protection Agen-
cy, Office of Water, Washington, DC EPA-821-R-06-009. I?
25 Method 1622 uses filtration, concentration, immunomagnetic separation of oocysts from captured material, immunofluorescence assay to determine concentrations, and confirmation O
through vital dye staining and differential interference contrast microscopy for the detection of Cryptosporidium. USEPA. 2001. Method 1622: Cryptosporidium in Water by Filtration/IMS/FA. jj\"
U.S. Environmental Protection Agency, Office of Water, Washington, DC EPA-821-R-01-026. f)
26 Method 1623 uses filtration, concentration, immunomagnetic separation of oocysts and cysts from captured material, immunofluorescence assay to determine concentrations, and con- 3;
firmation through vital dye staining and differential interference contrast microscopy for the simultaneous detection of Cryptosporidium and Giardia oocysts and cysts. USEPA. 2001. Method O
1623. Cryptosporidium and Giardia in Water by Filtration/IMS/FA. U.S. Environmental Protection Agency, Office of Water, Washington, DC EPA-821-R-01-025. 3
>
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§136.3
40 CFR Ch. I (7-1-10 Edition)
(b) The full texts of the methods from
the following references which are
cited In Tables IA, IB, 1C, ID, IE, IF, IG
and IH are Incorporated by reference
Into this regulation and may be ob-
tained from the source Identified. All
costs cited are subject to change and
must be verified from the Indicated
source. The full texts of all the test
procedures cited are available for In-
spection at the National Archives and
Records Administration (NARA). For
Information on the availability of this
material at NARA, call 202-741-6030, or
go to: http://www.archives.gov/
federal register/
code of_federal regulations/
ibr locations.html.
REFERENCES, SOURCES, COSTS, AND
TABLE CITATIONS:
(1) The full texts of Methods 601-613,
624, 625, 1613, 1624, and 1625 are printed
In appendix A of this part 136. The full
text for determining the method detec-
tion limit when using the test proce-
dures Is given In appendix B of this
part 136. The full text of Method 200.7 Is
printed In appendix C of this part 136.
Cited In: Table IB, Note 5; Table 1C,
Note 2; and Table ID, Note 2.
(2) USEPA. 1978. Microbiological
Methods for Monitoring the Environ-
ment, Water, and Wastes. Environ-
mental Monitoring and Support Lab-
oratory, U.S. Environmental Protec-
tion Agency, Cincinnati, Ohio. EPA/600/
8-78/017. Available at http://
www.epa.gov/clariton/srch.htm or from:
National Technical Information Serv-
ice, 5285 Port Royal Road, Springfield,
Virginia 22161, Pub. No. PB-290329/A.S.
Table IA, Note 3; Table IH, Note 3.
(3) "Methods for Chemical Analysis
of Water and Wastes," U.S. Environ-
mental Protection Agency, EPA-600/4-
79-020, March 1979, or "Methods for
Chemical Analysis of Water and
Wastes," U.S. Environmental Protec-
tion Agency, EPA-600/4-79-020, Revised
March 1983. Available from: ORD Publi-
cations, CERI, U.S. Environmental
Protection Agency, Cincinnati, Ohio
45268, Table IB, Note 1.
(4) "Methods for Benzldlne,
Chlorinated Organic Compounds,
Pentachlorophenol and Pesticides In
Water and Wastewater," U.S. Environ-
mental Protection Agency, 1978. Avail-
able from: ORD Publications, CERI,
U.S. Environmental Protection Agen-
cy, Cincinnati, Ohio 45268, Table 1C,
Note 3; Table D, Note 3.
(5) "Prescribed Procedures for Meas-
urement of Radioactivity In Drinking
Water," U.S. Environmental Protec-
tion Agency, EPA-600/4-80-032, 1980.
Available from: ORD Publications,
CERI, U.S. Environmental Protection
Agency, Cincinnati, Ohio 45268, Table
IE, Note 1.
(6) American Public Health Associa-
tion. 1992, 1995, and 1998. Standard
Methods for the Examination of Water
and Wastewater. 18th, 19th, and 20th
Edition (respectively). Available from:
American Public Health Association,
1015 15th Street, NW., Washington, DC
20005. Standard Methods Online Is
available through the Standard Meth-
ods Web site (http://
www.standardmethods.org). Tables IA,
IB, 1C, ID, IE, and IH.
(7) Ibid, 15th Edition, 1980. Table IB,
Note 30; Table ID.
(8) Ibid, 14th Edition, 1975. Table IB,
Notes 17 and 27.
(9) "Selected Analytical Methods Ap-
proved and Cited by the United States
Environmental Protection Agency,"
Supplement to the 15th Edition of
Standard Methods for the Examination
of Water and Wastewater, 1981. Avail-
able from: American Public Health As-
sociation, 1015 Fifteenth Street NW.,
Washington, DC 20036. Cost available
from publisher. Table IB, Note 10;
Table 1C, Note 6; Table ID, Note 6.
(10) ASTM International. Annual
Book of ASTM Standards, Water, and
Environmental Technology, Section 11,
Volumes 11.01 and 11.02, 1994, 1996, 1999,
Volume 11.02, 2000, and Individual
standards published after 2000. Avail-
able from: ASTM International, 100
Barr Harbor Drive, P.O. Box C700, West
Conshohocken, PA 19428-2959, or http://
www.astm.org. Tables IA, IB, 1C, ID, IE,
and IH.
(11) USGS. 1989. U.S. Geological Sur-
vey Techniques of Water-Resources In-
vestigations, Book 5, Laboratory Anal-
ysis, Chapter A4, Methods for Collec-
tion and Analysis of Aquatic Biological
and Microbiological Samples, U.S. Geo-
logical Survey, U.S. Department of the
Interior, Reston, Virginia. Available
50
168
April 2011
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Environmental Protection Agency
§136.3
from USGS Books and Open-File Re-
ports Section, Federal Center, Box
25425, Denver, Colorado 80225. Table IA,
Note 5; Table IH.
(12) "Methods for Determination of
Inorganic Substances in Water and
Fluvial Sediments," by M.J. Fishman
and Linda C. Friedman, Techniques of
Water-Resources Investigations of the
U.S. Geological Survey, Book 5 Chapter
Al (1989). Available from: U.S. Geologi-
cal Survey, Denver Federal Center, Box
25425, Denver, CO 80225. Cost: $108.75
(subject to change). Table IB, Note 2.
(13) "Methods for Determination of
Inorganic Substances in Water and
Fluvial Sediments," N.W. Skougstad
and others, editors. Techniques of
Water-Resources Investigations of the
U.S. Geological Survey, Book 5, Chap-
ter Al (1979). Available from: U.S. Geo-
logical Survey, Denver Federal Center,
Box 25425, Denver, CO 80225. Cost: $10.00
(subject to change), Table IB, Note 8.
(14) "Methods for the Determination
of Organic Substances in Water and
Fluvial Sediments," Wershaw, R.L., et
al, Techniques of Water-Resources In-
vestigations of the U.S. Geological Sur-
vey, Book 5, Chapter A3 (1987). Avail-
able from: U.S. Geological Survey,
Denver Federal Center, Box 25425, Den-
ver, CO 80225. Cost: $0.90 (subject to
change). Table IB, Note 24; Table ID,
Note 4.
(15) "Water Temperature—Influential
Factors, Field Measurement and Data
Presentation," by H.H. Stevens, Jr., J.
Ficke, and G.F. Smoot, Techniques of
Water-Resources Investigations of the
U.S. Geological Survey, Book 1, Chap-
ter Dl, 1975. Available from: U.S. Geo-
logical Survey, Denver Federal Center,
Box 25425, Denver, CO 80225. Cost: $1.60
(subject to change). Table IB, Note 32.
(16) "Selected Methods of the U.S.
Geological Survey of Analysis of
Wastewaters," by M.J. Fishman and
Eugene Brown; U.S. Geological Survey
Open File Report 76-77 (1976). Available
from: U.S. Geological Survey, Branch
of Distribution, 1200 South Eads Street,
Arlington, VA 22202. Cost: $13.50 (sub-
ject to change). Table IE, Note 2.
(17) AOAC-International. Official
Methods of Analysis of AOAC-Inter-
national, 16th Edition, (1995). Available
from: AOAC-International, 481 North
Frederick Avenue, Suite 500, Gaithers-
burg, MD 20877. Table IB, See footnote
3.
(18) "American National Standard on
Photographic Processing Effluents,"
April 2, 1975. Available from: American
National Standards Institute, 1430
Broadway, New York, New York 10018.
Table IB, Note 9.
(19) "An Investigation of Improved
Procedures for Measurement of Mill Ef-
fluent and Receiving Water Color,"
NCASI Technical Bulletin No. 253, De-
cember 1971. Available from: National
Council of the Paper Industry for Air
and Stream Improvements, Inc., 260
Madison Avenue, New York, NY 10016.
Cost available from publisher. Table
IB, Note 18.
(20) Ammonia, Automated Electrode
Method, Industrial Method Number
379-75WE, dated February 19, 1976.
Technicon Auto Analyzer II. Method
and price available from Technicon In-
dustrial Systems, Tarrytown, New
York 10591. Table IB, Note 7.
(21) Chemical Oxygen Demand, Meth-
od 8000, Hach Handbook of Water Anal-
ysis, 1979. Method price available from
Hach Chemical Company, P.O. Box 389,
Loveland, Colorado 80537. Table IB,
Note 14.
(22) QIC Chemical Oxygen Demand
Method, 1978. Method and price avail-
able from Oceanography International
Corporation, 512 West Loop, P.O. Box
2980, College Station, Texas 77840.
Table IB, Note 13.
(23) ORION Research Instruction
Manual, Residual Chlorine Electrode
Model 97-70, 1977. Method and price
available from ORION Research Incor-
poration, 840 Memorial Drive, Cam-
bridge, Massachusetts 02138. Table IB,
Note 16.
(24) Bicinchoninate Method for Cop-
per. Method 8506, Hach Handbook of
Water Analysis, 1979, Method and price
available from Hach Chemical Com-
pany, P.O. Box 300, Loveland, Colorado
80537. Table IB, Note 19.
(25) Hydrogen Ion (pH) Automated
Electrode Method, Industrial Method
Number 378-75WA. October 1976. Bran &
Luebbe (Technicon) Auto Analyzer II.
Method and price available from Bran
& Luebbe Analyzing Technologies, Inc.
Elmsford, N.Y. 10523. Table IB, Note 21.
(26) 1,10-Phenanthroline Method
using FerroVer Iron Reagent for Water,
51
April 2011
169
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§136.3
40 CFR Ch. I (7-1-10 Edition)
Hach Method 8008, 1980. Method and
price available from Hach Chemical
Company, P.O. Box 389 Loveland, Colo-
rado 80537. Table IB, Note 22.
(27) Periodate Oxidation Method for
Manganese, Method 8034, Hach Hand-
book for Water Analysis, 1979. Method
and price available from Hach Chem-
ical Company, P.O. Box 389, Loveland,
Colorado 80537. Table IB, Note 23.
(28) Nitrogen, Nitrite—Low Range,
Diazotization Method for Water and
Wastewater, Hach Method 8507, 1979.
Method and price available from Hach
Chemical Company, P.O. Box 389,
Loveland, Colorado 80537. Table IB,
Note 25.
(29) Zincon Method for Zinc, Method
8009. Hach Handbook for Water Anal-
ysis, 1979. Method and price available
from Hach Chemical Company, P.O.
Box 389, Loveland, Colorado 80537.
Table IB, Note 33.
(30) "Direct Determination of Ele-
mental Phosphorus by Gas-Liquid
Chromatography," by R.F. Addison and
R.G. Ackman, Journal of Chroma-
tography, Volume 47, No. 3, pp. 421-426,
1970. Available in most public libraries.
Back volumes of the Journal of Chro-
matography are available from
Elsevier/North-Holland, Inc., Journal
Information Centre, 52 Vanderbilt Ave-
nue, New York, NY 10164. Cost avail-
able from publisher. Table IB, Note 28.
(31) "Direct Current Plasma (DCP)
Optical Emission Spectrometric Meth-
od for Trace Elemental Analysis of
Water and Wastes", Method AES 0029,
1986-Revised 1991, Fison Instruments,
Inc., 32 Commerce Center, Cherry Hill
Drive, Danvers, MA 01923. Table B,
Note 34.
(32) "Closed Vessel Microwave Diges-
tion of Wastewater Samples for Deter-
mination of Metals, GEM Corporation,
P.O. Box 200, Matthews, North Carolina
28106-0200, April 16, 1992. Available from
the GEM Corporation. Table IB, Note
36.
(33) "Organochlorine Pesticides and
PCBs in Wastewater Using Empore™
Disk" Test Method 3M 0222, Revised 107
28/94. 3M Corporation, 3M Center Build-
ing 220-9E-10, St. Paul, MN 55144-1000.
Method available from 3M Corporation.
Table 1C, Note 8 and Table ID, Note 8.
(34) USEPA. October 2002. Methods
for Measuring the Acute Toxicity of
Effluents and Receiving Waters to
Freshwater and Marine Organisms.
Fifth Edition. U.S. Environmental Pro-
tection Agency, Office of Water, Wash-
ington, DC EPA 821-R-02-012. Available
at http://www.epa.gov/epahome/index/
sources.htm or from National Technical
Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161, Pub.
No. PB2002-108488. Table IA, Note 25.
(35) "Nitrogen, Total Kjeldahl, Meth-
od PAI-DK01 (Block Digestion, Steam
Distillation, Titrimetric Detection)",
revised 12/22/94. Available from
Perstorp Analytical Corporation, 9445
SW Ridder Rd., Suite 310, P.O. Box 648,
Wilsonville, OK 97070. Table IB, Note
39.
(36) "Nitrogen, Total Kjeldahl, Meth-
od PAI-DK02 (Block Digestion, Steam
Distillation, Colorimetric Detection)",
revised 12/22/94. Available from
Perstorp Analytical Corporation, 9445
SW Ridder Rd., Suite 310, P.O. Box 648,
Wilsonville, OK 97070. Table IB, Note
40.
(37) "Nitrogen, Total Kjeldahl, Meth-
od PAI-DK03 (Block Digestion, Auto-
mated FIA Gas Diffusion)", revised 127
22/94. Available from Perstorp Analyt-
ical Corporation, 9445 SW Ridder Rd.,
Suite 310, P.O. Box 648, Wilsonville, OK
97070. Table IB, Note 41.
(38) USEPA. October 2002. Short-
Term Methods for Measuring the
Chronic Toxicity of Effluents and Re-
ceiving Waters to Freshwater Orga-
nisms. Fourth Edition. U.S. Environ-
mental Protection Agency, Office of
Water, Washington, DC EPA 821-R-02-
013. Available at http://www.epa.gov/
epahome/index/sources.htm or from Na-
tional Technical Information Service,
5285 Port Royal Road, Springfield, Vir-
ginia 22161, Pub. No. PB2002-108489.
Table IA, Note 26.
(39) USEPA. October 2002. Short-
Term Methods for Measuring the
Chronic Toxicity of Effluents and Re-
ceiving Waters to Marine and Estua-
rine Organisms. Third Edition. U.S.
Environmental Protection Agency, Of-
fice of Water, Washington, DC EPA 821-
R-02-014. Available at http://
www.epa.gov/epahome/index/sources.htm
or from National Technical Informa-
tion Service, 5285 Port Royal Road,
Springfield, Virginia 22161, Pub. No.
PB2002-108490. Table IA, Note 27.
52
170
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Environmental Protection Agency
§136.3
(40) EPA Methods 1666, 1667, and 1671
listed in the table above are published
in the compendium titled Analytical
Methods for the Determination of Pol-
lutants in Pharmaceutical Manufac-
turing Industry Wastewaters (EPA 821-
B-98-016). EPA Methods 502.2 and 524.2
have been incorporated by reference
into 40 CFR 141.24 and are in Methods
for the Determination of Organic Com-
pounds in Drinking Water, EPA-600/4-
88-039, December 1988, Revised, July
1991, and Methods for the Determina-
tion of Organic Compounds in Drinking
Water-Supplement II, EPA-600/R-92-
129, August 1992, respectively. These
EPA test method compendia are avail-
able from the National Technical Infor-
mation Service, NTIS PB91-231480 and
PB92-207703, U.S. Department of Com-
merce, 5285 Port Royal Road, Spring-
field, Virginia 22161. The toll-free num-
ber is 800-553-6847. ASTM test methods
D3371, D3695, and D4763 are available
from the American Society for Testing
and Materials, 100 Barr Harbor Drive,
West Conshohocken, PA 19428-2959.
(41) USEPA. 2002. Method 1631, Revi-
sion E, "Mercury in Water by Oxida-
tion, Purge and Trap, and Cold Vapor
Atomic Fluorescence Spectrometry."
September 2002. Office of Water, U.S.
Environmental Protection Agency
(EPA-821-R-02-019). Available from:
National Technical Information Serv-
ice, 5285 Port Royal Road, Springfield,
Virginia 22161. Publication No. PB2002-
108220. Cost: $25.50 (subject to change).
(42) [Reserved]
(43) Method OIA-1677, Available Cya-
nide by Flow Injection, Ligand Ex-
change, and Amperometry. August
1999. ALPKEM, OI Analytical, Box 648,
Wilsonville, Oregon 97070 (EPA-821-R-
99-013). Available from: National Tech-
nical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22161.
Publication No. PB99-132011. Cost:
$22.50. Table IB, Note 44.
(44) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory Determination of
Ammonium Plus Organic Nitrogen by a
Kjeldahl Digestion Method and an
Automated Photometric Finish that
Includes Digest Cleanup by Gas Diffu-
sion", Open File Report (OFR) 00-170.
Available from: U.S. Geological Sur-
vey, Denver Federal Center, Box 25425,
Denver, CO 80225. Table IB, Note 45.
(45) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Chromium in Water by Graphite Fur-
nace Atomic Absorption
Spectrophotometry", Open File Report
(OFR) 93^149. Available from: U.S. Geo-
logical Survey, Denver Federal Center,
Box 25425, Denver, CO 80225. Table IB,
Note 46.
(46) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Molybdenum in Water by Graphite
Furnace Atomic Absorption
Spectrophotometry", Open File Report
(OFR) 97-198. Available from: U.S. Geo-
logical Survey, Denver Federal Center,
Box 25425, Denver, CO 80225. Table IB,
Note 47.
(47) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Total Phosphorus by Kjeldahl Diges-
tion Method and an Automated Colori-
metric Finish That Includes Dialysis"
Open File Report (OFR) 92-146. Avail-
able from: U.S. Geological Survey,
Denver Federal Center, Box 25425, Den-
ver, CO 80225. Table IB, Note 48.
(48) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Arsenic and Selenium in Water and
Sediment by Graphite Furnace—Atom-
ic Absorption Spectrometry" Open File
Report (OFR) 98-639. Table IB, Note 49.
(49) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Elements in Whole-Water Digests
Using Inductively Coupled Plasma-Op-
tical Emission Spectrometry and In-
ductively Coupled Plasma-Mass Spec-
trometry" , Open File Report (OFR) 98-
165. Available from: U.S. Geological
Survey, Denver Federal Center, Box
25425, Denver, CO 80225. Table IB, Note
50.
(50) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Triazine and Other Nitrogen-con-
taining Compounds by Gas Chroma-
tography with Nitrogen Phosphorus
Detectors" U.S.Geological Survey Open
File Report 94-37. Available from: U.S.
53
April 2011
171
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§136.3
40 CFR Ch. I (7-1-10 Edition)
Geological Survey, Denver Federal
Center, Box 25425, Denver, CO 80225.
Table ID, Note 9.
(51) "Methods of Analysis by the U.S.
Geological Survey National Water
Quality Laboratory—Determination of
Inorganic and Organic Constituents In
Water and Fluvial Sediments", Open
File Report (OFR) 93-125. Available
from: U.S. Geological Survey, Denver
Federal Center, Box 25425, Denver, CO
80225. Table IB, Note 51; Table 1C, Note
9.
(52) IDEXX Laboratories, Inc. 2002.
Description of Colllert®, Colllert-18®,
Quantl-Tray®, Quantl-Tray®/2000,
Enterolert® methods are available
from IDEXX Laboratories, Inc., One
Idexx Drive, Westbrook, Maine 04092.
Table IA, Notes 17 and 23; Table IH,
Notes 16 and 22.
(53) Hach Company, Inc. Revision 2,
1999. Description of m-CollBlue24®
Method, Total Conforms and E. coli, Is
available from Hach Company, 100 Day-
ton Ave, Ames IA 50010. Table IA, Note
18; Table IH, Note 17.
(54) USEPA. July 2006. Method 1103.1:
Escherichia coli (E. coli) In Water by
Membrane Filtration Using membrane-
Thermotolerant Escherichia coli Agar
(mTEC). U.S. Environmental Protec-
tion Agency, Office of Water, Wash-
ington DC EPA-621-R-06-010. Available
at http://www.epa.gov/water'science/meth-
ods/. Table IH, Note 19.
(55) USEPA. July 2006. Method 1106.1:
Enterococcl In Water by Membrane
Filtration Using membrane-
Enterococcus-Esculln Iron Agar (mE-
EIA). U.S. Environmental Protection
Agency, Office of Water, Washington
DC EPA-621-R-06-008. Available at
http://www.epa.gov/waterscience/methods/.
Table IH, Note 23
(56) USEPA. July 2006. Method 1603:
Escherichia coli (E. coli) In Water by
Membrane Filtration Using Modified
membrane-Thermotolerant Escherichia
coli Agar (Modified mTEC). U.S. Envi-
ronmental Protection Agency, Office of
Water, Washington DC EPA-821-R-06-
011. Available at http://www.epa.gov/
waterscience/methods/. Table IH, Note 19;
Table IH, Note 20.
(57) Brenner et al. 1993. New Medium
for the Simultaneous Detection of
Total Conforms and Escherichia coli In
Water. Appl. Environ. Mlcroblol.
59:3534-3544. Available from the Amer-
ican Society for Microbiology, 1752 N
Street NW., Washington DC 20036.
Table IH, Note 21.
(58) USEPA. September 2002. Method
1604: Total Conforms and Escherichia
coli (E. coli) In Water by Membrane Fil-
tration Using a Simultaneous Detec-
tion Technique (MI Medium). U.S. En-
vironmental Protection Agency, Office
of Water, Washington DC EPA-821-R-
02-024. Available at http://www.epa.gov/
waterscience/methods/. Table IH, Note 20.
(59) USEPA. July 2006. Method 1600:
Enterococcl In Water by Membrane
Filtration Using membrane-
Enterococcus Indoxyl-p-D-Glucoslde
Agar (mEI). U.S. Environmental Pro-
tection Agency, Office of Water, Wash-
ington DC EPA-821-R-06-009. Available
at http://www.epa.gov/waterscience/meth-
ods/. Table IA, Note 24; Table IH, Note
24.
(60) USEPA. April 2001. Method 1622:
Cryptosporidium In Water by Filtration/
IMS/FA. U.S. Environmental Protec-
tion Agency, Office of Water, Wash-
ington DC EPA-821-R-01-026. Available
at http://www.epa.gov/waterscience/meth-
ods/. Table IH, Note 25.
(61) USEPA. April 2001. Method 1623:
Cryptosporidium and Giardia In Water
by Flltratlon/IMS/FA. U.S. Environ-
mental Protection Agency, Office of
Water, Washington DC. EPA-821-R-01-
025. Available at http://www.epa.gov/
waterscience/methods/. Table IH, Note 26.
(62) AOAC. 1995. Official Methods of
Analysis of AOAC International, 16th
Edition, Volume I, Chapter 17. AOAC
International, 481 North Frederick Av-
enue, Suite 500, Galthersburg, Mary-
land 20877-2417. Table IA, Note 11; Table
IH.
(63) Waters Corporation. Method
D6508, Rev. 2, "Test Method for Deter-
mination of Dissolved Inorganic Anlons
In Aqueous Matrices Using Capillary
Ion Electrophoresls and Chromate
Electrolyte," available from Waters
Corp, 34 Maple Street, Mllford, MA
01757, Telephone: 508/482-2131, Fax: 508/
482-3625, Table IB, See footnote 54.
(64) Kelada-01, "Kelada Automated
Test Methods for Total Cyanide, Acid
Dissociable Cyanide, and
Thlocyanate," EPA 821-B-01-009 Revi-
sion 1.2, August 2001 Is available from
54
172
April 2011
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Environmental Protection Agency
§136.3
National Technical Information Serv-
ice (NTIS), 5285 Port Royal Road,
Springfield, VA 22161 [Order Number
PB 2001-108275]. Telephone: 800-553-6847.
Table IB, See footnote 55.
(65) QuikChem Method 10-204-00-1-X,
"Digestion and Distillation of Total
Cyanide in Drinking and Wastewaters
using MICRO DIST and Determination
of Cyanide by Flow Injection Analysis"
Revision 2.2, March 2005 is available
from Lachat Instruments 6645 W. Mill
Road, Milwaukee, WI 53218, Telephone:
414-358^1200. Table IB, See footnote 56.
(66) "Methods for the Determination
of Metals in Environmental Samples,"
Supplement I, National Exposure Risk
Laboratory-Cincinnati (NERL-CI),
EPA/600/R-94/111, May 1994; and "Meth-
ods for the Determination of Inorganic
Substances in Environmental Sam-
ples," NERL-CI, EPA/600/R-93/100, Au-
gust, 1993 are available from National
Technical Information Service (NTIS),
5285 Port Royal Road, Springfield, VA
22161. Telephone: 800-553-6847. Table IB.
(67) "Determination of Inorganic Ions
in Drinking Water by Ion Chroma-
tography," Rev. 1.0, 1997 is available
from from http://www.epa.gov/safetwater/
methods/metSOO.pdf. Table IB.
(68) Table IG Methods are available
in "Methods For The Determination of
Nonconventional Pesticides In Munic-
ipal and Industrial Wastewater, Vol-
ume I," EPA 821-R-93-010A, August
1993 Revision I, and "Methods For The
Determination of Nonconventional
Pesticides In Municipal and Industrial
Wastewater, Volume II," EPA 821-R-
93-010B (August 1993) are available
from National Technical Information
Service (NTIS), 5285 Port Royal Road,
Springfield, VA 22161. Telephone: 800-
553-6847.
(69) Method 245.7, Rev. 2.0, "Mercury
in Water by Cold Vapor Atomic Fluo-
rescence Spectrometry," February
2005, EPA-821-R-05-001, available from
the U.S. EPA Sample Control Center
(operated by CSC), 6101 Stevenson Ave-
nue, Alexandria, VA 22304, Telephone:
703-461-8056. Table IB, See footnote 59.
(70) USEPA. July 2006. Method 1680:
Fecal Coliforms in Sewage Sludge (Bio-
solids) by Multiple-Tube Fermentation
using Lauryl Tryptose Broth (LTB) and
EC Medium. U.S. Environmental Pro-
tection Agency, Office of Water, Wash-
ington DC. EPA 821-R-06-012. Available
at http://www.epa.gov/waterscience/meth-
ods/.
(71) USEPA. July 2006. Method 1681:
Fecal Coliforms in Sewage Sludge (Bio-
solids) by Multiple-Tube Fermentation
using A-l Medium. U.S. Environmental
Protection Agency, Office of Water,
Washington DC. EPA 821-R-06-013.
Available at http://www.epa.gov/
waterscience/methods/.
(72) USEPA. July 2006. Method 1682:
Salmonella in Sewage Sludge (Biosolids)
by Modified Semisolid Rappaport-
Vassiliadis (MSRV) Medium. U.S. Envi-
ronmental Protection Agency, Office of
Water, Washington DC. EPA 821-R-06-
014. Available at http://www.epa.gov/
waterscience/methods/.
(c) Under certain circumstances, the
Regional Administrator or the Director
in the Region or State where the dis-
charge will occur may determine for a
particular discharge that additional
parameters or pollutants must be re-
ported. Under such circumstances, ad-
ditional test procedures for analysis of
pollutants may be specified by the Re-
gional Administrator, or the Director
upon recommendation of the Alternate
Test Procedure Program Coordinator,
Washington, DC.
(d) Under certain circumstances, the
Administrator may approve additional
alternate test procedures for nation-
wide use, upon recommendation by the
Alternate Test Procedure Program Co-
ordinator, Washington, DC.
(e) Sample preservation procedures,
container materials, and maximum al-
lowable holding times for parameters
are cited in Tables IA, IB, 1C, ID, IE,
IF, IG and IH are prescribed in Table
II. Information in the table takes prec-
edence over information in specific
methods or elsewhere. Any person may
apply for a variance from the pre-
scribed preservation techniques, con-
tainer materials, and maximum hold-
ing times applicable to samples taken
from a specific discharge. Applications
for variances may be made by letters
to the Regional Administrator in the
Region in which the discharge will
occur. Sufficient data should be pro-
vided to assure such variance does not
adversely affect the integrity of the
sample. Such data will be forwarded by
55
April 2011
173
-------
§136.3
40 CFR Ch. I (7-1-10 Edition)
the Regional Administrator, to the Al-
ternate Test Procedure Program Coor-
dinator, Washington, DC, for technical
review and recommendations for action
on the variance application. Upon re-
ceipt of the recommendations from the
Alternate Test Procedure Program Co-
ordinator, the Regional Administrator
may grant a variance applicable to the
specific discharge to the applicant. A
decision to approve or deny a variance
will be made within 90 days of receipt
of the application by the Regional Ad-
ministrator.
TABLE II—REQUIRED CONTAINERS, PRESERVATION TECHNIQUES, AND HOLDING TIMES
Parameter No. /name
Table IA— Bacterial Tests:
coli.
Q. Fecal streptococci
7. Enterococci
Table IA — Aquatic Toxicity Tests:
Table IB — Inorganic Tests:
1. Acidity
2. Alkalinity
4. Ammonia
10 Boron
14. Biochemical oxygen demand,
carbonaceous.
16. Chloride
17. Chlorine, total residual
21 Color
23-24. Cyanide, total or available
(or CATC).
25. Fluoride
27. Hardness
28 Hydrogen ion (pH)
31 43 Kjeldahl and organic N
Table IB— Metals:7
18 Chromium VI
35 Mercury (CVAA)
35. Mercury (CVAFS)
3, 5-8, 12, 13, 19, 20, 22, 26, 29,
30, 32-34, 36, 37, 45, 47, 51, 52,
58-60, 62, 63, 70-72, 74, 75.
Metals, except boron, chromium VI,
and mercury.
38 Nitrate
39. Nitrate-nitrite
40 Nitrite
46. Oxygen, Dissolved Probe
47. Winkler
48 Phenols
49. Phosphorous (elemental)
50. Phosphorous, total
54. Residue, Filterable
55 Residue Nonfilterable (TSS)
56. Residue. Settleable
Container 1
PA G
PA, G
PA, G
PA G
P FP G
P, FP, G
P, FP, G
P, FP, G
P FP G
P FP or Quartz
P FP G
P, FPG
P FP G
P, FP, G
P, G
P FP G
P, FP, G
P
P, FP, G
P FP G
P FP G
P FP G
P FP G
FP, G; and FP-lined
cap".
P, FP, G
P FP G
P, FP, G
P FP G
G
P FP G
P FP G
G, Bottle and top
G, Bottle and top
G
G
P, FP, G
P FP G
P, FP, G
P FP G
P. FP. G
Preservation 2.3
Cool <10°C 00008%
Na2S2035
Cool, <10°C, 0.0008%
Na2S2035.
Cool, <10°C, 0.0008%
Na2S2035
Cool <10°C 00008%
Na2S2035.
Cool <6°C16
Cool, <6°C18
Cool, <6°C18
Cool, <6°C'8, H2S04to pH<2 ...
Cool <6°C18
HNO3 to pH<2
Cool, <6°C18
Cool <6°C18 H2SO4topH<2
None required
None required
Cool <6°C18
Cool, <6°C18, NaOH to pH>126,
reducing agent5.
None required
HNO3 or H2SO4 to pH<2
Cool <6°C18 H2SO4topH<2
Cool <6°C18 pH-93-9720
HNO3 to pH<2
5 mL/L 12N HCI or 5 mL/L
BrCI".
HNO3 to pH<2, or at least 24
hours prior to analysis19.
Cool <6°C18
Cool, <6°C18, H2S04to pH<2 ..
Cool <6°C18
Cool to <6°C18 HCI or H2SO4
to pH<2.
Coolto<6°C18 HCI H2SO4 or
H3PO4 to pH<2.
Cool <6°C18
None required
Fix on site and store in dark
Coo <6°C18 H2SO4topH<2
Coo, <6°C18
Coo, <6°C'8, H2S04to pH<2 ..
Coo <6°C18
Coo, <6°C18
Coo <6°C18
Coo. <6°C18
Maximum holding
time 4
6 hours 22-23
6 hours.22
6 hours.22
6 hours 22
36 hours
14 days.
14 days.
28 days.
28 days
48 hours.
28 days
28 days.
Analyze within 15
minutes.
14 days.
28 days.
6 months.
minutes.
28 days
28 days
28 days
90 days."
6 months.
28 days.
28 days
28 days
utes; Analyze with-
in 48 hours.
Analyze within 15
minutes.
8 hours.
28 days
48 hours.
28 days.
7 days.
48 hours.
56
174
April 2011
-------
Environmental Protection Agency § 136.3
TABLE II—REQUIRED CONTAINERS, PRESERVATION TECHNIQUES, AND HOLDING TIMES—Continued
Parameter No. /name
57. Residue, Volatile
61 Silica
64. Specific conductance
65 Sulfate
66. Sulfide
67 Sulfite
68 Surfactants
69. Temperature
73 Turbidity
Table 1C— Organic Tests8
13, 18-20, 22, 24-28, 34-37, 39-
43, 45-47, 56, 76, 104, 105,
108-111, 113. Purgeable
Halocarbons.
6, 57, 106. Purgeable aromatic hy-
drocarbons.
3, 4. Acrolein and acrylonitrile
23, 30, 44, 49, 53, 77, 80, 81, 98,
100, 112. Phenols11.
7, 38. Benzidines11-12
14, 17, 48, 50-52. Phthalate
esters 1 1 .
82-84. Nitrosamines11-14
88-94 PCBs11
54, 55, 75, 79. Nitroaromatics and
isophorone11.
1, 2, 5, 8-12, 32, 33, 58, 59, 74,
78, 99, 101. Polynudear aromatic
hydrocarbons11.
15, 16, 21, 31, 87. Haloethers11 ....
29, 35-37, 63-65, 107. Chlorinated
hydrocarbons11.
60-62, 66-72, 85, 86, 95-97, 102,
103. CDDs/CDFs11.
Aqueous Samples: Field and Lab
Preservation.
Solids and Mixed-Phase Samples:
Field Preservation.
Tissue Samples: Field Preservation
Solids, Mixed-Phase, and Tissue
Samples: Lab Preservation.
Table ID— Pesticides Tests:
1-70. Pesticides11
Table IE — Radiological Tests:
1—5 Alpha beta and radium
Table I H— Bacterial Tests:
1. E. coli
2 Enterococci
Table IH — Protozoan Tests:
8. CrvDtosooridium
Container 1
P, FP, G
P or Quartz
P, FP, G
P FP G
P, FP, G
P FP G
P FP G
P, FP, G
P FP G
G, FP-lined septum ...
G, FP-lined septum ...
G, FP-lined septum ...
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G, FP-lined cap
G
G
G
G
G, FP-lined cap
P FP G
PA, G
PA G
LDPE: field filtration ..
Preservation 2-3
Coo, <6°C18
Coo <6°C18
Coo, <6°C18
Coo <6°C18
Coo, <6°C18, add zinc acetate
plus sodium hydroxide to
pH>9.
None required
Cool <6°C18
None required
Cool <6°C18
Cool, <6°C18, 0.008%
Na2S2035.
Cool, <6°C18, 0.008%
Na2S2035, HCItopH29.
Cool, <6°C18, 0.008%
Na2S2O35, pHto4-510.
Cool, <6°C18, 0.008%
Na2S2035
Cool, <6°C18, 0.008%
Na2S2035
Cool <6°C18
Cool, <6°C18, store in dark,
0.008% Na2S2O35.
Cool <6°C18
Cool, <6°C18, store in dark,
0.008% Na2S2O35
Cool, <6°C18, store in dark,
0.008% Na2S2O35
Cool, <6°C18, 0.008%
Na2S2035.
Cool, <6°C18
Cool, <6°C18, 0.008%
Na2S2O35, pH<9.
Cool, <6°C18
Cool <6°C18
Freeze, <-10°C
Cool, <6°C18, pH 5-915
HNO3 to pH<2
Cool, <10°C, 0.0008%
Na2S2035
Cool, <10°C, 0.0008%
Na2S2035
0-8°C
Maximum holding
time 4
7 days.
28 days.
28 days.
28 days.
7 days.
Analyze within 15
minutes.
48 hours.
Analyze.
48 hours.
14 days.
14 days.9
14 days.10
7 days until extrac-
tion, 40 days after
extraction.
7 days until extrac-
tion.13
7 days until extrac-
tion, 40 days after
extraction.
7 days until extrac-
tion, 40 days after
extraction.
1 year until extrac-
tion, 1 year after
extraction.
7 days until extrac-
tion, 40 days after
extraction.
7 days until extrac-
tion, 40 days after
extraction.
7 days until extrac-
tion, 40 days after
extraction.
7 days until extrac-
tion, 40 days after
extraction.
1 year.
7 days.
24 hours.
1 year.
7 days until extrac-
tion, 40 days after
extraction.
6 months.
6 hours.22
6 hours.22
96 hours.21
57
April 2011
175
-------
§ 136.3 40 CFR Ch. I (7-1-10 Edition)
TABLE II—REQUIRED CONTAINERS, PRESERVATION TECHNIQUES, AND HOLDING TIMES—Continued
Parameter No. /name
9. Giardia
Container 1
LDPE: field filtration ..
Preservation 2-3
0-8°C
Maximum holding
time 4
96 hours.21
1 "P" is polyethylene; "FP" is fluoropolymer (polytetrafluoroethylene (PTFE; Teflon®), or other fluoropolymer, unless stated oth-
erwise in this Table II; "G" is glass; "PA" is any plastic that is made of a sterlizable material (polypropylene or other autoclavable
plastic); "LDPE" is low density polyethylene.
2Except where noted in this Table II and the method for the parameter, preserve each grab sample within 15 minutes of col-
lection. For a composite sample collected with an automated sampler (e.g., using a 24-hour composite sampler; see 40 CFR
122.21(g)(7)(i) or 40 CFR part 403, Appendix E), refrigerate the sample at <6°C during collection unless specified otherwise in
this Table II or in the method(s). For a composite sample to be split into separate aliquots for preservation and/or analysis, main-
tain the sample at <6°C, unless specified otherwise in this Table II or in the method(s), until collection, splitting, and preservation
is completed. Add the preservative to the sample container prior to sample collection when the preservative will not compromise
the integrity of a grab sample, a composite sample, or an aliquot split from a composite sample; otherwise, preserve the grab
sample, composite sample, or aliquot split from a composite sample within 15 minutes of collection. If a composite measurement
is required but a composite sample would compromise sample integrity, individual grab samples must be collected at prescribed
time intervals (e.g., 4 samples over the course of a day, at 6-hour intervals). Grab samples must be analyzed separately and the
concentrations averaged. Alternatively, grab samples may be collected in the field and composited in the laboratory if the
compositing procedure produces results equivalent to results produced by arithmetic averaging of the results of analysis of indi-
vidual grab samples. For examples of laboratory compositing procedures, see EPA Method 1664A (oil and grease) and the pro-
cedures at 40 CFR 141.34(f)(14)(iv) and (v) (volatile organics).
3When any sample is to be shipped by common carrier or sent via the U.S. Postal Service, it must comply with the Depart-
ment of Transportation Hazardous Materials Regulations (49 CFR part 172). The person offering such material for transportation
is responsible for ensuring such compliance. For the preservation requirements of Table II, the Office of Hazardous Materials,
Materials Transportation Bureau, Department of Transportation has determined that the Hazardous Materials Regulations do not
apply to the following materials: Hydrochloric acid (HCI) in water solutions at concentrations of 0.04% by weight or less (pH
about 1.96 or greater); Nitric acid (HNOs) in water solutions at concentrations of 0.15% by weight or less (pH about 1.62 or
greater); Sulfuric acid (^SCU) in water solutions at concentrations of 0.35% by weight or less (pH about 1.15 or greater); and
Sodium hydroxide (NaOH) in water solutions at concentrations of 0.080% by weight or less (pH about 12.30 or less).
4 Samples should be analyzed as soon as possible after collection. The times listed are the maximum times that samples may
be held before the start of analysis and still be considered valid (e.g., samples analyzed for fecal coliforms may be held up to 6
hours prior to commencing analysis). Samples may be held for longer periods only if the permittee or monitoring laboratory has
data on file to show that, for the specific types of samples under study, the analytes are stable for the longer time, and has re-
ceived a variance from the Regional Administrator under §136.3(e). For a grab sample, the holding time begins at the time of
collection. For a composite sample collected with an automated sampler (e.g., using a 24-hour composite sampler; see 40 CFR
122.21(g)(7)(i) or 40 CFR part 403, Appendix E), the holding time begins at the time of the end of collection of the composite
sample. For a set of grab samples composited in the field or laboratory, the holding time begins at the time of collection of the
last grab sample in the set. Some samples may not be stable for the maximum time period given in the table. A permittee or
monitoring laboratory is obligated to hold the sample for a shorter time if it knows that a shorter time is necessary to maintain
sample stability. See §136.3(e) for details. The date and time of collection of an individual grab sample is the date and time at
which the sample is collected. For a set of grab samples to be composited, and that are all collected on the same calendar date,
the date of collection is the date on which the samples are collected. For a set of grab samples to be composited, and that are
collected across two calendar dates, the date of collection is the dates of the two days; e.g., November 14-15. For a composite
sample collected automatically on a given date, the date of collection is the date on which the sample is collected. For a com-
posite sample collected automatically, and that is collected across two calendar dates, the date of collection is the dates of the
two days; e.g., November 14-15.
5Add a reducing agent only if an oxidant (e.g., chlorine) is present. Reducing agents shown to be effective are sodium
thiosulfate (Na2S2O3), ascorbic acid, sodium arsenite (NaAsO;:), or sodium borohydride (NaBH4). However, some of these
agents have been shown to produce a positive or negative cyanide bias, depending on other substances in the sample and the
analytical method used. Therefore, do not add an excess of reducing agent. Methods recommending ascorbic acid (e.g., EPA
Method 335.4) specify adding ascorbic acid crystals, 0.1-0.6 g, until a drop of sample produces no color on potassium iodide
(Kl) starch paper, then adding 0.06 g (60 mg) for each liter of sample volume. If NaBH4 or NaAsO2 is used, 25 mg/L NaBH4 or
100 mg/L NaAsO2 will reduce more than 50 mg/L of chlorine (see method "Kelada-01" and/or Standard Method 4500-CN- for
more information). After adding reducing agent, test the sample using Kl paper, a test strip (e.g. for chlorine, SenSafe™ Total
Chlorine Water Check 480010) moistened with acetate buffer solution (see Standard Method 4500-CI.C.3e), or a chlorine/oxi-
dant test method (e.g., EPA Method 330.4 or 330.5), to make sure all oxidant is removed. If oxidant remains, add more reducing
agent. Whatever agent is used, it should be tested to assure that cyanide results are not affected adversely.
6 Sample collection and preservation: Collect a volume of sample appropriate to the analytical method in a bottle of the mate-
rial specified. If the sample can be analyzed within 48 hours and sulfide is not present, adjust the pH to > 12 with sodium hy-
droxide solution (e.g., 5% w/v), refrigerate as specified, and analyze within 48 hours. Otherwise, to extend the holding time to 14
days and mitigate interferences, treat the sample immediately using any or all of the following techniques, as necessary, followed
by adjustment of the sample pH to > 12 and refrigeration as specified. There may be interferences that are not mitigated by ap-
proved procedures. Any procedure for removal or suppression of an interference may be employed, provided the laboratory dem-
onstrates that it more accurately measures cyanide. Particulate cyanide (e.g., ferric ferrocyanide) or a strong cyanide complex
(e.g., cobalt cyanide) are more accurately measured if the laboratory holds the sample at room temperature and pH > 12 for a
minimum of 4 hours prior to analysis, and performs UV digestion or dissolution under alkaline (pH=12) conditions, if necessary.
(1) Sulfur: To remove elemental sulfur (S8), filter the sample immediately. If the filtration time will exceed 15 minutes, use a
larger filter or a method that requires a smaller sample volume (e.g., EPA Method 335.4 or Lachat Method 01). Adjust the pH of
the filtrate to > 12 with NaOH, refrigerate the filter and filtrate, and ship or transport to the laboratory. In the laboratory, extract
the filter with 100 mL of 5% NaOH solution for a minimum of 2 hours. Filter the extract and discard the solids. Combine the 5%
NaOH-extracted filtrate with the initial filtrate, lower the pH to approximately 12 with concentrated hydrochloric or sulfuric acid,
and analyze the combined filtrate. Because the detection limit for cyanide will be increased by dilution by the filtrate from the sol-
ids, test the sample with and without the solids procedure if a low detection limit for cyanide is necessary. Do not use the solids
procedure if a higher cyanide concentration is obtained without it. Alternatively, analyze the filtrates from the sample and the sol-
ids separately, add the amounts determined (in |ig or mg), and divide by the original sample volume to obtain the cyanide con-
centration.
58
176 April 2011
-------
Environmental Protection Agency § 136.3
(2) Sulfide: If the sample contains sulfide as determined by lead acetate paper, or if sulfide is known or suspected to be
present, immediately conduct one of the volatilization treatments or the precipitation treatment as follows: Volatilization—
Headspace expelling. In a fume hood or well-ventilated area, transfer 0.75 liter of sample to a 4.4 L collapsible container (e.g.,
Cubitainer™). Acidify with concentrated hydrochloric acid to pH < 2. Cap the container and shake vigorously for 30 seconds. Re-
move the cap and expel the headspace into the fume hood or open area by collapsing the container without expelling the sam-
ple. Refill the headspace by expanding the container. Repeat expelling a total of five headspace volumes. Adjust the pH to > 12,
refrigerate, and ship or transport to the laboratory. Scaling to a smaller or larger sample volume must maintain the air to sample
volume ratio. A larger volume of air will result in too great a loss of cyanide (> 10%). Dynamic stripping: In a fume hood or well-
ventilated area, transfer 0.75 liter of sample to a container of the material specified and acidify with concentrated hydrochloric
acid to pH < 2. Using a calibrated air sampling pump or flowmeter, purge the acidified sample into the fume hood or open area
through a fritted glass aerator at a flow rate of 2.25 L/min for 4 minutes. Adjust the pH to > 12, refrigerate, and ship or transport
to the laboratory. Scaling to a smaller or larger sample volume must maintain the air to sample volume ratio. A larger volume of
air will result in too great a loss of cyanide (> 10%). Precipitation: If the sample contains particulate matter that would be re-
moved by filtration, filter the sample prior to treatment to assure that cyanide associated with the particulate matter is included in
the measurement. Ship or transport the filter to the laboratory. In the laboratory, extract the filter with 100 ml_ of 5% NaOH solu-
tion for a minimum of 2 hours. Filter the extract and discard the solids. Combine the 5% NaOH-extracted filtrate with the initial fil-
trate, lower the pH to approximately 12 with concentrated hydrochloric or sulfuric acid, and analyze the combined filtrate. Be-
cause the detection limit for cyanide will be increased by dilution by the filtrate from the solids, test the sample with and without
the solids procedure if a low detection limit for cyanide is necessary. Do not use the solids procedure if a higher cyanide con-
centration is obtained without it. Alternatively, analyze the filtrates from the sample and the solids separately, add the amounts
determined (in |ig or mg), and divide by the original sample volume to obtain the cyanide concentration. For removal of sulfide
by precipitation, raise the pH of the sample to > 12 with NaOH solution, then add approximately 1 mg of powdered cadmium
chloride for each ml_ of sample. For example, add approximately 500 mg to a 500-mL sample. Cap and shake the container to
mix. Allow the precipitate to settle and test the sample with lead acetate paper. If necessary, add cadmium chloride but avoid
adding an excess. Finally, filter through 0.45 micron filter. Cool the sample as specified and ship or transport the filtrate and filter
to the laboratory. In the laboratory, extract the filter with 100 ml_ of 5% NaOH solution for a minimum of 2 hours. Filter the ex-
tract and discard the solids. Combine the 5% NaOH-extracted filtrate with the initial filtrate, lower the pH to approximately 12 with
concentrated hydrochloric or sulfuric acid, and analyze the combined filtrate. Because the detection limit for cyanide will be in-
creased by dilution by the filtrate from the solids, test the sample with and without the solids procedure if a low detection limit for
cyanide is necessary. Do not use the solids procedure if a higher cyanide concentration is obtained without it. Alternatively, ana-
lyze the filtrates from the sample and the solids separately, add the amounts determined (in |ig or mg), and divide by the original
sample volume to obtain the cyanide concentration. If a ligand-exchange method is used (e.g., ASTM D6888), it may be nec-
essary to increase the ligand-exchange reagent to offset any excess of cadmium chloride.
(3) Sulfite, thiosulfate, or thiocyanate: If sulfite, thiosulfate, or thiocyanate is known or suspected to be present, use UV diges-
tion with a glass coil (Method Kelada-01) or ligand exchange (Method OIA-1677) to preclude cyanide loss or positive inter-
ference.
(4) Aldehyde: If formaldehyde, acetaldehyde, or another water-soluble aldehyde is known or suspected to be present, treat the
sample with 20 ml_ of 3.5% ethylenediamine solution per liter of sample.
(5) Carbonate: Carbonate interference is evidenced by noticeable effervescence upon acidification in the distillation flask, a re-
duction in the pH of the absorber solution, and incomplete cyanide spike recovery. When significant carbonate is present, adjust
the pH to >12 using calcium hydroxide instead of sodium hydroxide. Allow the precipitate to settle and decant or filter the sample
prior to analysis (also see Standard Method 4500-CN.B.3.d).
(6) Chlorine, hypochlorite, or other oxidant: Treat a sample known or suspected to contain chlorine, hypochlorite, or other oxi-
dant as directed in footnote 5.
7 For dissolved metals, filter grab samples within 15 minutes of collection and before adding preservatives. For a composite
sample collected with an automated sampler (e.g., using a 24-hour composite sampler; see 40 CFR 122.21(g)(7)(i) or 40 CFR
part 403, appendix E), filter the sample within 15 minutes after completion of collection and before adding preservatives. If it is
known or suspected that dissolved sample integrity will be compromised during collection of a composite sample collected auto-
matically over time (e.g., by interchange of a metal between dissolved and suspended forms), collect and filter grab samples to
be composited (footnote 2) in place of a composite sample collected automatically.
8 Guidance applies to samples to be analyzed by GC, LC, or GC/MS for specific compounds.
9 If the sample is not adjusted to pH 2, then the sample must be analyzed within seven days of sampling.
10The pH adjustment is not required if acrolein will not be measured. Samples for acrolein receiving no pH adjustment must
be analyzed within 3 days of sampling.
11 When the extractable analytes of concern fall within a single chemical category, the specified preservative and maximum
holding times should be observed for optimum safeguard of sample integrity (i.e., use all necessary preservatives and hold for
the shortest time listed). When the analytes of concern fall within two or more chemical categories, the sample may be preserved
by cooling to <6°C, reducing residual chlorine with 0.008% sodium thiosulfate, storing in the dark, and adjusting the pH to 6-9;
samples preserved in this manner may be held for seven days before extraction and for forty days after extraction. Exceptions to
this optional preservation and holding time procedure are noted in footnote 5 (regarding the requirement for thiosulfate reduc-
tion), and footnotes 12, 13 (regarding the analysis of benzidine).
12 If 1,2-diphenylhydrazine is likely to be present, adjust the pH of the sample to 4.0 ± 0.2 to prevent rearrangement to benzi-
dine.
13 Extracts may be stored up to 30 days at < 0 °C.
14 For the analysis of diphenylnitrosamine, add 0.008% Na2S2Oa and adjust pH to 7-10 with NaOH within 24 hours of sam-
pling.
15The pH adjustment may be performed upon receipt at the laboratory and may be omitted if the samples are extracted within
72 hours of collection. For the analysis of aldrin, add 0.008% Na2S2O3.
16Sufficient ice should be placed with the samples in the shipping container to ensure that ice is still present when the sam-
ples arrive at the laboratory. However, even if ice is present when the samples arrive, it is necessary to immediately measure the
temperature of the samples and confirm that the preservation temperature maximum has not been exceeded. In the isolated
cases where it can be documented that this holding temperature cannot be met, the permittee can be given the option of on-site
testing or can request a variance. The request for a variance should include supportive data which show that the toxicity of the
effluent samples is not reduced because of the increased holding temperature.
17Samples collected for the determination of trace level mercury (<100 ng/L) using EPA Method 1631 must be collected in
tightly-capped fluoropolymer or glass bottles and preserved with BrCI or HCI solution within 48 hours of sample collection. The
time to preservation may be extended to 28 days if a sample is oxidized in the sample bottle. A sample collected for dissolved
trace level mercury should be filtered in the laboratory within 24 hours of the time of collection. However, if circumstances pre-
clude overnight shipment, the sample should be filtered in a designated clean area in the field in accordance with procedures
given in Method 1669. If sample integrity will not be maintained by shipment to and filtration in the laboratory, the sample must
be filtered in a designated clean area in the field within the time period necessary to maintain sample integrity. A sample that has
been collected for determination of total or dissolved trace level mercury must be analyzed within 90 days of sample collection.
18Aqueous samples must be preserved at <6°C, and should not be frozen unless data demonstrating that sample freezing
does not adversely impact sample integrity is maintained on file and accepted as valid by the regulatory authority. Also, for pur-
poses of NPDES monitoring, the specification of "< °C" is used in place of the "4 °C" and "< 4 °C" sample temperature require-
ments listed in some methods. It is not necessary to measure the sample temperature to three significant figures (1/iooth of 1 de-
gree); rather, three significant figures are specified so that rounding down to 6 °C may not be used to meet the <6°C require-
ment. The preservation temperature does not apply to samples that are analyzed immediately (less than 15 minutes).
59
April 2011 177
-------
§136.4
40 CFR Ch. I (7-1-10 Edition)
19An aqueous sample may be collected and shipped without acid preservation. However, acid must be added at least 24
hours before analysis to dissolve any metals that adsorb to the container walls. If the sample must be analyzed within 24 hours
of collection, add the acid immediately (see footnote 2). Soil and sediment samples do not need to be preserved with acid. The
allowances in this footnote supersede the preservation and holding time requirements in the approved metals methods.
20To achieve the 28-day holding time, use the ammonium sulfate buffer solution specified in EPA Method 218.6. The allow-
ance in this footnote supersedes preservation and holding time requirements in the approved hexavalent chromium methods, un-
less this supersession would compromise the measurement, in which case requirements in the method must be followed.
21 Holding time is calculated from time of sample collection to elution for samples shipped to the laboratory in bulk and cal-
culated from the time of sample filtration to elution for samples filtered in the field.
22 Samples analysis should begin immediately, preferably within 2 hours of collection. The maximum transport time to the lab-
oratory is 6 hours, and samples should be processed within 2 hours of receipt at the laboratory.
23 For fecal coliform samples for sewage sludge (biosolids) only, the holding time is extended to 24 hours for the following
sample types using either EPA Method 1680 (LTB-EC) or 1681 (A-1): Class A composted, Class B aerobically digested, and
Class B anaerobically digested.
[38 FR 28758, Oct. 16, 1973]
EDITORIAL NOTE: For FEDERAL REGISTER citations affecting § 136.3, see the List of CFR Sec-
tions Affected, which appears in the Finding Aids section of the printed volume and on GPO
Access.
§ 136.4 Application for alternate test
procedures.
(a) Any person may apply to the Re-
gional Administrator In the Region
where the discharge occurs for ap-
proval of an alternative test procedure.
(b) When the discharge for which an
alternative test procedure Is proposed
occurs within a State having a permit
program approved pursuant to section
402 of the Act, the applicant shall sub-
mit his application to the Regional Ad-
ministrator through the Director of
the State agency having responsibility
for Issuance of NPDES permits within
such State.
(c) Unless and until printed applica-
tion forms are made available, an ap-
plication for an alternate test proce-
dure may be made by letter In trip-
licate. Any application for an alternate
test procedure under this paragraph (c)
shall:
(1) Provide the name and address of
the responsible person or firm making
the discharge (If not the applicant) and
the applicable ID number of the exist-
ing or pending permit, Issuing agency,
and type of permit for which the alter-
nate test procedure Is requested, and
the discharge serial number.
(2) Identify the pollutant or param-
eter for which approval of an alternate
testing procedure Is being requested.
(3) Provide justification for using
testing procedures other than those
specified In Table I.
(4) Provide a detailed description of
the proposed alternate test procedure,
together with references to published
studies of the applicability of the alter-
nate test procedure to the effluents In
question.
(d) An application for approval of an
alternate test procedure for nationwide
use may be made by letter In triplicate
to the Alternate Test Procedure Pro-
gram Coordinator, Office of Science
and Technology (4303), Office of Water,
U.S. Environmental Protection Agen-
cy, 1200 Pennsylvania Ave., NW., Wash-
ington, DC 20460. Any application for
an alternate test procedure under this
paragraph (d) shall:
(1) Provide the name and address of
the responsible person or firm making
the application.
(2) Identify the pollutant(s) or pa-
rameter(s) for which nationwide ap-
proval of an alternate testing proce-
dure Is being requested.
(3) Provide a detailed description of
the proposed alternate procedure, to-
gether with references to published or
other studies confirming the general
applicability of the alternate test pro-
cedure to the pollutant(s) or param-
eter^) In waste water discharges from
representative and specified Industrial
or other categories.
(4) Provide comparability data for
the performance of the proposed alter-
nate test procedure compared to the
performance of the approved test pro-
cedures.
[38 FR 28760, Oct. 16, 1973, as amended at 41
FR 52785, Dec. 1, 1976; 62 FR 30763, June 5,
1997; 72 FR 11239, Mar. 12, 2007]
§ 136.5 Approval of alternate test pro-
cedures.
(a) The Regional Administrator of
the region In which the discharge will
60
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April 2011
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Environmental Protection Agency
§136.6
occur has final responsibility for ap-
proval of any alternate test procedure
proposed by the responsible person or
firm making the discharge.
(b) Within thirty days of receipt of an
application, the Director will forward
such application proposed by the re-
sponsible person or firm making the
discharge, together with his rec-
ommendations, to the Regional Admin-
istrator. Where the Director rec-
ommends rejection of the application
for scientific and technical reasons
which he provides, the Regional Ad-
ministrator shall deny the application
and shall forward this decision to the
Director of the State Permit Program
and to the Alternate Test Procedure
Program Coordinator, Office of Science
and Technology (4303), Office of Water,
U.S. Environmental Protection Agen-
cy, 1200 Pennsylvania Ave., NW., Wash-
ington, DC 20460.
(c) Before approving any application
for an alternate test procedure pro-
posed by the responsible person or firm
making the discharge, the Regional
Administrator shall forward a copy of
the application to the Alternate Test
Procedure Program Coordinator, Office
of Science and Technology (4303), Office
of Water, U.S. Environmental Protec-
tion Agency, 1200 Pennsylvania Ave.,
NW., Washington, DC 20460.
(d) Within ninety days of receipt by
the Regional Administrator of an ap-
plication for an alternate test proce-
dure, proposed by the responsible per-
son or firm making the discharge, the
Regional Administrator shall notify
the applicant and the appropriate
State agency of approval or rejection,
or shall specify the additional informa-
tion which is required to determine
whether to approve the proposed test
procedure. Prior to the expiration of
such ninety day period, a recommenda-
tion providing the scientific and other
technical basis for acceptance or rejec-
tion will be forwarded to the Regional
Administrator by the Alternate Test
Procedure Program Coordinator, Wash-
ington, DC. A copy of all approval and
rejection notifications will be for-
warded to the Alternate Test Proce-
dure Program Coordinator, Office of
Science and Technology (4303), Office of
Water, U.S. Environmental Protection
Agency, 1200 Pennsylvania Ave., NW.,
Washington, DC 20460, for the purposes
of national coordination.
(e) Approval for nationwide use. (1) As
expeditiously as is practicable after re-
ceipt by the Alternate Test Procedure
Program Coordinator, Washington, DC,
of an application for an alternate test
procedure for nationwide use, the Al-
ternate Test Procedure Program Coor-
dinator, Washington, DC, shall notify
the applicant in writing whether the
application is complete. If the applica-
tion is incomplete, the applicant shall
be informed of the information nec-
essary to make the application com-
plete.
(2) As expeditiously as is practicable
after receipt of a complete package,
the Alternate Test Procedure Program
Coordinator shall perform any analysis
necessary to determine whether the al-
ternate test procedure satisfies the ap-
plicable requirements of this part, and
the Alternate Test Procedure Program
Coordinator shall recommend to the
Administrator that he/she approve or
reject the application and shall also
notify the application of the rec-
ommendation.
(3) As expeditiously as practicable,
an alternate method determined by the
Administrator to satisfy the applicable
requirements of this part shall be pro-
posed by EPA for incorporation in sub-
section 136.3 of 40 CFR part 136. EPA
shall make available for review all the
factual bases for its proposal, including
any performance data submitted by the
applicant and any available EPA anal-
ysis of those data.
(4) Following a period of public com-
ment, EPA shall, as expeditiously as
practicable, publish in the FEDERAL
REGISTER a final decision to approve or
reject the alternate method.
[38 FR 28760, Oct. 16, 1973, as amended at 41
FR 52785, Dec. 1, 1976; 55 FR 33440, Aug. 15,
1990; 62 FR 30763, June 5, 1997; 72 FR 11239,
Mar. 12, 2007]
§ 136.6 Method modifications and ana-
lytical requirements.
(a) Definitions of terms used in this sec-
tion.
(1) Analyst means the person or lab-
oratory using a test procedure (analyt-
ical method) in this Part.
(2) Chemistry of the method means the
reagents and reactions used in a test
61
April 2011
179
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§136.6
40 CFR Ch. I (7-1-10 Edition)
procedure that allow determination of
the analyte(s) of Interest In an environ-
mental sample.
(3) Determinative technique means the
way In which an analyte Is Identified
and quantified (e.g., colorlmetry, mass
spectrometry).
(4) Equivalent Performance means that
the modified method produces results
that meet the QC acceptance criteria of
the approved method at this part.
(5) Method-defined analyte means an
analyte defined solely by the method
used to determine the analyte. Such an
analyte may be a physical parameter, a
parameter that Is not a specific chem-
ical, or a parameter that may be com-
prised of a number of substances. Ex-
amples of such analytes Include tem-
perature, oil and grease, total sus-
pended solids, total phenollcs, tur-
bidity, chemical oxygen demand, and
biochemical oxygen demand.
(6) QC means "quality control."
(b) Method modifications—(1) Allowable
changes. Except as set forth In para-
graph (b)(3) of this section, an analyst
may modify an approved test procedure
(analytical method) provided that the
chemistry of the method or the deter-
minative technique Is not changed, and
provided that the requirements of para-
graph (b)(2) of this section are met.
(1) Potentially acceptable modifica-
tions regardless of current method per-
formance Include changes between
automated and manual discrete Instru-
mentation; changes In the calibration
range (provided that the modified
range covers any relevant regulatory
limit); changes In equipment such as
using similar equipment from a vendor
other than that mentioned In the
method (e.g., a purge-and-trap device
from OIA rather than Tekmar),
changes In equipment operating pa-
rameters such as changing the moni-
toring wavelength of a colorimeter or
modifying the temperature program for
a specific GC column; changes to
chromatographlc columns (treated In
greater detail In paragraph (d) of this
section); and Increases In purge-and-
trap sample volumes (provided speci-
fications In paragraph (e) of this sec-
tion are met). The changes are only al-
lowed provided that all the require-
ments of paragraph (b)(2) of this sec-
tion are met.
(11) If the characteristics of a waste-
water matrix prevent efficient recov-
ery of organic pollutants and prevent
the method from meeting QC require-
ments, the analyst may attempt to re-
solve the Issue by using salts as speci-
fied In Guidance on Evaluation, Resolu-
tion, and Documentation of Analytical
Problems Associated with Compliance
Monitoring (EPA 821-B-93-001, June
1993), provided that such salts do not
react with or Introduce the target pol-
lutant Into the sample (as evidenced by
the analysis of method blanks, labora-
tory control samples, and spiked sam-
ples that also contain such salts) and
that all requirements of paragraph
(b)(2) of this section are met.
Chlorinated samples must be
dechlorlnated prior to the addition of
such salts.
(Ill) If the characteristics of a waste-
water matrix result In poor sample dis-
persion or reagent deposition on equip-
ment and prevents the analyst from
meeting QC requirements, the analysts
may attempt to resolve the Issue by
adding an Inert surfactant (i.e. a sur-
factant that will not affect the chem-
istry of the method), which may In-
clude Brlj-35 or sodium dodecyl sulfate
(SDS), provided that such surfactant
does not react with or Introduce the
target pollutant Into the sample (as
evidenced by the analysis of method
blanks, laboratory control samples,
and spiked samples that also contain
such surfactant) and that all require-
ments of paragraph (b)(2) of this sec-
tion are met. Chlorinated samples
must be dechlorlnated prior to the ad-
dition of such surfactant.
(2) Requirements. A modified method
must produce equivalent performance
to the approved methods for the
analyte(s) of Interest, and the equiva-
lent performance must be documented.
(1) Requirements for establishing equiv-
alent performance
(A) If the approved method contains
QC tests and QC acceptance criteria,
the modified method must use these QC
tests and the modified method must
meet the QC acceptance criteria. The
Analyst may only rely on QC tests and
QC acceptance criteria In a method If
It Includes wastewater matrix QC tests
and QC acceptance criteria (e.g., as ma-
trix spikes) and both Initial (start-up)
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April 2011
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Environmental Protection Agency
§136.6
and ongoing QC tests and QC accept-
ance criteria.
(B) If the approved method does not
contain QC tests and QC acceptance
criteria, or if the QC tests and QC ac-
ceptance criteria in the method do not
meet the requirements of paragraph
(b)(2)(l)(A) of this section, the analyst
must employ QC tests specified in Pro-
tocol for EPA Approval of Alternate Test
Procedures for Organic and Inorganic
Analytes in Waste-water and Drinking
Water (EPA-821-B-98-002, March 1999)
and meet the QC provisions specified
therein. In addition, the Analyst must
perform on-going QC tests, including
assessment of performance of the modi-
fied method on the sample matrix (e.g.,
analysis of a matrix spike/matrix spike
duplicate pair for every twenty sam-
ples of a discharge analyzed), and anal-
ysis of an ongoing precision and recov-
ery sample and a blank with each
batch of 20 or fewer samples.
(C) Calibration must be performed
using the modified method and the
modified method must be tested with
every wastewater matrix to which it
will be applied (up to nine distinct
matrices; as described in the ATP Pro-
tocol, after validation in nine distinct
matrices, the method may be applied
to all wastewater matrices), in addi-
tion to any and all reagent water tests.
If the performance in the wastewater
matrix or reagent water does not meet
the QC acceptance criteria the method
modification may not be used.
(D) Analysts must test representa-
tive effluents with the modified meth-
od, and demonstrate that the results
are equivalent or superior to results
with the unmodified method.
(ii) Requirements for documentation.
The modified method must be docu-
mented in a method write-up or an ad-
dendum that describes the modifica-
tion^) to the approved method. The
write-up or addendum must include a
reference number (e.g., method num-
ber), revision number, and revision
date so that it may be referenced accu-
rately. In addition, the organization
that uses the modified method must
document the results of QC tests and
keep these records, along with a copy
of the method write-up or addendum,
for review by an auditor.
(3) Restrictions. An analyst may not
modify an approved analytical method
for a method-defined analyte. In addi-
tion, an analyst may not modify an ap-
proved method if the modification
would result in measurement of a dif-
ferent form or species of an analyte
(e.g., a change to a metals digestion or
total cyanide distillation). An analyst
may also may not modify any sample
preservation and/or holding time re-
quirements of an approved method.
(c) Analytical requirements for multi-
analyte methods (Target Analytes). For
the purpose of NPDES reporting, the
discharger or permittee must meet QC
requirements only for the analyte(s)
being measured and reported under the
NPDES permit.
(d) The following modifications to
approved methods are authorized in the
circumstances described below:
(1) Capillary column. Use of a cap-
illary (open tubular) GC column rather
than a packed column is allowed with
EPA Methods 601-613, 624, 625, and
1624B in Appendix A to this part, pro-
vided that all QC tests for the approved
method are performed and all QC ac-
ceptance criteria are met. When chang-
ing from a packed column to a cap-
illary column, retention times will
change. Analysts are not required to
meet retention time specified in the
approved method when this change is
made. Instead, analysts must generate
new retention time tables with cap-
illary columns to be kept on file along
with other startup test and ongoing QC
data, for review by auditors.
(2) Increased sample volume in purge
and trap methodology. Use of increased
sample volumes, up to a maximum of
25 mL, is allowed for an approved
method, provided that the height of the
water column in the purge vessel is at
least 5 cm. The analyst should also use
one or more surrogate analytes that
are chemically similar to the analytes
of interest in order to demonstrate
that the increased sample volume does
not adversely affect the analytical re-
sults.
[72 FR 11239, Mar. 12, 2007]
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April 2011
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Environmental Protection Agency
Pt. 136, App. B
1 Native/labeled.
2 Analysis of this pollutant is approved only for the Centralized Waste Treatment industry.
3 Analysis of this pollutant is approved only for the Centralized Waste Treatment and Landfills industries.
TABLE 6—ACID EXTRACTABLE COMPOUND CHARACTERISTIC M/Z'S
Compound
o-cresol2
Labeled Ana-
log
d7
Primary
m/z1
1 08/1 1 6
m/z = mass to charge ratio.
1 Native/labeled.
2 Analysis of this pollutant is approved only for the Centralized Waste Treatment and Landfills industries.
TABLE 7—ACCEPTANCE CRITERIA FOR PERFORMANCE TESTS
EGD No.
758
658
757
657
771
671
1744
1644
578
1330
1230
Compound
acetophenone-d5 1
aniline2
o-cresol1
p-cresol2
pyridine2
ovridine-d^ 2
Acceptance criteria
Initial precision and accu-
racy section 8.2
(ng/L)
(ng/L)
34
51
32
71
40
23
59
22
13
28
ns
X
44-167
23-254
30-171
15-278
31-226
30-146
54-1 40
11-618
40-160
10-421
7-392
Labeled
compound
recovery
sec. 8.3 and
14.2 P
(percent)
45-162
33-154
35-196
37-203
19-238
Calibration
verification
sec. 12.5
Hg/mL)
85-115
85-115
85-115
85-115
85-115
85-115
85-115
85-115
85-115
83-117
85-115
On-going
accuracy
sec. 12.7 R
(ng/L)
45-162
22-264
33-154
12-344
35-196
31-142
37-203
16-415
44-144
18-238
4-621
s = Standard deviation of four recovery measurements.
X = Average recovery for four recovery measurements.
EGD = Effluent Guidelines Division.
ns = no specification; limit is outside the range that can be measured reliably.
1 Analysis of this pollutant is approved only for the Centralized Waste Treatment industry.
2 Analysis of this pollutant is approved only for the Centralized Waste Treatment and Landfills industries.
[49 FR 43261, Oct. 26, 1984; 50 FR 692, 695, Jan. 4, 1985, as amended at 51 FR 23702, June 30, 1986;
62 FR 48405, Sept. 15, 1997; 65 FR 3044, Jan. 19, 2000; 65 FR 81295, 81298, Dec. 22, 2000]
APPENDIX B TO PART 136—DEFINITION
AND PROCEDURE FOR THE DETER-
MINATION OF THE METHOD DETEC-
TION LIMIT—REVISION 1.11
Definition
The method detection limit (MDL) is de-
fined as the minimum concentration of a
substance that can be measured and reported
with 99% confidence that the analyte con-
centration is greater than zero and is deter-
mined from analysis of a sample in a given
matrix containing the analyte.
Scope and Application
This procedure is designed for applicability
to a wide variety of sample types ranging
from reagent (blank) water containing
analyte to wastewater containing analyte.
The MDL for an analytical procedure may
vary as a function of sample type. The proce-
dure requires a complete, specific, and well
defined analytical method. It is essential
that all sample processing steps of the ana-
lytical method be included in the determina-
tion of the method detection limit.
The MDL obtained by this procedure is
used to judge the significance of a single
measurement of a future sample.
The MDL procedure was designed for appli-
cability to a broad variety of physical and
chemical methods. To accomplish this, the
procedure was made device- or instrument-
independent.
Procedure
1. Make an estimate of the detection limit
using one of the following:
(a) The concentration value that cor-
responds to an instrument signal/noise in the
range of 2.5 to 5.
(b) The concentration equivalent of three
times the standard deviation of replicate in-
strumental measurements of the analyte in
reagent water.
(c) That region of the standard curve where
there is a significant change in sensitivity,
i.e., a break in the slope of the standard
curve.
343
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April 2011
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Pt. 136, App. B
40 CFR Ch. I (7-1-10 Edition)
(d) Instrumental limitations.
It is recognized that the experience of the
analyst is important to this process. How-
ever, the analyst must include the above
considerations in the initial estimate of the
detection limit.
2. Prepare reagent (blank) water that is as
free of analyte as possible. Reagent or inter-
ference free water is defined as a water sam-
ple in which analyte and interferent con-
centrations are not detected at the method
detection limit of each analyte of interest.
Interferences are defined as systematic er-
rors in the measured analytical signal of an
established procedure caused by the presence
of interfering species (interferent). The
interferent concentration is presupposed to
be normally distributed in representative
samples of a given matrix.
3. (a) If the MDL is to be determined in re-
agent (blank) water, prepare a laboratory
standard (analyte in reagent water) at a con-
centration which is at least equal to or in
the same concentration range as the esti-
mated method detection limit. (Recommend
between 1 and 5 times the estimated method
detection limit.) Proceed to Step 4.
(b) If the MDL is to be determined in an-
other sample matrix, analyze the sample. If
the measured level of the analyte is in the
recommended range of one to five times the
estimated detection limit, proceed to Step 4.
If the measured level of analyte is less
than the estimated detection limit, add a
known amount of analyte to bring the level
of analyte between one and five times the es-
timated detection limit.
If the measured level of analyte is greater
than five times the estimated detection
limit, there are two options.
(1) Obtain another sample with a lower
level of analyte in the same matrix if pos-
sible.
(2) The sample may be used as is for deter-
mining the method detection limit if the
analyte level does not exceed 10 times the
MDL of the analyte in reagent water. The
variance of the analytical method changes as
the analyte concentration increases from the
MDL, hence the MDL determined under
these circumstances may not truly reflect
method variance at lower analyte concentra-
tions.
4. (a) Take a minimum of seven aliquots of
the sample to be used to calculate the meth-
od detection limit and process each through
the entire analytical method. Make all com-
putations according to the defined method
with final results in the method reporting
units. If a blank measurement is required to
calculate the measured level of analyte, ob-
tain a separate blank measurement for each
sample aliquot analyzed. The average blank
measurement is subtracted from the respec-
tive sample measurements.
(b) It may be economically and technically
desirable to evaluate the estimated method
detection limit before proceeding with 4a.
This will: (1) Prevent repeating this entire
procedure when the costs of analyses are
high and (2) insure that the procedure is
being conducted at the correct concentra-
tion. It is quite possible that an inflated
MDL will be calculated from data obtained
at many times the real MDL even though the
level of analyte is less than five times the
calculated method detection limit. To insure
that the estimate of the method detection
limit is a good estimate, it is necessary to
determine that a lower concentration of
analyte will not result in a significantly
lower method detection limit. Take two
aliquots of the sample to be used to calculate
the method detection limit and process each
through the entire method, including blank
measurements as described above in 4a.
Evaluate these data:
(1) If these measurements indicate the
sample is in desirable range for determina-
tion of the MDL, take five additional
aliquots and proceed. Use all seven measure-
ments for calculation of the MDL.
(2) If these measurements indicate the
sample is not in correct range, reestimate
the MDL, obtain new sample as in 3 and re-
peat either 4a or 4b.
5. Calculate the variance (S2) and standard
deviation (S) of the replicate measurements,
as follows:
where:
Xi; 1=1 to n, are the analytical results in the
final method reporting units obtained from
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Environmental Protection Agency
Pt. 136, App. B
the n sample aliquots and Z refers to the
sum of the X values from 1=1 to n.
6. (a) Compute the MDL as follows:
MDL =
(S)
where:
MDL = the method detection limit
t(n-i,i-cc-.99) = the students' t value appropriate
for a 99% confidence level and a standard
deviation estimate with n-1 degrees of free-
dom. See Table.
S = standard deviation of the replicate anal-
yses.
(b) The 95% confidence interval estimates
for the MDL derived in 6a are computed ac-
cording to the following equations derived
from percentiles of the chi square over de-
grees of freedom distribution (x2/df).
LCL = 0.64 MDL
UCL = 2.20 MDL
where: LCL and UCL are the lower and upper
95% confidence limits respectively based
on seven aliquots.
7. Optional iterative procedure to verify
the reasonableness of the estimate of the
MDL and subsequent MDL determinations.
(a) If this is the initial attempt to compute
MDL based on the estimate of MDL formu-
lated in Step 1, take the MDL as calculated
in Step 6, spike the matrix at this calculated
MDL and proceed through the procedure
starting with Step 4.
(b) If this is the second or later iteration of
the MDL calculation, use S2 from the cur-
rent MDL calculation and S2 from the pre-
vious MDL calculation to compute the F-
ratio. The F-ratio is calculated by sub-
stituting the larger S2 into the numerator
S2A and the other into the denominator S2e.
The computed F-ratio is then compared with
the F-ratio found in the table which is 3.05 as
follows: if S2A/S2B<3.05, then compute the
pooled standard deviation by the following
equation:
Spooled
12
if S2A/S2B>3.05, respike at the most recent
calculated MDL and process the samples
through the procedure starting with Step
4. If the most recent calculated MDL
does not permit qualitative identifica-
tion when samples are spiked at that
level, report the MDL as a concentration
between the current and previous MDL
which permits qualitative identification.
(c) Use the Spooied as calculated in 7b to
compute The final MDL according to the fol-
lowing equation:
MDL=2.681 (Spooied)
where 2.681 is equal to t(i2,i-ct.99).
(d) The 95% confidence limits for MDL de-
rived in 7c are computed according to the
following equations derived from precentiles
of the chi squared over degrees of freedom
distribution.
LCL=0.72 MDL
UCL=1.65 MDL
where LCL and UCL are the lower and upper
95% confidence limits respectively based
on 14 aliquots.
TABLES OF STUDENTS' T VALUES AT THE 99
PERCENT CONFIDENCE LEVEL
TABLES OF STUDENTS' T VALUES AT THE 99
PERCENT CONFIDENCE LEVEL—Continued
Number of replicates
7
Degrees
of free-
dom (n-1)
6
tcn-1,99)
3.143
Number of replicates
8
9
10
11
16
21
26
31
61
00
Degrees
of free-
dom (n-1)
7
8
9
10
15
20
25
30
60
00
tcn-1,99)
2998
2896
2821
2.764
2.602
2528
2485
2.457
2390
2.326
Reporting
The analytical method used must be spe-
cifically identified by number or title aid the
MDL for each analyte expressed in the ap-
propriate method reporting units. If the ana-
lytical method permits options which affect
the method detection limit, these conditions
must be specified with the MDL value. The
sample matrix used to determine the MDL
must also be identified with MDL value. Re-
port the mean analyte level with the MDL
and indicate if the MDL procedure was
iterated. If a laboratory standard or a sam-
ple that contained a known amount analyte
was used for this determination, also report
the mean recovery.
345
184
April 2011
-------
Pt. 136, App. C
40 CFR Ch. I (7-1-10 Edition)
If the level of analyte in the sample was
below the determined MDL or exceeds 10
times the MDL of the analyte in reagent
water, do not report a value for the MDL.
[49 FR 43430, Oct. 26, 1984; 50 FR 694, 696, Jan.
4, 1985, as amended at 51 FR 23703, June 30,
1986]
APPENDIX C TO PART 136—INDUCTIVELY
COUPLED PLASMA—ATOMIC EMISSION
SPECTROMETRIC METHOD FOR TRACE
ELEMENT ANALYSIS OP WATER AND
WASTES METHOD 200.7
1. Scope and Application
1.1 This method may be used for the de-
termination of dissolved, suspended, or total
elements in drinking water, surface water,
and domestic and industrial wastewaters.
1.2 Dissolved elements are determined in
filtered and acidified samples. Appropriate
steps must be taken in all analyses to ensure
that potential interferences are taken into
account. This is especially true when dis-
solved solids exceed 1500 mg/L. (See Section
5.)
1.3 Total elements are determined after
appropriate digestion procedures are per-
formed. Since digestion techniques increase
the dissolved solids content of the samples,
appropriate steps must be taken to correct
for potential interference effects. (See Sec-
tion 5.)
1.4 Table 1 lists elements for which this
method applies along with recommended
wavelengths and typical estimated instru-
mental detection limits using conventional
pneumatic nebulization. Actual working de-
tection limits are sample dependent and as
the sample matrix varies, these concentra-
tions may also vary. In time, other elements
may be added as more information becomes
available and as required.
1.5 Because of the differences between
various makes and models of satisfactory in-
struments, no detailed instrumental oper-
ating instructions can be provided. Instead,
the analyst is referred to the instruction
provided by the manufacturer of the par-
ticular instrument.
2. Summary of Method
2.1 The method describes a technique for
the simultaneous or sequential multielement
determination of trace elements in solution.
The basis of the method is the measurement
of atomic emission by an optical
spectroscopic technique. Samples are
nebulized and the aerosol that is produced is
transported to the plasma torch where exci-
tation occurs. Characteristic atomic-line
emission spectra are produced by a radio-fre-
quency inductively coupled plasma (ICP).
The spectra are dispersed by a grating spec-
trometer and the intensities of the lines are
monitored by photomultiplier tubes. The
photocurrents from the photomultiplier
tubes are processed and controlled by a com-
puter system. A background correction tech-
nique is required to compensate for variable
background contribution to the determina-
tion of trace elements. Background must be
measured adjacent to analyte lines on sam-
ples during analysis. The position selected
for the background intensity measurement,
on either or both sides of the analytical line,
will be determined by the complexity of the
spectrum adjacent to the analyte line. The
position used must be free of spectral inter-
ference and reflect the same change in back-
ground intensity as occurs at the analyte
wavelength measured. Background correc-
tion is not required in cases of line broad-
ening where a background correction meas-
urement would actually degrade the analyt-
ical result. The possibility of additional
interferences named in 5.1 (and tests for
their presence as described in 5.2) should also
be recognized and appropriate corrections
made.
3. Definitions
3.1 Dissolved—Those elements which will
pass through a 0.45 Jim membrane filter.
3.2 Suspended—Those elements which are
retained by a 0.45 Jim membrane filter.
3.3 Total—The concentration determined
on an unfiltered sample following vigorous
digestion (Section 9.3), or the sum of the dis-
solved plus suspended concentrations. (Sec-
tion 9.1 plus 9.2).
3.4 Total recoverable—The concentration
determined on an unfiltered sample fol-
lowing treatment with hot, dilute mineral
acid (Section 9.4).
3.5 Instrumental detection limit—The con-
centration equivalent to a signal, due to the
analyte, which is equal to three times the
standard deviation of a series of ten replicate
measurements of a reagent blank signal at
the same wavelength.
3.6 Sensitivity—The slope of the analytical
curve, i.e., functional relationship between
emission intensity and concentration.
3.7 Instrument check standard—A multiele-
ment standard of known concentrations pre-
pared by the analyst to monitor and verify
instrument performance on a daily basis.
(See 7.6.1)
3.8 Interference check sample—A solution
containing both interfering and analyte
elemelts of known concentration that can be
used to verify background and interelement
correction factors. (See 7.6.2.)
3.9 Quality control sample—A solution ob-
tained from an outside source having known,
concentration values to be used to verify the
calibration standards. (See 7.6.3)
3.10 Calibration standards—A series of
known standard solutions used by the ana-
lyst for calibration of the instrument (i.e.,
preparation of the analytical curve). (See 7.4)
346
April 2011
185
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CSO Post Construction Compliance Monitoring Guidance
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186 April 2011
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CSO Post Construction Compliance Monitoring Guidance
Appendix F. Case Studies
The case studies included in this appendix present some post construction compliance monitoring
issues. Please note that inclusion of these case studies does not constitute an endorsement by EPA of
the approaches taken in these cases.
April 2011 187
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CSO Post Construction Compliance Monitoring Guidance
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188 April 2011
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CSO Post Construction Compliance Monitoring Guidance
Case Study: Flushing Bay, New York
April 2011 189
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CSO Post Construction Compliance Monitoring Guidance
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190 April 2011
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New York State Department of Environmental Conservation
Division of Water
Bureau of Water Compliance, 4th Floor
625 Broadway, Albany, New York 12233-3506
Phone: (518) 402-8177 • FAX: (518) 402-8082 Alexand^Tcrannis
Website: www.dec.state.ny.us Commissioner
December 18, 2007
Mr. James G. Mueller, P.E.
Director
Facilities Planning and Design
Bureau of Engineering Design and Construction
NYC Department of Environmental Protection
59-17 Junction Boulevard
Flushing, New York 11373-5108
Dear Mr. Mueller:
Re: Order on Consent (CSO Order)
DEC Case #CO2-20000107-8
Flushing Bay/Creek and Spring Creek Retention Facilities - Interim Post-
Construction Compliance Monitoring Plans
The Department received your revised Interim Post-Construction Compliance Monitoring
(TPCM) Plans for the Flushing Bay/Creek and Spring Creek Retention Facilities on September 5,
2007 which addressed the Departments comments dated July 24, 2007. The Department has an
additional specific comment that DEP should address separate from the IPCMs.
In regard to your response to our General Comment #6: DEP expressed concern
regarding variability in precipitation dynamics and CSO control performance which may require
longer than five years of post-construction monitoring to statistically validate the models. The
Department understands that this variability is a concern but believes the data is fundamental to
verifying the 1988 rainfall data as the average year in all of the models. The Department plans
to review the data and updated models on a five-year basis, including the first five years, as
required by the USEPA guidance on Long Term Control Planning. Therefore, DEP must submit
a summary of the post construction monitoring and modeling verification, including the data,
every five years as a part of the required re-evaluation of the Long Term Control Plans (LTCP).
This information will be used to identify areas of significant water quality non-compliance and
gaps in the water quality modeling, and measure progress with the LTCP goals.
April 2011 191
-------
If you have any questions or concerns regarding this letter, please contact Mr. Gary E.
Kline, P.E. at (518) 402-9655.
Sincerely,
Joseph DiMura, P.E.
Director
Bureau of Water Compliance
cc: G. Kline, P.E.
S. McCormick, P.E.
C. Webber, P.E.
S. Crisafulli, Esq.
R. Elburn, P.E., Region 2
T. Burns, P.E., NYS EFC
K. Mahoney, P.E., NYCDEP
P. Young, P.E., Hazen and Sawyer
192 April 2011
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SM:ab
be: BWC Daybook
April 2011 193
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New York City Department of Environmental Protection Interim Poxt-Constntctioti Compliance Monitoring
Flushing Bay / Creek
FLUSHING BAY/CREEK INTERIM POST-CONSTRUCTION COMPLIANCE
MONITORING PROGRAM
January 25, 2008
Introduction
Post-construction compliance monitoring will be integral to the optimization of the
Flushing Bay CSO Retention Facility, providing data for model validation, feedback to facility
operations, and an assessment metric for the effectiveness of these facilities. Each year's data set
will be compiled and evaluated to refine the understanding of Ihe interaction between Flushing
Bay/Creek and the CSO retention facility, with the ultimate goal of fully attaining compliance
with current water quality standards or for supporting a UAA to revise such standards. The data
collection monitoring will contain three basic components:
S. The CSO retention facility monitoring requirc?nents contained in the Tallman Island
WPCP SPDES permit;
2. NYC'DEP Harbor Survey program data collection in Flushing Creek and Flushing
Bay; and
3. Modeling of the associated receiving waters to characterize water quality.
The Flushing Bay CSO Retention Facility was placed into service in the spring of 2007,
and monitoring in Flushing Bay/Creek has already commenced. The Flushing Bay/Creek Interim
Post-Construction Compliance Monitoring Program is described herein at the direction of
NYSDEC to provide documentation of the interim program. The full details of the program are
being developed under the City-Wide LTCP, including monitoring and laboratory protocols,
QA/QC, and other aspects, to ensure adequate spatial coverage, consistency, and a technically
sound sampling program for the entire New York Harbor. The details provided herein are limited
to the Flushing Bay/Creek Interim Post-Construction Compliance Monitoring Program and may
be modified as the City-Wide program takes form. Any further modifications to the Monitoring
Program will be submitted to NYSDEC for review and approval as part of the drainage specific
LTCPs.
SPPES Facility Monitoring Requirements
The Tallman Island WPCP SPDES Permit requires monitoring of certain effluent
overflow parameters at the Flushing Bay CSO Retention Facility, a CSO regional facility that
discharges to outfall TI-Q10. Such monitoring results will be reported on a monthly basis as an
addendum to the Tallman Island WPCP monthly operating report, and on an annual basis in the
CSO BMP report. Sampling results and summary statistics will be provided in the monthly
operating report, including the number of overflow events, the volume of overflow during each
event, and the volume retained and pumped to the Tallman Island WPCP. Table 1 summarizes
the relevant permit-required parameters from the current SPDES permit.
/ of 7 January 25, 2008
194 April 2011
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A/fir York City Department qf Environmental Protection Interim Post-Construction Compliance Monitoring
Flushing Bay >' Creek
Receiving Water Monitoring
The New York City Harbor Survey primarily measures four parameters related to water
quality: dissolved oxygen, fecal coliform, chlorophyll "a", and secchi depth. These parameters
have been used by the City to identity historical and spatial trends in water quality throughout
New York Harbor. Secchi depth and chlorophyll "a" have been monitored since 1986; DO and
fecal coliform have been monitored since before 1972. Recently, entcrococci analysis has been
added to the program. Except for secchi depth and pathogens, each parameter is collected and
analyzed at surface and bottom locations, which are three feet from the surface and bottom,
respectively, to eliminate influences external to the water column chemistry itself, such as wind
and precipitation influences near the surface or benthic and near-bottom suspended sediments
and aquatic vegetation near the bottom. Pathogens are analyzed in surface samples only.
NYCDEP regularly samples 33 open water stations annually, which is supplemented each year
with approximately 20 rotating tributary stations or periodic special stations sampled in
coordination with capital projects, planning, changes in facility operation, or in response to
regulatory changes.
The post-construction compliance monitoring program will continue along the protocols
of the Harbor Survey initially, including laboratory protocols listed in Table 2. As shown on
Figure 1, Flushing Creek contains two locations (mid-channel and mouth) that were added to the
Harbor Survey program in the fall of 2006 in anticipation of the CSO Retention Facility coming
on-line. In addition, three stations in Flushing Bay will be monitored regularly, in part to provide
boundary water quality conditions and benchmarking for observed changes in Flushing Bay
water quality during the survey. All stations related to the Interim Flushing Bay Post-
Construction Monitoring Program will be sampled a minimum of twice per month from May
through September and a minimum of once per month during the remainder of the year. The
program commenced monitoring in May 2007. Sampling stations FLC'l, FLC2, and E15 may be
covered with ice during cold weather. DEP personnel will not be engaging in sampling where
access is restricted by ice conditions.
Data collected during this program will be used primarily to verify the East River
Tributaries Model (ERTM) that will be used to demonstrate relative compliance levels in
Flushing Bay. Therefore, during each annual cycle of compliance monitoring, the data collected
will be evaluated for its utility in model verification, and stations may be added, eliminated, or
relocated depending on this evaluation. Similarly, the parameters measured will be evaluated for
their utility and appropriateness for verifying the receiving water model calibration. At a
minimum, the program will collect those parameters with numeric VVQS (i.e., DO, fecal
coliform, and entcrococci). In addition, moored instrumentation may be added or substituted at
one or more of these locations if continuous monitoring is determined to be beneficial to model
verification, or if logistical considerations preclude the routine operation of the program
(navigational limits, laboratory issues, etc.).
Floatabies Monitoring
The Flushing Bay/Creek Interim Post-Construction Compliance Monitoring Program
incorporates by reference the City-Wide Comprehensive CSO Floatabies Plan Modified Facility
Planning Report (NYCDEP, 2005a) and Addendum 1 - Pilot Floatabies Monitoring Program
2 of 7 January 25. 2008
April 2011 195
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jVevv York City Department of Environmental Protection Interim Post-Construction Compliance Monitoring
/''lushing Bay ' Creek
(December 2005) to the Floatables Plan, These documents contain a conceptual framework for
the monitoring of floatables conditions in New York Harbor and a work plan for the ongoing
pilot program to develop and test the monitoring methodology envisioned in the framework
before the program transitions to full scale in 2008. The objectives set forth in the Floatables
Plan provides a metric for LTCP performance, and floatables monitoring will be conducted in
conjunction with post-construction compliance monitoring with regard to staffing, timing, and
location of monitoring sites. The program will include the collection of basic floatables presence
/ absence data from monitoring sites throughout the harbor that will be used to rate and track
floatables conditions, correlate rating trends to floatables control programs where applicable, and
trigger investigations into the possible causes of consistently poor ratings should they occur.
Actions based on the floatables monitoring data and investigations could include short-term
remediation in areas where monitored floalables conditions create acute human or navigation
hazards and, as appropriate, longer-term remediation actions and modifications to the Flushing
Bay/Creek WaterbodyvWatershed Facility Plan if monitored floatables trends indicate
impairment of waters relative to their intended uses.
Meteorological Conditions
The performance of any CSO control facility cannot be fully evaluated without a detailed
analysis of precipitation, including the intensity, duration, total rainfall volume, and precipitation
event distribution that led to an overflow or, conversely, the statistical bounds within which the
facility may be expected to control CSO completely. NYCDEP has established 1988 as
representative of long-term average conditions and therefore uses it for analyzing facilities where
"'typical" conditions (rather than extreme conditions) serve as the basis for design. The
comparison of rainfall records at JFK airport from 1988 to the long-term rainfall record is shown
in Table 3, and includes the return period for 1988 conditions.
In addition to its aggregate statistics indicating that 1988 was representative of overall
long-term average conditions, 1988 also includes critical rainfall conditions during both
recreational and shellfishing periods. Further, the average storm intensity for 1988 is greater than
one standard deviation from the mean so that using 1988 as a design rainfall year would be
conservative with regard to water quality impacts since CSOs and stonnwater discharges are
driven primarily by rainfall intensity. However, considering the complexity and stochastic nature
of rainfall, selection of any year as "typical" is ultimately qualitative, and performance is not
expected to simply correlate to annual rainfall volume or any other single statistic. The
performance of the Flushing Bay CSO Retention Facility and the response of Flushing Bay with
respect to widely varying precipitation conditions will be evaluated with respect to observed
rainfall, and will be summarized in a manner similar to that shown in Table 3.
Multiple Sources of rainfall data will be compiled as part of the final City-Wide Post-
Construction Monitoring Program. On an interim basis, however, the primary source of rainfall
data will be from La Guardia Airport and from any NYCDEP gauges that may be available. The
use of NEXRAD cloud reflectivity data as proposed in the Watcrbody/Watershed Facility Plan
will be limited to testing implementation techniques until its utility is fully understood. Any data
sets determined to be of limited value in the analysis of compliance may be discontinued.
3 of 7 JantMiy 25. 2008
196 April 2011
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;VtTH' York City Department of Environmental Protection Interim Post-Construction Compliance Monitoring
Flushing Buv / Creek
Analysts
The performance of the Flushing Bay CSO Retention Facility will be evaluated on an
annual basis using a landside mathematical computer model as approved by NYSDEC. In
addition, NYCDEP believes that the analysis of water quality compliance is best accomplished
using computer modeling supported and verified with a water quality monitoring program.
Modeling has several advantages over monitoring:
1. Modeling provides a comprehensive vertical, spatial, and temporal coverage that
cannot reasonably be equaled with a monitoring program;
2. Modeling provides the data volume necessary to compute aggregate statistical
compliance values, such as a geometric mean, an absolute limit (e.g., "never-less-
than" or "not-to-exceed'n), or a cumulative statistic (e.g., the 66-day deficit-duration
standard for dissolved oxygen to be promulgated by NYSDEC in the near future);
3. Discrete grab sampling for data collection is necessarily biased to locations and
periods of logistical advantage, such as navigable waters, safe weather conditions,
daylight hours, etc.; and
4. Quantification of certain chemical parameters must be performed in a laboratory
setting which either (a) complicates the use of a smaller sampling vessel that is
necessary to access shallower waters not navigable by a vessel with on-board
laboratory facilities or (b) limits the number sampling locations that can be accessed
due to holding times and other laboratory quality assurance requirements if remote
laboratory (non-vessel mounted) facilities are used.
The InfoWorks collection system model of the Tallman Island WPCP service area was
developed under the LTCP project based in part on historical models used in facility planning.
InfoWorks is a state-of-the-art modeling package that includes the ability to represent retention
tank dynamics, hydraulic analyses and other sophisticated aspects of performance within the
collection system. Overflow volumes will be quantitatively analyzed on a monthly basis to
isolate any periods of performance issues and their impact on water quality. Water quality
modeling re-assessment will be conducted every two years based on the previous two years
water quality field data. Modeling conditions will be based on the hydrodynamic and
meteorological conditions for the study year, documented operational issues that may have
impacted the facility performance, and water quality boundary conditions based on the Harbor
Survey data from outside Flushing Bay. Results will be compared to the Harbor Survey data
collected within Flushing Bay and Creek to validate the water quality modeling system, and
performance will be expressed in a quantitative attainment level for applicable numerical criteria
based on the receiving water model. Should this analysis indicate that progress towards the
desired results is not being made, the analysis will:
• Re-verify all model inputs, collected data and available QA/QC reports;
" Consult with operations personnel to ensure unusual operational problems (e.g.,
screening channel o/s, pump repair, etc.) were adequately documented;
• Evaluate specific periods of deviations from modeled performance.
4 <>j 7 Jiimuny 25, 2008
April 2011 197
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,'Vnt1 York City Department (>/ Environmental Protection interim Pusl-Constrticlion Compliance Monitoring
Flushing Bay / Creek
" ConiliTn that all operational protocols were implemented, and that these protocols arc
sufficient to avoid operationally-induced undcrperformancc;
* Re-evaluate protocols as higher frequency and routine problems reveal themselves:
and finally
" Revise protocols as appropriate and conduct Use Attainability Analysis (UAA) and if
necessary, revise LTCP,
Because of the dynamic nature of water quality standards and approaches to non-
compliance conditions, a period of ten years of operation will be necessary to generate the
minimal amount of data necessary to perform meaningful statistical analyses for water quality
standards review and for any formal use attainability analysis (UAA) that may be indicated.
Following completion of the tenth annual report containing data during facility operation, a more
detailed evaluation of the capability of the Flushing Bay CSO Retention Facility to achieve the
desired water quality goals will take place, with appropriate weight given to the various issues
New York City identified during the evaluations documented in the annual reports. If it is
determined that the desired results are not achieved, NYCDEP will revisit the feasibility of cost-
effective improvements. Alternately, the water quality standards revision process may commence
with a UAA that would likely rely in part on the findings of the post construction compliance
monitoring program. The approach to future improvements beyond the 10-year post-construction
monitoring program will be dictated by the findings of that program as well as the input from
NYSDEC SPDES permit and CSO Consent Order administrators. This schedule is not intended
to contradict the 5-year cycle used for updating SPDES permits.
Reporting
Post-construction compliance monitoring will be added to the annual BMP report
submitted by NYCDEP in accordance with their SPDES permits. The monitoring report will
include an overview of the performance of the Flushing Bay CSO Retention Facility, although
the official facility overflow reporting will remain in the monthly operating report as required by
the SPDES permits. Summary statistics on rainfall, the amount of combined sewage, and the
proportions directed to the WPCP, passed through the facility overflow, and bypassed above the
head end of the facility will be provided in the Annual BMP Report. Verification and refinement
of the model framework as necessary will be documented, and modeling results will be presented
to assess water quality impacts in lieu of high-resolution sampling. Analyses of precipitation,
temperature effects, and other conditions external to the CSO Facility performance will also be
included in the Annual BMP Report.
In addition to the information to be provided in the Annual BMP Report, NYCDEP will
submit a summary of the monitoring and modeling, including the data, once every five years.
NYSDEC has acknowledged that the variability in precipitation dynamics may require more than
five successive years of data to statistically validate the models used for evaluating compliance,
but have nonetheless stated that this information will be used to identify areas of significant
water quality non-compliance and gaps in the water quality modeling, and measure progress with
the LTCP goals. They have also stated that they intend to verify the 1988 rainfall data as the
"average" year.
5 of 7 .tumidiy 25, 2008
198 April 2011
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New York City Department of Environmental Protection
Interim Posl-Constructivn Compliance Monitoring
Flushing Bay / Creek
Table 1. SPDES Permit Monitoring Parameters
PARAMETER
Overflow Volume
Retained Volume
BOD, 5-day
TSS
Settleable Solids
Oil & Grease
Screenings
Fecal Coliform
Precipitation
REPORT
Event total
Monthly total
Event average
Event average
Event average
Event average
Monthly total
Event geo. mean
Event total
UNITS
MG
MG
mg/L
mg/L
ml/L
mg/L
cu. vd
N o/l 00m L
inches
FREQUENCY
Per event
Per month
Per event-day
Per event-day
Per event-day
Per event-day
—
Per event-day
Hourly
TYPE
Calculated
Totalized
Composite
Composite
Grab
Grab
Calculated
Grab
Rain Gauge
NOTE
-
Flow to WPCP
Every 4 hr
Every 4 hr
Every 4 hr when manned
-
-
Every 4 hr when manned
-
See most recent Tallman Island WPCP SPDES Permit (NY0026239) for exact descriptions and definitions.
Table 2. Current Harbor Survey Laboratory Protocols
Parameter
Ammonia (as N)
Chlorophyll 'a'
Dissolved Oxygen
Dissolved Silica
Enterococcus
Fecal Coliform
Nitrate (as N)
Orthophosphate (as P)
_p_H. .. .
Total Kjeldahl Nitrogen
Total Phosphorus
Total Suspended Solids
Method
EPA 350.1
EPA 445.0. modified for the Welschmeyer Method
SM 4500-O C, Azide Modification (Winkler
Method)
SM 18-19 4500-Si D or USGS 1-2700-85
EPA Method 1600, Membrane Filter
SM 1 8-20 9222D, Membrane Filter
EPA 353.2 or SM 18-20 4500-NO3 F
EPA 365.1
SM 4500-H B. Elecirometnc Method
EPA 35 1.2
EPA 365.4
SM 1 8-20 2540D
Notes: SM - Standard Methods for the Examination of Water and Wastewater; EPA -
EPA's Sampling and Analysis Methods. Field instrumentation also includes an SBE 911
Sealogger CTD which collects salinity, temperature, and conductivity, among other
parameters.
Table 3. Rainfall Statistics, JFK Airport, 1988 and Long-Term Average
Statistic
Total Volume (inches)
Intensity, (in/hr)
Number of Storms
Storm Duration ( hours)
1970-2002
Median
39.4
0.057
112
6.08
1988
Value
40.7
0.068
100
6.12
Return
Period
(years)
2.6
11.3
I.I
2.1
April 2011
6 of 7
Januarv 25. 200N
199
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New York City Department of Environmental Protection Interim Post-Construction Compliance Monitoring
Flushing Bay / Creek
TI-019
E6
4* Tl-018
9 @
Tl-017
TI-016
Ti-015
TI-014
TI-013
FB1
©
TI-012
B6-QQ7
El 5
BB-008
(O)
B8-006
ft
FLC2
Ti-011
FLC1
TI-022
©
TI-010
©
Figure 1. Harbor Survey Sampling Locations to be incorporated into Flushing Bay Interim
Post-Construction Monitoring Program
7 of 7
200
January 25, 2008
April 2011
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New York City Department of Environmental Protection Interim Pom-Construction Compliance Monitoring
Spring Creek
SPRING CREEK INTERIM POST-CONSTRUCTION COMPLIANCE MONITORING
PROGRAM
January 25, 2008
Introduction
The Spring Creek Interim Post-Construction Compliance Monitoring Program will be
integral to the optimization of the Spring Creek Auxiliary Water Pollution Control Plant
(AWPCP), providing data for model validation, feedback to facility operations, and an
assessment metric for the effectiveness of these facilities. Each year's data set will be compiled
and evaluated to refine the understanding of the interaction between Spring Creek and the CSO
controls, with the ultimate goal of fully attaining compliance with current water quality standards
or for supporting a UAA to revise such standards. The data collection monitoring will contain
three basic components:
i. The CSO Facility monitoring requirements contained in the 26th Ward WPCP
SPDES permit;
2. Receiving water data collection in Spring Creek and Jamaica Bay using existing
NYCDEP Harbor Survey locations and adding stations as necessary; and
3. Modeling of the associated receiving waters to characterize water quality.
The improvements to the Spring Creek Auxiliary Water Pollution Control Plant were
substantially completed by the spring of 2007, and monitoring in Spring Creek has already
commenced. The Spring Creek Interim Post-Construction Compliance Monitoring Program is
described herein at the direction of NYSDEC to provide documentation of the interim program.
The full details of the program are being developed under the City-Wide LTCP, including
monitoring and laboratory protocols, QA/QC, and other aspects, to ensure adequate spatial
coverage, consistency, and a technically sound sampling program for the entire New York
Harbor. The details provided herein are limited to the Spring Creek Interim Post-Construction
Compliance Monitoring Program and may be modified as the City-Wide program takes form.
Any further modifications to the Monitoring Program will be submitted to iNYSDEC for review
and approval as part of the drainage basin specific LTCPs.
SPDES Facility Monitoring Requirements
The 26th Ward WPCP SPDES Permit requires monitoring for certain effluent overflow
parameters from the Spring Creek Auxiliary WPCP, a CSO regional facility that discharges to
outfall 26-005. This outfall will be monitored in accordance with the SPDES Permit, and results
will be reported on a monthly basis as an addendum to the 26th Ward WPCPs monthly operating
report, and on an annual basis in the CSO BMP report. Sampling results and summary statistics
will be provided in the monthly operating report, including the number of overflow events, the
volume of overflow during each event, and the volume retained and pumped to the 26th Ward
WPCP. Table 1 summarizes the relevant required parameters from the current SPDES permit.
DRAFT I of 8 January 25. 2008
April 2011 201
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/Vi'ir }<>rk Citv Department oj Environmental Protection Interim Patit-ConstntctioH Compliance Monitoring
Spring Creek
Receiving Water Monitoring
The post-construction compliance monitoring program will continue along the protocols
of the Harbor Survey initially, including laboratory protocols listed in Table 2. This program
primarily measures four parameters related to water quality: dissolved oxygen, fecal colifonn,
chlorophyll a, and secchi depth. These parameters have been used by the City to identify
historical and spatial trends in water quality throughout New York Harbor. Secchi depth and
chlorophyll a have been monitored since !986; DO and fecal coliform have been monitored since
before 1972. Recently, enterococci analysis has been added to the program. Except for secchi
depth and pathogens, each parameter is collected and analyzed at surface and bottom locations.
which are three feet from the surface and bottom, respectively, to eliminate influences external to
the water column chemistry itself, such as wind and precipitation influences near the surface or
benthic and near-bottom suspended sediments and aquatic vegetation near the bottom. Pathogens
are analyzed in surface samples only. NYCDEP regularly samples 33 open water stations
annually, which is supplemented each year with approximately 20 rotating tributary stations or
periodic special stations sampled in coordination with capital projects, planning, changes in
facility operation, or in response to regulatory changes.
Historically, the Spring Creek waierbody has not been monitored due primarily to
difficult logistics. The waterbody is very shallow and much of it is intertidally dry, rendering it
navigationally hazardous. Sampling from the shoreline is infeasible as well because the shallow
slopes and surrounding marshland make it virtually impossible to access water with sufficient
depth to collect a representative sample. Limited sampling has occurred from the top of the
AWPCP discharge structure, but sampling at this location is not believed to be reliably
representative of the water quality in the upper reaches of the waterbody.
Because of these limitations, the Harbor Suivcy has located one station (J8) just outside
the mouth of the Creek in Jamaica Bay, as shown on Figure 1. An additional location will be
included at the Belt Parkway Bridge, which has a pedestrian path protected from parkwray traffic
from which sampling can be performed. Spring Creek will be monitored regularly at Station J8
and from the Belt Parkway Bridge, with an additional Jamaica Bay sampling location to be used
to provide boundary water quality conditions and benchmarking for observed changes in Spring
Creek water quality during the survey. All stations related to the Interim Spring Creek Post-
Construction Monitoring Program will be sampled a minimum of twice per month from May
through September and a minimum of once per month during the remainder of the year. If
sampling stations are covered with ice during cold weather, NYCDEP personnel will not be
engaging in sampling where access is restricted by ice conditions. The program commenced
monitoring in May 2007.
Data collected during this program will be used primarily to verify the North Channel
Model that will be used to demonstrate relative compliance levels in Spring Creek. The North
Channel Model was developed from the Jamaica Eutrophication Model (JEM). The
hydrodynamic and chemical kinetic processes are computed in the same manner as JEM, but the
North Channel Model was constructed specifically to quantify water quality in Spring Creek,
Fresh Creek, and Hendrix Creek, so it has a much higher resolution in these areas. The calibrated
North Channel Model will be used to measure compliance, and will be verified annually with the
post-construction compliance monitoring data collected.
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Because the dala will be used in this manner, the data collected will be evaluated for its
utility in model verification during each annual cycle of compliance monitoring, and stations
may be added, eliminated, or relocated depending on this evaluation. Similarly, the parameters
measured will be evaluated for their utility and appropriateness for verifying the receiving water
model calibration. At a minimum, the program will collect those parameters with numeric WQS
(i.e., DO, fecal coliform, and cntcrococci). In addition, moored instrumentation may be added or
substituted at one or more of these locations if continuous monitoring is determined to be
beneficial to model verification, or if logistical considerations preclude the routine operation of
the program (navigational limits, laboratory issues, etc.).
FloatablesMonitoring
The Spring Creek Interim Post-Construction Compliance Monitoring Program
incorporates by reference the City-Wide Comprehensive CSO Floatables Plan Modified Facility
Planning Report (NYCDEP, 2005a) and Addendum I - Pilot Floatabies Monitoring Program
(December 2005) to the Floatables Plan. These documents contain a conceptual framework for
the monitoring of floatables conditions in New York Harbor and a work plan for the ongoing
pilot program to develop and test the monitoring methodology envisioned in the framework
before the program transitions to full scale in 2008. The objectives set forth in the Floatables
Plan provides a metric for LTCP performance, and floatables monitoring will be conducted in
conjunction with post-construction compliance monitoring with regard to staffing, timing, and
location of monitoring sites. The program will include the collection of basic floatables presence
/ absence data from monitoring sites throughout the harbor that will be used to rate and track
floatables conditions, correlate rating trends to floatables control programs where applicable, and
triggei investigations into the possible causes of consistently poor ratings should they occur.
Actions based on the floatables monitoring data and investigations could include short-term
remediation in areas where monitored floatables conditions create acute human or navigation
hazards and, as appropriate, longer-term remediation actions and modifications to the Spring
Creek Waterbody/Watershed Facility Plan if monitored floatables trends indicate impairment of
waters relative to their intended uses.
Meteorological Conditions
The performance of any CSO control facility cannot be fully evaluated without a detailed
analysis of precipitation, including the intensity, duration, total rainfall volume, and precipitation
event distribution that led to an overflow or, conversely, the statistical bounds within which the
facility may be expected to control CSO completely. NYCDEP has established 1988 as
representative of long-term average conditions and therefore uses it for analyzing facilities where
"typical" conditions (rather than extreme conditions) serve as the basis for design. The
comparison of rainfall records at JFK airport from 1988 to the long-term rainfall record is shown
in Table 3, and includes the return period for 1988 conditions.
In addition to its aggregate statistics indicating that 1988 was representative of overall
long-term average conditions, 1988 also includes critical rainfall conditions during both
recreational and shellfishing periods. Further, the average storm intensity for 1988 is greater than
DRAFT 3 of 8 January 25. 2008
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Spring Creek
one standard deviation From the mean so that using 1988 as a design rainfall year would be
conservative with regard to water quality impacts since CSOs and stormwater discharges are
driven primarily by rainfall intensity. However, considering the complexity and stochastic nature
of rainfall, selection of any year as "typical" is ultimately qualitative, and performance is not
expected to simply correlate to annual rainfall volume or any other single statistic. The
performance of the Spring Creek AWPCP and the response of Spring Creek with respect to
widely varying precipitation conditions will he evaluated with respect to observed rainfall, and
will be summarized in a manner similar to that shown in Table 3.
Multiple sources of rainfall data will be compiled as part of the final City-Wide Post-
Construction Monitoring Program. On an interim basis, however, the primary source of rainfall
data will be from JFK Airport and from any NYCDEP gauges that may be available. The use of
NEXRAD cloud reflectivity dala as proposed in the Waterbody/Watershed Facility Plan will be
limited to testing implementation techniques until its utility is fully understood. Any data sets
determined to be of limited value in the analysis of compliance may be discontinued.
Analysis
The performance of the Spring Creek AWPCP will be evaluated on an annual basis using
a landside mathematical computer model as approved by NYSDEC. In addition, NYCDEP
believes that the analysis of water quality compliance is best accomplished using computer
modeling supported and verified with a water quality monitoring program. Modeling has several
advantages over monitoring:
1. Modeling provides a comprehensive vertical, spatial, and temporal coverage that
cannot reasonably be equaled, with a monitoring program;
2, Modeling provides the data volume necessary to compute aggregate statistical
compliance values, such as a geometric mean, an absolute limit (e.g., "never-Iess-
tlian" or "not-to-excecd"), or a cumulative statistic (e.g., the 66-day deficit-duration
standard for dissolved oxygen to be promulgated by NYSDEC in the near future);
3, Discrete grab sampling for data collection is necessarily biased to locations and
periods of logistical advantage, such as navigable waters, safe weather conditions,
daylight hours, etc.; and
4. Quantification of certain chemical parameters must be performed in a laboratory
setting which either (a) complicates the use of a smaller sampling vessel that is
necessary to access shallower waters not navigable by a vessel with on-board
laboratory facilities or (b) limits the number sampling locations that can be accessed
due to holding times and other laboratory quality assurance requirements if remote
laboratory (non-vessel mounted) facilities are used.
The InfoWorks collection system model of the 26th Ward WPCP service area was
developed under the LTCP project based in part on historical models used in facility planning.
InfoWorks is a state-of-the-art modeling package that includes the ability to represent retention
tank dynamics and other sophisticated aspects of performance. Overflow volumes will be
quantitatively analyzed on a monthly basis to isolate any periods of performance issues and their
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impact on water quality. Water quality modeling re-assessment will be conducted every two
years based on the previous two years water quality field data. Modeling conditions will be based
on the hydrodynamic and meteorological conditions for the study year, documented operational
issues that may have impacted the facility performance, and water quality boundary conditions
based on the Harbor Survey data from Jamaica Bay. Results will be compared to the Harbor
Survey data collected within Spring Creek to validate the water quality modeling system, and
performance will be expressed in a quantitative attainment level for applicable numerical criteria
based on the receiving water model. Should this analysis indicate that progress towards the
desired results is not being made, the analysis will:
" Re-verify all model inputs, collected data and available QA/QC reports;
« Consult with operations personnel to ensure unusual operational problems (e.g..
screening channel o/s, pump repair, etc.) were adequately documented;
» Evaluate specific periods of deviations from modeled performance;
H Confirm that all operational protocols were implemented, and that these protocols are
sufficient to avoid operationally-induced underperforrnanee;
* Re-evaluate protocols as higher frequency and routine problems reveal themselves;
and finally
» Revise protocols as appropriate and conduct Use Attainability Analysis (UAA) and if
necessary, revise LTCP.
Because of the dynamic nature of water quality standards and approaches to non-
compliance conditions, a period of ten years of operation will be necessary to generate the
minimal amount of data necessary lo perform meaningful statistical analyses for water quality
standards review and for any formal use attainability analysis (UAA) that may be indicated.
Following completion of the tenth annual report containing data during facility operation, a more
detailed evaluation of the capability of the Spring Creek AWPCP to achieve the desired water
quality goals will take place, with appropriate weight given to the various issues identified
during the evaluations documented in the annual reports. If it is determined that the desired
results are not achieved, NYCDEP will revisit the feasibility of cost-effective improvements.
Alternately, the water quality standards revision process may commence with a UAA that would
likely rely in part on the findings of the post-construction compliance monitoring program. The
approach to future improvements beyond the 10-year post-construction monitoring program will
be dictated by the findings of that program as well as the input from NYSDEC SPDES permit
and CSO Consent Order administrators. This schedule is not intended to contradict the 5-year
cycle used for updating SPDES permits.
Reporting
Post-construction compliance monitoring will be added to the annual BMP report
submitted by NYCDEP in accordance with their SPDES permits. The monitoring report will
include an overview of the performance of the Spring Creek AWPCP, although the official
facility overflow reporting will remain in the monthly operating report, as required by the
SPDES permits. Summary statistics on rainfall, the amount of combined sewage, and the
DRAFT SojH January 25. 2008
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,'Vevt' York City Department of Environmental Protection Interim Pout-Construction Compliance Monitoring
Spring Creek
proportions directed to the WPCP, passed through the facility overflow, and bypassed above the
head end of the facility will be provided in the Annual BMP report. Verification and refinement
of the model framework as necessary will be documented, and modeling results will be presented
to assess water quality impacts in lieu of high-resolution sampling. Analyses of precipitation,
temperature effects, and other conditions external to the CSO Facility performance will also be
included in the BMP report,
In addition to the information to be provided in the Annual BMP Report, NYCDEP will
submit a summary of the monitoring and modeling, including the data, once every five years.
NYSDEC has acknowledged that the variability in precipitation dynamics may require more than
five successive years of data to statistically validate the models used for evaluating compliance,
but have nonetheless stated that this information will be used to identify areas of significant
water quality non-compliance and gaps in the water quality modeling, and measure progress with
the LTCP goals. They have also stated that they intend to verify the 1988 rainfall data as the
"average" year.
DRAFT 6 /if 8 January 25, 2008
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Mm York City Department of Environmental Protection
Interim Post-Construction Compliance Monitoring
Spring Creek
Table 1. SPDES Permit Monitoring Parameters
PARAMETER
Overflow Volume
Retained Volume
BOD. 5-day_
TSS
Settleable Solids
Oil & Grease
Screenings
Fecal Co li form
Precipitation
REPORT
Event total
Monthly total
Event average
Event average
Event average
Event average
Monthly total
Event geo. mean
Event total
UNITS
MG
MG
mg/L
FREQUENCY
Per event
Per month
Per event-day
mg/L | Per event-day
mt/L
mg/L
eu, yd
No/IOOmL
inehes
Per event-day
Per event-day
—
Per event-day
Hourly
TYPE
Calculated
Totalized
Composite
Composite
Grab
Grab
NOTE
-
Flow to WPCP
Every 4 hr
Every 4 hr
Every 4 hr when manned
-
Calculated I -
Grab
Rain Gauge
Every 4 hr when manned
-
See most recent 26th Ward WPCP SPDES Permit (NY0026212) for exact descriptions and definitions.
Table 2. Current Harbor Survey Laboratory Protocols
Parameter
Ammonia (as N)
Chlorophyll 'a'
Dissolved Oxygen
Dissolved Silica
Enterococcus
Fecal Co li form
Nitrate (as N)
Orthophosphate (as ?)
PH
Total Kjeldahl Nitrogen
Total Phosphorus
Total Suspended Solids
Method
EPA 350. 1
EPA 445.0, modified for the Wclschraeycr Method
SM 4500-O C, Azide Modification (Winkler
Method)
SM 18-19 4500-Si D orUSGS 1-2700-85
EPA Method 1600, Membrane Filter
SM 1 8-20 9222D, Membrane Filter
EPA 353.2 or SM 18-20 4500-NO3 F
EPA 365,1
SM 4500-H B. tleetrometnc Method
EPA 35 1.2
EPA 365.4
SM 18-202540D
Notes: SM Standard Methods for the Examination of Water and Wasiewaier: EPA -
EPA's Sampling and Analysis Methods. Field instrumentation also includes an SEE 91
Sealogger CTD which collects salinity, temperature, and conductivity, among other
parameters.
Table 3. Rainfall Statistics, JFK Airport, 1988 and Long-Term Average
Statistic
Total Volume (inches)
Intensity, (in/lir)
Number of Storms
Storm Duration (hours)
1970-2002
Median
39.4
0.057
112
6,08
1988
Value
40.7
0.068
100
6.12
Return
Period
(years)
2.6
11.3
I.I
2.1
DH4FT
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264)04
©
26-002
CI-007
26-005
(o)
Belt Pkwy Br
HS J8
Figure I. Spring Creek I PCM Sampling Locations
DRAFT
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January 25, 2008
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Case Study: Northeast Ohio
Regional Sewer District
April 2011 209
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210 April 2011
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United States and State of Ohio v. Northeast Ohio
Regional Sewer District
Consent Decree
Appendix 2
Post-Construction Monitoring Program
April 2011 211
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Appendix 2 - Post-Construction Monitoring Program
Contents:
2.1 Introduction
2.2 Performance Criteria
2.3 Post-Construction Monitoring and Data Collection
2.4 Performance Assessment
2.5 Quality Assurance/Quality Control
2.6 Progress Reporting
2.7 Summary
2.1 Introduction
The purpose of the Post-Construction Monitoring Program (PCMP) is to verify that projects
constructed as part of the Long Term Control Plan (LTCP) meet the Performance Criteria
stipulated in Table 1.1 of Appendix 1 and the water quality goals established during the
development of the CSO Phase II Facilities Plans for the Easterly, Westerly and Southerly
combined sewer Districts. Terms used in this Appendix that are defined herein, or in the
Consent Decree or any other Appendix thereto shall have the meanings assigned to them in such
documents.
NEORSD developed LTCPs for systems tributary to the Easterly, Southerly and Westerly
wastewater treatment plants. NEORSD's CSO program was developed with water quality
monitoring and modeling components in order to identify water quality impairments attributable
to wet weather discharges from the system. The results of these studies were coupled with
extensive hydrologic and hydraulic modeling activities to understand the systems' response to
wet weather events. In order to calibrate these models, NEORSD also completed several flow
monitoring programs to quantify sewer flows. These monitoring programs, model development
and application as well as evaluation of control alternatives to meet water quality goals were
completed with specific LTCP project recommendations.
The last series of these studies was completed in March 2002 as required by the CSO NPDES
Permits for the Easterly and Southerly combined sewer service areas. Following the submission
of these plans NEORSD has continued with the design and construction of some of the
recommended facilities including early action projects in the Westerly, Easterly and Southerly
Districts, and an initial LTCP project in the Easterly District. In addition, NEORSD engaged in
negotiations with the United States and Ohio EPAs and the U.S. Department of Justice to agree
upon a consent decree that would govern the scope and implementation schedule of the
remaining LTCP recommendations.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 1
212 April 2011
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The recommended LTCP projects depicted in Appendix 1 (treatment facilities, tunnels, pump
stations, relief sewers, etc) comprise "Gray Infrastructure" control measures. In addition,
NEORSD will also be developing "Green Infrastructure" control measures for wet weather
control providing stormwater inflow reduction and/or detention to reduce overflow volumes.
These control measures have not been developed in terms of location and type(s) of Green
Infrastructure control measures although the general performance criteria and conditions for the
program are outlined in Appendices 3 and 4. It is NEORSD's intent to implement these Green
Infrastructure control measures subsequent to a Green Infrastructure Feasibility Study and
concurrent with the LTCP projects as a means to provide additional CSO control and provide for
credits where Green Infrastructure can be substituted for Gray Infrastructure control measures, in
whole or in part, in accordance with the provisions governing Tier Ib and Green for Gray
substitutions under the Consent Decree. If this objective is accomplished, the projects selected
will complement the LTCP projects and would be integrated into the PCMP monitoring and
evaluation for both the Gray and Green Infrastructure components.
The main elements of the PCMP include the following:
• A process to determine whether the CSO control measures are meeting the Performance
Criteria identified in Appendix 1.
• A process for assessing environmental benefits attributable to the CSO control measures.
• A monitoring schedule, initial sampling locations, associated monitoring, modeling
procedures to collect data related to the Performance Criteria, and the impacts from CSOs
on E. coli levels in CSO impacted receiving streams and Lake Erie; and
• Evaluation and analysis of the monitoring data to determine whether CSO control
measures are achieving desired outcomes and for reporting progress to the regulatory
agencies and general public.
2.1.1 Regulatory Requirements
U.S.EPA requires CSO communities to conduct a post-construction monitoring program during
and after LTCP implementation "to help determine the effectiveness of the overall program in
meeting [Clean Water Act] requirements and achieving local water quality goals."1 This
program should collect data that measure the effectiveness of CSO controls and their impact on
water quality, and should utilize existing monitoring stations used in previous studies of the
waterways and sewer system in order to compare results to conditions before controls were put
in place. The program should include a map of monitoring stations, a record of sampling
frequency at each station, a list of data to be collected, and a quality assurance/quality control
(QA/QC) plan.
In U.SEPA's December 2001 Report to Congress: Implementation and Enforcement of the
Combined Sewer Overflow Control Policy, the agency noted the difficulty of establishing a
monitoring and tracking program for CSO control programs. "Monitoring programs need to be
targeted and implemented in a consistent manner from year to year to be able to establish pre-
1 Combined Sewer Overflows, Guidance for Long-Term Control Plan (EPA 832-B-95-002, August 1995)
p. 4-15.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 2
April 2011 213
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control baseline conditions and to identify meaningful trends over time as CSO controls are
implemented," the report said. "In practice, it is often difficult, and in some instances impossible,
to link environmental conditions or results to a single source of pollution, such as CSOs. In most
instances, water quality is impacted by multiple sources, and trends over time reflect the change
in loadings on a watershed scale from a variety of environmental programs." The report also
noted that weather conditions and rainfall totals vary significantly from storm to storm and year
to year, making comparisons difficult.
2.1.2 Purpose and Scope
The Post-Construction Monitoring Program will collect data needed to document receiving
streams and Lake Erie improvements that can be attributed to the implementation of the control
measures identified in the LTCP, to evaluate whether CSO control measures have met the
Performance Criteria, and whether NEORSD's CSOs comply with the NPDES permits. In order
to enable comparisons to historic data, NEORSD will integrate the required CSO post-
construction monitoring program into its current monitoring programs. The general scope of the
post-construction monitoring program will include preparation and execution of the monitoring
plan, as well as evaluation of the effectiveness of CSO control measures. The combined sewer
districts included in this plan include the Easterly, Southerly and Westerly Districts. The
following receiving waters are covered by this PCMP - Lake Erie, Cuyahoga River, Big Creek,
Burke Brook, Doan Brook, Dugway Brook, Euclid Creek, Green Creek Culvert, Kingsbury Run,
Morgana Run, Nine Mile Creek, Rocky River, Shaw Brook Culvert, West Creek, Spring Creek
and Treadway Creek. The monitoring program has been developed based upon the following
scope of work:
• Document Current Baseline Conditions: During the CSO Phase II Facilities Plans for the
Easterly, Southerly and Westerly Districts, NEORSD performed a comprehensive
assessment of the baseline conditions for CSO frequency and volumes for the "typical
year" as well as baseline conditions for water quality within the receiving streams and
Lake Erie. These assessments will be used as the baseline conditions for comparing the
post-construction performance of the various control measures within the LTCP.
• Identify Parameters of Concern: NEORSD evaluated CSO control measures to analyze
their ability to improve receiving streams and Lake Erie water quality for specific
parameters of concern. During the development of the LTCPs and subsequent
discussions with the U.S. EPA and Ohio EPA, NEORSD identified E. coli bacteria as the
main parameter of concern. NEORSD will use E. coli bacteria to measure the effect of
its LTCP CSO control measures on its receiving streams and Lake Erie.
• Prepare and Execute Post-Construction Monitoring: The monitoring program will
evaluate whether specific CSO control measures are performing as designed and
constructed to meet its Performance Criteria. The program will identify how NEORSD
will collect data needed to document receiving waters improvements and any pollutant
reduction achieved through implementation of these control measures. Sections 2.2
through 2.5 further describe NEORSD's PCMP.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 3
214 April 2011
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• Report results to State and Federal Agencies: The results of the PCMP will be reported
to the U.S. EPA and the Ohio EPA. Upon completion of each CSO control measure,
NEORSD will prepare a Control Measure Report that evaluates whether the constructed
projects that comprise that Control Measure have achieved the desired results. Section
2.6 presents NEORSD's approach for tracking and reporting on the achievement of
Performance Criteria described in Table 1.1 of Appendix 1.
• Provide Public Information on Water Quality: Information from the monitoring program
will be available to the general Cleveland area public and interested parties. This
information will allow the public to be informed and educated relative to NEORSD's
water quality improvement programs and water quality issues.
2.2 Performance Criteria
The Performance Criteria developed during the CSO Control Program by NEORSD were based
on number of overflows per a "typical year" as defined in the CSO Phase II Facilities Plans for
the Easterly, Southerly and Westerly Districts. The original LTCP recommended numbers of
overflows that have been updated through subsequent discussions with the U.S. EPA and the
Ohio EPA. Appendix 1 shows the Performance Criteria for the various control measures
comprising the current LTCP, design criteria, critical milestones and provides information on
outfalls controlled.
2.3 Post-Construction Monitoring and Data Collection
An important element of the PCMP is the type, location and frequency of monitoring. The intent
is not to replicate the extent of intense monitoring that was performed during the development of
the LTCP. To the extent possible, these monitoring locations will be used again for the
performance monitoring. The difference is that density of monitoring locations will be reduced;
however, the duration of monitoring will likely be longer on average than what was done during
the planning phase. These locations will be reviewed prior to installation of new monitoring for
the PCMP. This section describes the various types of monitoring to be performed.
Flow and activation monitoring will be performed for a one-year post-construction monitoring
period following "Achievement of Full Operation" for each control measure as indicated in
Table 2.1 and discussed in Section 2.3.1, and CSO activation monitoring will again be performed
for a one year period following implementation of all Control Measures for each district
(Easterly, Southerly, Westerly).
In-stream monitoring will be performed on a continued system-wide basis for the duration of the
LTCP implementation beginning at the Achievement of Full Operation of the first control
measure to monitor stream improvements over time, as discussed in Section 2.3.2.
General performance criteria and monitoring approaches for the green infrastructure projects will
be integrated into the PCMP during planning of the green infrastructure projects as discussed in
Appendices 3 and 4.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 4
April 2011 215
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2.3.1 Flow Monitoring
Numerous temporary flow monitors were installed during the development of the CSO LTCP to
calibrate the hydraulic models. These monitors have since been removed. NEORSD will install
flow and/or activation monitors at numerous locations and utilize, where applicable, existing
permanent flow meters to validate and calibrate the models, as described in Section 2.4.1, during
the post-construction phase of the CSO control measure implementation. These locations were
considered to reflect overflow monitoring in all priority outfall locations, including at least one
CSO location within each control measure and represent the CSOs contributing 86% of the
current baseline CSO volume and 96% of the CSO volume expected following implementation
of the CSO controls required by this Consent Decree. These locations are listed in Table 2.2.
CSOs not monitored have remaining volumes less than 1 MG each.
The flow meter locations listed in Table 2.2 are identified by outfall. However, the actual flow
monitors would be placed within the new diversion structures that divert flow to either the
associated control facility (i.e., tunnel, storage tank, etc.) or the CSO outfall if the capacity of the
control measure is exceeded. These diversion structures are situated downstream of the
combined sewer regulator structures, on the outfall conduits. When the control facility exceeds
its capacity, these structures divert overflow to this existing conduit, and a flow monitor would
be placed within this structure to measure these overflows. For some outfalls, such as the
Dugway Brook (CSO-230), multiple diversion structures would be constructed upstream of the
permitted outfall location diverting flow to the control facility. In these cases, each diversion
structure would be equipped with a flow monitor to measure the total overflow activation event
in a cumulative manner. These locations will be confirmed and additional monitoring will be
performed as deemed necessary as the program design advances to ensure that the appropriate
data to validate and/or calibrate the model and subsequently prove achievement of the
Performance Criteria is collected. Augmentation of the monitoring locations will proceed with
approval from Ohio EPA and U.S. EPA.
Planning, design and construction of the control measures will take place over several years.
Consequently, the dates for "Achievement of Full Operation" will vary by project. Table 2.1
summarizes the Achievement of Full Operation for these control measures, which is the year that
would initiate the post-construction monitoring for each control measure, and how the CSO
control measures in Appendix 1 will be assessed. NEORSD will perform this evaluation by
collecting precipitation and CSO outfall monitoring data for a one-year post-construction
monitoring period following Achievement of Full Operation of each CSO control measure as
identified in Appendix 1. Following collection system hydraulic model validation using the
selected monitoring data, a "typical year" simulation will determine performance relative to the
overflow frequency for each control measure.
2.3.2 In-stream Monitoring
NEORSD performed an analysis of water quality conditions, for baseline conditions and for
conditions after the implementation of the recommended LTCP projects. This analysis was
performed to establish levels of CSO controls that would result in water quality benefits. The
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 5
216 April 2011
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analysis was performed primarily through the simulation of fecal coliform bacteria loads in the
receiving streams, rivers and lake. The analysis involved the following streams: Big Creek,
Burke Brook, Doan Brook, Dugway Brook, Euclid Creek, Green Creek Culvert, Kingsbury Run,
Mill Creek, Morgana Run, Nine Mile Creek, Rocky River, Shaw Brook Culvert, West Creek,
Spring Creek and Treadway Creek. These streams were modeled and the outputs from these
models were used to estimate impacts on either the Cuyahoga River or Lake Erie, or both,
depending on which is the downstream receiving water.
The LTCP identified fecal coliform bacteria loads for dry weather, storm water and CSOs. This
was done to document the specific contribution of CSOs to violations of the in-stream bacteria
standards. Through discussions with the U.S. EPA and Ohio EPA, E. coli bacteria were
identified as the pollutant of concern to measure during the post-construction monitoring period.
NEORSD will measure E. coli bacteria counts in order to identify trends in water quality.
Biological and other monitoring data (to the extent that these are already being collected by
NEORSD) can be used as a check since NEORSD is already routinely monitoring the lake and
points along tributary rivers and streams. NEORSD has performed several special lake
monitoring projects. Among these are fish tissue sampling, which contributed to the State's basis
for issuing safe fish consumption advice, and the ongoing daily sampling at two area beaches for
bacteriological analysis, which provides the State's basis for posting safe swimming advice at
these locations.
Based on the requirements of the CSO permits issued to NEORSD, in-stream monitoring of
biological water quality indicators in Big Creek, Doan Brook, Euclid Creek and Mill Creek have
been collected for use in establishing baseline conditions prior to implementation of the
recommended CSO LTCP. NEORSD will continue to monitor for E.coli in these streams.
NEORSD proposes additional sites for E. coli monitoring in the Cuyahoga River, Dugway
Brook, Nine Mile Creek, Ohio Canal, Rocky River, Shaw Brook, Spring Creek, West Creek and
Treadway Creek. These sites are appropriate for the purposes of the Post-Construction
Monitoring Program to document achievement of Performance Criteria and to document
improvements to water quality over time. These sites are listed in Table 2.2 and illustrated in
Figure 2.2. NEORSD may add, modify, remove or relocate monitoring stations, as necessary,
during or after implementation of control measures to address any changes that may be necessary
as a result of planning, design and construction, provided NEORSD obtains approval from the
U.S. EPA and Ohio EPA.
2.3.3 Outfall Monitoring for Activations
Pursuant to the EPA's CSO permit and EPA's CSO Nine Minimum Controls Guidance,
NEORSD provides public notification of CSO occurrences at various CSO locations. NEORSD
monitors CSO activations on a continuous basis at these locations. NEORSD will continue to
monitor and collect this type of data at the relevant locations which are listed in Table 2.2 as
"activation only" and illustrated in Figure 2.1 Following implementation of all control measures
for each district (Easterly, Southerly, Westerly), NEORSD shall conduct one year of activation
monitoring at all CSO monitoring locations listed in Table 2.2. These data will be used to
validate the models and demonstrate achievement of the Performance Criteria.
2.3.4 Outfall Monitoring for CSO Treatment Facilities
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April 2011 217
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The current list of projects includes Chemically Enhanced High Rate Treatment (CEHRT)
facilities at the Easterly and Westerly WWTPs to control CSO-001 and CSO-002, respectively.
The monitoring plan for these projects will be developed separately and used to demonstrate
effectiveness of the CEHRT facilities. These facilities will include monitoring systems to
measure E. coli, total suspended solids and chlorine residual in the treated effluent to
demonstrate achievement of their respective Performance Criteria. In addition, these facilities
will monitor the overflows that exceed the peak treatment capacity of the CEHRTs. For
informational purposes, NEORSD will also measure CBOD, nitrogen, and phosphorus.
2.3.5 Wastewater Treatment Plant Monitoring
Routine WWTP monitoring will be used to demonstrate compliance for control measures that
require increased secondary capacity in order to eliminate primary effluent bypasses (PEB) (in a
typical year). PCMP compliance of the increased secondary treatment capacity can be
performed within the normal plant monitoring contained in their respective NPDES permits.
NEORSD will continue to flow monitor the PEB.
2.3.6 Rainfall Monitoring
NEORSD currently maintains a rain gauge network within the service area. Table 2.3 and
Figure 2.3 show these existing rain gauges. These rain gauges will be utilized in each Control
Measure post-construction monitoring period and in the district-by-district post-construction
monitoring periods to measure rainfall within the service area for each CSO control measure. If
required, additional rain gauges will be installed to ensure accurate measurement of rainfall, and
NEORSD will consider the use of radar-rainfall measurements to improve accuracy of rainfall
estimates, and particularly where rain gage coverage is not adequate or difficult to implement.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
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218 April 2011
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Table 2.3 NEORSD's Rain Gauges
Site ID
RNT
RWF
RST
ROA
RJA
RBT
RSG
RNR
ROL
RBC
RIN
RMA
RJO
RPM
RSY
RMY
RBH
RDA
RDR
RWK
RCL
REA
RMN
RMD
RSO
North Olmsted
Westlake
Strongsville
Oakwood
James Rhodes H.S.
Brook Park
Shaker Heights
North Royalton
Olmsted Falls
Brecksville
Independence
Maple Heights
John Marshall H.S.
Parma
Southerly WWTP
Mayfield
Beachwood
Division Ave P.S.
Dille P.S.
Wade Park
Cleveland Heights
Easterly WWTP
Moreland Hills
Macedonia P.S.
South Euclid
2.3.7 Data Management
NEORSD currently maintains its data within various data management systems for the collection
system and its three wastewater plants. Considering the number of monitoring locations and
types of data that are being collected, the retrieval, record keeping and analysis of the data is
essential in maintaining an effective monitoring program. Field procedures and QA/QC
approaches to ensure that the collected data are suitable for the intended analysis are also a
critical component of this program. This PCMP will use the existing NEORSD data management
systems to store the data. The effectiveness of the CSO control measures will be evaluated using
appropriate modeling tools. The PCMP will be designed to ensure collection of appropriate data;
establish consistency of sampling methods and data acquisition; and define performance
standards for maintaining data integrity. All measures necessary will be taken to validate, track,
store and manage the collected data to ensure that monitoring objectives are achieved.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 8
April 2011
219
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Sampling and modeling protocols will be administered and conducted by experienced personnel
responsible for the existing database and model. As data are generated during the PCMP, the
program may need to be revised to accommodate alternative data collection techniques or data
evaluation approaches to meet monitoring objectives. Any revisions or additions to the data
retrieval or management aspects of the PCMP will be submitted to the U.S. EPA and Ohio EPA
for review and approval.
2.4 Performance Assessment
2.4.1 Model-Based Approach to Assessing Compliance
Under the model based approach to demonstrate compliance, NEORSD plans to update and
utilize the various CSO models that were prepared during the development of the LTCP. The
models will be used to perform appropriate simulations to demonstrate compliance with the
performance criteria for each CSO control measure identified in Appendix 1. Models will also
be used in conjunction with monitoring data to assess the performance of Green Infrastructure
control measures installed pursuant to Appendices 3 and 4. This approach is outlined in the
following steps:
1. Collect selected rainfall and CSO outfall data for the post-construction monitoring period of
each CSO control measure upon completion, and rainfall data and activation data for all
selected CSO outfalls following implementation of all control measures for each district
(Easterly, Southerly, Westerly).
2. Perform quality assurance and quality control of the data collected in Step 1.
3. Utilize the appropriate LTCP CSO model and rainfall data collected during the monitoring
period to run simulations of CSO discharges for the post-construction monitoring period.
4. Adjust precipitation/runoff information used in the model to take into account the effects of
green infrastructure implementation, reflecting green infrastructure monitoring data.
5. Compare the simulation outputs to the CSO monitoring data for the post-construction
monitoring period to determine whether re-calibration of the hydraulic model is required.
Model re-calibration will not be required if the model-predicted activations are not less than
the monitored CSO activations for each remaining CSO outfall for the post-construction
monitoring period. Otherwise, model re-calibration will be required in accordance with
Steps 6 -8 below.
6. For re-calibration, select two or more appropriate rainfall events from the post-construction
monitoring period.
7. Develop an initial data set for use with the model and perform successive applications of the
model with appropriate parameter adjustments until the degree of agreement between the
model output and the CSO monitoring data for the post-construction monitoring period
meets the criteria set forth in Step 5, above. In making re-parameterization adjustments,
NEORSD will consider the inherent variability in both the collection system model and in
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flow monitoring data, and will exercise sound engineering judgment and best industry
practices so as to not compromise the overall representativeness of the model.
8. Upon completion of Step 7, NEORSD shall run an additional continuous simulation for the
entire post-construction monitoring period to verify the recalibrated model. Thereafter,
NEORSD shall compare the continuous simulation outputs to the CSO monitoring data
described in Step 5 to determine whether additional recalibration is needed. If so, NEORSD
shall conduct recalibration in accordance with steps 6 through 7 until the model achieves the
criteria described in Step 5, above.
9. Overflow frequency performance criterion is based upon a "typical year" developed as part
of the CSO Phase II Facilities Plans. The "typical year" was comprised of actual rain
events recorded at Cleveland Hopkins Airport based on an analysis of 46 years of rainfall
recorded at this site. Table C-l - Storm Events for Typical Year Continuous Year
Simulation from the CSO Facilities Planning Summary Report, March 2005 is attached to
the PCMP. This table lists all the typical year storms, the dates, the hour, duration, depth
and intensity of rainfall.
10. NEORSD will utilize the validated, and/or re-calibrated, hydraulic models to run the
"typical year" to determine whether the CSO control measures have achieved the
Performance Criteria identified in Appendix 1. If the modeled overflow frequency exceeds
this level for any of the CSO control measures, NEORSD shall submit an analysis that will
include: (1) the factors causing the additional overflow frequency, (2) any impact on water
quality from the additional overflow frequency, (3) control options, including green
infrastructure improvements, to reduce the overflow frequency to meet the Performance
Criteria levels, (4) associated costs from the additional control options, (5) any expected
benefits from such control options and (6) a recommendation of additional control measures
necessary to meet water quality requirements.
2.4.2 Evaluating the Performance of Green Infrastructure CSO Control Measures
NEORSD will submit its proposed Tier 1 green infrastructure post-construction monitoring
program in accordance with Appendix 3. NEORSD may also submit proposals to substitute
green infrastructure CSO control volumes for gray infrastructure control volumes in accordance
with Appendix 4. Once approved by U.S. EPA and Ohio EPA, NEORSD shall perform green
infrastructure post construction monitoring (GIPCM) for the green infrastructure control as
described in Appendices 3 and 4.
2.4.3 Control Measures Reports
Following Achievement of Full Operation of each CSO Control Measure listed in Appendix 1,
NEORSD shall submit a Control Measures Report to the U.S EPA and Ohio EPA for their
approval. The Control Measures Report will be submitted within 24 months of the date of
Achievement of Full Operation for each control measure. The reports will include information
for the completed control measures implemented and data related to the following:
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April 2011 221
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• Description of the area served by the particular CSO Control Measure, affected receiving
waters, and CSO Control Measures being evaluated
• CSO Monitoring and Rainfall Monitoring Results
• Evaluation of the CSO Control Measures
• Significant Variances and Impacting Factors (with regard to verification of level of
control)
• Re-evaluation and Corrective Actions as outlined in section 2.4.4 (if necessary)
The green infrastructure improvements schedule for Control Measure reporting would be
developed as part of the Green Infrastructure Feasibility Study and would be reviewed and
approved upon completion of the study. NEORSD can submit the Control Measures Report for
the Big Creek Tunnel System as part of the Final Post Construction Monitoring Program Report
pursuant to section 2.6.1.
2.4.4 Corrective Action Plans
If, following post construction monitoring, the analysis conducted pursuant to Sections 2.4.2and
2.4.3 above fails to demonstrate that the CSO control measures, combined with any Green for
Gray substitutions if applicable, have met the pertinent performance criteria in a typical year set
forth in Appendix 1, NEORSD shall submit to EPA and Ohio EPA for their approval, a
Corrective Action Plan ("CAP") as part of the Control Measure Report. The CAP shall
describe: (1) the specific measures to be carried out to address performance shortcomings and
ensure the performance criteria in Appendix 1 are met; (2) a schedule, as expeditious as possible,
for implementation of the corrective measures and (3) how the improvements when fully
constructed shall be evaluated in accordance with this Appendix. The corrective measures
described in the CAP shall achieve the performance criteria set forth in Appendix 1.
U.S. EPA and Ohio EPA shall review each CAP submitted by NEORSD. The Agencies may
request clarifications or supplemental information to make informed decisions on each CAP.
Upon the conclusion of reviews of the CAP, the Agencies will approve the CAP, approve with
conditions, or disapprove the CAP. If a CAP is disapproved, NEORSD must submit a revised
CAP addressing the deficiencies identified by U.S. EPA and Ohio EPA in the initial CAP.
NEORSD shall implement those measures set forth in the approved CAP in accordance with the
schedule in the approved CAP
2.4.4.1 Green Infrastructure Measures Implemented Pursuant to Appendix 4
Proposals to substitute green infrastructure control measures for gray infrastructure control
measures will include a description of post-construction monitoring and modeling to be
performed to determine whether the performance criteria set forth in Appendix 1 will be met
upon completion and implementation of the control measures outlined in the Proposal.
NEORSD shall implement the post-construction monitoring of green and gray infrastructure as
described in approved proposals. If green infrastructure post-construction monitoring does not
demonstrate that constructed green infrastructure components are meeting the performance
criteria in a typical year on which the substitution was based, NEORSD may implement early
corrective measures to address identified deficiencies. Early correction actions may include
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measures such as constructing additional green infrastructure capacity or increasing the size
and/or capacity of gray infrastructure control measures. Stipulated Penalties will not accrue and
become payable if an individual green infrastructure control measure is not meeting the criteria
on which the substitution was based beginning at the time the green infrastructure control
measure begins operation. However, stipulated penalties will accrue and become payable as of
the date of Achievement of Full Operation as defined in Appendix 1 if at the time the pertinent
green and gray control measures together are not meeting the performance criteria for a typical
year.
2.5 Quality Assurance/Quality Control
An important component of any CSO quality sampling effort includes sample preservation, handling,
and shipping; chain of custody documentation; and quality assurance and quality control (QA/QC)
procedures. The QA/QC procedures are essential to ensure that data collected in environmental
monitoring programs are useful and reliable. NEORSD will employ quality control procedures to
ensure consistent delivery of quality work and products for all aspects of the PCMP. The quality
control procedures include documentation for the following:
• Monitoring and field measurement activities
• CSO outfall monitoring activities including installation activities, calibration records,
field truthing equipment and maintenance, and data downloads
• Field sampling activities
• Laboratory analysis activities
• Rainfall monitoring activities
• Data retrieval, management and analysis activities
• Quality control reviews of all internal and external deliverables
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
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Flow Monitoring Data
Data will be reviewed continually throughout the monitoring program by a data analyst to
identify data gaps, questionable data, estimate uncertainty in flow data, and monitor service or
gage maintenance needs. The data will be reviewed for the following items:
• consistent diurnal patterns, as applicable
• consistent flow vs. level patterns
• consistent level vs. velocity patterns (i.e., scatter graphs)
• correspondence with field points and wet weather responses to rainfall
Questionable data will be flagged and the raw data will be converted into final data by editing
questionable data, where possible.
Upon installation and activation of each flow meter, field crews will take manual depth and
velocity readings (when there is a reasonable amount of flow present) using independent
instrumentation to confirm that the monitor in-situ yields data representative of actual field
conditions, and to quantify uncertainty in the instrument's measurement of flow. All
measurements, adjustments, and efforts undertaken during site visits will be logged. In addition
to the manual measurements taken at installation, routine calibrations will be performed
throughout the flow monitoring period including at least two wet weather calibrations. These
routine calibrations will provide an independent confirmation that the meters are working
properly.
Water Quality Data
The NEORSD Analytical Services Quality Manual and associated Standard Operating Procedures are on
file with Ohio EPA. The Quality Assurance Officer at Analytical Service will send updates, revisions and
any information on document control to Ohio EPA as needed.
2.6 Progress Reporting and Final Post Construction Monitoring Procedures
The post-construction monitoring program will evaluate whether CSO control measures are
achieving the Performance Criteria. It will also assess water quality conditions in CSO receiving
waters within the NEORSD combined sewer service areas against the baseline conditions
identified in the CSO Phase II Facilities Plans for the Easterly, Southerly and Westerly districts.
This section discusses how progress will be reported to the U.S. EPA, Ohio EPA and the public.
2.6.1 Final Post-Construction Monitoring Program Report
Within three years following Achievement of Full Operation for all of the LTCP projects,
NEORSD shall submit a Final PCMP Report to the U.S. EPA and Ohio EPA for their approval,
containing a consolidation of all of the information identified in Section 2.4.3 for each control
measure, the results of the final district-by-district rainfall and activation monitoring of all CSOs
listed in Table 2.2, a re-validation of the collection system models using the aforementioned
CSO activation monitoring results for the outfalls listed in Table 2.2 for each District, water
quality monitoring results, effluent testing results, plus any additional relevant information
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
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collected since submittal of the Control Measures Reports. The purpose of the Final PCMP
Report shall be to evaluate and document the performance of NEORSD's fully implemented
LTCP CSO control measures on a system-wide basis (based upon CSO activation data and water
quality monitoring). The report shall include an assessment of whether the improvements are
meeting the Performance Criteria in accordance with Appendix 1 (CSO activation frequencies,
bypass frequencies) and water quality based numeric and/or narrative effluent limitations
applicable to CSO discharges in NEORSD's NPDES Permits. NEORSD shall also provide a
further assessment of the long-term trends in water quality of NEORSD's receiving waters. If
the Final PCMP Report fails to demonstrate that the Performance Criteria are met, NEORSD
shall include in the report whatever further re-evaluation or corrective action necessary to meet
the Performance Criteria as well as a schedule for such re-evaluation or corrective action.
NEORSD shall then implement any further re-evaluations or corrective actions in accordance
with the approved Final PCMP Report.
2.6.2 Progress Reports to Public
Public involvement, information and education is an important part of the overall LTCP Program
development approach recommended by U.S. EPA's CSO Control Policy and utilized by
NEORSD in the development of the control program. As part of the PCMP, public outreach
activities will continue with periodic updates using various media available to NEORSD.
Available media will include the NEORSD website, local newsprint, radio and television.
Updates will include status of remaining construction projects, improvements or trends in
monitored water quality parameters any available anecdotal evidence from public's interaction
with the waterways.
2.7 Summary
NEORSD's Post-Construction Monitoring Program will determine the effectiveness of the CSO
control program in achieving its performance requirements and water quality objectives. The
program includes the following elements:
• Implementation of a defined monitoring program designed to measure reductions in
overflow activations and changes in steam water quality
• Analysis and assessment of monitoring data and/or model simulation results to determine
whether implemented CSO Control Measures are meeting the Performance Criteria in
Appendix 1
• Analysis and assessment of in-stream monitoring data to establish trends in stream
improvements
• Preparation of Control Measures Reports and a Final PCMP Report to document the
success of the LTCP implementation or identify any shortcomings and necessary
corrective action
• Dissemination of information on the LTCP implementation to NEORSD's rate payers
and Cleveland area general public
NEORSD's Post-Construction Monitoring Program addresses the U.S. EPA and Ohio EPA
requirements for monitoring the performance of the CSO control measures. NEORSD will use
the Performance Criteria in Appendix 1 as performance measures to determine the effectiveness
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
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April 2011 225
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of the overall LTCP CSO control measures, augmented by any additional green infrastructure
improvements. NEORSD will use existing monitoring systems, augmented as necessary, to
collect and evaluate data. This includes flow and/or activation monitoring, in-stream sampling,
plant sampling and rain gauge monitoring. NEORSD shall also use the appropriate LTCP CSO
hydraulic models to measure performance of the CSO control measures as described in Section
2.4. NEORSD shall submit Control Measures Reports to the U.S. EPA and Ohio EPA, as
required, to demonstrate performance and achievement of LTCP objectives. In addition,
NEORSD shall prepare public information reports to educate the public on the advancement of
the program and the effectiveness of the control measures being implemented.
Appendix 2 to Consent Decree in United States and State of Ohio v. Northeast Ohio Regional Sewer
District, N.D. Ohio - FINAL Draft Page 15
226 April 2011
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NJ
O
Easterly Plant
Easterly Treatment and Disinfection of CSO 001 using CEHRT
Westerly Plant
..... Treatment and Disinfection of CSO 002 using CEHRT
westerly |n g|| g Quadrants (quads)
Southerly Plant
_ th . Increase Secondary Treatment Capacity and Treat
y Primary Effluent Bypass with CEHRT
Easterly CSO Projects
Easterly Euclid Creek Tunnel/Dugway Storage System
Easterly Shoreline Tunnel System
Easterly Doan Valley Tunnel System
Easterly Superior Avenue Pump Station Upgrade
Easterly Stones Levee Pump Station Upgrade
Easterly Canal Road In-Line Storage
Westerly CSO Projects
Westerly Westerly Tunnel System
Westerly Columbus Road Storage Tank
Westerly Center Street Storage Tank
Westerly West Third Street Storage Tank
Westerly Mary Street Pump Station Upgrade
Outfall 001
Outfall 002
Outfalls 206, 208,209, 210,
211,212, 214, 230, 231, 232,
239, 242
Outfalls 093, 094, 095, 096,
097, 098, 200, 201, 202, 203,
204, and 205
Outfalls 073, 217,218, 219,
220, 221, 222, 223/224, 226,
and 234
Outfalls 090, W.
Hth/Superior Pump Station
CSO
Outfalls 235, Stones Levee
Pump Station CSO;
surcharging relief
Outfalls 090, 235; Additional
storage capacity and flow
attenuation
Outfalls 074, 075, 080, 087
Outfall 078
Outfall 076
Outfall 082
Outfall 086
Dependent on the approved
pilot program schedule.
Dependent on the approved
pilot program schedule.
Dependent on the approved
pilot program schedule.
2021
2017
2024
2019
2024
2025
2017
2 partially treated
overflows/year
3 partially treated
overflows/year
Priority outfalls = 2 or less;
Nonpriority = 3 or less
3 or less
Priority outfalls = 2 or less;
Nonpriority = 3 or less
0
0
4 or less
4 or less
NJ
NJ
Commencement of first flow monitoring for control measure and system-wide in-stream monitoring.
-------
NJ
NJ
00
Westerly Jefferson Avenue Separation
Westerly West 3rd St/Quigley Parallel Storage System
Southerly CSO Projects
Southerly Southerly Tunnel System
Southerly Big Creek Tunnel System
Southerly CSO-045 Storage Tank
Outfall 240
Outfall 089
Outfalls 033, 035, 036, 039,
040, and 072
Outfalls 043, 044, 049, 050,
051, 053, 054, 055, 056, 057,
058, 059, 233, 238, & Cooley
Avenue
Outfalls 045, 088
2028
2021
2035
2023
0
2 or less
Priority outfalls = 3 or less;
Nonpriority = 4 or less
NJ
O
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Table 2.2
CSO and Stream Monitoring
Site ID
Easterly System CSOs
CSO-001
CSO-098
CSO-206
CSO-209
CSO-210
CSO-211
CSO-230
CSO-232
CSO-239
CSO-242
CSO-090
CSO-200
CSO-202
CSO-204
W. llth/Superior P.S.
Location
Easterly WWTP
North of E. 33rd St. & Lakeside Ave.
North end of E. 156th St. @ Lake Erie
West side of Euclid Creek & Lake Shore
Blvd.
East of Nottingham R. and St. Clair Ave
Nine Mile Creek east of Coit Rd.
Dugway Brook approx. 600-ft from
Lakeshore Blvd.
East of Eddy Rd. @ Shaw Brook
Lakeshore Blvd. @ Euclid Creek
E. 142nd St. & Lakeshore Blvd.
End of Superior Avenue @ Cuyahoga
River
North of E. 40th St. & King Ave.
E. 55th St. & Lake Erie
West of E. 72nd St. @ Lake Erie
End of Superior Avenue @ Cuyahoga
River
Receiving
Stream
Lake Erie
Lake Erie
Lake Erie
Euclid Creek
Euclid Creek
Nine Mile
Dugway
Brook
Shaw Brook
Euclid Creek
Lake Erie
Cuyahoga
River
Lake Erie
Lake Erie
Lake Erie
Cuyahoga
River
Rationale
Priority CSO Point, CSO Treatment
Facility Effluent
Non-priority CSO within Shoreline
Tunnel System
Priority CSO within Euclid
Creek/Dugway Storage System
Priority CSO within Euclid
Creek/Dugway Storage System
Priority CSO within Euclid
Creek/Dugway Storage System
Priority CSO within Euclid
Creek/Dugway Storage System
Priority CSO within Euclid
Creek/Dugway Storage System
Priority CSO within Euclid
Creek/Dugway Storage System
CSO currently monitored tributary
to the Euclid Creek/Dugway
Storage System
CSO currently monitored tributary
to the Euclid Creek/Dugway
Storage System
Non-priority CSO controlled by
Superior Avenue Pump Station
Upgrade and Canal Road In-line
Storage
Priority CSO within Shoreline
Tunnel System
Priority CSO within Shoreline
Tunnel System
Priority CSO within Shoreline
Tunnel System
Non-priority CSO controlled by
Superior Avenue Pump Station
Upgrade
Real-time
Discharge
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Water Quality
X
Monitoring
Frequency
(during compliance)
Continuous
During discharge
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Monitoring Protocols
Flow, Level, Velocity, Onset
Duration
E.Coli, TSS
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Activation only
Activation only
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Table_2 2_CSO_and_Stream_Monitoring_2010_1110.xlsx
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Table 2.2
CSO and Stream Monitoring
Site ID
Stones Levee P.S.
CSO-073
CSO-221
CSO-222
Westerly System CSOs
CSO-002
CSO-067
CSO-069
CSO-071
CSO-075
CSO-076
CSO-078
CSO-080
CSO-082
CSO-086
CSO-089
Southerly System CSOs
CSO-035
CSO-036
Location
W. 3rd at Canal East Side of River
Giddings Brook @ Doan Brook NE of
Baldwin Rd. & Fairhill Rd.
E. 1 05th St. & Hough Ave
E. 105th St. & Doan Brook
Westerly WWTP
West of 3870 Rocky River Dr., northwest
corner of Kamm's Plaza
Upper Edgewater Park, approx. 300 yds.
west of beach
Harborview Dr. & W 1 17th St., behind
11644HarborviewDr.
River Rd. & Elm St.
Center St, & Cuyahoga River
Columbus Rd. & Cuyahoga River
SE of Scranton Rd. @ University Rd.
Under Bridge @ W. 3rd St. & Cuyahoga
River
Mary St. east of W. 3rd St. @ Cuyahoga
River
East of W. 3rd St. Pump Station
Burke Brook @ Cuyahoga River
West of Campbell Rd. & Independence
Intersection
Receiving
Stream
Cuyahoga
River
Doan Brook
Doan Brook
Doan Brook
Lake Erie
Rocky River
Lake Erie
Lake Erie
Cuyahoga
River
Cuyahoga
River
Cuyahoga
River
Cuyahoga
River
Cuyahoga
River
Cuyahoga
River
Cuyahoga
River
Burke Brook
Cuyahoga
River
Rationale
Non-priority CSO controlled by
Stones Levee Pump Station
Upgrade
Priority CSO within Doan Valley
Tunnel System
Priority CSO within Doan Valley
Tunnel System
Priority CSO within Doan Valley
Tunnel System
Priority CSO Point, CSO Treatment
Facility Effluent
CSO currently monitored within
Westerly Tunnel System
CSO currently monitored within
Westerly Tunnel System
CSO currently monitored within
Westerly Tunnel System
CSO currently monitored within
Westerly Tunnel System
Non-priority CSO controlled by
Center Street Storage Tank
Non-priority CSO controlled by
Columbus Road Storage Tank
Priority CSO within Westerly
Tunnel System
Non-priority CSO controlled by
West Third Street Storage Tank
Non-priority CSO controlled by
Mary Street Pump Station Upgrade
Non-priority CSO controlled by
West 3rd St./Quigley Parallel
Storage System
CSO currently monitored within
Southerly Tunnel System
Priority CSO within Southerly
Tunnel System
Real-time
Discharge
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Water Quality
X
Monitoring
Frequency
(during compliance)
Continuous
Continuous
Continuous
Continuous
Continuous
During discharge
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Monitoring Protocols
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, Velocity, Onset
Duration
E.Coli, TSS
Activation only
Activation only
Activation only
Activation only
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Flow, Level, and activation
Activation only
Flow, Level, and activation
Table_2 2_CSO_and_Stream_Monitoring_2010_1110.xlsx
-------
Table 2.2
CSO and Stream Monitoring
Site ID
CSO-038
CSO-040
CSO-043
CSO-044
CSO-045
CSO-051
CSO-055
CSO-056
CSO-057
CSO-058
CSO-059
CSO-063
Stream Monitoring
EMI
EM2
EMS
EM4
EMS
Location
600' Southwest of E 26th St. &
Independence Rd.
Kingsbury Run @ Cuyahoga River - North
of Jefferson Rd.
East of Intersection of Tarlton Ave. & W.
15th St.
North of Intersection of Irving Ave. &
South Hills Dr.
Northeast of Intersection of Jennings Ave.
& Valley Ave.
Brookside Dr. at mouth of triple culvert
Under Bridge East of Bellaire Rd. &
Kensington Rd.
Under Bridge East of Bellaire Rd. &
Kensington Rd.
Under Interstate @ Memphis & 1-71
W. 1 14th St. & Peony Ave.
Spring Rd. @ Jennings Rd.
Southeast of Brookpark R. & W. 10th St.
Intersection
Big Creek mile 0.15. Approximately 330
feet downstream of Jennings Road
(41.4460, -81.6865)*
Cuyahoga River mile 0.25. River left,
approximately 200 feet downstream of
railroad bridge (41.5002, -81.7100)
Doan Brook mile 0.75. Approximately
170 feet downstream of St.Clair Avenue
(41.5330, -81.6296)
Dugway Brook mile 0.37. Approximately
200 feet downstream of culvert opening
(41.5497, -81.6088)
Euclid Creek mile 0.55. Approximately
500 feet downstream of Lake Shore Blvd.
(41.5833, -81.5594)
Receiving
Stream
Cuyahoga
River
Cuyahoga
River
Treadway
Creek
Treadway
Creek
Big Creek
Big Creek
Big Creek
Big Creek
Big Creek
Big Creek
Spring Creek
West Creek
Big Creek
Cuyahoga
River
Doan Brook
Dugway
Brook
Euclid Creek
Rationale
CSO currently monitored within
Southerly Tunnel System
Priority CSO within Southerly
Tunnel System
CSO currently monitored within
Big Creek Tunnel System
CSO currently monitored within
Big Creek Tunnel System
Non-priority CSO controlled by
CSO-045 Storage Tank
CSO currently monitored within
Big Creek Tunnel System
CSO currently monitored within
Big Creek Tunnel System
CSO currently monitored within
Big Creek Tunnel System
Priority CSO within Big Creek
Tunnel System
Priority CSO within Big Creek
Tunnel System
CSO currently monitored within
Big Creek Tunnel System
Priority CSO within Southerly
Tunnel System
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Real-time
Discharge
X
X
X
X
X
X
X
X
X
X
X
X
Water Quality
X
X
X
X
X
Monitoring
Frequency
(during compliance)
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Monitoring Protocols
Activation only
Flow, Level, and activation
Activation only
Activation only
Flow, Level, and activation
Activation only
Activation only
Activation only
Flow, Level, and activation
Flow, Level, and activation
Activation only
Flow, Level, and activation
E. coli
E. coli
E. coli
E. coli
E. coli
Table_2 2_CSO_and_Stream_Monitoring_2010_1110.xlsx
-------
Table 2.2
CSO and Stream Monitoring
NJ
(JO
NJ
Site ID
EM6
EM7
EM8
EM9
EM10
EMU
EM12
EM13
EM14
EM15
*
Location
Edgewater Beach East
(41.4893, -81.7392)
Euclid Beach East
(41.5843, -81.5686)
Villa Angela Beach East
(41. 5851, -81. 5677)
Nine Mile mile 0.40. Approximately 325
feet upstream of Lake Shore Blvd.
(41.5575, -81.5991)
Ohio Canal at the bridge at Kurtz Broz
access road, approximately 275 feet
southwest of intersection of Canal Road
and East 49th Street
(41.4213, -81.6559)
Rocky River mile 2.40. Approximately
230 feet upstream of Hilliard Road bridge
(41.4705, -81.8238)
Shaw Brook mile 0.10. Approximately
100 feet upstream of Lake Shore Blvd
(41.5554, -81.6018)
Spring Creek mile 0.30. Approximately
650 feet downstream of CSO 059 outfall
(41.4378, -81.6801)
West Creek mile 1.95. Upstream side of
Lancaster Road Bridge
(41.4148, -81.6655)
Treadway Creek mile 0.40. Approximately
285 feet east of intersection of Tarlton
Avenue and West 15th Street (41.4409, -
81.6902)
Receiving
Stream
Lake Erie
Lake Erie
Lake Erie
Nine Mile
Ohio Canal
Rocky River
Shaw Brook
Spring Creek
West Creek
Treadway
Creek
Rationale
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Track receiving water conditions
downstream of CSO control
measures
Real-time
Discharge
Water Quality
X
X
X
X
X
X
X
X
X
X
Monitoring
Frequency
(during compliance)
Routinely during
recreation season
Routinely during
recreation season
Routinely during
recreation season
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Following significant
rainfall events
Monitoring Protocols
E. coli
E. coli
E. coli
E. coli
E. coli
E. coli
E. coli
E. coli
E. coli
E. coli
Latitude and longitude coordinates are taken from hand-digitized GIS maps and are not surveyed.
NJ
O
Table_2 2_CSO_and_Stream_Monitoring_2010_1110.xlsx
-------
Lake Erie
•J>'
S9f ipso-200
50:098 JT
CSO-098 j
Jf
r xO cs
f /
>J
Clevelan
Heights r«Jouth
Euclid
i
% ^StonesLeyeeP.S. *
jCSO-O^acso^jX
— • cso^sj i
,S^+ CSO-058
CSO-055^CS0^56_
CSO-057^J r
J$
rr •-• —k ^Ji
Independence
n
^ j Middleburg
Legend
EASTERLY WWTP
SOUTHERLY WWTC
WESTERLY WPCC
Proposed CSO Locations with
Flow/Activation Monitoring
Stream
NEORSD Long Term Control Plan
NEORSD Combined Service Area
April
Figure 2.1
Proposed CSO Locations with Flow/Activation Monitoring
Northeast Ohio Regional
Sewer District
Protecting Your Health and Environment
SOURCE:
NEORSD GIS, Cuyahoga County GIS
DATE: 15 October 2010
CREATOR: Engineering Technical Services
233
This map/data was compiled by the Northeast Ohio Regional Sewer District ("District") which makes every effort to produce and publish the most current and accurate information possible. This map/data was created and compiled to serve the
District for planning and analysis purposes. The District makes no warranties, expressed or implied, with respect to the accuracy of this map/data and its use for any specific purpose. The District and its employees expressly disclaim
any liability that may result from the use of this map/data. For more information, please contact: Jeffrey Duke, RE. (Engineering Technical Services) 3900 Euclid Avenue, Cleveland, Ohio 44115 (216-881-6600).
-------
Lake Erie
Legend
9 Proposed In Stream Monitoring Locations
E Easterly WWTP
S Southerly WWTC
W Westerly WPCC
Stream
^ NEORSD Long Term Control Plan
NEORSD Combined Service Area
234
Figure 2.2
Proposed In Stream Monitoring Locations
Northeast Ohio Regional
Sewer District
Protecting Your Health and Environment
SOURCE:
NEORSD CIS, Cuyahoga County CIS
DATE: 05 July 2010
CREATOR: Engineering Technical Services
April
This map/data was compiled by the Northeast Ohio Regional Sewer District ("District") which makes every effort to produce and publish the most current and accurate information possible. This map/data was created and compiled to serve the
District for planning and analysis purposes. The District makes no warranties, expressed or implied, with respect to the accuracy of this map/data and its use for any specific purpose. The District and its employees expressly disclaim
any liability that may result from the use of this map/data. For more information, please contact: Jeffrey Duke, RE. (Engineering Technical Services) 3900 Euclid Avenue, Cleveland, Ohio 44115 (216-881-6600).
-------
£
I
Z
§
Middleburg
Heights
W
•
Legend
NEORSD Rain Gauge
EASTERLY WWTP
SOUTHERLY WWTC
WESTERLY WPCC
NEORSD CSO Permit Point
Stream
April
NEORSD Combined Service Area
?mi
Figure 2.3
NEORSD Rain Gauges
Northeast Ohio Regional
District
SOURCE:
NEORSD CIS, Cuyahoga County CIS
DATE: 05 August 2010
Protecting Vow Health and Environment CREATOR: Engineering Technical Services
_; _ 235 _
This map/data was compiled by the Northeast Ohio Regional Sewer District ("District") which makes every effort to produce and publish the most current and accurate information possible. This map/data was created and compiled to serve the
any liability that may result from the use of this map/data. For more information, please contact: Jeffrey Duke, P.E. (Engineering Technical Services) 3900 Euclid Avenue, Cleveland, Ohio 44115 (216-881-6600).
-------
Table C-l. Storm Events for Typical Year Continuous Year Simulation
Storm
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
Date
1/3/91
1/5/91
1/9/91
1/11/91
1/12/91
1/15/91
1/16/91
1/20/91
1/26/91
1/27/91
1/29/91
1/30/91
1/31/91
2/5/91
2/6/91
2/10/91
2/13/91
2/16/91
2/18/91
2/19/91
2/26/91
2/28/91
3/2/91
3/3/91
3/6/91
3/9/91
3/10/91
3/17/91
3/22/91
3/22/91
3/23/91
3/26/91
3/27/91
3/31/91
4/1/93
4/2/93
4/9/93
4/11/93
4/14/93
4/15/93
4/19/93
4/20/93
4/24/93
4/25/93
4/30/93
5/4/93
5/19/93
5/23/93
5/24/93
5/28/93
5/31/93
6/3/93
6/5/93
6/7/93
6/9/93
6/9/93
6/19/93
6/20/93
6/25/93
6/27/93
7/1/93
Hour
12
13
13
4
12
24
19
13
7
19
20
18
14
7
15
15
14
24
15
17
4
9
1
13
6
18
12
21
6
24
24
13
24
19
23
17
14
16
19
23
17
16
12
8
1
13
4
16
6
24
23
23
5
16
10
24
6
13
20
18
21
Duration
(Hrs)
1
10
2
19
21
8
10
30
10
4
11
1
1
1
9
20
59
14
13
7
40
4
14
24
14
2
4
31
4
3
10
1
1
6
5
12
16
1
2
3
13
18
2
15
6
25
6
1
6
2
2
2
6
9
1
1
2
26
1
1
4
Depth
(In)
0.01
0.18
0.03
0.39
0.04
0.33
0.17
0.53
0.03
0.08
0.37
0.01
0.01
0.01
0.1
0.73
1.53
0.18
0.08
0.29
0.08
0.04
0.06
0.7
0.83
0.07
0.08
0.5
0.32
0.14
0.23
0.02
0.62
0.07
0.16
0.06
0.77
0.09
0.03
0.34
0.27
0.61
0.03
0.46
0.1
0.63
0.15
0.01
0.08
0.03
0.16
0.07
0.37
1.56
0.21
0.24
0.31
0.54
0.08
0.94
0.05
Average
Intensity
(In/Hr)
0.01
0.02
0.02
0.02
0
0.04
0.02
0.02
0
0.02
0.03
0.01
0.01
0.01
0.01
0.04
0.03
0.01
0.01
0.04
0
0.01
0
0.03
0.06
0.04
0.02
0.02
0.08
0.05
0.02
0.02
0.62
0.01
0.03
0.01
0.05
0.09
0.02
0.11
0.02
0.03
0.02
0.03
0.02
0.03
0.03
0.01
0.01
0.02
0.08
0.04
0.06
0.17
0.21
0.24
0.16
0.02
0.08
0.94
0.01
Maximum
Intensity
(In/Hr))
0.01
0.03
0.02
0.09
0.01
0.08
0.03
0.05
0.01
0.03
0.1
0.01
0.01
0.01
0.02
0.09
0.16
0.04
0.04
0.1
0.01
0.02
0.02
0.1
0.13
0.05
0.03
0.07
0.18
0.08
0.06
0.02
0.62
0.03
0.07
0.02
0.09
0.09
0.02
0.16
0.11
0.13
0.02
0.16
0.03
0.22
0.07
0.01
0.04
0.02
0.08
0.04
0.25
0.67
0.21
0.24
0.22
0.15
0.08
0.94
0.02
Storm
Number
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
Date
7/3/93
7/4/93
7/6/93
7/11/93
7/19/93
7/26/93
7/28/93
7/29/93
8/2/93
8/3/93
8/6/93
8/7/93
8/10/93
8/11/93
8/12/93
8/16/93
8/20/93
8/28/93
8/31/93
9/2/93
9/6/93
9/7/93
9/10/93
9/10/93
9/15/93
9/22/93
9/25/93
9/27/93
9/28/93
9/29/93
10/1/93
10/1/93
10/9/93
10/16/93
10/19/93
10/20/93
10/27/93
10/30/93
11/1/91
11/7/91
11/11/91
11/12/91
11/15/91
11/18/91
11/20/91
11/23/91
11/24/91
11/25/91
11/28/91
11/30/91
12/2/91
12/3/91
12/12/91
12/14/91
12/15/91
12/18/91
12/18/91
12/20/91
12/23/91
12/28/91
Hr
2
16
16
20
14
6
17
20
5
21
19
13
16
4
17
4
9
2
13
8
13
9
1
13
20
24
16
13
10
10
10
23
6
22
15
15
22
10
17
9
2
11
1
17
17
20
17
14
6
6
16
21
15
7
16
3
16
22
7
22
Duration
(Hrs)
1
1
1
3
2
2
9
3
2
10
4
1
2
4
1
1
1
1
6
21
1
1
1
1
16
16
20
9
3
17
1
6
13
16
1
6
4
39
1
12
7
12
31
21
19
3
8
1
8
1
17
11
17
6
16
2
16
8
6
35
Depth
(In)
0.01
0.44
0.47
0.35
0.14
0.04
1.08
0.67
0.42
0.42
0.1
0.13
0.02
0.24
0.02
0.07
0.01
0.06
0.03
1.02
0.35
0.01
0.01
0.01
2.38
0.12
1.63
0.15
0.23
0.97
0.01
0.58
0.43
0.6
0.04
0.04
0.15
1.67
0.01
0.12
0.69
0.21
0.62
0.3
0.46
0.24
0.03
0.01
0.19
0.04
1.19
0.06
0.16
0.15
0.07
0.02
0.03
0.22
0.1
0.26
Average
Intensity
(In/Hr)
0.01
0.44
0.47
0.12
0.07
0.02
0.12
0.22
0.21
0.04
0.03
0.13
0.01
0.06
0.02
0.07
0.01
0.06
0.01
0.05
0.35
0.01
0.01
0.01
0.15
0.01
0.08
0.02
0.08
0.06
0.01
0.1
0.03
0.04
0.04
0.01
0.04
0.04
0.01
0.01
0.1
0.02
0.02
0.01
0.02
0.08
0
0.01
0.02
0.04
0.07
0.01
0.01
0.03
0
0.01
0
0.03
0.02
0.01
Maximum
Intensity
(In/Hr)
0.01
0.44
0.47
0.24
0.13
0.02
0.72
0.31
0.41
0.2
0.06
0.13
0.01
0.23
0.02
0.07
0.01
0.06
0.02
0.67
0.35
0.01
0.01
0.01
0.4
0.05
0.29
0.06
0.12
0.24
0.01
0.22
0.13
0.18
0.04
0.02
0.1
0.12
0.01
0.02
0.14
0.06
0.1
0.1
0.14
0.12
0.01
0.01
0.05
0.04
0.29
0.02
0.06
0.12
0.01
0.01
0.01
0.07
0.03
0.03
Total 37.51
NEORSD CSO Facilities Planning Summary Report
236
Appendix C-2
April 2011
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