Service Change Bulletin 624.1 - March 12, 2018
In 2017, the USEPA finalized an update to the approved test procedures for sampling and analyzing samples under the Clean Water Act. That "Methods Update Rule (MUR)" became effective on September 27, 2017. One of the changes in the MUR was the mandatory replacement of EPA method 624 with EPA method 624.1. While reviewing and implementing the new requirements of EPA 624.1, Paragon recognized that an adjusted sampling protocol was needed for three specific volatile organic compounds (VOCs). After further examining the regulations at 40CFR136 that incorporated the MUR, Paragon determined the desired sampling protocol.
Paragon SOP-N0172, “Sampling Wastewater and Other Water for Volatile Organic Compounds (VOCs) Analysis using USEPA Method 624.1 ” describes this new sampling protocol. In essence, special collections are necessary if the VOCs to be determined include the following three compounds:
(a) Acrolein, (b) Acrylonitrile, &/or (c) 2-Chloroethylvinyl ether
Our prescribed practice for sampling analytes for EPA 624.1 analysis reflects what is necessary to maximize all holding times to 14 days. It also presumes that samples do not contain residual chlorine; arrangements with the laboratory must be made in advance if a sample will contain residual chlorine.
It is important to note that all 3 of the above compounds are included in the routine NPDES AMR compound list and in the IPP TTO compound list. The potential also exists to impact other sampling events, depending on their specific compound lists.
Lastly, due to the special collections, separate analyses are also required.
Selected excerpts from 40CFR136 are provided below for reference.