Change is in the Air for the National Pollutant Discharge Elimination System Program

Spring is just around the corner but that’s not the only thing being carried in by the wind.

For many years, EPA Regions 4 & 5 have made noises about requiring more laboratory data and ultra low detection limits for new permits and renewals. Generally this involves ultra low (0.5 PPT - yes, Trillion) for mercury and PPB levels for many other metals.

What’s the big deal you say? Well, the EPA is driving detection limits into a ridiculous realm for one. Secondly, the lab equipment in most of the labs in our region can’t detect that low. These methods require special equipment and (in the case of mercury), a clean room environment. So, it’s not surprising that the cost is at least twice what you’d normally pay (for mercury it’s more like 10 X).

 

Such talk has been rumored for years, but very few states have adopted these changes. New lab equipment has been languishing on the shelves of instrument manufacturers because there has been no regulatory demand for the ultra low detection limits. Who can blame the lab for not investing in the latest & greatest expensive equipment when there’s no guaranteed demand for volume?

ECS recently assisted a client with an NPDES permit renewal and found that EPA Region IV is actively moving in this direction. This is rather surprising, as Region V is generally more on the cutting edge. The bottom line is that where EPA Region IV goes, you can expect Region V to be not far behind.

When you budget for your next NPDES renewal, allow for extra time and laboratory costs. Expect to have to provide 5 samples of industrial effluents for Total Toxic Organics. The days of giving one result and saying that’s representative are fading quickly into the sunset.