Sampling for Discharge Monitoring Reports

1
Sampling for Discharge Monitoring Reports

• L. Peyton Adams
• Madisonville Regional Office
• Kentucky Division of Water

2
Introduction

• KPDES Permits that require sampling also require
  following QA/QC requirements.
• The goal of this presentation is to have a permit
  holder know what to do in order to have a winning
  sampling program during a federal inspection.
• One of the most common Notices of Violation
  during a federal inspection is for paperwork
  errors.

3
Agenda

• Each permit may have different parameters and
  frequency of analysis requirements but share the
  requirement that 40 CFR Part 136 has to be
  followed.
• Sampling correctly can solve problems. Sampling
  wrong can generate liability and bad data can
  lead to bad decisions.

4
Overview

• A typical permit for a sanitary discharge tends
  to have similar traits.
• The principles of sampling and documentation fit
  a wide variety of permits.

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5
Vocabulary

• KPDES permit is Kentucky Pollutant Discharge
  Elimination System
• BOD5 Total Biochemical Oxygen Demand
• CBOD5 Carbonaceous BOD5
• NH3 ammonia nitrogen
• pH hydrogen ion concentration
• Fecal coliform bacteria sampling of effluent
• Effluent final discharge prior to mixing with
  the receiving waters
• Influent raw prior to any preliminary treatment
  sampling
• removal Influent Effluent divided by the
  Influent percentage
• Flow measuring per the permit and which may be
  used in mass loading.
• Concentration test result in ppm
• Mass loading kg or pounds per day loading

6
Introduction

• The most common error detected during federal
  inspections of permit holders is related to
  sampling techniques and methods.
• Permit holders can have a good effluent and have
  bad sampling ruin their official record.
• Proper sampling and preservatives are given in
  the KPDES permit and 40 CFR Part 136.
• Mailing late past the 28th day of the reporting
  period can result in all data coded as no data
  submitted for every parameter for every
  discharge on the permit. Have a record that the
  DMR was submitted on time.

7
Concepts

• Follow the permit at all costs. If it says
  composite sampling, it means composite. If it
  says grab, do not composite it. If it says 24
  hour composite, then an 8 hour composite does not
  meet the permit.
• If the permit says effluent after all treatment
  prior to mixing with the receiving waters, then
  do not sample before the post aeration phase, but
  at the end of the pipe. If it says influent, then
  it means RAW prior to any preliminary treatment
  including screening. If you have removal
  requirements, the nastier the influent the easier
  it is to achieve.
• Composite jugs must be kept cold at 4 degrees C.
  Do not let samples ROT in the container prior to
  reaching the laboratory.

8
Fecal sampling

• Fecal coliform sample containers are sterile and
  must NOT be rinsed out. Fecal samples are always
  grab samples. Fecal samples should be grabbed at
  the last minute to be as fresh as possible. There
  is a 6 hour holding time between the sample and
  the arrival at the laboratory. Longer holding
  times not only do not meet 40 CFR Part 136, but
  make the numbers higher. Bacteria always grow in
  log fashion. Counts are always by geometric mean
  for averages. If you use chlorine for
  disinfection, check the chlorine residual before
  opening the bottle. If using UV, make sure its
  working before opening the container.
• Ex. -you have 180 colonies and the second sample
  has 215 colonies. Its not (180 215)/2 the
  mean you report. Its (the log of 180 the log
  of 215) / 2 sampling events with the antilog of
  the result reported. The maximum is the biggest
  and the minimum is the smallest.

9
Dissolved Oxygen

• Dissolved oxygen or DO has no holding time. It
  must be run on site immediately. A DO meter is a
  good tool. Numbers reported in excess of 10 mg/l
  are frequently indicators of bad calibration or
  analysis at our normal temperatures and
  pressures. Always run the dissolved oxygen test
  for a DMR after the post aerator if present. A
  minimum DO is the DMR limit on permits.
• If the minimum DO limit is 2.0 mg/l, a cold day
  is easier to meet the limit. Warm days tend to
  lower the saturation possible in water. A post
  aerated effluent with lots of splashing can raise
  DO.

10
pH

• Most permits have limits of 6.0-9.0 on the
  permit. The pH parameter must be run on site,
  immediately, and tested using a calibrated pH
  meter. Dont ice down a sample and then carry it
  back to the lab to test.
• The calibration data must be recorded and the
  temperature recorded when the pH is run. Standard
  Methods states using a two buffer system that
  each buffer should be two pH units apart
  bracketing the expected range. A common buffer
  method is to use 4.0, 6.0 and 10 buffers. Follow
  the manufacturers manual.
• pH is a log number so going from 7.0 to 8.0 is a
  ten fold rise in hydrogen ion concentration. You
  dont average pH.

11
Calibrations and Documentation

• Calibrations performed and not recorded will be
  treated as if not done at all. Quality assurance
  guidelines as given in USEPA manuals and Standard
  Methods are required for all tests. Documentation
  can be in a logbook, a laboratory bench sheet, or
  on the chain of custody sheet.
• Its wise to try and make the chain of custody
  handle as much of the documentation as possible.
  If pH is going to be a parameter, then recording
  the result and showing the buffer numbers on the
  form can work. Its better to say in 4.0 buffer it
  read 3.99 than to only have a checkmark by 4.0.
• Do NOT erase numbers on raw data. Do not put raw
  numbers on post it notes. If you record data in
  an excel spreadsheet, there has to be a paper
  trail that can show any changes for raw data.

12
Chain of custody record keeping

• Sampling without chain of custody invalidates the
  data. A chain of custody record must show who
  did the sampling, for what parameter, when it was
  sampled, in what container, using what
  preservative, who took it to the laboratory, who
  received it at the laboratory, and when was it
  received. Every variable and every person who had
  the sample in their possession has to be
  documented. You have to show no one had the
  opportunity to tamper with the sample from the
  time collected until it was in the laboratory.
• If you go to court, the first thing usually
  attacked will be the chain of custody by the
  opposing counsel. Make one form handle as much
  documentation in one document to keep it simple
• Incomplete chain of custody information can taint
  data.

13
Field labeling of samples

• A typical label on a permit with BOD5, TSS,
  sampling of the influent and effluent would have
• Example A plastic container one liter in size
  for the influent composite, kept cold at 4 C and
  labeled Anytown WWTP Influent, KY000666, Our
  County, 3-24-2004 24-hour composite, L. Peyton
  Adams, BOD5-TSS Preservation 4 C ICE
• Goal Document where, who, when, what, and
  preserved by what method. It must match the chain
  of custody description.
• A grab sample would document the date and exact
  time of the sampling event. Example 3-24-2004
  1009 am CST. For pH and chlorine residuals
  without a holding time, document the calibration
  data, time of calibration, and analyst prior to
  running the test of the unknown.

14
PPE- sampling safely

• Wear gloves when handling sewage samples and wash
  hands after sampling. Do not eat or drink while
  sampling sewage. Do not store food in the same
  refrigerator as the sewage samples.
• If sampling industrial impacted wastewater, wear
  the right PPE for the hazard.
• Avoid entry into a confined space in order to get
  a sample. Know your surroundings hazards before
  sampling. This can include electrical hazards.
• One thing I have seen as an inspector is an
  operator wearing gloves and pushing a scraper in
  a clarifier up and down while reaching up and
  taking his cigarette in and out of his mouth
  while wearing his gloves. This can make smoking
  taste funny.

15
Sampling frequency for a permit

• The permit will specify the minimum sampling
  frequency. Its perfectly legal to sample more
  frequently and average all of the results. If you
  test by valid means a parameter and have a
  contract laboratory also doing the same parameter
  during the reporting period, then ALL the data
  has to be reported from ALL of the parties on the
  DMR. The biggest will be the maximum.
• Valid data requires running a sample by 40 CFR
  Part 136, per the permit, and using a detection
  limit methodology that is at least as good as the
  permit value for the parameter. ALL VALID DATA
  MUST BE USED FOR THE REPORTING PERIOD ON THE DMR.
• You cannot pick and choose data to report if its
  valid. Two labs running pH side by side are
  valid, but litmus paper testing is only good for
  process control and not for reporting on a DMR.

16
Common composite samples

• BOD5 is a measure of the organic strength of the
  waste and must be kept cold at 4 C.
• Composite sample jugs must be kept at 4 C during
  the compositing, but also during transport to the
  laboratory. The analyst must then bring up the
  temperature to reach 20 C for the test to avoid
  blanks that are supersaturated during the test.
  Bubbles would then escape on the 5th day of the
  test showing the samples were incubated too cold.
• If you composite 9600 ml in a composite jug _at_ 100
  ml every 15 minutes for 24 hours, be sure to
  shake the contents the next day when pulling
  aliquots of cubicontainers to be shipped to the
  laboratory. Otherwise you end up decanting the
  sample. This can ruin removal efficiency on a
  raw sample that settles rapidly with grit in it.
  It effects TSS in a major way.

17
TSS- Total Suspended Solids

• It is a measure of the solids in wastewater that
  will not go through a filter and has weight. In
  sewage its close to the BOD5 test in showing the
  strength of the waste. It must be kept at 4 C
  during compositing and transport to the
  laboratory.
• TSS can be egg shells, grit, fecal matter, blood
  cells, hair, sand, clay, soil, bone etc.
• In a sewer plant effluent, food in the sanitary
  wastewater plant is converted into the biological
  zooglea and TSS can be a measure of the biomass
  that escaped the clarifier to reach the effluent.
• Process control testing may use TSS in the
  Influent, Effluent, Return Activated Sludge
  (RAS), Waste Activated Sludge (WAS), and Mixed
  Liquor Activated Sludge (MLSS) in operation and
  maintenance of a sanitary plant.

18
Inspection permit review

• During an inspection, its important to have the
  laboratory have a copy of the KPDES permit.
  Parameters can change between permits. There is a
  difference analytically between BOD5 and CBOD5 on
  a permit and if a lab runs the wrong one data can
  be thrown out. This can result in a citation for
  a violation of 401 KAR 5065.
• If a permit requires a Best Management Practices
  plan (BMP) that will be inspected too.
• It is wise to label in the field the sampling
  location and number it if multiple outfalls are
  on the permit.

19
Flow data

• All pounds per day mass loading calculations use
  the flow on sample day and not the monthly
  average reported at the flow parameter line.
• It is not proper to record as NO DISCHARGE during
  a reporting period unless every single day of the
  month not a drop of water discharged from the
  outfall and there is documentation it was checked
  and found not flowing.
• Do not arbitrarily pick a day of the month and if
  not flowing that day pretend it did not flow the
  other days of the month.

20
Types of Flow data

• Permits specify the type of flow required to be
  recorded.
• Instantaneous must be tested and recorded by
  reading the gallons per minute during the
  sampling. Its the flow at a specific moment in
  time. Example would be at 1100 am the flow when
  a grab sample was collected.
• Continuous requires a recorder working off a
  totalizer and chart. Its the flow during a
  stretch of time like a 24-hour period during the
  time a flow proportional sampler was running.
• Even if no flow, send in a DMR on time showing no
  discharge for the reporting period.

21
Sampling frequency

• All permits specify the sampling frequency for
  self-monitoring..
• It is legal to sample more frequently than the
  permit requires and average the results. Sampling
  early may allow a person to see they need to get
  additional samples to average themselves into
  compliance. Resamples have to be during the
  reporting period and recorded on the DMR. All
  valid data will have to be used in the reporting
  for that reporting period. You cannot pick and
  choose.
• It is of little value to resample a violation of
  maximum or minimum permit conditions. It may be
  useful simply to show the violation was of a
  short term condition.
• It is never acceptable to sample less frequently
  than the permit condition.
• Even if a REPORT ONLY permit, failure to report a
  parameter required to be sampled is a violation.

22
Temperature

• Temperature is a good thing to test for during a
  pH test or Dissolved Oxygen test since it is such
  an important variable. Temperature during ammonia
  nitrogen testing can help determine the amount of
  free ammonia ion in the test. This is useful for
  401 KAR 5031 water quality.
• Temperature can also on a cooling water permit be
  a parameter of its own. Unless the permit says
  use logging methods, a test must be done per 40
  CFR Part 136 using an accurate thermometer
  calibrated to the equivalent of a NIST standard
  criteria. You do not have to take the expensive
  thermometer itself out into the field.
• Calibrate any temperature measurement device with
  a NIST certified thermometer before field use.
  Follow Standard Methods 2550 B.

23
Settleable Solids Standard Methods 2540F

• Settleable Solids requires only an Imhoff cone
  and gravity. It is not the same test as Total
  Suspended Solids.
• Fill an Imhoff cone to 1-L mark with a well mixed
  sample. Settle for 45 minutes, gently agitate
  sample near the sides of the cone with a rod,
  settle 15 min longer, and record volume of
  Settleable solids in the cone as milliliters per
  liter.
• This is on coal permits depending upon higher
  flows and stormwater permits.

24
Summary

• Good data collection can help solve problems. Bad
  data collection can cause permit noncompliance,
  violations that are needless, and bad decisions.
• Sampling has to meet the permit to be valid.
• Know the permit requirements to know the proper
  sampling SOP to set up.
• The KPDES Permit WebPage is at
  http//www.water.ky.gov/permitting/wastewaterperm
  itting/

25
Where to Get More Information

• 40 CFR Part 136 at www.epa.gov
• KPDES Branch 502-564-3410
• Standard Methods for the Examination of Water and
  Wastewater
• Documents incorporated by reference in 401 KAR
  5200
• http//www.epa.gov/epahome/index/ Index of test
  methods.
• Handbook for Sampling and Sample Preservation for
  Water and Wastewater via
• http//www.epa.gov/clariton/clhtml/pubtitleORD.htm
  l and
• 600479020 Methods for Chemical Analysis of Water
  and Wastes