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Representative Sampling EPA Region 9, Clean Water Act Compliance Office CWEA 35th Annual P3S Conference February 27, 2008 Long Beach, California. Greg V. Arthur US EPA, 75 Hawthorne Street, San Francisco, CA 94105 (415) 972-3504 [email protected]. 40 CFR 403.12(e)(1) Self-Monitoring - PowerPoint PPT Presentation
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Representative SamplingRepresentative SamplingEPA Region 9, Clean Water Act Compliance OfficeEPA Region 9, Clean Water Act Compliance Office
CWEA 35th AnnualCWEA 35th Annual
P3S Conference P3S Conference
February 27, 2008February 27, 2008
Long Beach, CaliforniaLong Beach, California
Greg V. ArthurGreg V. Arthur
US EPA, 75 Hawthorne Street, San Francisco, CA 94105US EPA, 75 Hawthorne Street, San Francisco, CA 94105
(415) 972-3504(415) 972-3504
[email protected]@epa.gov
40 CFR 403.12(e)(1)40 CFR 403.12(e)(1)
Self-MonitoringSelf-MonitoringRequirementsRequirements
40 CFR 403.12(g)(1)40 CFR 403.12(g)(1)
Self-MonitoringSelf-MonitoringRequirementsRequirements
40 CFR 403.12(g)(1)40 CFR 403.12(g)(1)
Self-MonitoringSelf-MonitoringRequirementsRequirements
40 CFR 403.12(g)(3)40 CFR 403.12(g)(3)
Self-MonitoringSelf-MonitoringRequirementsRequirements
40 CFR 403.12(g)(3)40 CFR 403.12(g)(3)
Self-MonitoringSelf-MonitoringRequirementsRequirements
40 CFR 403.1240 CFR 403.12
Self-MonitoringSelf-MonitoringRequirementsRequirements
The Bottom LineThe Bottom LineThe Bottom LineThe Bottom Line
• Twice per year Twice per year reportsreports of self-monitoring.of self-monitoring.
• Each sample must be Each sample must be representative over the representative over the sampling day.sampling day.
• The sample record must The sample record must be representative over be representative over the six-month reporting the six-month reporting period.period.
40 CFR 403.1240 CFR 403.12
Self-MonitoringSelf-MonitoringRequirementsRequirements
So …So …Self-MonitoringSelf-MonitoringComplies with Fed RegsComplies with Fed Regs
So …So …Self-MonitoringSelf-MonitoringComplies with Fed RegsComplies with Fed Regs
If …If …All samples together are All samples together are representative of therepresentative of theflow, nature, and concen-flow, nature, and concen-tration of the dischargetration of the dischargeover the entire six-monthover the entire six-monthreporting period.reporting period.
The Test forThe Test forRepresentative SamplingRepresentative SamplingThe Test forThe Test forRepresentative SamplingRepresentative Sampling
Are there enough samples Are there enough samples taken at the right times from taken at the right times from the right locations to be the right locations to be representative of the representative of the discharge over the entire discharge over the entire six-month reporting period?six-month reporting period?
Federal MinimumFederal MinimumCan one 24-hr comp sampleCan one 24-hr comp samplebe representative over abe representative over asix-month reporting period?six-month reporting period?
Federal MinimumFederal MinimumCan one 24-hr comp sampleCan one 24-hr comp samplebe representative over abe representative over asix-month reporting period?six-month reporting period?
Yes, but only if …Yes, but only if …• Consistent flow and natureConsistent flow and nature• Random distributionRandom distribution• Variability only from BATVariability only from BAT• Little variability from opsLittle variability from ops
Are there enough samples taken at Are there enough samples taken at the right times and locations to be the right times and locations to be representative of the discharge over representative of the discharge over the six-month reporting period?the six-month reporting period?
Complication #1Complication #1
Independent eventsIndependent events• batch treatmentbatch treatment
• spent solutionsspent solutions
• intermittent operationsintermittent operations
continuous treatcontinuous treatfor metals rinsesfor metals rinses
lamellalamellaclarifierclarifier
batch treatbatch treatfor CNfor CNspentsspents
batch treatbatch treatfor metalsfor metals
spentsspents
~7 days~7 days
intermittentintermittentbatch treatbatch treatfor CNfor CNspentsspents
batch treatbatch treatfor metalsfor metals
spentsspents
lamellalamellaclarifierclarifier
continuous treatcontinuous treatfor metals rinsesfor metals rinses
spents spents
spentsspents
rinsesrinses
continuouscontinuous
intermittentintermittent
sample sample pointpoint How many samples are necessary to capture How many samples are necessary to capture
both independent events (continuous & 7day)?both independent events (continuous & 7day)?
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
continuouscontinuousonlyonly
continuouscontinuousplus ~7day batchplus ~7day batch
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Runs 1 - 10ooooo
oooooooooooooooooooooo
oo
oooooooo
oooooooooooooo
ooooo
ooooooooo
oooooooooo
oooooooo
o
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Runs 11 - 20ooooooooooooooo
ooo
ooooooooooooooooooooooooo
ooooooooo
oooooo
oo
oooooooooooooooo
oooooooooooooooo
o
oooooo
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Runs 21 - 30oooooo
oooooo
oo
oooooo
ooo
ooooooooo
ooooooooooo
ooooo
ooo
oooo
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Runs 31 - 40oo
o
oo
ooooo
ooooooo
oooo
ooo
ooooo
o
oooo
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Runs 41 - 50o
oooooooo
oooooooooooo
oooo
oooooooo
oo
ooo
ooooooooooo
ooooooooooooo
o
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Mean = 7.0 StDev = 5.4
Probability of capturing bothindependent events in:1 sample – 15%2 samples – 20%3 samples – 25%6 samples – 43% (monthly)7 samples – 50%12 samples – 80%20 samples – 99%
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Mean = 3.0 StDev = 2.5
Probability of capturing bothindependent events in:1 sample – 21%2 samples – 34%3 samples – 50%4 samples – 66%5 samples – 79%6 samples – 88% (monthly)9 samples – 99%
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
An Independent Event is any An Independent Event is any significant source of variability in significant source of variability in the discharge quality or flowthe discharge quality or flowLikely significant sourcesLikely significant sourcesProcessProcess spent solutionsspent solutions
seasonalseasonalO&MO&Mblowdownsblowdowns
TreatmentTreatment batch treatmentbatch treatmentdewateringdewatering
DischargeDischarge combined sourcescombined sources
Are there enough samples taken at Are there enough samples taken at the right times and locations to be the right times and locations to be representative of the discharge over representative of the discharge over the six-month reporting period?the six-month reporting period?
Complication #2Complication #2
Non-random BiasNon-random Bias• weekend operationsweekend operations
• periodic contributionsperiodic contributions
• scheduled blowdownsscheduled blowdowns
How many samples are necessary to capture How many samples are necessary to capture both independent events (continuous & 7day)?both independent events (continuous & 7day)?
Runs Mon – SunMon ooooooooooooooo
Tue ooo
Wed oooooooooooooooooo
Thu ooooooooooo
Fri ooooooo
Sat oo
Sun oooooooooooooooo
1 Mon-Fri and 1 Sat-Sun
Complication #1Complication #1
Independent eventsIndependent events• test prior to dischargetest prior to discharge
• sampling to cover all eventssampling to cover all events
• determine if on schedulesdetermine if on schedules
• meteringmetering
• equalizationequalizationComplication #2Complication #2
Non-random BiasNon-random Bias• scheduled samplingscheduled sampling
• equalizationequalization
Representative SamplingRepresentative SamplingEPA Region 9, Clean Water Act Compliance OfficeEPA Region 9, Clean Water Act Compliance Office
CWEA 35th AnnualCWEA 35th Annual
P3S Conference P3S Conference
February 27, 2008February 27, 2008
Long Beach, CaliforniaLong Beach, California
Greg V. ArthurGreg V. Arthur
US EPA, 75 Hawthorne Street, San Francisco, CA 94105US EPA, 75 Hawthorne Street, San Francisco, CA 94105
(415) 972-3504(415) 972-3504
[email protected]@epa.gov
