Comment submitted by Sandra Rintoul, Wilks Enterprise

Document ID: EPA-HQ-OW-2010-0192-0224
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: December 31 2011, at 12:00 AM Eastern Standard Time
Date Posted: January 5 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: December 14 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: February 13 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80f8db78
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This is comment on Notice

Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act; Analysis and Sampling Procedures; Data Availability

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Having a solvent-less oil and grease method would be a benefit. However, many applications of oil and grease analysis are improved by having an on-site method for quick results. Sending samples back to a laboratory can add costly delays both environmentally and economically. Both ASTM D7575 method and current EPA 1664 method require equipment that is not amenable to on-site (or offshore) analysis. ASTM D7066 is an infrared method that only differs from EPA 413.2 and 418.1 in the non-CFC solvent that is used for extraction. The EPA should consider ASTM D7066 as well as ASTM D7575 as alternate methods to EPA 1664.

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Comment submitted by C. Tunick
Public Submission Posted: 12/15/2011 ID: EPA-HQ-OW-2010-0192-0221