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May 23rd, 2013, 6:28am
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To distill or not to distill (Read 217 times)
akanae
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To distill or not to distill
Nov 30th, 2010, 8:49am
 
I had a fellow WW operator get written up by EPA two years ago for not distilling her NH3 sample when performing the ISE method.  Now I’m trying to help another operator set his lab up and we are not able to find anything that says you are required to distill your sample prior to analysis when doing the ISE method.   SM 4500, 21st E says that it is not needed.   I had been told that EPA withdrew the remark of distillation not being necessary when using this method and that all methods require distillation.    Can anyone solve this mystery?
Thanks in advance.
Dennae
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Re: To distill or not to distill
Reply #1 - Nov 30th, 2010, 1:01pm
 
The most current rule, March 2007, in 40CFR136 still requires distillation unless comparability data are on file.

Footnote 6 to table 1B:

6 Manual distillation is not required if comparability data on representative effluent samples are on file to show that this preliminary distillation step is not necessary: however, manual distillation will be required to resolve any controversies.
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akanae
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Re: To distill or not to distill
Reply #2 - Nov 30th, 2010, 4:44pm
 
Smiley  Thank you thank you.  

This might be a really stupid question but wouldn't it matter what state you are in for the reference to the CSR's?  I am in Missouri.  Are all state regs the same?

I wonder why they can't put this information in SM for all to see?

Again, Thank you, I was going crazy looking for the info.,
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Re: To distill or not to distill
Reply #3 - Dec 1st, 2010, 11:35am
 
The Federal Code (40CFR) is the law of the land, states can not pass any regulation which is less strict than the federal regulation.

So in a limited sense it doesn't matter what state you live in unless they have a stricter regulation than the Federal rule.

Most state environmental regulations I have seen incorporate the federal rule by reference so you are simply following the federal regulation anyway.
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akanae
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Re: To distill or not to distill
Reply #4 - Dec 1st, 2010, 1:46pm
 
Howz that for not seeing whats right in front of your face.  I read CFR but I was thinking CSR.  I'm so sorry for not seeing something so plain.  (Boy do I feel stupid)
Thank you again for holding my hand.
Dennae
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