1 

United States Environmental Protection Agency 

Response to Public Comments on Notice of Data Availability; Guidelines Establishing Test 

Procedures for the Analysis of Pollutants Under the Clean Water Act; Analysis and 

Sampling Procedures (76 FR 77742, December 14, 2011) 

February 2013 

Introduction 

The comments in this document are arranged by topic (i.e., A, B.1, etc). Each comment has a

unique number that is a shortened form of the docket assigned comment identifier. For example, 

if the docket identifier was EPA-OW-2010-0192-0229, that identifier has been shortened to 

"Comment 229," followed by the commenter's name and affiliation. Where EPA references a 

response to a specific comment, EPA means the response to that commenter within the topic. 

For example, under topic B.3, EPA’s response to Comment 246, includes “See response to 

comment 244.” In that case, EPA means the response to comment 244 in topic B.3. Comments 

are included verbatim.

Table of Contents 

A. Support for ASTM Method D7575

B. Opposition to Approval of ASTM Method D7575 

B.1 OSS is sole supplier 

B.2 Method comparison of ASTM D7575 to Freon vs. n-hexane methods 

B.3 Sampling requirements and preparation 

B.4 Matrix spikes requirements 

B.5 Method detection limit (MDL)

B.6 Method applicability 

B.7 Infrared (IR) measurement

B.8 Working range of method 

B.9 Calibration 

B.10 Membrane drying

B.11 Method-defined parameters and comparability

B.12 Analysis cost 

B.13 Handling waste

B.14 Method validation

B.15 Unfunded mandate 

B.16 Method version (ASTM versions and EPA Method 1664 versions) 

B.17 Green chemistry

B.18 National Technology Transfer and Advancement Act (NTTAA) 

B.19 Accuracy of vendor information 

B.20 Number of oil and grease analyses per year

B.21 NPDES permit limit adjustment

B.22 Replacement of EPA Method 1664 with ASTM D7575 
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B.23 Method portability 

B.24 Time required to perform test

B.25 Use of chromatography in the test 

B.26 Blank must be lower than the MDL 

C. Other comments

C.1 Using the same side-by-side comparisons when switching from Freon to N-hexane for Nhexane to infrared analysis

C.2 Document availability

C.3 Requests for approval of IDEXX method 

C.4 Preservation 

C.5 Comment period extension 

C.6 Transparency 

C.7 Duplicate samples

C.8 Appropriateness of paint shaker in a certified laboratory 

C.9 EPA is purposely delaying a final ruling to allow a single method to “catch up” 
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A. Support for ASTM Method D7575 

Summary: Many commenters expressed support for approval of this method for various reasons 

such as its green technology basis, ease of use and its portability. Other commenters also 

recommended the approval of ASTM Method D7066. 

Comment 221 C. Tunick: While there is considerable interest in a solventless method for 

analyzing oil and grease in water, the current method is not field-portable and cannot be used for 

on-site measurements. It would be ideal for use in a laboratory environment but not for on-site 

use such as on off-shore and on-shore oil drilling platforms or in manufacturing industries using 

oil and grease in their process who want a quick, easy way to check their wastewater effluent 

prior to discharge without having to wait for lab results. There is a current ASTM Method D7066 

using infrared analysis and S-316 as an extracting solvent for measuring oil and grease in water. 

This method is based on the tried and true EPA Methods 413.2 and 418.1 which have been used 

and accepted worldwide for the measurement of oil and grease in water for over 30 years. If the 

EPA is to consider ASTM D7575-10 as an alternate analysis and sampling method, they should 

give serious consideration to also approving and accepting ASTM Method D7066 as an 

additional alternate method. Infrared analysis for measuring oil and grease in water is accurate, 

cost effective, and easy to use by both non-technical personnel and skilled technicians but 

provides a method that can be used on-site, as well as in the analytical or testing laboratory. 

Today, it is still the most widely-used method worldwide for measuring oil and grease in water. 

Response: EPA acknowledges the benefits of D7575. However, for the reasons explained in the 

notice, EPA is not promulgating D7575 in Part 136 for nationwide use. The commenter did not 

provide any additional data or analyses that are at odds with EPA’s conclusion that it should not 

adopt the method for nationwide use. 

EPA thanks the commenter for his/her comments on ASTM D7066. ASTM has not requested 

EPA to consider D7066 nor did EPA discuss it in its proposal. Thus, it is outside the scope of 

this action. 

Additionally, EPA notes that Part 136 methods must be used for compliance with CWA 

requirements. Part 136 does not govern other uses. As such, if a facility or researcher would like 

to use either of these methods for non CWA uses, the lack of inclusion in Part 136 does not 

prevent them from doing so. 

Finally, as is the case with all methods, if a permittee wishes to use a method that is not 

promulgated in Part 136 for CWA compliance, the authority exists under Part 136.5 to request 

the use of an alternative method for a specific application (i.e. limited use ATP). 

Comment 222 Robert J. Polis, Metropolitan Water Reclamation District of Greater 

Chicago (MWRD): Comment 1: The Metropolitan Water Reclamation District of Greater 

Chicago ("District") concurs with the EPA’s decision to reconsider promulgating method ASTM 

D7575-10 as an alternative (not a replacement) for EPA Method 1664A. Additionally, pending 

further instructions from the EPA, the District would consider using ASTM D7575-10 after the 

useful lifespan of its existing equipment – used for method 1664A determinations – has expired. 
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We applaud the EPA’s continued diligence in considering green initiatives that will either 

minimize or eliminate the use of solvents in analytical procedures and the analysts’ exposure to 

these solvents. 

Comment 2: The District likewise concurs with the EPA’s conclusion that permit limit 

adjustment based on side-by-side comparisons of EPA Method 1664A and ASTM D7575-10 is 

not appropriate. 

Comment 3: If the EPA allows side-by-side comparison of EPA Method 1664A and 

ASTM D7575-10 to establish a conversion factor, then the approach should be similar to the one 

used when the EPA promulgated EPA Method 1664A (which uses n-hexane as the solvent) to 

replace EPA Method 413.3 (which used Freon as the solvent). 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Similarly, in response to the second and third comments on the use of a 

conversion factor, EPA is not allowing the use of the permit limit adjustment, nor is EPA 

allowing side-by-side comparisons between EPA Method 1664A and ASTM D7575 to establish 

a conversion factor. 

Comment 223 Curt McCormick: The following comments are respectfully submitted on the 

following FR request for comments: Guidelines Establishing Test Procedures for the Analysis 

of Pollutants Under the Clean Water Act; Analysis and Sampling Procedures; Notice of Data 

Availability Federal Register / Vol. 76, No. 240 / Wednesday, December 14, 2011 / Proposed 

Rules. Page 77742-77747.

I am very impressed EPA has moved aggressively on this and sought to approve this alternate 

method while dealing concurrently with other important rulemaking activities.

Response: EPA thanks the commenter for his support.

Comment 224 Sandra Rintoul, Wilks Enterprise: 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. 

Response: See response to comment 221. 

Comment 225 Yarden: The ASTM D7066 and the ASTM D7575 would provide far superior 

advantages to the EPA 1664. These would allow portable, solventless methods where no 

enviromentaly harmful methods would be used. Such methods would also allow its application 

with no need of skilled laboratory technicians and costly lab environment. 

Response: See response to comment 221. 

Comment 226 Wilks (no name provided): Many applications of oil and grease analysis are 

improved by having an on-site method for quick results. The solvent-less D7575 method like 
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EPA 1664 requires cumbersome sample handling which is not ideal as an on-site method. The 

on-site methods can avoid economically and environmentally costly delays which could be 

incurred while waiting for off-site results. D7066 was developed specifically for either on-site or 

laboratory use. 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. 

Response: See response to comment 221. 

Comment 227 Dr. Rob Leishman, Western Resource Recovery, Western Australian DEC: I 

would be most interested to see a solventless method alternative for the determination of FOG. 

Please give D7575 consideration as an alternative method for this determination. 

Response: ASTM did not submit D7575 for consideration for the measurement of FOG, nor did 

EPA’s proposal discuss D7575 as a method for the measurement of FOG. Thus, this request is 

outside the scope of this action. Also see response to comment 221. 

Comment 228 On behalf of Pensalab: 1. The solvent-less D7575 method like EPA 1664 

requires cumbersome sample handling which is not ideal as an on-site method. D7066 was 

developed specifically for either on-site or laboratory use. 

 2. On-site methods can avoid economically and environmentally costly delays which 

could be incurred while waiting for off-site results 

 3. D7066 is based on well-established EPA 413.2 and 418.1 methods, used worldwide for 

over 35 years. The primary difference is the use of in the non-ODS solvent in D7066 for the 

extraction. 

Response: See response to comment 221. 

Comment 229 Anonymous: As a soil chemistry researcher working in the area of oil-based 

drilling mud, it would be very helpful if the ASTM D7066 and D7575 were approved as 

alternatives to EPA 1664. The D7066 method is a suitable alternative in regard to TPH and is 

much easier, faster, and cheaper than a GC method. Such an approval would allow us to conduct 

MUCH more research on the impact of oil-based drilling mud on soil quality and environmental 

risk. Please consider that the D7066 method is a well established infra-red method based on EPA 

413.2 and 418.1 methods, but utilizes a non ozone depleting substance during extraction. 

Response: See response to comment 221. 

Comment 230 L. LaRusso: While the solvent-less D7575 is good for laboratories, it would be 

advantageous to have and include as an alternate method D7066 for on-site infrared analysis.

Response: See response to comment 221. 

Comment 231 Rebeca Rondón, Corporación Científica Venezolana: The EPA 1664 should 

considerer the ASTM 7066 as well ASTM 7575 because the first one is very similar to EPA 

413.2 and 418.1 and it could be used on site; that is one of the most important things to have in 
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this kind of instruments. The D7575 is very attractive because it is a solvent-less method, but it is 

important to have another economic an easy method to do the same test.

Response: See response to comment 221. 

Comment 232 Glen Blackstock, Micron Scientific Pty Ltd.: On behalf of our existing 

customers and prospective customers using solvent extraction technology for TPH and FOG 

analysis in the field we request that the EPA consider both ASTM D7066 as well as D7575 as 

alternate methods to EPA 1664. 

 The Wilks InfraCal is a popular, potable analyser used for in field analysis of oil and fat 

in water. If the EPA omit the solvent extraction technique as a method, current users and 

prospective users will be hugely inconvenienced. Many laboratories would need to purchase new 

technology to perform the analysis which takes long purchase cycles and there will be long 

sample result periods while waiting for results from laboratories.

Response: See response to comment 221. Also, EPA is not considering removing the 

promulgated n-hexane methods for measuring oil and grease. 

 

Comment 233 Michael Travers, VHG Labs: I would like to see ASTM D7066, as well as 

ASTM D7575, as an alternative method to EPA 1664. D7066 is ideal for quick on-site analysis 

of waste water effluent prior to discharge. It is an IR method that uses S-316 as an extracting 

solvent for measuring oil & grease in water. It is commonly used and is based upon EPA 

Methods 413.2 and 418.1 which have been accepted for many years. 

Response: See response to comment 221. 

Comment 234 Anonymous: It would be beneficial to have an on-site method available such as 

ASTM D7066 to perform IR analysis rather than sending to an outside lab for testing. 

Response: See response to comment 221. 

Comment 235 Shanta Ramkissoon Cruickshank, ROSE Environmental Limited: Although 

having a solvent-less method for TOG analysis has its benefits it does not offer portability or 

quick field measurements capability. There is an ASTM Method D7066 using infrared analysis 

and a non-CFC solvent (S-316) for measuring oil and grease in water that correlates closely to 

the EPA 413.2 and 418.1. In an effort to promote environmental sustainability the EPA should 

acknowledge the ASTM D7066 and consider this as well and the ASTM 7575 as alternate 

methods to EPA 1664. 

Response: See response to comment 221. 

Comment 236 Donald Lavery and Associates: ASTM D7575 - 11 Standard Test Method for 

Solvent-Free Membrane Recoverable Oil and Grease by Infrared Determination is an appropriate 

choice for inclusion as an EPA alternate method. It does, however, require rather cumbersome 

equipment and the analysis is quite time consuming. The much simpler and quicker ASTM 

D7066 that uses S-316 solvent extraction will often be preferred where space is limited and 
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analysis time is important. Adoption of both of these ASTM methods as EPA alternate methods 

would be appropriate. 

Response: See response to comment 221. 

Comment 256 D. Smith: EPA's requirement to test the amounts of oil and grease sample should 

require only green testing if the proper tests exist. In the instance for oil and grease, the green 

validation test exists and should be extensively used. These green tests have met established 

criteria for accuracy, in addition they are far easier to perform as I have actually performed oil 

and grease tests in laboratories years ago. I believe at this time our resources need to be 

conserved and contamination needs to be limited as much as possible. 

Response: See response to comment 221. 

Comment 258 Anonymous 24: The major reason for seeking an alternative to EPA1664 is the 

removal of hexane from the method, therefore ASTM Method D7066 using infrared analysis and 

non-cfc non-hexane S-316 as the extracting solvent seems more suitable. ASTM Method D7066 

is based on the well established EPA Methods 413.2 and 418.1, it is a method that offers rapid on 

site measurements performed by non technical personnel and produces repeatable results that 

correlate well with EPA1664. ASTM Method D7066 is most widely used oil and grease method 

worldwide and should be considered alongside ASTM D7575-10 as an alternative to EPA1664.

Response: See response to comment 221. 

Comment 270 E. G. Roy, Ph.D., Senior Scientist, OSS Inc.: The purpose of this comment is to 

reflect on the reactions from the independent labs that I trained during the single and multi 

laboratory validation and demonstration studies. In each case, the laboratory personnel were 

initially skeptical of D7575 technology, due to the simplicity of the process when compared to 

EPA 1664. However, after each 2 day test sessions, all technicians and analysts repeatedly 

commented on the advantages that D7575 has over EPA 1664 including: 

 1) D7575 does not require the use of a hood, while 1664, occupies a hood for a batch of 

samples while the hexane evaporates. This was of particular importance to the smaller labs, 

where hood space is limiting 

 2) D7575 does not require solvents, and therefore does not require flammable storage or 

waste disposal. The technicians were also pleased that they were not exposed to a hexane, a 

known neurotoxin. 

 3) The amount of technician effort per sample is much lower for D7575 when compared 

to EPA1664 or 1664A, raising the overall efficiency of the contract laboratory. In each case, the 

technicians were blown away by the number of samples that they were able to process in a <16 

hour period (including training). Furthermore, the technicians noted that all pieces of the method 

that touch sample were disposable, thus eliminating the need to wash glassware and the 

possibility of contamination from carryover. 

 4) Because D7575 is much simpler than EPA 1664, there are fewer opportunities for 

human error throughout the analytical process. 
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 5) Because D7575 requires a much smaller volume than EPA 1664 (10 mL vs 1000 mL), 

the contract lab managers and QA/QC officers liked that the remaining sample could be 

reanalyzed if something went wrong or could be saved as proof of a violation. 

 6) Because the equipment used in D7575 has a small footprint, spill response personnel 

appreciated that the technology could be deployed in a mobile laboratory. 

Response: See response to comment 221. 

Comment 272 Rachel Gettings, Orono Spectral Solutions: I am currently employed as a 

research technician by OSS and was brought on after the development of the ASTM D7575 

method. I have had many opportunities since to run the method, both running figures of merit 

samples and many different real world samples. I have found the new technology to be simple 

and reliable, requiring minimal time and equipment. Using ASTM D7575, I have processed a 

higher number of samples in a shorter period of time than with the current LLE method. As a 

research technician, being ableto process multiple samples quickly and accurately is a necessity 

and the ASTM method allows for this when a large number of oil and grease samples arrive. In 

addition to faster sample processing, there is very little prep-work and clean-up involved with the 

ASTM D7575; compared to the LLE method where apparatus set-up and waste disposal can 

become very time consuming. The ASTM method uses cheap, disposable parts and does not 

require a series of complicated steps to process a single sample. As an advocate of green 

chemistry I also appreciate that the method is completely solventless and does not involve 

significant exposure risks to the neurotoxin n-Hexane like the current EPA 1664 method does. I 

hope for the safety and ease of use of all the other technicians out there that ASTM D7575 soon 

becomes available!

Response: See response to comment 221. 

Comment 273 Jack Hall, Chairman ASTM D-19 Committee on Water Methods: I strongly 

support the acceptance of the USEPA of the ASTM Method D7575 as a valid method for Oil and 

Grease since it is able to replace use of any solvents and has performed very well in 

comparability studies to the current method. The USEPA must be responsive to new technology 

to assure the public that approved methods are the best that are available. I support the letter 

from ASTM which I have attached. 

[EPA Note: The ASTM letter from ASTM to EPA dated 6/28/11 attached to the comment is not 

included here.] 

Response: See response to comment 221. 

Comment 275 Peter Rush, Portland Water District Portland Maine: The Portland Water 

District participated in an inter laboratory study in August 2009 using OSS solvent less oil and 

grease method. 

 The driving force behind our interest in this method is the elimination of hazardous 

solvents. We had in the past performed oil and grease in our utility laboratory by EPA Method 

1664, but found the added expense of disposing hazardous waste solvent prohibitive. Portland 
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Water District considers the environment in all of its decisions therefore the green nature of this 

method is an added attraction. 

 We found the method proposed by OSS to be straight forward and following their 

standard operating procedures one that could be done with a minimum of training. The results 

obtained by the OSS method were comparable to the previous method used. Based on our 

experience, we would recommend acceptance of this method. 

Response: See response to comment 221. 

Comment 282 Anonymous: I was personally involved in some of the early testing of OSS's 

ASTM D7575. Our lab was utilized in several ways. We supplied samples for them to analyze to 

compare results that we determined by 1664. We tested samples that they sent to us using our 

own Horizon Oil & Grease machine. I was invited to their facility to observe their method first 

hand, as well provide insight and concerns. I would like to comment on my experience with 

ASTM D7575. 

 Given my own choice, I would personally prefer to be extracting and analyzing oil and 

grease sample by way of D7575. First of all, D7575 is a much more environmentally friendly 

and green method. This method eliminates the use of n-Hexane, which poses environmental and 

health concerns. With our instrument, if samples are especially dirty or there is not a perfect seal 

in a bottle cap, sample can leak out onto the counter, creating a hazardous mess. Part of my job is 

to dispose of hazardous waste. Oil and grease samples are generally received in duplicate. Once 

the analysis is completed, we have an extra 1 liter bottle of sample preserved with sulfuric acid. 

Samples for D7575 could potentially be sampled with a simple disposable syringe. That would 

eliminate almost all of the sample waste and reduce the amount of container waste for 2 bottles 

to a small syringe. Our instrument takes up a lot of counter space and must be vented due to use 

of solvents. D7575 takes up much less space and could be portable. D7575 has also been 

determined to produce equal or better results in a fraction of the time. When we run a full batch 

of samples using 1664, it takes a full day of extracting and drying. Using the D7575, I was able 

to complete an entire batch in only a couple of hours. Using 1664 produces an MDL of 5mg/L 

can reached. D7575 produces results of 1mg/L. In summary, D7575 produces better, more 

efficient results without the hazards of 1664. D7575 creates less waste, is safer, and is easier to 

use than 1664. 

Response: See response to comment 221. 

Comment 284 Charles Voinche, Petroleum Laboratories, Inc.: The proposed ASTM D7575-

10 method may be a good alternate method to EPA 1664, it appears functional for research and 

testing laboratories use, but is far from having realistic application for field analysis, such as in 

the offshore oil and gas industry. If EPA grants alternate method status to ASTM D7575-10 it 

should realistically also approve ASTM D7066 method as an alternate method. The ASTM 

D7066 method is similar to ASTM D7575-10 method in that they both use IR technology. 

 The existing EPA 1664 method uses a solvent with gravimetric finish, ASTM D7066 

method uses a solvent with an IR finish, and ASTM D7575-10 uses no solvent with an IR finish, 

but may not be a viable candidate method for field application, all things being considered. 

Response: See response to comment 221. 
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Comment 285 Joe Boyd, Environmental Express: We at Environmental Express support the 

adoption of method ASTM D7575 in an effort to allow for the use of "greener" methods for 

various types of analyses. Supporting documentation shows that ASTM D7575 provides 

equivalent data results when compared to EPA Method 1664 and has many advantages, namely 

eliminating harmful solvents used in the 1664 method. 

 The EPA has begun to support alternative technologies used in existing methodology to 

help laboratories reduce costs as long as results produced using those technologies are 

reproducible with the validated technology. This philosophy has helped numerous laboratories 

streamline their analyses and provide better data to their customers. 

 The next step in method flexibility should be the allowances of technology that makes the 

analysis more friendly to the environment. Laboratories often test for pollutants yet create 

environmental hazards themselves while doing so. Any new technology that can eliminate or 

greatly reduce these hazards should be supported by the EPA and the regulatory community. 

Response: See response to comment 221. 

Comment 286 R. Schumann: When studying the effects of oil spills on marine life, having an 

alternate on-site EPA method is critical if spill offenders are to be targeted for responsibility for 

low levels of oil that could be detrimental to marine species. Neither the current EPA 1664 

method nor the proposed D7575 method are field portable. D7066 has been in operation for 8 

years and we have found this to be a suitable on-site method. We would ask you to consider 

making D7066 an alternate method as well as D7575 for those of us who are down in the 

trenches doing oil in water analysis.

Response: See response to comment 221. 

Comment 305 B. P. Eynon: I am a professional statistician with over 30 years of experience in 

applying statistics to the environmental and biotechnology fields. In the early 1990s I was a 

statistical consultant to the US EPA Office of Water and provided statistical and data analyses of 

laboratory measurement data for Oil and Grease in the EPA Freon Replacement studies, 

including the Phase 1(US EPA, 1993), Phase 2(US EPA, 1995) and Validation (US EPA, 1995) 

studies that led to EPA Method 1664A (US EPA, 2000), in work done through SRI International 

and Dyncorp/VIAR (EPA Sample Control Center). These analyses formed the basis for the 

statistical tests of equivalence between analytical methods that is presented in the Analytical 

Method Guidance for EPA Method 1664A Implementation and Use (40 CFR part 136) (US 

EPA, 2000). 

 I am writing today to support EPA’s proposal to approve the ASTM D7575-10 

Solventless Oil and Grease method as a substitute for EPA Method 1664A. In light of previously 

submitted data and analyses I concur that the demonstrated substantial agreement of the two 

methods in addition to the provision of solventless / greener alternative to the use of 

environmentally unfriendly and hazardous n-hexane used in EPA Method 1664A provide a more 

than sufficient justification for the acceptance of ASTM D7575-10 as an alternative method for 

measurement of Oil and Grease.

Response: See response to comment 221 and 232. 
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Comment 308 J. Betts: I am pleased to see a more environmentally responsible method 

proposed for analysis of "oil and grease", specifically one that does not use the dangerous 

solvent, n-hexane. Working with organic solvents is costly with respect to hazard training, 

permitting and management and is an unnecessary risk to human and environmental health. As 

an individual that has worked in the biofuels industry dealing specifically in lipid extraction and 

analysis, I am intimately aware of solvent hazards and the necessity for improved methods. 

Response: See response to comment 221. 

Comment 309 Anonymous: We believe that EPA should endorse multiple methods for oil and 

grease based on different extractants and determinative techniques than EPA Method 1664A. 

 Reason 1: EPA 1664A is not suitable for all kinds of oil. Oils with low boiling point (e.g. 

condensates) are lost during the distillation step. This leads to underestimation of oil and grease 

values in these cases. 

Reason 2: New methods or technologies, better suited for oil and grease detection, should 

not be finally excluded due to a necessity to follow existing standards. The goal should always 

be to implement the best available technology (BAT).

Response: See response to comment 221. 

Comment 315 Camille Turcotte, Wisconsin Department of Natural Resources: Issue 1. Yes 

for the same reasons listed 

Issue 2. Yes for the same reasons listed. [EPA Note: These comments are in 

reference to the 4 NODA request for comment issues. For issue 1, the commenter 

refers to whether EPA should promulgate this method. The commenter agrees with 

EPA’s reconsideration. For issue 2, the commenter agrees that the ASTM method is 

an acceptable choice.]

Response: See response to comment 221. 

Comment 316 Thomas Schwarz, Research Scientist, Orono Spectral Solutions: I have 

worked for OSS throughout the entire development of ASTM D7575. During the Validation 

phase, it was my job to install equipment and train laboratory personnel on the proper procedure 

for ASTM D7575. Before training, laboratories were provided with a copy of the method as 

well as an operating procedure for the equipment. At the end of a single day of training, 

laboratory end users were proficient at performing the method, and were able to autonomously 

demonstrate all of the figures of merit (calibration, detection limit, precision and recovery) 

required to perform ASTM D7575. In most cases, the analyst performing the method had little 

(if any) experience with infrared spectroscopy. In every case, the analyst finished the training 

with proficient understanding of the IR techniques needed to make accurate measurements 

of the IR absorbance peak used by ASTM D7575 to quantify Oil and Grease in a water 

sample without the help OSS personnel. 

One IR technique that was especially important was determining when the extractor was 

sufficiently dry enough to provide an accurate Oil and Grease measurement. As is outlined in 

the Operating Procedure, the analyst was trained to able to identify the IR peak in the spectrum 
12

associated with water on the extractor membrane. If the water peak interfered with 

quantification of the Oil and Grease peak, the analyst was trained to dry the extractor further 

and rescan the extractor. When the water peak was reduced enough so that it no longer 

interfered with accurate quantification of the Oil and Grease peak, it was considered dry. This 

iterative drying procedure is analogous to a similar procedure found in section 11.4 of EPA 

1664. In the procedure for EPA 1664, the extracted sample is heated to 70°C and weighed 

iteratively until no more significant weight loss is detected with no strict limitations on drying 

time. In the case of ASTM D7575, if there was a correlation between extended drying time 

and lower analyte recoveries, it would have been reflected in the validation data, but this simply 

was not the case. In a final related note, in the time since the validation studies were completed, 

extensive work has been conducted into developing automated software for the IR analysis step 

of the procedure. An automated software platform will be capable of determining dryness and 

quantifying the Oil and Grease peak without any intervention from the user. This software 

package eliminates the requirement for laboratory personnel to learn IR techniques to 

conduct ASTM D7575. 

On the second day of validation testing, laboratory personnel autonomously processed the 

provided samples. It is important to note that OSS employees were not present for the testing of 

matrices during the single lab and multi lab validation studies for ASTM D7575. Once the 

analyst was properly trained, all data generated and reported in the validation study was 

produced by independent analysts without the help or influence of OSS personnel. Analysts 

were able to complete all of the testing in less than a day. At the end of the study, the only 

waste that had been generated was the solid waste (e.g. used extractors, syringes, paper towels, 

gloves) and aqueous waste from the tested samples. In the case of both ASTM D7575 and 

EPA 1664, the aqueous waste can be neutralized and disposed of. ASTM D7575 does not 

generate any more aqueous waste than EPA 1664. Analysts were generally pleased with the 

easy cleanup associated with ASTM D7575. There was very little (if any) glassware to clean 

and no solvent to dispose of. Analysts also expressed overwhelmingly positive sentiment 

regarding the ease of the entire testing process compared to EPA 1664, which could have easily 

taken over a week to complete the training, compliance verification, and sample testing that was 

completed in less than two days with ASTM D7575.

Response: See response to comment 221.

Comment 317 Ray A. Morales, Naval Surface Warfare Center Carderock Division 

(NSWCCD): We are the In-Service Engineering Agent (ISEA) and Life Cycle Managers (LCM) 

for Oil Water Separators (OWS) and Oil Content Monitors (OCM), installed onboard almost all 

US Navy surface ships. 

 Navy policy is to use EPA approved methods for oil-in-water determination. However, 

the current EPA Method 1664A has many limitations for our application, especially for 

shipboard evaluation of OPA systems. Navy ships are all over the world and EPA Method 

1664A definitely is not a field method. Transporting n-hexane all over is almost impossible due 

to hazardous material restrictions. Likewise, collecting, preserving, and shipping samples may 

not be practical in long ship's deployments. 

Our laboratory participated in a field trial of ASTM Method D7575-10. This method was 

easy to use, faster than EPA 1664A, did not required specialized equipment other than the solid 

phase extraction membranes and the IR that we already had, and do not use any hazardous 

materials. All the instrumentation and material required for this method are easy to transport for 
13

field application. ASTM D7575 is within our measurement range of interest (5 to 200 mg/L). 

Some samples of known concentrations were prepared at the laboratory and others were taken 

from our test stand for this trial. Not enough samples were taking for a comprehensive statistical 

analysis. However, the results obtained during this field trial suggested that this method is equal 

or better for our application that EPA 1664A. 

 Based on the above narrative, we recommend EPA to promulgate ASTM D7575-10 in 40 

CFR Part 136 as an alternative method to EPA Method 1664A for oil and grease determination. 

However, EPA should establish clear guidance to determine whether or not to consider future 

requests for other methods. 

[EPA Note: The following text is from the attachment to the comment. The second and third 

paragraphs of the attachment are not included here, as they are verbatim to the second and third 

paragraphs, respectively, from the comment (above).] 

We are the In-Service Engineering Agent (ISEA) and Life Cycle Managers (LCM) for 

the Oil Pollution abatement (OPA) systems, including Oil Water Separators (OWS) and Oil 

Content Monitors (OCM), installed onboard almost all US Navy surface ships. The OWS 

system is install onboard Navy ships to treat the oily wastewater generated in the machinery 

spaces, while the OCM monitors the OWS overboard discharge to ensure compliance with the 

applicable regulations, currently not to exceed 15 parts per million (PPM). As part of our 

responsibilities, we conduct both, laboratory and shipboard test and evaluations of OWS and 

OCM systems. 

 Responses to specific EPA comment requests are as follows:

1. Whether EPA should reconsider promulgating this additional method for oil and grease based 

on different extractants and determinative techniques than EPA Method 1664A. 

 COMMENT: Based on the above narrative, we recommend EPA to promulgate ASTM 

D7575-10 in 40 CFR Part 136 as an alternative method to EPA Method 1664A for oil and 

grease determination.

2. EPA's current view, based on the data it has reviewed to date, that ASTM D7575-10 is an 

acceptable choice for the determination of oil and grease for the range (5 to 200 mg/L) evaluated.

 COMMENT: Based on the information provided, we concur with this EPA's view. 

However, EPA should establish clear guidance to determine whether or not to consider 

future requests for other methods. 

3. EPA's current conclusion that permit limit adjustment based on side-by-side comparisons of 

EPA Method 1664A and ASTM D7575-10 is not appropriate. EPA is particularly interested in 

obtaining comments from permitting authorities on this issue and estimates of the burden 

associated with reviewing such requests.

 COMMENT: No comments. We are not a permitting authority, nor are we directly 

responsible for a discharge permit.

4. If EPA were to allow a side-by-side comparison with limit adjustment as necessary, should 

EPA look to the approach used for n-hexane in place of Freon (see section III.C) or should EPA 

consider a different approach? 

COMMENT: No comments.

Response: See response to comment 221. 

Also, many of the applications specified by the commenter are not for CWA compliance, and 

there is nothing in Part 136 which prevent these uses. Modifying Navy policy is outside the 

scope of this action. 
14

Comment 319 Patsy Root, IDEXX Laboratories: Overall, IDEXX applauds the pursuit of 

methods, such as D7575-10, that are more “green” and remove health hazards for lab personnel. 

We appreciate the opportunity to be part of this process and hope to continue to partner 

with the EPA, and other stakeholders, in the protection of public health and our environment.

Response: EPA thanks the commenter for her view.

Comment 320 Rebecca Labranche, A & L Laboratory Inc.: During my participation in the 

laboratory trials for the ASTM D7575 method developed by Orono Spectral Solutions I found 

the method very easy to understand and execute. With only minimal training I was able to learn 

how to operate the instruments and process the analysis on several samples. I believe that the 

method would be a valuable alternative for laboratories mainly because it is solvent-Free and 

eliminates the use of n-hexane a known neurotoxin. Reducing exposure to n-hexane and 

eliminating hazardous waste would significantly reduce laboratories impact on the environment 

and help to improve the quality of health within the laboratory. The data supplied by the 

validation studies show that the infrared method produces results equivalent to those of the 

current EPA method 1664. The potential use of a more “green” method would be an attractive 

alternative for many laboratories. In a time when the EPA is striving to regulate chemicals for 

both the Clean Water and Clean Air Acts the removal of a regulated contaminate from any 

method is a step in the right direction. I hope the EPA will consider the approval of the ASTM 

D7575 method for use in the measurement of Oil and Grease and help laboratories reduce their 

impact on the environment. 

Response: See response to comment 221. 

Comment 323 Mark Citriglia, Manager of Analytical Services NEORSD: The Analytical 

Services department of the Northeast Ohio Regional Sewer District participated in field-testing of 

Solvent-Free Membrane Recoverable Oil and Grease by Infrared Determination (ASTM Method 

D7575). The laboratory tested a wide variety of sample matrices including influent and effluent 

samples from three of our wastewater treatment facilities, and industrial waste samples.

The method performed extremely well on all samples collected from our final effluent 

of our wastewater treatment facilities and samples containing less than 50 mg/L of total 

suspended solids. One recommended enhancement to the method would be the ability to use 

various syringe sizes from 5ml to 50ml. Using a larger sample volume for treated effluent 

samples decrease the method detection limit. The smaller syringes would make dilutions more 

accurate.

The method performance decreased and the time for analysis increased with samples 

having suspended matter greater than 500mg/L. The higher the suspended mater or turbidity of 

the sample made it much more difficult to obtain a representative sample. Additionally samples 

with highly complex matrices required multiple analyses which increased analysis time and 

cost. The most difficult sample to analyze using this method were those composed of industrial 

waste or waste with high concentrations of oil grease.

Our recommendation would be to accept this method for use under the Clean Water 

Act for samples containing less than 50 mg/L of total suspended solids. For samples 

containing greater than 50mg/L of total suspended solids would require additional quality 

control such as duplicate or triplicate analysis to address sample variability. Another option 
15

would be to require duplicate analysis for every sample with a relative percent difference 

requirement. Additionally not using the hazardous solvent n-hexane reduces waste disposal 

costs and reduces risk to employees. Having a smaller sample volume for analysis allows for 

retaining sample for reanalysis if needed.

Response: See response to comment 221. 

EPA notes that while the method currently specifies a 10 mg/L, EPA agrees that smaller or 

larger samples could be used provided the acceptance criteria of the method are met. 

EPA appreciates the comments on TSS but notes the commenter provided no data to support its 

assertion so EPA can not offer guidance on this topic for specific uses. 

B. Opposition to Approval of ASTM Method D7575

Summary: Many commenters opposed the approval of this method for various reasons such as 

the use of proprietary materials, differences with the approved method, and a number of 

technical reasons. The comments are grouped below by general area of concern. 

B.1. OSS is the sole supplier 

Comment 245 Anonymous: In considering the proposed ASTM 7575 method as an alternative 

to method 1664, I see that Orono Spectral Solutions is the only current supplier of this hardware / 

equipment. The EPA states in most of their methods that it does not desire to promote any one 

product over the use of another. Seeing that there is only one producer of the technology 

mentioned in ASTM 7575, this, by default, violates the EPA policy on non-promotion. If a new 

method is to be proposed, I think it only fair that the method be approved when other vendors 

have entered the market, and the end user has several choices of vendors. Until that time, I 

suggest this method not be allowed. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

However, EPA approves test methods but does not endorse vendors. Even though the ASTM 

method specifically states in footnotes 5 and 6 that the only known source of the apparatus is 

Orono Spectral Solutions, it also indicates that it will consider alternative suppliers. The same 

policy has been adopted by EPA in the past. An EPA method may refer to one or more suppliers 

for a specific piece of equipment or standard but it also adds “or equivalent” so that alternative 

suppliers could be used if and when available. 

Comment 257 Anonymous: With regards to including ASTM D7575-10 as an acceptable 

alternative to 1664, I find myself appalled. In reading the method I find that it is written 

specifically to cater to Orono Spectral Systems as there are no other manufacturers for the 

products required for this test. In almost every EPA method that I have read there is a disclaimer 
16

stating that EPA does not wish to promote any one manufacturer of a particular product (whether 

its a consumable or a piece of equipment), however they are willing to make an exception when 

an investor in the company used to work for EPA? Does this not violate EPA's own policies?

Response: See response to comment 245. 

B.2. Method comparison of ASTM D7575 to Freon vs. n-hexane methods

Comment 254 Anonymous: This might be getting picky about the proposed 7575 method, but 

in Section 17 of the method, it mentions that the results were compared to those of 1664. Based 

on the information available, the average recovery as a percentage of EPA Method 1664 was 

94%. It was stated in the Federal Register Vol 76 No 240, that hexane was found to extract 96% 

of the oil and grease that could be extracted by Freon. This means that the total error is 

somewhere along the lines of 10% from the original Freon method. For this test to be valid, the 

results should be compared to the original Freon method, so any errors are not compounded. If 

this is done and the results still show merit, than it might be worth reviewing this proposal again.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA disagrees. The current approved method has been in use since 1999 and EPA’s policy is to 

compare candidate test methods to a currently approved method. The Freon method was 

withdrawn years ago and thus it is not appropriate to compare ASTM D7575 to that method. 

Comment 271 Debra Waller, NJDEP: Side by side comparison appropriate? Freon or nhexane? The NJDEP agrees. Since there are changes to both the extraction and determinative steps, 

a straight forward comparison may not be successful. However similar to the removal of 

Freon and the switch to n-hexane, this method may not yield comparable results and could 

cause permittees currently in compliance with any NPDES permit limits to become noncomplaint. So the method comparison when done should be against hexane and not Freon and 

permittees with difficult matrices should be given special considerations as a result of the change in 

the determinative step and extraction.

Thank you for the opportunity to comment.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA agrees with the commenter in that the method may not yield comparable results in all cases 

and that method comparison should be done against hexane and not Freon.

Comment 296 Anonymous: In section 17 it is mentioned that the results of the ASTM D7575-

10 method were compared to those of the 1664 method. Based on the data available in this 

method, the average recovery on the different matricies as a percentage of 1664A is 94%. As it is 

stated in the Federal Register Vol 76 No 240, "n-hexane was found to extract 96% of the total oil 
17

and grease that could be extracted by Freon". This means that the total error is somewhere along 

the lines of 10% from the original Freon method. For this test to be valid, the results should be 

compared to the original Freon method so that the errors are not compounded. Until that data is 

available, I would not recommend that this method be included as an alternative. 

Response: See response to comment 254. 

Comment 315 Camille Turcotte, Wisconsin Department of Natural Resources: [EPA note: 

The comments are in reference to the 4 NODA request for comment issues.] Issue 3. No the EPA 

should allow side by side comparisons and permit adjustment based on those results as we know the 

method provides 20% lower recovery

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. [EPA Note: The commenter does not agree with a blanket approval and 

recommends side by side comparison.] EPA is not in agreement with the commenter statement 

regarding the lower recovery of the ASTM compared to EPA Method 1164. Please see Table 2 

in the ASTM method and Section 17.0 Table 1 for the recoveries.

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Commenters have discussed that 

ASTM D7575 development testing should have been compared to Freon. Response: Freon is 

banned. EPA 1664 was the method of record during ASTM D7575 development. EPA was 

involved in the development and approval of test plans and matrices.

Response: See response to comment 254. 

B.3. Sampling requirements and preparation 

Comment 244 Anonymous: I was just made aware that the EPA was considering the proposal 

of the ASTM 7575 method for Oil and Grease, and felt compelled to respond. There are many 

parts of the method which I strongly disagree with, but here is one observation. 

In Note 10, it states that if the sample (10 mL volume) plugs the extractor (which I guess 

means the filter) that a smaller sample size should be used, or alternatively, dilute the sample (I 

guess so it will flow through the filter?), and re-run the analysis. I am trouble by this suggestion, 

as once I have taken a portion of the sample from the original sample bottle, I do not now have 

the same sample that I started with. I have reduced the O&G concentration of the sample. As I do 

not know how much O&G I have lost due to a plugged filter, the final value I report will not be 

correct, it will be low. I guess this means I could pretend to always plug my filter and continue 

re-running the sample until a get a report value that I like. Seems a strange way to propose a 

method. 

 While I am not in love with 1664, at least I am processing the entire sample, and the 

results I report are from the entire, original sample, and there is no guess work or additional 

manipulation required on my part. I suggest not moving forward with this method. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 
18

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA disagrees with the statement that once a portion of the sample is taken out that the O&G 

concentration of the sample has been reduced. It is true that the total O&G amount has been 

decreased from the total sample volume but not the concentration of O&G in the homogeneous 

sample. The withdrawal of a portion of the sample would affect an O&G measurement using 

Method 1664 because this method measures the total weight from the original sample. 

Comment 246 Anonymous: While I applaud the EPA for looking towards the future and 

considering new analytical methods, to improve on the sample preparation steps, I am very 

concerned about the proposed ASTM 7575 method. Let me explain. 

 Per the ASTM method, the sample bottle should not be completely filled, as there needs 

to be room in the bottle to properly mix, or homogenize the sample, by shaking. As a side note, I 

can guarantee that a bottle would arrive in the lab that is completely filled, and that the end user 

would simply pour out some of the sample. Already I have a new problem. Plus, all sample 

collects would need to be retrained, which I think is even beyond God's ability to do. But back to 

the issue. 

 Per Note 3, about 5-10% of volume head space (represents about 50 to 100 mL of 

sample) is needed to perform the proper sample mixing. But what if a smaller sample volume is 

collected, and I can reach the syringe barrel down into the sample bottle. What do I do now? I 

guess I could add reagent water to bring the sample back up to a point where I could reach the 

sample with the syringe, but now I have to factor in the dilution of the sample. 

 As a lab manger responsible for processing samples quickly and with minimal issues, I 

see the end user having to make many, real time decisions on how to properly treat, and deal 

with samples of varying volumes. I can immediately see the recovery and reported values 

starting to look like a shot gun pattern - very little consistency. 

 I suggest the EPA hold off on any approval, until several more years of test data can be 

submitted, whereby the ASTM method has worked out all of these little potential problems that 

will quickly become issues in a real lab environment. 

 Thanks for the chance to share my thoughts and concerns. 

Response: See response to comment 244. 

The total sample volume is not a critical aspect for ASTM D7575 as it is for Method 1664 

because ASTM D7575 measures a concentration directly, not a weight that it is then converted to 

a concentration (which is the case for Method 1664). The addition of reagent water to the bottle 

is not necessary, nor the need to make decisions on how to treat samples of varying volumes. 

With respect to instruction to sample collectors, EPA asserts that training of sample collectors 

should be a standard practice regardless of the method(s) used. 

Comment 247 Anonymous: First, I must say that I am very surprised (shocked might be a better 

word) that the ASTM committee could allow a method like 7575 to be approved for routine use. 

I have never seen a more awkward and unscientifically sound procedure for sample prep testing 

and analysis. I suggest everyone read this method in detail, and I am sure you will come to the 

same conclusions, and understand why your local auditor will be all over you for reporting 

random and inconsistent results. 
19

 Here is one key point. Since the begin of time when samples were collected for Oil and 

Grease analysis, it was well known, that once a sample was collected, if an aliquot was taken 

from the original sample, that the "nature" of the original sample was changed, and if another 

aliquot was taken, that a different result would be reported. The entire sample needs to be 

processed, not a smaller aliquot. 

 After years of processing the "whole" sample, someone on the ASTM committee thinks 

that is is now OK to remove small aliquots, and that the results be correct? If these were clean 

water samples and I were looking for pharmaceutical by-products, and using LC/MS/MS, a 

smaller sample is OK, as the MS can provide the sensitivity and resolution to identify 

compounds. The 7575 method talks about using a small aliquot from an extremely dirty sample, 

and pretends that I will get a "true" value when passing an IR beam through a mud caked filter. 

Give me a break. 

 Maybe what they should consider is using Raman with the proper embedded library. It 

would get much closer to the "true" answer. 

 Lastly, in case you cannot tell, EPA, don't waste your time with this method.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA disagrees with the commenter’s premise that in the ASTM method, an aliquot of a 

presumably homogenized sample is not representative of the original sample. If the proper 

procedure for sample homogeneity is followed, multiple aliquots from the original sample should 

be representative. The ASTM method has demonstrated sensitivity to make measurements at 

concentrations similar to Method 1664 based on the MDL provided in Table 1 of the method. 

EPA may consider other techniques such as Raman if the Agency becomes aware of a specific 

method that uses this technology. With respect to the comment regarding extremely dirty 

samples, this method may not be appropriate for such samples, and Method 1664 must be used 

for these cases (see Note 2 in the method, which states that a different measurement technique 

may be necessary for samples where the solid matter is not sufficiently IR transmitting).

Comment 249 Anonymous: As the EPA asked for my comments on the proposed ASTM 7575 

method, here is one observation. I am making this comment based on information (literature and 

PowerPoint presentations) I found on line. 

It looks like the method proposes collecting the O&G sample in a one liter bottle, but 

making sure not to totally fill the bottle so as to leave a "mixing" headspace, insert a syringe into 

the sample and remove 10 mL of a truly homogenous and representation sample from the bottle. 

 For many of the typical O&G samples that need to be run in a commercial lab, there is no 

convenient, nor scientific way to take a 10 mL aliquot from one liter, and make the assumption 

that this is a truly homogenous and representative sample. It just is not so. Therefore, to see that 

the ASTM method thinks it is, clearly indicates that this method is seriously flawed and is not 

ready for prime time play. While I applaud the effort to always be on the look out for new 

technologies that will improve the sample prep procedures, this is not one of them. I see nothing 

but confusion in the lab industry with this particular method, and therefore propose this method 

be sent back for rethinking and better proof of concept. 
20

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA disagrees with the commenter in his/her assertion that a sample cannot be made 

homogeneous and that a 10 mL aliquot is not representative of the original samples. The 

comparability replicate data demonstrates that the results were very close in almost every case to 

the results obtained using EPA Method 1664. Detailed instructions on sample homogenization 

are given in section 14.2 of the method and in Note 9. For particularly challenging samples, if 

sample homogenization is not achieved, ASTM acknowledges a different method may be 

required (see Note 9). 

Comment 252 Anonymous: In regards to whether the ASTM 7575 method should be approved, 

I want to offer the following concern over the validity of the method. 

For many years, Bill Telliard was adamant about nothing coming in contact with the Oil 

and Grease sample, such as a stir bar, mixing rod, or even pH paper, as anything that touched the 

sample would change the samples integrity. The labs have all accepted this approach and 

currently respect this technique. 

 Now, it appears due to deficiencies in this proposed ASTM procedure, see Note 9, that it 

is OK to make contact with the sample to try and make it homogenous. Picture a typical Oil and 

Grease sample with a thick layer of oil floating on the top, and this method now would allow me 

to mix the sample with a stir rod, and then ignore the residual oil coating the rod. How can the 

rules change so quickly? It almost feels like there is an ulterior motive hidden behind the desire 

to have this method approved, versus being based on trying to make an easier method for oil and 

grease testing. I say no approval. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Note 9 in ASTM D7575 clarifies that for challenging samples, a paint shaker or ultrasonic 

vibration may be used and that contact mixing (i.e., ultrasonic homogenization, stand mixer etc.) 

has been not been found to cause interferences. EPA Method 1664A allows stirring (Section 

11.3.5) if an emulsion forms between the organic and aqueous phases during extraction. 

Comment 278 Anonymous: The proposed ASTM 7575 method specifies a sample volume of 10 

mL, to be passed through the IR membrane. As the method does not seem to indicate the original 

starting sample container, I am guessing that any container could be used? Plastic, metal, etc? 

This is a concern. 

 But the bigger issue is trying to get a homogenous sample from the original sample 

container. The method references a "paint shaker" or even a contact mixer. 

 I struggle with how this proposed method has drifted so far from the current 1664 

procedure - that is, a one liter sample, that nothing should contact the sample before use, that all 

of the sample should be used, that an aliquot should not be taken, etc, etc. 
21

While I am sure everyone is always looking for better technology to improve current 

sample prep steps, the drive to approve these changes appear to be very self serving for a few 

individuals, or companies. If all revenue generated by this proposed technique were to be 

donated to the American Cancer Foundation, than I might consider suggesting approval of this 

method. Until that time, I say do not approve this method!! 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

In response to the sample container, EPA refers the commenter to Table II in 40 CFR part 136 

which specifies appropriate containers (glass for oil and grease). With respect to sample 

homogenization, Note 9 provides information on this step. With respect to sample volumes and 

taking an aliquot, see response to comment 246. 

Comment 279 Anonymous: Regarding the proposed ASTM 7575 method, I question the 

recommendation to insert the tip of the sample syringe into the actual sample, and then pull the 

sample. I realize that this is the only physical way to remove an aliquot of sample, but as the 

outside of the syringe is now contaminated with the sample, I am sure this would be wiped off 

before attaching the IR membrane. The method also mentions that there might be times when 

another aliquot needs to be taken from the same bottle. 

 Extensive work was done for the development of Method 1664, and now it seems that all 

of that knowledge and work is being ignored to serve the benefit of a few. If maintaining sample 

integrity is/was such an issue in the past, why does this proposed method feel that its approach is 

better and the rules should now be changed. 

 Too many moving parts in this proposed method which scientifically have not been 

proven out. I recommend the EPA not move forward with approval of this method until these 

issues are addressed and resolved. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to request use 

of this method for a limited use through existing authorities in 136.5, EPA is providing a 

response. 

With regard to contamination of the outside of the syringe with sample, the syringe with the 

withdrawn sample is attached to an extractor and the entire withdrawn sample goes through the 

extractor. The outside is not wiped off. With respect to the comment on taking another aliquot, 

EPA refers the commenter to the response to comment 244. As indicated above, the 

concentration of the homogenized sample should not be affected. 

Comment 287 Anonymous: I don't know if this should be posted here or not, but I have a 

question with the ASTM method mentioned. In the lab that I work in, we have a subcontractor 

who performs all the sampling for us. They charge us extra for any special conditions placed on 

the sampling. Since the ASTM method requires us specifically to leave 50 to 100 mL of space in 
22

a 1 liter bottle for homogenization purposes, this is a change from what we currently do and 

would require special conditions. If we don't put the special conditions on the sample, and we 

recieve it in for this test, it would require us to either empty out some of the sample or transfer 

the sample. Either way would result in lower recoveries and loss of analytes. This method does 

not seem up to the standards currently employed by most EPA methods and definately should 

not be included in the 1664 method. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA cautions the commenter that emptying out some of the sample prior to homogenization 

could adversely affect the results. Arrangements between a lab and its subcontractors are outside 

the scope of EPA’s authority and this action. 

Comment 288 Anonymous: In ASTM section 10.2 it makes mention of an equivalency equation 

that would adjust the final concentration of the sample based on the amount of acid added. The 

use of the equation does not seem mandatory and is contradictory to all our current practices with 

ANY other EPA method. I worry that some labs may use this equation and others may not 

resulting in inconsistent data across laboratories. This would also require a retraining on the part 

of my analysts who produce the data. Any inclusion of this method will result in a high level of 

confusion amongst labs running this method and may result in mis-reported data.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Both Method 1664 and ASTM D7575 require the adjustment of the pH to 2 using sulfuric or 

hydrochloric acid if the sample is not analyzed within four hours. For Method 1664, the total 

amount of oil and grease is not affected by the additional volume of acid since the measured 

value is a weight, not a concentration. For the analysis of samples using ASTM D7575, the 

amount of acid added could be a few drops or more. Thus, for a large sample volume a 

correction of the concentration may be unnecessary when a very small amount of acid is added; 

however, when a large amount of acid is added it causes a change in the measured concentration. 

Only in such cases would it be necessary to use the equation in section 10.2. 

Comment 301 Don Shelly, Food and Environmental Technical Service: Does the 

homogenization protocol work with all matrices including motor oil? 

If an oil laden sample is passed through the device, is there residue left in the devices 

pathways and syringes? Could there be carryover? 

Questions regarding homogenization: a. Will the ultrasonic bath accommodate a full 

batch of samples plus QC? b. Is it really expected that the analyst can determine homogeneity 

by looking at the sample through a tinted glass bottle? c. How is homogeneity defined? d. Are 

there instructions for performing dilutions? 
23

 The ASTM method requires the assumption of homogeneity and 1664 does not, as 

dilutions are neither allowed nor required 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Regarding the question on whether or not homogenization will work with motor oil, motor oil is 

mixture of compounds of various compositions. Therefore some of these compounds may be 

extracted more or less than when using n-hexane. ASTM did not submit data on this method 

with motor oil, so EPA can not respond more directly to this question. 

Regarding the question on residue on the device pathways and syringes, the syringe and 

membrane are single use devices, so there would be no carryover.

Regarding the question on the ultrasonic bath capacity, laboratories are free to choose any 

ultrasonic bath that meets the requirements of the method, and thus, they should choose the 

appropriate size or number of baths as needed.

Regarding the question on the use of a tinted bottle disallowing determination of 

homogeneity, there is no requirement for the use of a tinted glass bottle. The Federal Register, at 

40 CFR Part 136, Table II, only requires an unspecified type of glass bottle. 

Regarding the question of how homogeneity is defined and the assumption of 

homogeneity, as implied in Note 9 of the method, a sample is considered homogenous if there is 

no stratification in the sample.

Regarding the question on whether or not there are instructions on how to perform 

dilutions, there are no such instructions in the method. 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Some commenters have 

discussed that the sample container is not specified in the method. Response: Sampling 

and sampling containers are discussed in the Referenced Documents (Section 2.2) of the 

method. Specifically EPA Method 1664 is referenced in which sampling containers are 

addressed in Section 6.1.1. Here is the link to that document: 

http://water.epa.gov/scitech/methods/cwa/oil/upload/20070710methodsmethod oil 

1664.pdf As well, sampling is discussed in the ASTM D7575 Standard Operating 

Procedure that was placed in the docket found here: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-0219 

Some commenters have discussed concerns over homogenization using techniques other 

than non-invasive. Response: The method states (Section 14.2) that it is up to the operator to 

ensure homogenization and suggests non-invasive techniques that have been found suitable.

In the case that the non-invasive techniques are insufficient – the method (only 

then) suggests homogenization that might utilize contact. It should be understood that this 

method may not be suitable for all matrices. 

Homogenization is further discussed in the ASTM D7575 Standard Operating Procedure 

that was placed in the docket found here: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-0219
24

Data results compared to EPA 1664 demonstrate the success of 

homogenization for challenging real world samples.

http://www.regulations.gov/#!documentDetail;D=EPAHQ-OW-2010-0192-0202 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

We agree with the commenters statement on sampling containers and homogenization. The 

method developer did not provide data on non-invasive techniques and their effect on the 

method results, so EPA can not speak to this specific issue. 

Comment 319 Patsy Root, IDEXX Laboratories: There are too many outstanding issues with the 

D7575-1 0 method at this time and, therefore IDEXX advocates resolving those issues first before 

promulgating the OSS D7575-1 0 method.

Certain steps in this method require clarification: What type of sample container must 

be used to collect samples? 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA refers the commenter to Table II in 40 CFR part 136. 

Comment 321 Stephen Arms, Florida DOH Environmental Laboratory Certification 

Program: At Lem's direction, I am sending you my short comment on the referenced proposed 

rule.

The proposed method ASTM 7575-10 allows for subsampling from the sample container and 

does not provide for rinsing the sample container with solvent to remove any material that might have 

adhered to the interior. EPA, in method 1664A, and more emphatically so in 1664B, speaks to this issue as 

critical to accurate measurements of Oil and Grease. These methods require using the entire sample 

followed by rinsing the container with solvent, which is included in the volume analyzed. Use of the 

proposed method could compromise analytical accuracy and comparability with past results. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA disagrees. In the case of Method 1664, rinsing of the container is done to ensure that the entire 

sample has been extracted. For ASTM D7575, only an aliquot is necessary due to the nature of the 

determinative technique. The critical requirement for this method is to ensure that the sample is 

sufficiently homogenized so that the aliquot is representative of the entire sample.

Comment 326 Debra Weber, Louisiana Government: The NODA does not show or present 

any new data for the EPA to consider the ASTM as an equivalent Oil and Grease method to 
25

EPA Method 1664A. It is the laboratory communities understanding that Oil and Grease is a 

Part 136 method defined analyte, to approve this method would require the EPA to redefine 

the definition of “Method Defined” analytes. 

There is no way to make sure a sample is homogenous also since calibration devices are 

used there is no data to show what kind of calibration can be established when calibrations are 

used as prescribed in EPA Method 1664A.

Response: See response to comment 247. 

As EPA is not promulgating this method in Part 136 and limited use ATPs are an appropriate 

vehicle for consideration of alternatives to method defined parameters, the comment about 

the definition of method defined parameters is outside the scope of this action.

B.4. Matrix spike requirements 

Comment 250 Anonymous: I have been running oil and grease sample for many years (almost 

back before the days of Freon), so I was very glad to hear that a new method might be available, 

to take us to the next level. Unfortunately, I do not see that this proposed ASTM 7575 method is 

the ticket. 

 I have read through the method completely and i picked out one part that I struggle with. 

Please note, that this is not the biggest problem in the method, just one of them, but 

unfortunately, there are many. 

 Section 12.8.4 suggests that if the MS/MSD does not pass, that "all samples in the batch 

must be reanalyzed by a test method not affected by the matrix interference". As a lab manger, it 

does not make any practical sense for me to run all of my samples, only to find that I need to 

reanalyze them by another technique - I guess LLE or SPE? 

 As mentioned, this is only one issue I have with the proposed method, so when you total 

them all up, I do not see value in this method, and strongly urge the EPA not to approved it. My 

life is difficult already. You will only add to it and get my local auditor annoyed as well. 

 thanks for the chance to share my thoughts. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The language in this section is analogous to the language in Method 1664 (i.e., in section 9.3.4.2 

it indicates that if the analytical system is out of control, the problem should be identified and 

corrected and the sample batch reanalyzed). ASTM D7575 specifies that if repeated attempts 

fail, one of the three options available is to use a different test method. As the commenter 

suggests, LLE or SPE are appropriate choices. 

 

Comment 251 Anonymous: Subject: ASTM 7575 Method Issue: 

Wider Acceptable Matrix Spike Recovery Windows 

 In Table 2 of the ASTM method, the Matrix Spike % Recovery Window is 70% to 126%. 

I propose that these values be the same as the current 1664 method - 83% to 101%. 
26

 I interpret this need for a wider recovery window as a deficiency of the method, and now 

question its viability.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA agrees that the matrix spike percent recovery is wider than for Method 1664. However, the 

correct range for Method 1664 is 78 to 114% (see section 17.0, Table 1). EPA acknowledges 

that for one of the acceptance criteria (matrix spike percent recovery), the ASTM method does 

not perform as well as the approved method. However the difference is not large, and thus the 

Agency concluded that this method is acceptable provided that side-by-side comparability data 

shows that the method results are comparable to that of the approved method.

Comment 291 Anonymous: For so many years I was told that dilutions of my samples was 

strictly not allowed and now I find that you are thinking of including a method which actually 

promotes the dilution of the samples (section 12.8.1, 12.8.2)! To move forward with this method, 

EPA needs to reevaluate what is and isn't acceptable within the current method. My thought is 

that the ASTM method shouldn't be allowed because it contradicts what I've been being told for 

years now. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The referenced sections address the concentration of matrix spikes, not actual samples. However, 

in Note 10 of the ASTM method, dilutions are allowed during the extraction portion of the 

procedure if the sample clogs the extractor. EPA suggests that if the extractor becomes clogged, 

then EPA Method 1664 be used. EPA Method 1664 calls for using a smaller volume so that the 

background measure and the spike do not exceed the method range of 1000 mg/L (see Note in 

Section 9.3.2.1). 

Comment 292 Anonymous: ASTM D7575-10 Section 12.8.4: "all samples in the batch must be 

reanalyzed by a test method not affected by the matrix interference" 

 This is what my auditor will latch onto and I will be left with no choice but to comply. 

Shouldn't any new methods being allowed be robust enough to handle the majority of the 

samples that are run using it? This gives me severe reservations about this method. 

Response: See response to comment 250. 

Comment 293 Anonymous: Table 2 of the ASTM method D7575-10 has MS requirements that 

are broader than the current recovery limits in the oil and grease method. This is definately not 

holding to EPA's purpose to ensure that the public safe and is, in fact, taking a step backwards. 

Any change to the method should improve ALL points of the method and not sacrifice one point 

for others.
27

Response: See response to comment 251. 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: A commenter was concerned about 

the case where and MS MSD fails and having to qualify or rerun the batch of samples. Response: 

As a specific point of consistency with EPA 1664, ASTM D7575 suggests the same.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The ASTM method, in section 12.8.4, contains recommendations to address what to do if the 

matrix spike samples fail. EPA Method 1664, in section 9.3.4.1, contains similar instructions.

B.5. Method detection limit (MDL) 

Comment 255 Anonymous: Quick comment on ASTM 7575. Table 1 of the method calls out an 

MDL value of 1.0 mg/L. Yet, in Table 3, the 7 replicate runs generated an MDL value of 1.29 

mg/L. Reading this, it indicates this method cannot even achieve its own specified MDL values. 

Looks like more work needs to be done. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The commenter is correct that the calculated MDL in Table 3 is 1.29 mg/L. The ASTM method 

rounds the MDL down to 1.0 mg/L. The calculated MDL rounded down would be 1.0, so, the 

information in Table 3 does correspond with the method specifications. Further, the MDL for 

Method 1664 is given as 1.4 mg/L so, in fact, the ASTM method produced a slightly lower MDL

than Method 1664. Also, the recommended lower reporting limit for the ASTM method of 5 

mg/L is comparable to Method 1664 (this number was rounded up from a calculated value of 4.1

mg/L). 

Comment 295 Anonymous: The data illustrated in ASTM D7575-10 does not even pass its own 

criteria! Table 1 states that the MDL must be 1.0 mg/L or less and Table 3 lists an MDL value of 

1.29 mg/L. If the pioneers of this method cannot even pass their own criteria, how could it be 

expected that others could. This also says much to me about ASTM methods that they are not 

fully vetted before they are promoted. I would definately not recommend the inclusion of this 

technique as an alternative to my current techniques.

Response: See response to comment 255. 

Comment 302 Anonymous: We believe that the MDL of method ASTM D7575-10 (5 to 200 

mg/L) is not sufficient and not convincing in the mid- and longterm. The vision for oil-in-water 

discharge stated by e.g. Statoil is "zero discharge" 
28

(http://www.statoil.com/en/technologyinnovation/protectingtheenvironment/wastedisposal/pages

/zerodischarge.aspx). 

 Many polluters (e.g. US oil companies) using internal guidelines have begun to set 

discharge limits <1 mg/L. Challenging goals for discharge reduction should not be hindered by 

analytical methods which are not able to measure low concentrations. Methods with minimum 

range 0.5-200 mg/L should be promoted by the EPA. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA promulgates new or revised methods that are as good as or better than existing promulgated 

methods with respect to minimum levels. The lowest concentration (i.e. reporting limit) stated in 

the method for the application of the promulgated methods and ASTM D7575 is 5 mg/L. 

Therefore, the commenter’s concern that ASTM D7575 does not measure to lower values is not 

relevant to its consideration. A larger sample volume may be required to achieve lower limits.

Comment 312 Anonymous: I wanted to make it known that when we were round tabling this 

method in our department meeting we noticed that in table 3 of ASTM D7575-10 lists a MDL 

value that does not even pass its own criteria. ASTM D7575-10 states it requires a MDL of 

1mg/L or less to pass. Table 3 shows runs and a result of 1.29 mg/L, which fails their own 

criteria. If the parties involved promoting this ASTM method cannot generate a working MDL 

then how is anyone else going to? I hope the EPA does not consider this method. 

Response: See response to comment 255. 

B.6. Method applicability

Comment 223 Curt McCormick: Does EPA believe this method is only appropriate for POTW 

effluents (post treatment wastewaters)?

POTWs will have to specify the appropriate method for their permitted users and others 

(e.g, restaurants, automotive servicing, etc.) based upon historical concentrations of oil and 

grease since EPA believes this method is valid up to 200 mg/L.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

ASTM submitted this method to EPA for consideration on all effluents (i.e. nationwide us). 

For the reasons explained in the notice, EPA is not approving this method for nationwide use 

in Part 136. A POTW can not specify ASTM D7575 in its permits or control mechanisms and 

a permittee cannot conduct compliance monitoring using ASTM D7575 for the permit or 

control mechanism unless the Regional ATP coordinator has approved a limited use ATP for 

the specific application being permitted. 
29

Comment 238 Anonymous: I currently need to analyze for non-polar material in my Oil and 

Grease samples. In reviewing the ASTM D7575 Method for Oil and Grease testing, as I do not 

see any provision for handling and reporting non-polar material, I see no value in proposing this 

method for approval, and suggest the EPA not consider approval. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

ASTM and EPA agree that D7575 is not applicable for measurement of non-polar material. As 

such, it is not appropriate to consider it for measurements of non-polar materials for nationwide 

applications or limited use applications. Method 1664 is available for the measurement of nonpolar material.

Comment 239 Anonymous: My permit specifically needs a technique for the non-polar aspect 

of the 1664A method (SGT-HEM).

Response: See response to comment 238. 

Comment 241 Anonymous: I disagree with the EPA considering the proposal and consideration 

of the ASTM 7575 method for the following reason. In section 6.3 of the method, it states that 

samples which contain a relatively large amount of particulate or biological material, processing 

the standard 10 mL amount of sample may not be possible. Note 2 further states that there may 

be samples wherein the solid matter is not sufficiently IR transmitting. This means that I have no 

guarantee of knowing if my sample will pass or fail, until it fails to report the correct value. Why 

would I ever consider using a poorly thought out procedure like this? I am disappointed that the 

EPA is wasting their time with garbage methods like this. Do not waste everyone's time with 

approving this method. Focus on better methods that solve problems - not create new ones!!!!

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

As the commenter states, in sections 6.3 and Note 2 of the method, there is a cautionary 

statement that for certain samples this method may not be appropriate and another measurement 

technique may be necessary. EPA asserts that this kind of cautionary statement is generally 

appropriate in many test methods that have potential interferences so that a permittee and/or 

laboratory are able to use judgment in the selection of the most suitable method for a specific 

sample. This type of cautionary statement is not unique to ASTM D7575. 

Permittees should consider these cautions if they wish to explore ASTM D7575 for a limited use 

application. 
30

Comment 243 Anonymous: Per the EPA's request, I am writing this comment about the 

proposed ASTM 7575 method for Oil and Grease. After a quick review of the method, one thing 

that caught my eye was the comment in Note 2, that if the sample contains a large concentration 

of metal particulates, that a different measure technique may be used. What would this other 

technique be, and how would I know it was equivalent? My samples currently do contain high 

metal contents, so why would I use this method. I see no value in this method for my work, and 

suggest that the EPA do not consider approval, as it will only confuse my auditor even further, 

and make my life that much more difficult. Please EPA, add simplicity to my life - don't make it 

more difficult

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Permittees should carefully consider the limitations and cautions in the method if they wish to 

explore ASTM D7575 for limited use applications. 

Comment 263 Anonymous: For what is is worth, I have spent many years using IR for 

techniques, unrelated to the proposed Oil and Grease ASTM method. But as I reviewed the 

method, I see a major problem. 

For IR in general, the measured IR absorbance generally matches a previously 

determined weight for petroleum hydrocarbons, because of the CH group, and this technique has 

been used for many years, in the petroleum industry. However, if the sample contain any 

synthetic silicone based products, or perfluorinated oils, the carboxyl group is not detected 2920 

cm, which will result in a lower value being reported. 

 While reporting a lower value is the goal on any oil and grease permit holder, I do not 

think this was the intent of the EPA. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The commenter’s concern is addressed in a cautionary (Note 1) in the ASTM method. Likewise, 

similar cautionary language is in Method 1664 for some materials such as crude oils and heavy 

fuel oils that may not be soluble in n-hexane. Permittees should carefully consider the limitations 

and cautions in the method if they wish to explore ASTM D7575 for limited use applications. 

Comment 294 Anonymous: The inclusion of this ASTM method D7575-10 should not happen 

as almost none of my samples sound like they would be sufficiently homogenized to be able to 

be run this way. Its not that they have high levels of O&G content, which would put them above 

the 200 mg/L limit of the ASTM method, but its the organic content of the samples. Even if I 

could get a sample to appear sufficiently homogenized, there is no guarantee that when I skim 

off 10 mL of the 1 Liter that is collected that it will representative of the entire sample. It is 

obvious to me that this method has not been tested with real samples and, instead, has only been 
31

tested in very controlled settings and I would request that this not be allowed as an option for 

anyone to be able to run. 

Response: See response to comment 243. 

Comment 297 Larry LaFluer, NCASI: We have reviewed the materials provided in the 

docket and agree that for the specific matrices that were evaluated with respect to 

comparability of results using EPA 1664A vs. ASTM D7575-10 the methods provided 

reasonably comparable but not necessarily identical results. However, in our view, the 

range of matrices tested is far too narrow to consider approval for use across all SIC 

codes. Although ten matrices were tested, there was similarity in some (four were food 

processing operations and three were clear uses of petroleum products). We do not 

believe this is a sufficient test of the broader range of industrial wastewaters where other 

organic substance might be present. Furthermore, ten matrices would be the minimum 

required for a nationwide approval of an alternative test procedure for a specific target 

substance where procedures exist to estimate and quantify accuracy and precision and 

detection limits. These traditional analytical metrics and evaluation procedures cannot be 

applied to a method-defined parameter. Thus, a much higher burden of proof must be met 

before an alternative test procedure should be approved for a method-defined parameter.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. 

Comment 319 Patsy Root, IDEXX Laboratories: Revise or expand sample processing for 

those samples suspected to have high metal content. Add an EPA recommendation to the method 

for NPDES permit writers in states that require a technique that could be applicable or comparable 

to the non-polar aspects of 1664A. Revise or expand method procedure if a large amount of 

particulate or biological material is suspected to be present in the sample; this will help labs avoid 

re-running samples. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Regarding the comment on revising or expanding the sample processing, as the ASTM method 

suggests (see Note 2), this method may not be appropriate for samples with high metal content. 

Regarding the comment on the suggested addition to the method for non-polar aspects, EPA is 

unclear as to what the commenter means. This method is not applicable to non-polar material but 

for total oil and grease measurement. See response to comment 238 under topic B.6. 

Regarding the comment on expanding the procedure if particulate or biological material is 

suspected, EPA thanks the commenter for this suggestion. In Note 2 of the method, it states that 

for samples where IR transmission is impeded, "a different measurement technique may be 

necessary."

Permittees should carefully consider the limitations and cautions in the method if they wish to 

explore ASTM D7575 for limited use applications. 
32

B.7. Infrared (IR) measurement

Comment 242 Anonymous: Maybe I am missing something here, and someone can enlighten 

me. As I look at this proposed ASTM 7575 method, it looks like once the sample has been forced 

through the membrane filter, that the filter is placed into the IR system, and only the dead center 

of the filter is hit with the IR beam. What happens with reading the entire surface of the 

membrane? Having done filtration work for most of my life, it is well known that the entire 

surface of any filter should be analyzed, not just a small portion. Plus, as most of the sample is 

forced through the center, I would guess that the IR readings would be biased high, as this is 

where most of the sample will reside. Why would I want to report a higher value than I need to? 

I would ask the EPA not to consider this method - at least not until more valid and scientific 

work has been done. This approach looks half baked. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Regarding the comment about the IR beam analysis and extractor spot size, based on the data in 

the record, the replicate sample results demonstrated that the results are reproducible using the 

technique. 

Comment 266 Anonymous: My lab currently runs EPA method 1664B for oil and grease 

samples. As this method requires a 4 place balance, I am required to make sure this balance is 

properly calibrated and traceable back to the NIST Weights and Measurement Division. I do not 

see any similar requirement for the IR device. Why? 

 If the IR unit is going to be used, than this device should also be required to be certified 

and traceable.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

It is true that Method 1664 (see Section 9.1.2.2.5) requires that the analytical balance and 

weights are traceable back to NIST. However, when instruments are used for a measurement, 

EPA generally includes a statement that the analysts must follow instrument manufacturer 

recommendations. This is a prudent approach since laboratories may have instruments from 

different manufacturers. 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Indirect Vs. Direct 

Measurement of Oil and Grease. D7575 does not measure Oil and Grease weight directly. 

Instead, it primarily measures the infrared absorbance of CH2 groups at the specified wavelength 

of 2920 cm-1. Using properly prepared working calibration standards, the observed infrared 

intensity can then be correlated back to the weight of the analyte(s) used to prepare the working 

calibration standards. For IR in general, the observed infrared absorbance typically correlates 

well with the observed weight for petroleum hydrocarbons (e.g. hexadecane) since they are 
33

comprised of various CH groups. For fatty acids (e.g. stearic acid), the observed weight is 

typically greater than the observed absorbance due to the carboxyl group that contributes to the 

weight but is not detected at 2920 cm-1. As such, erroneous data can be expected for high grease 

containing samples as well as synthetic silicone-based or perfluorinated oils. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA agrees that the method acknowledges that synthetic silicone-based or perfluorinated oils 

may produce inconsistent results as stated in Note 1 of the method. N-Hexane has similar 

problems with crude oils and heavy fuel oils. 

Permittees should carefully consider the limitations and cautions in the method if they wish to 

explore ASTM D7575 for limited use applications. 

Comment 318 ASTM D19 Subcommittee on D7575: The ASTM D19 Subcommittee on ASTM 

D7575: Standard Test Method for Solvent-Free Membrane Recoverable Oil and Grease by Infrared 

Determination would like to address some of the relevant comments specific to ASTM D7575 in 

this Notice of Data Availability.

Commenters were concerned about the IR beam analysis and spot size of the extractor. 

Response: These comments and concerns are not supported by the data. The extractor and 

optimized membrane therein has unique patent pending qualities that have been developed to 

ensure homogeneous distribution across the field of analysis. The data and QC results from 

the significant amount of testing would have shown this to be an issue if that was not the case. 

It did not.

A commenter was concerned about the analysis of synthetic oils that may have no C-H 

bands at 2920. Response: This is addressed in Note 1 and Note 7 of the Method.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Regarding the comment about the IR beam analysis and extractor spot size, see response to 

comment 242. Regarding the comment on synthetic oils analyses, EPA is in agreement with 

the response.

Comment 326 Debra Weber, Louisiana Government: The use of IR is prohibited in EPA 

1664A so therefore to consider a method where IR is used violates the only approved Oil and 

Grease method in CFR Part 136.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of this 

method for a limited use through existing authorities in 136.5, EPA is providing a response. 
34

EPA is in agreement with the statement that Method 1664 disallows the use of IR for the 

method. However, this prohibition does not apply to the use of IR in other methods such as 

ASTM D7575. Nor does it prohibit a permittee for requesting an alternative method that uses IR 

using existing authorities under 136.5. 

B.8. Working range of method

Comment 223 Curt McCormick: Does EPA believe this method is only appropriate when the 

actual concentration of oil and grease never exceeds 200 mg/L. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to request use 

of this method for a limited use through existing authorities in 136.5, EPA is providing a 

response. 

As specified in the method, the method range of ASTM is 5-200 mg/L and thus the method is 

limited to this range. As with any method, if the actual concentration of the parameter being 

measured can exceed this range of the method and other methods exist with wider ranges, the 

alternative method should be chosen. In this case, Method 1664 has a range of 5-1,000 mg/L.

Comment 240 Anonymous: I frequently have samples which are outside the working range of 

the ASTM method specified (>200 mg/L). This will not work for my laboratory. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA recognizes that the ASTM method range is 5-200 mg/L. Method 1664 provides a wider 

range and it is available for samples with concentrations >200 mg/L.

Comment 271 Debra Waller, NJDEP: ASTM D7575-11 as an acceptable choice? 

Comment: Aside from the potential interference from water in the extraction/membrane 

analysis, the comparability data presented in the docket appeared to be acceptable as compared to 

recoveries from samples tested with the hexane based method. NJDEP would like to see 

stronger language related to the fact that the ASTM method can only go up to 200 mg/L 

without dilutions. EPA Method 1664 extends that range up to 1000mg/L. When sample 

concentrations are greater than 200 mg/L, a hexane extraction will be more effective and stronger 

language should be in the 40CFR regarding this matter. Data should have also included sample 

sites where the concentration of the sample was determined to be closer to the top end of the 

working range than towards the lower end. For example a chicken rendering facility in NJ would 

have oil and grease concentrations closer to 200 or higher and this method would most likely 

not be appropriate for that type of sample. Also some really strong language about how this 

method is not for use when reporting total petroleum hydrocarbons is imperative.
35

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA agrees with the commenter on both the concentration range limitation and the inapplicability 

to total petroleum hydrocarbons.

Comment 300 Anonymous: My current Oil and Grease samples typically have a reporting value 

of 450 to 700 mg/L, but it looks like the proposed ASTM 7575 method can only handle samples 

between a range of 5 to 200 mg/L. Therefore, I do not see how this method can help me. Plus, 

allow two so totally different methods (1664 with a range of 5 - 1000 mg/L and ASTM 7575 

with a range of 5 - 200 mg/L) would create so much confusion for end users and the State 

Auditors, that I strongly recommend that this method not be approved. We have bigger and more 

pressing issues to deal with in the lab. The last thing we need is more confusion. Thank you.

Response: See response to comment 240. 

Comment 310 Anonymous: My laboratory is concerned with this proposed ASTM method 

D7575-10. We couldn't find anywhere in this method that states its able to extract non-polar 

(SGT-HEM) as part of the procedure. We currently use automated SPE and we are able to 

extract samples with a much wider concentration range and this method is only limited to 

200mg/L at the most. I would only hope the EPA will not accept this method. 

Response: See response to comment 239 regarding non-polar material. See response to comment 

240 regarding the concentration range.

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Commenters have asked about 

the performance of ASTM D7575 in matrices that include metal particulates. Response: ASTM 

D7575 specifically looked into these types of matrices during development. Comparative 

evaluation to EPA Method 1664 was performed in: Aluminum Can Manufacturer, Machine 

Shop, Auto Garage, Auto Salvage, Gunsmith, and Bilge samples. Please refer to slides in 

the docket file here: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-

0192-0218 

Commenters have asked: “Can ASTM D7575 can do TPH?” a. Response: No. 

ASTM D7575 is currently for total oil and grease measurement.

Commenters have discussed how to handle samples outside of range (e.g. > 200 

mg/L). Response: The method discusses the option of process volume reduction and dilution in 

Section 14.3.3 Note 10 and the qualification thereof. Section 16 addresses reporting.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated 

in Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to 

request use of this method for a limited use through existing authorities in 136.5, EPA is 

providing a response. 
36

Regarding the method performance in matrices that include metal particulates, EPA is in 

agreement with this statement, the method measures oil & grease, not total petroleum 

hydrocarbons (TPH). 

Regarding the comment on whether or not the method can assay for TPH, EPA thanks the 

commenter. In addition, please see Note 2 in the method regarding how to address 

samples containing a large concentration of metal particulates.

Regarding the comment on how to handle samples outside the method range, see 

response to comment 240. See Table 1 for the reporting range limits of the method.

Comment 319 Patsy Root, IDEXX Laboratories: The method limit for D7575-10 is 5–200 

mg/L. What if results are historically higher than this limit? Can dilutions of the original sample 

be made using D7575-10? The additional data on D7575-10 says that dilutions are not 

recommended and another method should be used. If that is the case, labs would have to be 

certified for both methods, which increases burden on the lab. 

Response: See response to comment 223. 

Regarding the need for certification on both methods should a second method be required, 

under the Clean Water Act, certification is not required. However, some States or permitting 

authorities may require certification for each method used in the laboratory.

B.9. Calibration 

Comment 237 Department of Defense: This letter provides the Department of Defense's 

comments on the Guidelines for Establishing Test Procedures for the Analysis of Pollutants. 

These were prepared by the Clean Water Act Services Steering Committee (CWA SSC) which 

represents the Departments of the Navy, Air Force, and Army as well as several DoD components 

and agencies. These comments were developed in consultation with the DoD Environmental 

Data Quality Workgroup. 

DoD supports EPA's consideration of new and revised test methods. However, DoD

wants to ensure use of the most current methods, consistency in preservation requirements, and 

alignment of calibration methods with EPA methodologies. Enclosed are our detailed comments 

and recommendations. 

 DoD appreciates the opportunity to provide comments. If you have any questions 

concerning these comments, please contact the CWA SSC chair, Ms. Lindsay Nehm at 703-695-

5179 or via email at lindsay.nehm@navy.mil. 

[EPA Note: the following comments are from the attachment.]

Specific comments: Calibration criteria of ASTM D7575 are inconsistent with requirements 

of EPA methods. 

Proposed Requirement/ Section Addressed: ASTM D7575-11, Section 12.2.4 (ASTM 

D7575-10, Section 12.2.4). 

Comment: ASTM D7575 has a calibration curve coefficient of determination criteria (r2 > 

0.95 for linear and > 0.97 for quadratic). The ASTM method also allows for calibration points 
37

within the calibration curve (i.e., not the lowest or highest points) to be reanalyzed or eliminated 

completely from the calibration curve calculations.

Discussion: The elimination of calibration points within the calibration curve is not 

permitted for most methods and should not be allowed. The coefficient of determination criteria in 

ASTM D7575-11 is wider than most methods allow. 

 Recommendation: Recommend modifying the requirements for the calibration to be more 

in line with EPA methodologies.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA does not currently have a requirement for specific calibration curve coefficient of 

determination criteria for every method. However, generally, such criteria should be stated 

and be > 0.95.

Comment 248 Anonymous: I am sending this comment on ASTM 7575, as my local auditor 

asked for my help. 

 His comment pertained to section 12.2.4 and 12.2.5. In this section, it is stated that the 

coefficient of determination should be >0.95 for linearity and >0.97 for quadratics. For most of 

the existing EPA methods, the coefficient of determination is required to be >=0.99. His 

recommendation is to hold the ASTM method to the same 0.99 value, as currently approved, and 

used EPA methods. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA does not currently have a universal requirement for the coefficient of determination. 

However, EPA agrees that metal methods that employ linear regression specify a criterion for 

correlation coefficient (coefficient of determination) of 0.995 (Solutions to Analytical Chemistry 

Problems with Clean Water Act Methods, EPA 821-R-07-002). 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Instrument Calibration 

Standards Vs. Method Calibration Standards. D7575 utilizes a set of Calibration Standard 

Devices to ensure the instrument is within calibration. They are also used as the working 

calibration standards for development of the method calibration curve. However, their use in this 

fashion assumes the lab technician has perfected the technique for drying the infrared-amenable 

membrane using the ill defined period of time specified in the method which will vary from 

sample to sample, instrument to instrument and operator to operator. No data was found in any 

study to demonstrate the competence of a lab technician to successfully generate an acceptable 

calibration curve using the method as written with fresh, laboratory- prepared standards of 

known weight. This competence must be demonstrated as part of a new Tier III study to assure 

satisfactory technique for analyzing both known and unknown samples. 
38

 Calibration and Standardization Traceable to Independent Reference. The analytical 

balance employed in EPA 1664A is calibrated at 2mg and 1000mg using class “S” weights 

which are traceable to commonly accepted criteria of the National Institute of Standards and 

Technology, Weights and Measures Division. There is no data to suggest that Method D7575 

Calibration Standard devices are traceable to any independent, reference standard. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Regarding the point about membrane dryness, see response to comment 253 (in Section B.10 

membrane drying) below. Regarding the point about calibration curves, EPA does not require 

NTTAA methods developers to provide methods development data, which would include data 

for the generation of an acceptable calibration curve. EPA only requires methods validation data. 

The calibration is simple and easy to check with freshly prepared standards. Regarding the third 

point about a Tier III study, see response to comment 283 (in Section B.14 method validation) 

below. Regarding the point about reference traceability, because this is a new technology, the 

calibration standard devices are not traceable to an independent reference standard. However, 

the method contains procedural steps (see section 12) to ensure that analytical values obtained 

using the method are valid and accurate within the confidence limits of the test. 

Comment 289 Anonymous: In regards to ASTM method D7575-10: 

Sections 12.2.4 and 12.2.5 require that the coefficients of determination for linearity and 

quadratics be greater than 0.95 and 0.97 respectively. For this method to be included in the EPA 

method all equipment should be held to the same high analytical requirements as each other, 

namely that the coefficient of determination be >= 0.99 as in most GC work. A lower coefficient 

will result in lower confidence in the final result.

Response: See response to comment 248. 

B.10. Membrane drying

Comment 253 Anonymous: This is my first time for sending a comment to the EPA, so if there 

is an established protocol to follow, I apologize that I do not know it. 

 However, it was suggested that I look at the proposed membrane IR method and, as I 

have years of experience using SPE for my oil and grease samples, that I respond if I see 

something that could create new problems. While I am encouraged, and support, the EPA in 

looking at new technologies, I see many issues with this proposed method. Here is one of the 

biggest issues I see. 

 Per the current 1664 method when using SPE, one requirement is to remove as much 

residual water as possible from the SPE material, before introducing the hexane layer. If too 

much water is present, than the hexane will not efficiently extract the oil and grease off. While 

conventional wisdom would say to simply increase the amount of the air dry time, it is a well 

known fact that too much air will also volatilize the lighter end of the sample. This is easily 
39

demonstrated when running a DI water spike, as the hexadecane will be lost, if longer than 5 

minute air dry times are used. 

 This new method also states that any residual water should be removed prior to using the 

IR (see Section 14.4.1 and Note 11), as too much water will cause an interference with the 

spectra. In one example, the method showed an air dry time of 45 minutes. One, who wants to 

wait 45 minutes for this, and two, with 5 minutes, the hexadecane value will be adversely 

impacted. 

Based on the need to remove residual water from the membrane so the spectra can be 

read, it seems that there will be a significant loss of the light end with this procedure. Don't 

forget the original 418 method, which used IR had no evaporation step, nor was there an issue 

with residual water. That is one of the reason 418 was such a good method. The only down side 

was the use of Freon. I see more problems by approving this method, than problems that will be 

solved. Say no to 7575! 

Response: Permittees should continue to use an oil and grease method promulgated in Part 136 

for CWA compliance. Because EPA recognizes that permittees may wish to request use of this 

method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The ASTM procedure states that for most samples a short drying time may be sufficient and 

suggests an iterative step of drying/measurement to verify that the sample is sufficiently dried. 

The dryness of the membrane is easy to check and does not require extensive training. This is 

analogous to the drying step in Method 1664 which requires drying, cooling, and weighing until 

the weight is less than 4% of the previous weight or less than 0.5 mg, whichever is less. In both 

cases, it is possible that some volatile materials may not be captured.

Comment 264 Anonymous: ASTM method 7575 clearly indicates that residual water left on the 

membrane will adversely impact the IR reading. The method then implies that if the residual has 

not been sufficiently removed, to dry the membrane longer. As samples, especially those filled 

with suspended material, will have different characteristics, the amount of drying time will need 

to vary for these types of samples. As soon as random drying times are used, random recovery 

values will be reported. The proposed method is implying that the end user should determine the 

amount of air dry time, which is counter to most other EPA methods. 

 It has been well documented that when using SPE disk technology, that if too long of an 

air dry time is used, that the hexadecane standard will be volatilized off of the disk. Therefore, all 

dry times with SPE disk are made to be consistent, and any residual water is dealt with in another 

fashion, that does not involve an air dry step. This approach provides better accuracy and 

precision. 

My experience indicates that auditors are currently looking for a level of consistency in 

the environmental methods being used, so they are able to assess when a lab is generating correct 

and accurate data. I see the adoption of 7575 as a step backwards and will only create more 

confusion in the environmental testing lab community. I feel 7575 should not be approved at this 

time.

Response: See response to comment 253. 
40

Comment 265 Anonymous: Several comments have already been made about the use of air to 

dry the IR membrane, i.e. the adverse impact of losing the more volatile light end of the sample. 

 However, another issue to consider is the potential of introducing compressor pump oil 

when using a compressed air source. The better way around this issue is to require the use of dry 

nitrogen instead. This would solve any problem with compressor pump oil being introduced onto 

the membrane, but the amount of nitrogen purging would still be an issue and needs to be 

addressed before this method becomes approved. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

In regard to the use of air to dry the membrane, see response to comment 253. Based on the data 

in the record, the use of a pressurized dried air apparatus has not been found to cause any 

problems as the commenter suggests. 

Comment 268 Anonymous: Key concern. The presence of water is such a huge interference to 

IR, that Method 7575 has its own appendix which states that it can "potentially influence the 

placement of the baseline points...leading to inaccurate analysis. 

 This variation will only lead to mass confusion in the environmental community. 

Response: See response to comment 253. Air drying of the sample eliminates the water 

interference.

Comment 269 Anonymous: The ASTM 7575 method mentions that anywhere from 5 to 20 

minutes may be required to dry the membrane of residual water. Plus, in one PowerPoint 

presentation from OSS, an air dry time of 45 minutes was used. 

 Studies have shown when using SPE disks, that air dry times longer than 10 minutes will 

adversely impact recoveries. This is due to the volatilization of the light end of the extract. I 

cannot see that passing air through the IR membrane would not contribute to the same lose. But 

if the membrane cannot be dried for longer than 10 minutes, than the residual water still left in 

the membrane will cause random and inconsistent recoveries. 

Response: See response to comment 253. In most cases the drying time is less than 10 minutes. 

Comment 271 Debra Waller, NJDEP: 

Comment: Since water remains to be an interferent in this procedure, why not include a step to dry 

the sample with a filter with sodium sulfate? If sodium sulfate fines are a concern, a .45 micron 

filter could be used. How many laboratories processing samples will take the time to really 

determine if the samples are completely dry on a routine basis and not just when an auditor is present 

or when PT samples are being analyzed?

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to request 
41

use of this method for a limited use through existing authorities in 136.5, EPA is providing a 

response. 

With respect to the dryness of the sample, this is a very simple step when using an FTIR 

instrument. If the sample is not completely dried, the disk can be dried for a longer period of time 

and then re-measured. This is analogous to section 14.4.4 of Method 1664, where the procedure 

calls for desiccating and weighing the sample until the weight loss is less than 4% of the previous 

weight or less than 0.5 mg, whichever is less. For the ASTM method, if the membrane is not 

completely dry, you would not be able to see an absorbance peak and thus you would not be able 

to quantify oil and grease. You would then need to re-dry the membrane and redo the 

measurement. 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Water is an Interfering 

Substance. The presence of water in the final sample analysis can lead to inaccurate results. 

D7575 utilizes clean, dry compressed air to dry the infrared-amenable membrane for an ill 

defined period of time which will vary from sample to sample (See ASTM 7575 Note 11) 

although Appendix X1 contains some non-mandatory information for determining membrane 

dryness spectroscopically. EPA 1664A utilizes 10g of sodium sulfate or other equivalent means 

to remove water from the final n-hexane extract. If water does happen to remain in the final 

1664A extract, it is very visible as a known interference. If water remains in the D7575 

extractor, it is not so visible and its presence may not be known. It will be extremely easy to 

report an erroneous value with D7575 as the first result possible will be used since the iterative 

drying/measurement step is not a core part of the method, e.g., similar to achievement of a stable 

gravimetric measurement in EPA 1664A. 

Response: See response to comment 253. 

Comment 311 Anonymous: I wanted to comment on this method. It has been noted in section 

14.4.1 and as well in note 11 that how critical the removal of water is from the extraction 

membrane. In this proposed method they state it may need multiple air dry times to ensure no 

interferences within the spectra. In my experiences with 1664 the longer you air dry the sample 

the lower the recovery in the samples. The compounds are the same and hexadecane is smaller 

molecular weight compound so I really am concerned with their statement of multiple air dry 

times may be needed. I find it counter productive and less efficient compared to my current SPE 

procedures. 

Response: See response to comment 253. 

Comment 313 Anonymous: ASTM D7575-10 is going to be more trouble than its worth with 

the possibility of too much water in that membrane. It will severely influence the placement of 

the baseline on the IR and would lead to inaccurate results and additional or excessive air-dry 

times that could impact the overall results of the sample since there will be smaller molecular 

weight compounds in the samples. I am very concerned with this method and how inconstant it 

can be with the supporting data within the ATSM method D7575-10. 

Response: See response to comment 253. 
42

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Some commenters discuss the 

sample-dependent drying time of the method and the potential recovery loss. Response: These 

comments and concerns are not supported by the data. Drying time is discussed in the Method 

(Section 14), Note 11 provides guidance on this process, and the Appendix provides specific 

details. The Standard Operating Procedure provided in the docket

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192- 0219 also 

provides detailed information on this topic. As can be seen in the quality of results compared to 

EPA Method 1664 http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-

0202 All technicians that have used this method have had no issues with the drying process. Any 

significant loss of recovery would have demonstrated a bias and/or significant reproducibility 

issues between EPA 1664 and ASTM D7575 results. This was not the case. It should be noted 

that there is an iterative drying step in EPA Method 1664.

A commenter expressed concerns with the compressor for drying, saying that a compressor 

would contaminate the sample with oil. Response: The method states that a drying system 

must be capable of drying sufficiently for IR analysis without affecting analyte retention. The 

compressors used are oil free, and the drying system includes in-line dessicant and filtration, the 

results of which are reflected in the numerous blanks in the validation studies.

Response: EPA is in agreement with this comment. 

Comment 319 Patsy Root, IDEXX Laboratories: Air drying times need to be standardized to 

avoid volatilization of the lighter end of the sample. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

This is similar to drying times for Method 1664 and, based on the data in the record, drying does 

not appear to be a problem. 

B.11. Method-defined parameters and comparability

Comment 223 Curt McCormick: For Significant Industrial Users (SIUs) regulated under 40 

CFR Part 403 that have to monitor oil and grease for a Categorical Standard, shouldn't 

comparison data be included with Method 1664 for these specific wastewaters? If this is an 

alternate method under Part 136, this seems like a requirement. Without doing this could 

create havoc with permitting, compliance determinations and enforcement.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. A significant industrial user (and all dischargers to POTWs) must monitor for 

oil and grease using a promulgated Method in Part 136 unless the Regional ATP coordinator has 

approved a limited use ATP for the specific application being permitted. 

Comment 261 Anonymous: General question and concern for the group. "Oil and Grease" is a 

method defined analyte, but the definition of O&G is different as defined by Method 1664 and 

the proposed ASTM method, as the procedure and equipment is different. There was a report 
43

issued by a consultant (Ed Askew) which demonstrated that when comparing certain matrix 

types, that the results were so different, that the two methods (1664 and 7575) were not 

equivalent. It is my understanding that the only definition suitable for compliance monitoring is 

HEM and SGT-HEM. It would seem that introducing a new definition (call it MEM) without a 

clearly thought out regulatory plan would simply create confusion within the environmental lab 

industry, and would create many new issues for the EPA. Look at confusion that was caused by 

simply trying to remove the use of a co-extracting solvent when using SPE. I suggest this 

proposed ASTM method be sent back, until it can be shown to be a direct equivalent to the 

current definition of O&G. The EPA has bigger and more pressing issues to deal with, than to 

get caught up trying to deal with the non-equivalent results of the ASTM method. 

Response: EPA acknowledges that because the methods measure different things (weight versus 

IR absorbance), it is unlikely that they will produce the same results. As explained in the notice, 

EPA did not promulgate Method D7575 for nationwide use. 

Comment 262 Anonymous: While in theory a method which does not use a solvent is a good 

idea, the bottom line is that the proposed method is not "equivalent" to the current 1664 

procedure. 1664 uses hexane (replacing Freon) which was a good choice, as hexane being nonpolar, will do an excellent job extracting oil and grease from a water sample. Therefore, by the 

approved 1664 method, anything soluble in hexane, is by definition, Oil and Grease. 

 There is plenty of supporting data on the web, which clearly shows that trapping oil and 

grease on a membrane is not "equivalent" to extracting the oil and grease in a solvent. Making 

the assumption that they are equivalent would be believing that one could also take an SPE disk, 

after the sample has been filtered, and pass an IR beam through the disk to get a reading. The 

problem with this approach is the amount of residual water still present, and all of the particulate 

matter which would be present on the surface of the disk. 

 If the 7575 method were to be changed to make more like the original 418 IR method, 

which sent the IR beam through the solvent, than 1664 and 7575 might(?) be more equivalent. 

As a side note, many years ago the EPA was thinking about Method 1665 which was to be an IR 

method, that would complement method to 1664. 

 Based on the confusion i see reading the other comments, i suggest the EPA not approve 

this 7575 method. I also suggest that the EPA remain the driving force behind developing and 

proposing methods, and not allow the general public develop methods that are self serving. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. 

Comment 281 Anonymous: Pertaining to the proposed ASTM 7575 method, and that this 

method appears counter to every standard of excellence that the EPA tries to develop their 

methods to, I struggle to understand how and why the EPA would do such an about face, and 

even consider this method for approval. 

 This is further reinforced when you look at the recent change from 1664A to 1664B, 

wherein a co-eluting solvent was no permitted to be collected. The EPA was holding firm that 

only hexane should be collected in the vial with the final extract, and this EPA requirement 

caused considerable confusion and frustration in the lab community. 
44

Now it seems that the EPA is adopting an anything goes attitude, and willing to consider 

any method that randomly comes along. What happened to scientific integrity and holding firm 

when you know something is right? 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: "Oil and Grease” is a 

Method Defined Analyte. The “definition” of Oil and Grease by D7575 and 1664A are different 

as these definitions are dependent on the procedure and equipment used to make the 

determination. The Ed Askew report demonstrated results across certain matrix types were so 

different that the two methods were not “equivalent”. Currently the only definition suitable for 

compliance monitoring is HEM and SGT-HEM and introduction of a new definition (MEM) 

without a clear and complete regulatory plan for it would create confusion within the analytical 

community and would be a major uncontrollable distraction for the EPA in years to come. 

No Solvent Extraction/IR Vs. n-hexane Extraction/Gravimetry. D7575 does not employ a 

solvent to extract the oil and grease analytes from the water sample or from the infraredamenable membrane before determination by IR. 1664A uses n-hexane (85% minimum purity, 

99.0% minimum saturated C6 isomers, residue < 1mg/mL) to extract the oil and grease analytes 

from the water sample or in the case of a modified 1664A SPE method, from the SPE filter prior 

to gravimetric determination. The presence of a solvent is particularly important for grease 

containing samples as these are usually solid/semi-solids at room temperature and do not 

homogenize well – especially in 1L bottles which are typically filled to the top in order to meet 

current EPA sample volume requirements. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to request use 

of this method for a limited use through existing authorities in 136.5, EPA is providing a 

response. 

EPA acknowledges that ASM D7575 may not be the appropriate choice for certain matrices that 

do not homogenize well (see Note 2 in the method). 

Comment 297 Larry LaFluer, NCASI: The National Council for Air and Stream 

Improvement, Inc. (NCASI) is an independent, nonprofit membership organization that provides 

technical support to the forest products industry on environmental issues. An important part of our 

mission is to ensure that regulatory decision making is based on sound science. Therefore, 

NCASI is pleased to provide the following comments on EPA’s consideration of the possible 

approval of an alternative test procedure for oil and grease that was posed by the United States 

Environmental Protection Agency (EPA) on December 14, 2011 (Fed. Reg. Vol .76, No. 240, 

77742-77747).

1. Whether EPA should reconsider promulgating this additional method for oil and 

grease based on different extractants and determinative techniques than EPA Method 1 664A. 

We believe that EPA has correctly identified “oil and grease” as a method-defined parameter, the 
45

method being EPA Method 1 664A. We also agree that a method-defined parameter is correctly 

described as “the measurements obtained by the method are a specific artifact of the method and 

defined solely by the elements (solvent, determinative technique) used to measure the analyte.” 

Because the method EPA is considering adding to 40 CFR Part 136.3 (ASTM D7575-1 0) uses a 

proprietary membrane to isolate oil and grease, we cannot know how or if it will isolate the exact 

same materials that Method 1664A would isolate by n-hexane extraction. Thus, we cannot be 

assured that for any given matrix the methods would measure the same parameter. For this 

reason, we recommend that EPA not add ASTM D7575-10 as an alternative test procedure for 

oil and grease. 

2. EPA's current view, based on the data it has reviewed to date, that ASTM D7575-10 is 

an acceptable choice for the determination of oil and grease for the range (5 to 200 mg/L) 

evaluated. We recommend that EPA consider the requirements and protocols for demonstrating 

the acceptability of a method-defined parameter and that it publish those procedures in the Federal 

Register for comments just as it did for the alternative test procedures for specific target analyte 

methods.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. EPA is considering identifying protocols for demonstrating the acceptability of 

method defined parameters. 

Comment 303 Anonymous: We believe that EPA's current conclusion that permit limit 

adjustment based on side-by-side comparisons is not appropriate seems not to be a good position. 

The two methods will show strongly different values for oil and grease for certain types of oil, 

e.g. in the case of low boiling crude oils (condensates). Following EPAs current conclusion will 

lead to the situation that different values for one sample may be reported. There is the danger, 

that pollutors will choose the method with the lower oil and grease value for reporting. 

This cannot be of interest for the EPA. Therefore it seems more applicable to set the 

reference method as "golden standard" and establish a conversion factor by having the discharger 

perform a side-by-side comparison for a limited concentration range, a distinct sample stream 

(non-changing oil composition) and a distinct matrix. This concept was followed in Europe by 

setting gas chromatography as the reference method (ISO 9377-2 mod.) and providing a 

guideline on criteria for alternative method acceptance (published by the OSPAR commission, 

Ref. No. 2006-6).

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. 

 

Comment 304 Anonymous: If EPA were to allow a side-by-side comparison with limit 

adjustment as necessary, EPA should adapt the approach used for n-hexane in place of Freon. 

We believe that it is more appropriate to define a reference method and provide guidelines for 

determining a conversion factor to be used with alternative methods (e.g. as established by the 

OSPAR commission, Ref. No. 2006-6). Permitted alternative methods should fulfill the 

following requirements: - No underestimation. - Best available technology. - Suitability for all 

kinds of oils and matrixes. Alternative methods may have drawbacks (e.g. calibration) but should 

have advantages as speed and ease of use. 
46

 Method ASTM D7575-10 does not show the potential for replacing the reference method 

due to the loss of light ends (during the tedious drying procedure of the membrane) and the 

limited matrix properties, being a result of the membrane filtration principle. Samples with a 

high content of particles or organic material will block the membrane for spectroscopy; a prior 

removal of the particles would also remove the oil sticking on these particles. 

 Suitable references methods could be gas chromatography methods (e.g. ISO 9377-2) or 

EPA 1664A. Other methods such as ASTM D7575-10 should be acceptable as alternative

methods with a conversion factor subject to acceptance criteria issued by the EPA.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. 

Comment 307 William Telliard, Consultant: [EPA Note: The following is from the attachment 

to the comment. It contains comments from Joe Stefkovich (see comment 283) (JS) followed by 

response from William Telliard (WT response)]. 

[JS] Method D7575 and most other Oil and Grease methods being considered for 

inclusion in Table IB are all not suitable for compliance monitoring of the method- defined 

analyte Oil and Grease and as such are not required to be promulgated per the National Technology 

Transfer and Advancement Act. If Method D7575 was included in Table IB and the other 

equally not suitable methods were not, almost certain legal consequence would result from the 

other method developers due to the appearance of impropriety and inconsistent treatment of their 

methods by the EPA. 

 [WT response] Method D7575 has been proposed as an alternative to Method 1664A. 

The current Administration and EPA Administrator have asked for environmentally friendly 

methods to augment existing toxic methods. JS's expressed concern about legal consequences 

seems inane; he is not an attorney, nor does he have experience in the enforcement field.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. 

Comment 319 Patsy Root, IDEXX Laboratories: As stated in the NODA, oil and grease is a 

method-defined parameter. How will historical data using EPA 1664A be compared to data 

derived using D7575-10? The NODA does not clearly cover the statistical difference labs and 

data users will see when comparing methods. For example, how do the two methods compare 

statistically in variety and quantity of components detected, percent difference between the two 

methods. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. The notice also reminds permittees of existing authorities to request 

alternative methods for a specific use (Part 136.5). The notice additionally provides guidance 

on how to demonstrate comparability for such requests. 

B.12. Analysis cost 

Comment 258 Anonymous: The driver for identifying an alternative oil and grease method is 

the need to move away from hexane as an extraction solvent. A solvent-less method sounds 
47

ideal, however the ASTM D7575-10 method proposed has distinct disadvantages over the 

existing EPA1664. ASTM D7575-10 requires the use of an expensive technically advanced 

FTIR analyser, large scale labware, on-site sampling system and filter consumables (I do not 

have sufficient information on the filter manufacturing process, re-use or disposability to 

comment but these issues should be considered). ASTM D7575-10 also seems a step backwards 

from the current system in that it would be a difficult method for end users to implement on site 

(such as off shore platforms), thus prohibiting the fast analysis response times required to keep 

systems running as efficiently and environmentally sound as possible. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

As with any technology, environmental laboratories wishing to use this method may have an 

initial investment cost (FTIR analyzers have been available for other applications). With respect 

to the method being difficult to implement on site, the current method is also a laboratory 

method, not a field method. The FTIR technology can be adapted for field use. 

Comment 301 Don Shelly, Food and Environmental Technical Service: What is the cost of 

analyzing samples using ASTM D7575-10 vs. 1664? 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to request use 

of this method for a limited use through existing authorities in 136.5, EPA is providing a 

response. 

After the initial investment in equipment (FTIR), we estimate that the cost will be comparable or 

slightly lower. 

 

B.13. Handling waste

Comment 259 Anonymous: This is more of a general comparison question between the 

proposed ASTM 7575 method, and the current SPE 1664 method i use. 

 If I use the 7575 method, what am I expected to do with the left over sample? That is, I 

receive almost a liter of sample, but take only 10 mL out. Do I pour this down the drain? Do I 

consider it hazardous waste? I am not sure. 

 With 1664, I use the entire liquid sample, and as the sample has been filtered and is now 

much cleaner than when I started, this water is poured down the drain. I am left only with a dirty 

filter, which I dispose of properly, which I guess I would also do with the IR membrane. 

My concern and question is, am I generating more waste, which in turn will cost me 

money? 

 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 
48

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Although the ASTM method does not specifically address waste management, section 2.2 of the 

method does refer to EPA Method 1664. Please see the Waste Management section of EPA 

Method 1664 (15.0), which addresses how to dispose of waste from the method. In addition, 

ASTM has a method D4447, “Standard Guide for Disposal of Laboratory Chemical and 

Samples,” that addresses this issue more fully. 

Comment 319 Patsy Root, IDEXX Laboratories: Add guidance on disposal and hazardous 

waste designation of any remaining, unused sample

Response: See response to comment 259 and Section 1.5 of the method, where this issue is 

addressed. 

B.14. Method validation

Comment 223 Curt McCormick: The data found on the Internet indicate only one PubliclyOwned Treatment Works (POTW) wastewater (influent or effluent?) with a true oil and grease 

value of 10 mg/L was tested. Based upon this, EPA appears to be saying the Agency believes 

the method is equivalent to Method 1664. This assumption would appear to be unsupported 

based upon information found on the Internet from the company that developed the method: 

Oil and grease samples of POTW influent and effluent should be tested. These samples should 

include multiple oil and grease true concentrations in the 5 mg/L to 200 mg/L range. These 

sample should be sent to multiple independent wastewater laboratories. EPA seems to be 

indicating that based upon the data it reviewed (not provided in this Notice), this method is 

approved for use under the Clean Water Act. EPA needs to do a more thorough public notice of 

the data it reviewed (provide the data) to make a decision that this method is equivalent to 

Method 1664 for raw and final wastewaters approved under 40 CFR Part 136. 

Does EPA believe that this approach to method validation and the apparent lack of data on 

significant matrices (POTW influent wastewater, oil and grease from grease interceptors, etc) is 

appropriate to support approval of an alternate, enforceable method under the Clean Water Act?

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. 

Regarding the point on the validation studies conducted, the commenter seems to be confusing the 

validation study with the method comparability study. The method comparability study included 

seven POTWs. The second phase of the ASTM study was the multi-laboratory study in which one of 

the matrices used was a POTW. The purpose of these two studies is different. The multi-laboratory 

study is done to define expected performance for the method (e.g., recovery, precision). Both the 

comparability data and the validation data were provided in the NODA docket for review and 

comment. 
49

Comment 267 Anonymous: From information that appears on various web sites, it appears that 

the evaluation of method 7575 was validated by the developers direct personnel, setting up the 

same equipment at various labs, and most likely running the samples. This means that the 7575 

method does not meet the standard requirements for ASTM or the EPA Multi-Lab, Multi-Matrix 

study requirements.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The developers have stated that they provided equipment to the laboratories, trained the 

personnel prior to the validation study tests, and that the tests were conducted solely by 

laboratory personnel after the training session. Because this is a new technology, this is not an 

unreasonable process when introducing it to a laboratory.

 

Comment 280 Anonymous: It was mentioned in an earlier comment, and I agree, that the EPA 

should be very careful about approving the ASTM 7575 method, as there would most likely be 

lawsuits filed by those vested parties who have worked so hard to assist with the development of 

1664. If the 7575 method were truly revolutionary and followed the guidelines established for 

other EPA methods, lawsuits would be less of an issue. 

 But on close examination of 7575, there are too many inconsistencies, the data is suspect, 

smaller aliquots are taken from a larger container, contact mixing is suggested, a detection 

technique which has problems with water and particulate material, air dry times which are 

random, and it appears that a technical representative from OSS was present at each site which 

evaluated this approach, smacks of impropriety by those people who are promoting this method. 

 The EPA could have a large and expensive lawsuit on its hand, if the EPA continues to 

consider this 7575 method. 

Response: See response to comment 283. 

Regarding the general list of issues specific to D7575, please see the following sections wherein 

similar comments have been addressed. Regarding the comment on “too many inconsistencies” 

more detail is needed. Regarding problems with water and particulate material, and air dry 

times, see responses in Section B.3, sampling requirements and preparation. Regarding the 

comment on the presence of an OSS technical representative, see Section B.14 method 

validation. 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Thank you for the 

opportunity to review ASTM Method D7575 and related information for purposes of comparing 

it to EPA Method 1664A and rendering an independent opinion regarding possible inclusion of 

D7575 in the upcoming MUR, Table IB. 

At this time we would strongly advise EPA to not include ASTM Method D7575 in the 

upcoming MUR, Table IB. Based on our review of the method, the Ed Askew report/rebuttal, 

comments from the various EPA Regions and other information: 
50

There appear to be serious technical issues or concerns with the method and submitted 

validation study so a successful EPA Tier III Multi-Lab, Multi-Matrix Validation study to 

address these issues should be performed prior to inclusion in Table IB as we believe it would be 

better for the EPA to push forward a known good method rather than pull back on a known bad 

one in the future. 

 While a solvent-free Oil and Grease method is certainly appealing, it is highly unlikely 

that EPA or anyone else can say with certainty at this time that Method D7575 is acceptable for 

use and what could or should be done with a potentially new regulatory definition for Oil and 

Grease. As Oil and Grease is the 2nd most enforced against parameter (pH is 1st), we would 

strongly advise EPA to not include Method D7575 in the upcoming MUR, Table IB until the 

method is proven reliable with a new EPA Tier III study and EPA has a clear directive to replace 

the current Oil and Grease regulatory definition of HEM and SGT-HEM with MEM. As I’m 

sure you can appreciate, once EPA enables additional confusion on D7575, it will be like 

opening Pandora’s Box with the net result being much self-inflicted pain, distraction and 

embarrassment on the part of the EPA. 

Incomplete ASTM and EPA Multi-Lab, Multi-Matrix Study Requirements. EPA 1664A 

was validated by independent work of at least 9 laboratories analyzing at least 9 different matrix 

types with at least 3 sets of Youden pairs per matrix. D7575 was validated by the dependent

work of method developer personnel setting up the same equipment at 12 local laboratories and 

who were probably present when the study tests were performed. In addition only 3 matrix types 

were tested with only 1 set of Youden pairs per matrix. The D7575 validation study did not meet 

the standard requirements for ASTM or EPA Multi-Lab, Multi-Matrix study requirements and 

could really be considered an EPA Tier I study performed by 12 analysts. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Under the National Technology Transfer and Advancement Act (NTTAA), EPA is required to 

consider methods validated by consensus standard organization, e.g., ASTM, which have 

validation requirements that are different from EPA's ATP requirements. EPA asked for and 

received the underlying data from the validation studies conducted by ASTM and provided it for 

public review and comment. Consensus standard organizations are not required to follow the 

same procedures as EPA and may choose not to conduct an EPA Tier III Multi-Lab, MultiMatrix Validation study. EPA does not favor one approach over the other with respect to 

validation. That is, a vendor or method developer is free to go through EPA’s process or may 

choose to go through a voluntary consensus organization process. The key is that they must 

choose only one approach. Neither process guarantees that EPA will approve the proposed 

method. With regard to the point on incomplete multi-lab, multi-matrix study requirements, 

ASTM has confirmed that ASTM guidelines for method validation were followed. The assertion 

that the developer personnel were present during the study tests has been denied by the method 

developer. The method developer acknowledged that equipment and training was provided to the 

participating laboratories prior to when the study data was collected. However, this is not 

unusual when new technology is introduced that is not standard for environmental analyses.
51

Comment 301 Don Shelly, Food and Environmental Technical Service. Comments 

regarding Proposed Rule for ASTM D7575-10 (Oil & Grease) EPA-HQ-2010-0192. 

 It is my opinion that many concerns remain unaddressed. 

 Were the standards used in comparison studies between methods 1664 and ASTM 

D7575-10 certified and independent? 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

The standards were prepared as described in the methods. Neither method states that the 

standards must be certified and independent, but rather they give specifications on purity and 

preparation. In addition, standards are not required to be certified or independent in validation 

studies. Only for certification/accreditation purposes may independent standards be required. 

Comment 307 William Telliard, Consultant: As a member of the D19 Committee of ASTM, I 

strongly support and recommend its new ASTM Method D7575. 

As the author of record for EPA Method 1664 and 1 664A, I feel it is my responsibility to 

submit some clarifying comments on a document submitted to the docket by Mr. Joseph Stefkovich 

(JS) to Lemuel Walker, EPA Office of Water: Office of Science and Technology. For your 

convenience, JS's letter and review (with my clarifying notes) are included at the end of this 

comment. My comments and opinion are the result of over thirty-four years of experience at the 

Agency. While at EPA, I served in the Office of Water, the Permits Division, Office of Water 

Enforcement, and the Office of Science and Technology. Approximately a hundred analytical 

methods were developed and promulgated under my direction. Numerous industrial guidelines 

and regulations for the energy and mining industries were also developed under my aegis. 

The author, JS, asserts that he is providing an independent opinion on D7575. A difficult 

notion to support since he is employed by a direct, industrial competitor of this new green 

technology. JS and others were also supplied information on comments from the EPA Regions 

(as noted in his attached letter) and from other Agency "inside information." This information 

was not made available to ASTM D19 or the developer of the method (OSS, Inc.), nor included 

in any correspondence with ASTM. To my recollection, inter-Agency correspondence and work 

products are to be kept confidential or within the Agency's purview. I question why this data 

was circulated to outside entities. Based on the this, can his review be considered 

"independent"? Also, I question his experience to express an opinion on permit, legal, and 

enforcement issues.

[EPA Note: The following is from the attachment to the comment. It contains comments from 

Joe Stefkovich (see comment 283) [JS] followed by the response from William Telliard [WT 

response]] 

 [JS]: Thank you for the opportunity to review ASTM Method D7575 and related 

information for purposes of comparing it to EPA Method 1 664A and rendering an independent 

opinion regarding possible inclusion of D7575 in the upcoming MUR, Table IB. 

At this time we would strongly advise EPA to not include ASTM Method D7575 in the 

upcoming MUR, Table IB. Based on our review of the method, the Ed Askew report/rebuttal, 

comments from the various EPA Regions and other information: 
52

There appear to be serious technical issues or concerns with the method and 

submitted validation study so a successful EPA Tier III Multi-Lab, Multi-Matrix Validation study 

to address these issues should be performed prior to inclusion in Table IB as we believe it would 

be better for the EPA to push forward a known good method rather than pull back on a known 

bad one in the future. 

 [WT response]: ASTM has already exceeded the requirements of a Tier III Multi-Lab 

study. See the information below which is a NODA -updated version of the same chart provided 

in a previously submitted EPA docket document found here:

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010- 0192-0218 see slide 

12.

[JS] Attached with this report is a product data sheet the D7575 method developer has 

been distributing for the past 12 months which strongly implies the D7575 method/product 

is suitable for NPDES regulatory compliance testing and is a replacement for EPA 1664. 

While this implication is not true, inclusion in Table IB would make it “more believable” and as 

such, EPA would directly enable increased confusion regarding D7575 and as a result will have 

to deal with an unnecessary major distraction out of their control for years to come. 

 While a solvent-free Oil and Grease method is certainly appealing, it is highly unlikely 

that EPA or anyone else can say with certainty at this time that Method D7575 is acceptable 

for use and what could or should be done with a potentially new regulatory definition for Oil and 

Grease. As Oil and Grease is the 2nd most enforced against parameter (pH is 1st), we would 

strongly advise EPA to not include Method D7575 in the upcoming MUR, Table IB until the 

method is proven reliable with a new EPA Tier III study and EPA has a clear directive to replace 

the current Oil and Grease regulatory definition of HEM and SGT-HEM with MEM. As I’m sure 

you can appreciate, once EPA enables additional confusion on D7575, it will be like opening 

Pandora’s Box with the net result being much self-inflicted pain, distraction and 

embarrassment on the part of the EPA.

 [WT response] Note: A data sheet for D7575 was not attached to this report. D7575 has 

not been proposed as a REPLACEMENT FOR D1664A, BUT AS AN ALTERNATIVE. 

Thus, competitors could continue to market their outdated products. The method makes 

absolutely no change in the definition of oil and grease, as JS infers. The author apparently 
53

believes that the laboratory industry and the regulatory community are incompetent when 

dealing with a table in a Federal Register notice. (They do read and write.) I believe his final, 

closing sentence of this letter expresses his opinion of the US technical community.

Response: EPA agrees with this commenter that EPA’s consideration of D7575 was as an 

alternative to Method 1664A and not a replacement.

Comment 314 Scott C Hoatson, Oregon Department of Environmental Quality: I think I 

would like to see more side by side data in more matrices before this method is added to the 

MUR. Most samples were quite comparable but there were some that were different by a fair 

amount. If there is a potential for a bias in certain matrices, we would have a concern regarding a 

carte blanche acceptance of the method.

Additionally, though I have not scrutinized all of the supporting validation information, I 

reviewed some of the raw data in the attached file that was part of the supporting documentation 

and have some concerns. If this is an example of the supporting documentation, I cannot 

support adding the method to the MUR at this time.

There are several of the MDL studies where a point was dropped for no apparent reason 

(It was not a statistical outlier); MDLs would be higher if the values were included. There are a 

lot of hand corrections in the raw data without explanation and the corrected values are the ones 

used in the spreadsheet (see notebook pages – though it is not that unusual but it is obviously 

frowned upon practice). There are sample analyses that were rerun again after additional 

drying (sample numbers do not correlate with sample numbers on spreadsheet but raw values 

do). I suspect that these issues are likely innocent, but I don’t think it should be used to support 

any decision unless it is corrected.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response 

that may be relevant to such considerations. 

EPA agrees with the commenter with respect to the potential bias in certain matrices. 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: A commenter suggested that 

ASTM D7575 did not meet EPA Tier III guidance for nationwide approval. Response: Prior to 

the NODA study, ASTM D7575 had already exceeded the guidance of an EPA Tier III MultiLab study for nationwide approval of a method. The informational chart below presents and 

even stronger case. It is a NODA-updated version of the same chart provided in a previously 

submitted EPA docket document found here: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-0218 see slide 12. 

EPA personnel were involved in all study plans.
54

Some commenters have asked about equivalence of ASTM D7575 and EPA 

Method 1664. Response: Statistical equivalence has been documented, see: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-0163 and 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-0202 

Commenters have suggested that the development of ASTM D7575 did not include 

independent autonomous testing. Response: Not true. See the scans of the laboratory 

notebooks from the 12 different operators from 12 different certified laboratories that 

participated in the ASTM D7575 multilab study and autonomously performed the testing 

here: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OW-2010-0192-0201 

Response: See response to comment 283.

Comment 319 Patsy Root, IDEXX Laboratories: Data Collection Process: It is 

disconcerting that the generation and review of data was performed by OSS personnel. 

Documents in this docket indicate that the same OSS personnel and consultant (retired EPA 

official) set up the same equipment at each site and were at least present at each site, and prescreening samples. This does not give the appearance of being the type of ‘hands-off’ testing 

typically required by EPA. For example, in a typical ATP, the laboratory personnel 

themselves actually perform the testing, although training prior to testing is acceptable. 

Would EPA please comment on why, in this case, OSS personnel were allowed to participate 

in the testing process?

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 
55

EPA disagrees. See response to comment 267. The comparability and validation data were 

collected by independent laboratories and not by OSS. ASTM and EPA staff independently 

reviewed the data. 

Comment 322 Joe Stefkovich: As a follow up to my February 10 note, I was disappointed to 

learn that there is no raw data in either the MUR or NODA dockets for any of the D7575 multilab validation reports. I was and have been under the impression that for a new method to be 

considered for compliance monitoring, all aspects of it must first be vetted via public disclosure.

In the proposed MUR docket, I could not find any raw data to tie back to the summary 

data and see if the method really does “work as advertised.” This observation however is not 

that surprising as the original EPA position was to not propose the method for the MUR so it 

was probably thought by the EPA that this data probably wasn’t necessary since the method 

wasn’t being proposed in the MUR.

However, now that the method is being considered, the public review of raw data is 

now more important than ever. Unfortunately it seems that the cart is before the horse 

when it comes to D7575 as the public is being asked to comment on how the method 

could be employed without establishing the method works “as advertised” and is worth 

employing in the first place.

At a minimum I would suggest the EPA might want to consider issuing a new 

NODA containing all the D7575 raw data and other pertinent information before taking 

action on D7575 as due to the apparent “special treatment” this method has received, 

there is a growing negative perception within the industry regarding EPA and this 

D7575 method. Thanks.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA provided all the data ASTM submitted on method performance in the NODA docket, 

whether from the comparability study or from the validation studies for vetting and public 

disclosure. Contrary to this commenter’s assertion, EPA included raw data for the studies 

conducted for this ASTM method. In fact, EPA has gone beyond what is normally requested 

for methods from voluntary consensus standard bodies (VCSBs) when submitting adopted 

methods for consideration. Methods and the underlying data from VCSBs are peer-reviewed 

and adopted by these organizations based on their peer-review policies. EPA reviews these 

methods to ensure that such methods meet EPA’s needs and places the submitted information 

in the docket for public review and comment prior to making a final determination. We 

typically do not request or review the raw data from such organizations. Such a blanket 

request would be a change in practice and may be considered in the future but is not a 

requirement. In this and prior regulatory actions, all methods are indeed vetted through the 

public notice and comment.
56

Therefore, contrary to this commenter’s assertion, the data available on D7575 is more 

extensive than typical and has been properly provided to the public for consideration. Also 

see response to comment 283.

B.15 Unfunded mandate 

Comment 277 Anonymous: Heads up to EPA. 

 In the early days of developing Method 1664, one of the problems the EPA ran into was 

that the EPA had not conducted an Unfunded Mandate Study to understand the potential 

financial impact to the EPA, if certain sectors of the oil and grease permit holders were to put out 

of compliance by using this method. If these people were to file a lawsuit against the EPA, where 

would the money come from. As no study had been done, the method development group 

decided to fore go the study and released the method a LLE procedure, with the ability to use 

SPE as an alternative extraction technique. 

 I do not see any indication that such a financial impact study has been done for 7575. 

Therefore, the EPA could find itself with a lawsuit from the current method developers who are 

being unfairly treated, as the 7575 developers are being given preferential treatment. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. 

The commenter misunderstands the unfunded mandate Reform Act. Title II of the Unfunded 

Mandates Reform Act of 1995 (UMRA), 2 U.S.C. 1531-1538, requires federal agencies, unless 

otherwise prohibited by law, to assess the effects of their regulatory actions on State, local, and 

tribal governments and the private sector. In particular, UMRA focuses on rules that contain a 

federal mandate that may result in expenditures of $100 million or more for State, local, and 

tribal governments, in the aggregate, or the private sector in any one year. If EPA had adopted 

ASTM D-7575, it would not have required the use of this method. Rather, rather it would have 

added this method to the list of approved methods for oil and grease. Thus, the unfunded 

mandate requirements do not apply. 

B.16 Method version (ASTM versions and EPA Method 1664 versions) 

Comment 237 Department of Defense: Current Version of ASTM D7575 is not correct.

 Proposed Requirement/ Section Addressed: 76 FR 240, A.1, Proposes to allow ASTM 

D7575-10. 

Comment: ASTM D7575-10 is not the current active version of this method. The method 

was revised and reissued on 1 November 2011 as ASTM D7575-11. 

Discussion: When ASTM updates a method, the older versions are no longer active. 

 Recommendation: Recommend allowing the use of ASTM D7575-11 instead of ASTM 

D7575-10. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method 

for nationwide use. Permittees should continue to use an oil and grease method promulgated 

in Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to 
57

request use of this method for a limited use through existing authorities in 136.5, EPA is 

providing a response.

The two versions are nearly identical. D7575-11 contains some editorial clarifications that EPA 

requested. 

Comment 271 Debra Waller, NJDEP: Should EPS reconsider promulgating this additional 

method for oil and grease based on different extractants and determinative techniques than EPA 

1664A? Comment: The US EPA is withdrawing Method 1664A from 40CFR Part 136.3 and 

replacing Revision A with Revision B. Everything I read about the method refers to its 

comparability to Revision A and not Revision B. If the EPA is removing Revision A from the 

40CFR why are there references to Revision A in the docket?

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in 

Part 136 for CWA compliance. Because EPA recognizes that permittees may wish to request 

use of this method for a limited use through existing authorities in 136.5, EPA is providing a 

response. 

EPA added version B of Method 1664 in the recent Methods Update Rule. EPA did not remove 

Method 1664 version A. The documents in the docket refer to documents that ASTM followed in 

their approach when they compared their method to EPA Method 1664 version A. 

Comment 274 Anonymous: ASTM method D7575-10 is not the current method sold by ASTM. 

D7575-10 is listed as an historical method and D7575-11 is the current method. (1) what is the 

difference between the two technically that required an ASTM re-balloting and (2) can EPA 

promulgate an historical method?

Response: See response to comment 237. Note that both versions are in the record and were 

available for public review and comment. 

Comment 299 Ed Askew: 1. The comments on the Notice of Data Availability (NODA) will 

not focus on original method submitted to the EPA for the current Method Update Rule (MUR) 

which was ASTM D7575-10, but instead will focus on how the NODA concerns:

a. A final ASTM method that is not the same as the original ASTM method 

submitted for inclusion into the MUR.

b. That the method listed in the NODA is not the final method to be considered 

by EPA.

c. That EPA staff was aware that the current ASTM D7575-11 has significant 

changes from the original ASTM method in the NODA.

2. From the NODA, Federal Register /Vol. 76, No. 240 /Wednesday, December 14, 2011:

a. Based on the new information and EPA's analysis of this information as described 

in this Notice, EPA is reconsidering whether to promulgate ASTM D75 75-10 in 

40 CFR Part 136 as an alternative method for oil and grease.

3. The docket contains information on a meeting (August 3, 2011) with EPA, Orono 

Spectral Solutions (OSS) staff and other interested 3rd parties that indicate that EPA staff 

required major method procedural changes before the ASTM method D7575-10 would 

pass muster as an acceptable regulatory analytical method.
58

a. Summary: Attendees discussed the analysis of additional matrices to compare 

Methods 1 664B and ASTM 07575. ASTM agreed to prepare a study plan for EPA 

review prior to testing additional matrices. In addition, EPA discussed the need for 

some changes to the ASTM method, as follows: 

4. By ASTM rules whenever a method is technically modified it must be balloted within the 

consensus organization as a new method, not a modification of the older method. Thus, 

the current ASTM method which contains the new validation data, procedural changes 

and Quality Control IS NOT D7575-10, but D7575-1 1. The changes to D7575 were not 

editorial in nature, but significant (See c below)

(As per ASTM rules http://www.astm.org/COMMIT/Regs.pdf ) 

a. Reapproval of Standards—If approved by a motion passed by the subcommittee, 

or by authorization of the subcommittee chairman, reapprovals shall be issued to 

main committee ballot and Society Review

b. Revisions to Standards—Revisions can be proposed at any time and shall be 

considered by the responsible subcommittee.

c. Editorial Changes—Editorial changes may be made at any time without a 

requirement for ballot. Editorial changes are of two types: (1) those which 

introduce no change in technical content, but correct typographical errors, 

modify editorial style, change non-technical information, or reduce ambiguity, 

and (2) those which correct typographical errors in substance (essential 

information that could be misused). In the latter case, the year designation of the 

standard is changed.

5. EPA in communication with me confirmed that the method D7575-10 did have method 

procedural changes (See attached email from Dr. Michael Shapiro).

a. In addition to submitting additional data, ASTM also agreed to revise some of the 

language in the method to clarify the scope and applicability and to add 

additional information to the sample pretreatment section. ASTM adopted these 

revisions in November 2011.

So, the following can be said about the ASTM D7575 and the EPA NODA:

> The ASTM method being considered for inclusion into the MUR is the ASTM 

method that contains all of the additional EPA requirements which is D7575-11, not 

D7575-10.

> The EPA has not clearly identified the ASTM approved method that contains all of their 

required changes in the NODA.

> ASTM did not edit D7575-10 method and reissue it as D7575-10, as the changes to the 

method were not editorial in nature. But instead these changes met the requirements for a 

new ASTM consensus ballot and reissuance of the method with a new date, ASTM 

D7575-11.

> Therefore, the NODA is flawed as it seeks approval an older outdated ASTM method, 

D7575-10, instead of the ASTM method that EPA wants D 7575-11. Therefore, the EPA 

has not provided accurate and correct information in the NODA and it does not meet the 

requirements of federal public notice as it did not provide accurate and clear information so the 

public can comment.

> Therefore, the NODA should be withdrawn. An IG investigation may be need to 

identify EPA staff that drafted the inaccuracies in the NODA and any other 3rd parties 

that would profit from it.
59

[EPA Note: The letter to Mike Shapiro attachment is not shown here.] 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA consulted ASTM with respect to the requested changes/clarifications and ASTM 

indicated (and EPA agrees) that the changes are editorial in nature, serve to provide 

clarification, and do not affect method performance. A copy of both versions of the method 

was placed in the NODA docket for comment and page 77745 discussed the changes 

requested by EPA and incorporated in the revised version of the method. The -10 versus -11 

indicates that there are differences (editorial) between the two versions. It would be confusing to 

make any changes (e.g., clarification on scope and applicability) and keep the same method 

identifying number. The Mike Shapiro letter does not imply that there were procedural changes, 

but merely that additional procedural details were added (as per the SOP that validation 

participating laboratories followed). In addition, it is not uncommon for editorial changes to be 

made to methods between the proposal and final approval ruling. Also see response to comment 

319. 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Commenters have discussed 

that the current version ASTM D7575-11 be the one considered. a. Response: We agree. 

Explanation of the confusion: During the recent NODA study, EPA has provided some 

(non-technical) language changes to ASTM D7575-10. These changes were constructive 

and added some clarification to the method. The changes were voted on and accepted by 

ASTM and resulted in an updated version ASTM D7575- 11.

Response: EPA agrees the version of ASTM D-7575 it ultimately considered for 

promulgation in Part 136 was ASTM D7575-11.

Comment 319 Patsy Root, IDEXX Laboratories: B. NODA-specific comments: 1. This notice 

of data availability is for an historical ASTM method, D7575-10. ASTM lists the valid version as: 

D7575-11. Could EPA explain which method it intends to promulgate? 

Response: EPA discussed both methods. In the NODA, EPA specified what changes were 

made to D7575-10 in response to EPA comments. The revised version (D7575-11) was 

added to the NODA docket to give the public the opportunity to comment on the method and 

the changes. ASTM D7575-11 is the current version of the method. 

B.17 Green chemistry

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: The driving force 

regarding the 1.1 million liters in n-hexane savings/green chemistry is probably overstated by a 

factor of 10-20 times based on the method developer’s assumptions regarding the number of 

EPA 1664A tests performed per year. 
60

Response: For the reasons explained in the notice, EPA did not promulgate ASTM D7575 in 

Part 136 for nationwide use. Also, EPA notes that this commenter did not provide any data to 

support its statement.

Comment 307 William Telliard, Consultant: [EPA Note: The following is from the attachment 

to the comment. It contains comments from Joe Stefkovich (see comment 283) (JS) followed by 

response from William Telliard (WT response)]

[JS] The driving force regarding the 1.1 million liters in n-hexane savings/green 

chemistry is probably overstated by a factor of 10-20 times based on the method developer’s 

assumptions regarding the number of EPA 1 664A tests performed per year. 

 [WT response]: The volume of hexane saved is based on state-by-state evaluation of 

permits, both for direct- and indirect- discharges. A significant number of analyses are required in 

the pretreatment program. Perhaps JS is not familiar with the permitting process.

Response: See response to 283. 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Some commenters discuss 

the green aspects of ASTM D7575 as compared the EPA Method 1664 which uses the 

neurotoxin n-Hexane (a regulated-against chemical in the Clean Water and Clean Air Acts). 

Response: Here is a table that demonstrates the green aspects of ASTM D7575 versus the 

principles of green chemistry – this chart was developed in conjunction with USEPA Office of 

Green Chemistry personnel:

 

Here is a report that was submitted previously to the docket that provides great detail on the 

health and occupational hazards of Hexane used in EPA Method 1664. See the report and 
61

comment here: http://www.regulations.gov/#!documentDetail;D=EPA-HQOW-2010-0192-

0148 

Response: EPA agrees with the green aspects of the method.

B.18 National Technology Transfer and Advancement Act (NTTAA)

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Method D7575 and most 

other Oil and Grease methods being considered for inclusion in Table IB are all not suitable for 

compliance monitoring of the method-defined analyte Oil and Grease and as such are not 

required to be promulgated per the National Technology Transfer and Advancement Act. If 

Method D7575 was included in Table IB and the other equally not suitable methods were not, 

almost certain legal consequence would result from the other method developers due to the 

appearance of impropriety and inconsistent treatment of their methods by the EPA. 

Response: For the reasons explained in the notice, EPA has decided not to adopt ASTM D-7575 

in Part 136 for nationwide use. 

EPA agrees that it is not required to approve methods adopted by voluntary consensus standard 

organizations under NTTAA in Part 136. Rather, Section 12(d) of the National Technology 

Transfer and Advancement Act (NTTAA) of 1995, (Public Law 104-113; 15 U.S.C. 272 note) 

directs EPA to use voluntary consensus standards in its regulatory activities unless to do so 

would be inconsistent with applicable law or is otherwise impractical. ASTM requested that EPA 

consider their D7575 method for promulgation and in accordance with NTTAA, EPA did so. Just 

as it did for other oil and grease methods in its proposed MUR. EPA re-considered ASTM D7575 because commenters including ASTM asked us to do so and submitted additional data to 

support their request. EPA did not receive such requests and additional data for the other oil and 

grease methods that it discussed but did not propose in the 2010 proposed MUR. As such, EPA’s 

handling of this method was lawful. 

 

B.19 Accuracy of vendor information 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Attached with this report 

is a product data sheet the D7575 method developer has been distributing for the past 12 months 

which strongly implies the D7575 method/product is suitable for NPDES regulatory compliance 

testing and is a replacement for EPA 1664. While this implication is not true, inclusion in Table 

IB would make it “more believable” and as such, EPA would directly enable increased confusion 

regarding D7575 and as a result will have to deal with an unnecessary major distraction out of 

their control for years to come. 

Response: EPA is not responsible for the accuracy of vendor materials. 

B.20 Number of oil and grease analyses per year 

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Developer Assumption 

of 5.9 Million Oil and Grease Analyses per Year. There are approximately 20,000 NPDES Oil 
62

and Grease permits so some simple math would indicate that each NPDES permittee (including 

shopping center parking lots) would need to have their discharge points tested 295 times per year 

on average (5,900,000/20,000=295). Clearly this could not be the case as the typical testing 

frequency for most major dischargers is approximately once per month. Further analysis 

indicates the following approximate assumptions:

 2,500 x 12/yr = 30,000 NPDES Major Discharger Tests per Year

 7,500 x 4/yr = 30,000 NPDES Minor Discharger Tests per Year 

 10,000 x 1/yr = 10,000 NPDES Minor (Parking Lots, Schools, etc) 

20,000 x 3.5/yr= 70,000 NPDES Major and Minor Tests per Year 

It is obvious that there is a huge gap between the 70,000 Oil and Grease tests easily 

verifiable as being required for NPDES and the developer assumption of 5,900,000 tests as being 

performed per year for the same NPDES permit base. Considering Conoco Phillips, the main 

producer of the 85% minimum purity n-hexane originally specified in the method notified the 

EPA in 2004 that they were discontinuing this grade of n-hexane, the true testing volume (and 

subsequent hexane savings of 1.1 Million Liters per Year) is most likely overstated by a factor of 

10-20 times. This value would also most likely include all of the “unregulated” testing as well 

which was omitted in the Developer’s original “conservative” estimate. A much clearer picture 

of the true n-hexane requirements for EPA 1664A should be developed by EPA before proposing 

D7575 as this could present an extreme amount of risk to the EPA without the promised reward 

based on clearly questionable assumptions. 

Response: EPA did not propose to withdraw Method 1664 and replace it with ASTM D7575. If 

EPA chose to approve the ASTM method, it would be to provide another choice of method. 

Further, including permits and control mechanisms for discharges to POTWs, EPA estimates that 

hundreds of thousands of permits include oil and grease limits and/or measurement requirements. 

EPA does not know the exact number and the exact number is not determinative. Solventless 

methods do reduce the use of n-hexane.

B.21 NPDES permit limit adjustment

Comment 297 Larry LaFluer, NCASI: In addition, as discussed below in our comments on 

EPA’s question 3, the whole concept of the potential need for a permit limit adjustment factor 

supports the conclusion that the two methods are, indeed, not comparable and do not 

produce equivalent results. Thus the ASTM method should not be promulgated as an 

alternative test procedure for oil and grease . 

EPA's current conclusion that permit limit adjustment based on side-by-side 

comparisons of EPA Method 1664A and ASTM D75 75-10 is not appropriate. EPA is 

particularly interested in obtaining comments from permitting authorities on this issue and 

estimates of the burden associated with reviewing such requests.

We believe that the fact that the methods produce sufficiently different results to 

warrant an adjustment factor is essentially evidence that the methods are not equivalent. 

Furthermore, without knowing the specifics of why the methods produce different results, 

one could not determine how representative a single evaluation of the adjustment factor 

would be over the long term. If the differences in results produced by the two methods were 
63

attributable to a specific substance, one would have to know the variability in the level of that 

substance to know how to establish an appropriate adjustment factor. Alternatively, the 

evaluation of the adjustment factor could be performed multiple times, but we believe that the 

level of effort needed to develop the required insight and review those data would not be a 

productive use of resources.

NCASI has not examined the side-by-side comparison procedure in detail and therefore 

offers no comments on EPA’s question number 4.

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA notes that Part 136.5 does not allow for use of an adjustment factor for alternative 

methods. 

B.22 Replacement of EPA Method 1664 with ASTM D7575 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7579: Some commenters seem to be 

confused in thinking that ASTM D7575 would replace EPA Method 1664. Response: ASTM 

D7575 has been proposed as a green alternative to EPA Method 1664.

Comments have suggested that promulgating D7575 will create confusion for permit 

holders and auditors since it will replace EPA Method 1664. Response: As pointed out in the 

NODA, the promulgation of D7575 will not replace 1664, but rather will provide an alternative 

method which may offer benefits to certain permit holders (for example, eliminating your 

exposure to n-hexane, which is required for 1664 and has been shown to cause neurological 

disorders when regularly inhaled (http://www.regulations.gov/#!documentDetail;D=EPA-HQOW-2010-0192-0148). The intent is not to force end users into one method over the other, but is 

instead attempting to provide additional flexibility to permit holders in analyzing for oil and 

grease.

Response: EPA is in agreement with these responses. EPA agrees that its consideration of 

ASTM D7575 was as an alternative to existing promulgated methods and not a replacement. 

B.23 Method portability 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Commenters have suggested that 

ASTM D7575 technology is not field-portable. Response: Not true. ASTM D7575 has been 

designed specifically for and has demonstrated its field portability on several occasions – most 

importantly during the Gulf of Mexico Deep Water Horizon Disaster. Please refer to slides 43, 

and 73 through 79 of the docket file here:

http://www.regulations.gov/#!documentDetail;D=EPA-HQOW-2010-0192-0218 

Response: EPA agrees with the commenter that the method is portable.
64

B.24 Time required to perform test

Comment 301 Don Shelly, Food and Environmental Technical Service: Observations of 

Concern. 1. The ASTM method extractor can only handle one channel at a time in the event of 

heavy particulate loading 

2. Compared to 1664, the ASTM looks like it is very time consuming 

a. 20 + minutes for homogenization 

b. Time to manually load the extractor 

c. Up to 2 hours to dry membrane 

The ASTM method realistically will require several hours per sample. 1664 can easily 

extract 24 samples in 1.5 hours (using the SPE option) 

Response: It is unclear what the significance of these comments is. EPA disagrees with the 

concerns about the time required to perform this test. See method video at 

http://ossmaine.com/commercial.php. 

B.25 Use of chromatography in ASTM D7575 method 

Comment 301 Don Shelly, Food and Environmental Technical Service: Chromatography 

requires manual integrations. 

 The ASTM method requires the skills of an experiences chromatographer. 1664 only 

requires a trained technician

Response: The ASTM method does not use chromatography. 

B.26 The blank must be lower than the MDL of 1.0 mg/L

 

Comment 290 Anonymous: The fact that the blank must be lower than the MDL of 1.0 mg/L as 

stated in section 12.7.1 means that many more samples will have levels reported to my customers 

which are not normally (the current method's blank is 5 mg/L). This will cause a general 

confusion among the public who receives these test results which will not be favorable. The 

public has proven throughout the years to react negatively to changes such as these. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Vendor methods may be more restrictive than EPA methods, such as in this case. The complete 

sentence in the ASTM method is "The concentration of oil and grease found in the blank must be 

below the MDL determined in Section 12.4 [i.e., 1.0 mg/L] or less than 10% of the known 

concentration of the associated test samples.” Thus the blank level can be higher than 1.0 mg/L. 

 

 
65

C. Other comments

C.1. Using the same side-by-side comparisons when switching from Freon to N-hexane for 

N-hexane to infrared analysis 

Comment 315 Camille Turcotte, Wisconsin Department of Natural Resources: Issue 4. Yes 

same as n-hexane because it is a defined process. 

[EPA Note: This comment is in reference to the 4 NODA request for comment issues. 

For issue 4, the commenter recommends the same approach to side by side comparisons 

as used when switching from Freon to n-hexane.] 

Response: EPA thanks the commenter for her comment.

C.2. Document availability

Comment 223 Curt McCormick: Provide a link on EPA's website to the method and allow for 

download of the method at no cost for review before approving.

Provide a link to all of the data referenced in the Federal Register notice (see end of FR 

notice).

Response: EPA cannot post methods on its website from voluntary consensus organizationssuch 

as ASTM on its website, as these are proprietary. The method was available for viewing at EPA’s 

docket office. The data referenced in the Federal Register notice were available in the rulemaking 

docket as supporting documents are available for viewing there. 

Comment 276 Magdi Ibrahim, North Carolina Department of Environment and Natural 

Resources (NCDENR): Please, provide a link to the method for download and all of the data 

referenced in the Federal Register notice.

Response: The docket contains all of the referenced documents. See response to comment 223. 

Comment 318 ASTM D19 SUBCOMMITTEE ON D7575: Commenters have asked for 

links to the method and for supporting documents. Response: The ASTM D7575 method 

can be found here: http://www.astm.org/Standards/D7575.htm and the supporting materials 

that were placed in the docket 12/14/2011 can be found in the docket here: 

http://www.regulations.gov/#!docketDetail;dct=SR;rpp=50;so=DESC;sb=docId;po=0;D=E

PA-HQ-OW-2010-0192 by looking at docket ID items 196 through 220. Other previously 

provided supporting materials may be found here: 

http://www.regulations.gov/#!docketDetail;dct=SR;rpp=50;so=DESC;sb=docId;po=0;D=E

PA-HQ-OW-2010-0192 in docket ID items 41,55,128,135-148,159,163, and 170.

Response: EPA thanks the commenter. 

Comment 326 Debra Weber, Louisiana Government: In the 2010 Methods Update Rule, the 

EPA placed in the docket a document titled to OSS 2009, ASTM D7575 “Inter-Laboratory Study 

to Establish Precision Statements for ASTM WK23240—Standard Test Method for Solvent-Free 
66

Membrane Recoverable Oil and Grease by Infrared Determination” Since Oil and Grease is a 

Method Defined Part 136.6 Method Defined Parameter: 

1 The EPA should show all raw lab data that clearly demonstrated how the OSS 

method compared to EPA method 1664A since the method procedural steps are extremely 

different. Unlike 1664A, D7575 does not use hexane as a solvent, does not wash the sample 

collection containers, in which oil and grease can adhere to, does not involve heating as 1664A..

2 The EPA should show all the matrices tested with raw data from the participating labs.

3 The EPA should show the entire interlaboratory data used to determine that this 

method can achieve similar results in various matrices tested in different laboratories. Due to 

number of limited matrices and the number of laboratories used in the original OSS 

interlaboratory study, there is no concrete data to support the conclusion that the method even 

works.

4 The EPA should make available all raw data; internal and external reports associated

studies and various versions of the ASTM-OSS method. The EPA should provide a copy of 

all the supported ASTM reports used to approve the ASTM D7575 method. There was very 

little time elapsed between the various ASTM D7575 versions to perform adequate lab studies. 

What did the EPA used to determine that D7575 is equivalent and properly multi-lab validated?

Response: EPA does not understand the commenter's concern, since all of these materials were 

included in the docket. EPA does not normally include the raw data from NTTAA methods, but 

did so for this method for clarification purposes. Also see response to comment 322 in B.14.

C.3 Requests for approval of IDEXX method

Comment 260 Matthew J. Sica, Principal Scientist, Matthew Sica Consulting: 

Please accept the following comment of behalf of Matthew Sica Consulting:

 We kindly request EPA add the IDEXX Colilert-18/Quanti-Tray method (ATP Case No. 

N09-0004) at 40 CFR 136.3 either by addition to this Notice of Data Availability or by 

Supplemental Notice of Rulemaking . 

 The ATP Case No. N09-0004 method received EPA notification on June 28, 2010 and, 

according to the letter, met all EPA requirements for testing at 40 CFR 136.3 at that time. 

 By adding this method to 40 CFR 136.3 for compliance testing, EPA would remove the 

current regulatory barrier and make it easier for our lab, and others, to adopt this method in a 

more straight forward manner. Being able to adopt the Colilert-18/Quanti-Tray method will 

reduce labor costs and facilitate adhering to sample processing times for facility laboratories. 

Waiting for the next Method Update Rule seems an unreasonable barrier since Agency 

has already deemed the method fit for the intended use. Given allowances made by EPA for 

other methods (such as ASTM D7575-10/D7575-11) it makes sense to include the Colilert18/Quanti-Tray method for compliance at this time in the final NODA, another NODA specific 

to this method or by a Supplemental Notice of Rulemaking. 

Thank you for considering my comment. 

Respectfully submitted, Matthew J Sica Prinicipal Scientist Matthew Sica Consulting 29 

Roger Road Vassalboro, ME 04989 207-624-1532 matthew.j.sica@gmail.com 

Response: Unlike ASTMD7575, EPA did not discuss the IDEXX method in its 2010 proposed 

MUR and therefore does not have the same standing as ASTM D-7575. As required by the 

Clean Water Act and the Administrative Procedure Act, EPA may amend its regulations in 40 
67

C.F.R. Part 136 to include additional methods only after notice and comment rulemaking. EPA 

agrees it has been positively reviewed for nationwide use through EPA’s nationwide ATP 

program and will propose this method in the next Methods Update Rule. 

Comment 298 Kevin Cesar, Laboratory Supervisor, City of Millbrae WPCP, CA: Please 

accept the following comment on behalf of City of Millbrae WPCP, Laboratory. 

 We kindly request EPA add the IDEXX Colilert-18/Quanti-Tray method (ATP Case No. 

N09-0004) at 40 CFR 136.3 either by addition to this Notice of Data Availability or by 

Supplemental Notice of Rulemaking.

 The ATP Case No. N09-0004 method received EPA notification on June 28, 2010 and, 

according to the letter, met all EPA requirements for testing at 40 CFR 136.3 at that time.

 By adding this method to 40 CFR 136.3 for compliance testing, EPA would remove the 

current regulatory barrier and make it easier for other labs to adopt this method in a more straight 

forward manner. The City of Millbrae has gone through the ATP procedure and ELAP and is 

approved to use colilert-18 for fecal coliform but only for our own WPCP samples. The Colilert18/Quanti-Tray method has reduced our costs and has allowed us to respond much quicker 

operationally to problems in the plant when fecal coliform exceed our limits. Yet, other treatment 

plants and commercial labs cannot or will not adopt this method until it is promulgated in 40 

CFR 136.3. Having other labs use this method is beneficial to us. If our sealer or incubator fails 

we could then sub out our samples to these labs and still get the results within 24 hours. 

 Thank you for considering my comment. 

Response: See response to comment 260. 

Comment 319 Patsy Root, IDEXX Laboratories: In addition, and based on points made under 

A 1 above, IDEXX requests that EPA opens up a venue at this time, which would allow the 

Colilert-1 8 for fecal coliform testing method to listed at 40 CFR Part 136.3.

Response: See response to comment 260. 

Comment 327 Thomas Granato, Metropolitan Water Reclamation District of Greater 

Chicago: 

Please accept the following comment on behalf of the Monitoring and Research Department of the Metropolitan Water Reclamation District of Greater Chicago (District).

We kindly request that the United States Environmental Protection Agency (USEPA) add 

the IDEXX Colilert-18/Quanti-Tray method for fecal coliform density quantification (ATP Case 

No. N09-0004) to the lists of approved methods in the USEPA 40 Code of Federal Regulations 

(CFR) Part 136 for measurement of fecal coliform. It is recommended that the USEPA 

include in the 40 CFR Part 136.3 the option of utilizing the commercially available IDEXX 

Colilert18/Quanti-Tray, which is a convenient, reproducible method for determining fecal 

coliform density in wastewater. The attached documents support the use of this method for 

measuring fecal coliform in wastewater.

The District may employ the IDEXX Colilert-18/Quant-Tray method in special circumstances to supplement the USEPA-approved SM9222D, membrane filtration method for the measurement of fecal coliform bacteria. Adding this method to 40 CFR 136.3 for compliance testing 

will simplify performance of fecal coliform analyses. The Colilert-18/Quanti-Tray method will 

reduce labor costs and facilitate adherence to sample processing times for special wet weather 
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analyses in our laboratory. If you have any questions concerning this' comment, please contact 

Dr. Geeta Rij al at 708-588-4224.

[EPA Note: The "Summary of ATP Report for Colilert*-18, Detection and Enumeration of Fecal 

Coliforms in US Wastewater Samples" and "IDEXX Summary" attachments are not included 

here.]

Response: See response to comment 260. 

C.4 Preservation 

Comment 237 Department of Defense: Preservation is not verified in ASTM D7575-11.

Proposed Requirement /Section Addressed: ASTM D7575-11, Section 14.2 (ASTM 

D7575-10, Section 14.2) versus Method 1664A, Section 11.2.1. 

Comment: ASTM D7575 does not require the pH of the sample to be checked and 

modified, if needed, prior to analysis as Method 1664A does. 

Discussion: Preservation should be verified as correct prior to analysis for both methods.

Recommendation: Recommend preservation verification requirements be identified as the 

same for both methods. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA agrees with the commenter. In addition, the preservation and holding time requirements in 

Table II of 40 CFR part 136 would be applicable. 

C.5 Comment period extension

Comment 306 Jessica Skerritt, TRSA: This letter formally requests an extension for comment 

until June 30, 2012, for Docket ID No. EPA-HQ-OW-20100192, Guidelines Establishing Test 

Procedures for the Analysis of Pollutants Under the Clean Water Act; Analysis and Sampling 

Procedures; Notice of Data Availability.

The testing protocol for D7575 has yet to be verified applicable to the industrial laundry 

sector. The primary results do not adequately reflect the measurement across all industry sectors, 

and with only one test there is not yet enough data for our industry for statistical validation. 

Industrial laundries are in the process of applying the protocol to the specific demands of the 

industry and are awaiting a more detailed, comprehensive study on the impacts of the protocol on 

the industrial laundry industry. TRSA would be better able to comment after this further testing is 

done. 

 Again, to reduce the chance of unintended negative consequences, I ask that the comment 

period be extended until June 30, 2012 when further tests are accomplished and analyzed. 

TRSA represents a $16-billion industry employing nearly 200,000 people at more than 

1,500 facilities nationwide. These independent and national companies provide laundered, 

reusable textiles and other products and services that help businesses project a clean and 

attractive public image. The industry reaches every major business and industrial region and 

municipality in the country. Most Americans benefit at least once a week from the cleanliness and 
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safety provided by the industry—through its laundering and delivery of reusable linens, uniforms, 

towels, floor mats and other products for the healthcare, hospitality and industrial/manufacturing 

sectors. TRSA member companies' services minimize environmental impacts on air, water and 

solid waste disposal while reducing costs for millions of customers.

Response: EPA is not extending the comment period for the NODA. EPA notes that if it had 

promulgated ASTM D7575 in Part 136, it would have been an alternative to the existing 

promulgated methods rather than a requirement.

C.6 Transparency

Comment 283 Joe Stefkovich, Xenosep Technologies, Boonton, NJ: Inconsistent 

Treatment by EPA Regarding Various Oil and Grease Methods. EPA 1664A measures the 

method defined parameter commonly known as Oil and Grease. EPA has already informed the 

appropriate Voluntary Consensus Body and Vendor method developers of SM 5520G, ASTM 

D7066-04 and the Horizon Methanol Rinse-Collection that their methods would not be proposed 

in the upcoming MUR, Table IB due to the method-defined differences of these methods with 

1664A and the potential confusion they may cause within the analytical community. If EPA 

were to propose D7575 in the upcoming MUR, Table IB, this could be perceived as unfair and 

inconsistent treatment by the EPA towards the various method developers and would almost 

certainly result in potential litigation due to the appearance of impropriety towards the D7575 

developers. 

Response: As is the case with any proposed rulemaking, based on new information or in 

response to comments, EPA may choose not to adopt a method it has proposed, to adopt or, 

where it has decided not to propose a method for adoption, may change its mind and choose to 

adopt something it has announced in a proposal its preliminary intention not to adopt. Often, 

when EPA obtains new data and information following proposal where it may take a different 

approach than proposed, EPA may choose to issue a notice of data availability (NODA) 

affording the public an additional opportunity to provide comment. EPA then takes into account 

any additional information received in comment on the NODA prior to making a final 

determination. This is the approach EPA has been followed with ASTM D-7575. 

EPA did not receive similar comments and new data on the other oil and grease methods it 

discussed but did not propose. As such, the approach EPA has followed here for ASTM D7575 

was not applicable to these other oil and grease methods. 

Comment 319 Patsy Root, IDEXX Laboratories: A. General comments relating to procedures, 

transparency and equal treatment for method developers.

 1. Timeline / Transparency: The deadline for inclusion in the current MUR was July 17, 

2009 as indicated by Dr Richard Reding in a letter dated July 17, 2009 ..”we are drafting the 

proposed rule with the methods and suggestions collected so far.”

Timeline for OSS method D7575-10: It is obvious from the docket that the request for 

inclusion of D7575-10 was submitted September 2010 (EPA-HW-OW-0192-0209). In fact, the 

collection of data to satisfy EPA requirements and various meetings to that effect continued 

through November 2011. This resulted in EPA publishing a NODA for the OSS method on 

December 14, 2011.
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Timeline for IDEXX method Colilert-18 for fecal coliform testing: In June 2010, EPA 

issued a letter of positive disposition for this method indicating “.. will recommend that this

method be included in future regulatory actions in which EPA periodically adds to the list of 

approved methods at 40 CFR Part 136.3”.

 Even though the IDEXX method satisfied all the requirements by June 2010 to be 

included in the current MUR, we were told that it was too late. According to the document EPAHW-OW-0192-0209, Mr. Jack Hall formally requested EPA include D7575-10 in the current 

MUR in September 2010. The MUR was then published September 23, 2010 and included the 

D7575-10 method but not the IDEXX method.

This shows preferential treatment in terms of having a transparent EPA timeline for all 

method developers.

 2. Equal Treatment of method developers: Of equal concern is the apparent ownership 

EPA has taken in the approval path for this method. A follow- up e-mail from OSS to EPA 

(document EPA-HQ-OW-2010-0192-0145) reviews an on-site meeting between OSS and 

Agency representatives in which EPA provided guidance on two options OSS could follow to 

get D7575-10 into the current Method Update Rule. 

In contrast, IDEXX had requested similar meetings to better understand EPA processes and 

review our options but the Agency declined all such interactions. 

 An explanation is in order to better understand why the Agency was so personally 

involved in coaching and recommending an approval pathway to this particular method 

developer. 

Response: Timeline: EPA treated ASTM method D7575 in the same way it would have treated 

any other method at a similar stage of review that it might have been received at that time. It 

appears the commenter misunderstood the intent in Dr. Reding’s letter. Before EPA will include 

a new or revised CWA method in a proposed rulemaking, the method must either have been 

positively reviewed by EPA as indicated by a letter to that effect) under the ATP program or 

have been adopted by a voluntary standards organization. It may take a significant amount of 

time from receipt of an ATP application to EPA to receipt of a letter from EPA indicating our 

positive review. Similarly, from the time a voluntary standards organization begins discussions 

on a new or revised method to adoption also takes significant time. Dr. Reding’s letter simply 

communicates that it was highly unlikely that a method that had not already begun review under 

the ATP program or had not already begun development by a consensus standards organization 

would be completed in time to include in the 2010 proposed MUR. 

The above is different from a “cut-off” date in which an ATP must have completed review or a 

consensus standard organization must have adopted and submitted to EPA. The cut-off date 

reflects the level of internal and external review that EPA proposals must undergo before EPA 

signs a notice of proposal for publication in the Federal Register. In contrast to your method, all 

of the methods cited above were completed at least seven months prior to the August 2010 

proposed publication date for the MUR. EPA plans to propose the IDEXX method in the next 

Methods Update Rule. EPA also disagrees with the statement that EPA shows preferential 

treatment but realizes from these comments that greater clarify and transparency are necessary in the 

future to avoid confusion regarding the inclusion of methods in a Methods Update Rule.

Equal Treatment: See response to comment 283. When EPA discusses a method in a proposal 

and it receives public comment that it needs to address, EPA often works with the developer (if it 
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went through the ATP process) or the voluntary standards organization to respond to such 

comments. The e-mail you cited by the commenter was dated 10/5/10- clearly after ASTM D7575 was adopted by ASTM and clearly after ASTM D-7575 was already discussed in the 

proposed MUR. As such, these interactions fall into the above category. Finally, EPA notes that 

it has met with IDEXX concerning their method. 

 

Comment 325 Janet Eastep, Fairway Laboratories: Please accept the following comment on 

behalf of Fairway Laboratories.

We kindly request EPA add the IDEXX Colilert-18/Quanti-Tray method (ATP Case 

No. N09-0004) at 40 CFR 136.3 either by addition to this Notice of Data Availability or by 

Supplemental Notice of Rulemaking .

The ATP Case No. N09-0004 method received EPA notification on June 28, 2010 

and, according to the letter, met all EPA requirements for testing at 40 CFR 136.3 at that 

time.

By adding this method to 40 CFR 136.3 for compliance testing, EPA would remove 

the current regulatory barrier and make it easier for our lab, and others, to adopt this 

method in a more straight forward manner. Being able to adopt the Colilert-18/QuantiTray method will reduce labor costs, facilitate adhering to sample processing times, and 

overall will help the Micro. Dept. run more smoothly on the busier days.

Waiting for the next Method Update Rule seems an unreasonable barrier since 

Agency has already deemed the method fit for the intended use. Given allowances made by 

EPA for other methods (such as ASTM D7575- 10/D7575-11) it makes sense to include the 

Colilert-18/Quanti-Tray method for compliance at this time in the final NODA, another 

NODA specific to this method or by a Supplemental Notice of Rulemaking.

Thank you for considering my comment.

Response: See response to comment 319 and comment 260 in C.3.

C.7 Duplicate samples

Comment 319 Patsy Root, IDEXX Laboratories: Requiring duplicate samples in every run 

should be recommended to avoid contamination if re- sampling from the original container 

presents a contamination issue. 

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

Also, EPA notes that the promulgated oil and grease method does not require duplicate samples.

 

C.8 Appropriateness of paint shaker in a certified laboratory

Comment 319 Patsy Root, IDEXX Laboratories: The use of a paint shaker doesn’t seem like 

appropriate equipment for a certified laboratory; suggest OSS provide an alternative process or 

equipment. 
72

Response: For the reasons specified in the notice, EPA has decided not to adopt this method for 

nationwide use. Permittees should continue to use an oil and grease method promulgated in Part 

136 for CWA compliance. Because EPA recognizes that permittees may wish to request use of 

this method for a limited use through existing authorities in 136.5, EPA is providing a response. 

EPA requested that ASTM add information on the homogenization apparatus as OSS had 

included in SOPs they prepared for laboratories that use the method. In response to EPA’s 

request, this information was added to D7575-11. 

C.9 EPA is purposely delaying a final ruling to allow a single method to "catch up" 

Comment 319 Patsy Root, IDEXX Laboratories: Procedural: The extended delay in 

finalizing the current MUR in order to accommodate one method is highly unusual and not in 

line with prior practices. It is not fair to delay the promulgation of several other methods in 

order to allow one method to ‘catch up’ with work required to demonstrate qualification. 

Response: EPA disagrees. The Agency did not delay promulgation of the MUR due to ASTM 

D7575 as demonstrated by the fact that it promulgated the final MUR in May, 2011 without a 

determination on D7575 and that it is issuing its determination through this notice after that date.