A performance-based framework for demonstrating appropriate use of an alternate method for wastewater compliance...

The choice of wastewater compliance methods used in the United States has been largely prescribed; however, in some cases, this has led to data of unknown or poor quality. This problem is further compounded by the relatively slow regulatory approval process to incorporate discharge-specific method modifications or flexibility to using alternate, potentially better technologies. In this study, a framework is presented, using a performance-based-system approach, which a discharger could use to verify proper use of an alternate or modified method. An example, using two chemical oxygen demand methods (a currently approved method and an alternate method that does not generate hazardous waste) demonstrates that the protocol is simple to use, yet scientifically defensible and effective and that this approach should be readily understandable to both regulators and the regulated community. Our results also suggest that the reference method approach, without associated measurement quality objectives, may yield a false sense of competency with an alternate method.