40 CFR 268.40 footnote 7 for cyanide analysis states you may use the test Methods 9010C or 9012B with the sample weight of 10 g with the distillation time of 1 hour and 15 minutes. Can a lab run test Method 9012B or 9010C and use 1 gram sample weight using the midi‐vap distillation and still be compliant with footnote 7?
Both Methods 9012B and 9010C are method defined parameters (MDPs) and must be followed prescriptively as written, with no exceptions. The text “are to be” in footnote 7 is synonymous with “must”. Therefore, use of a 10 gram of sample and distilling for 1 hour and 15 minutes is required to be compliant.
Other Category: 9000 series