DOW Laboratory Certification Program Update – 2014

Presentation to: KWWOA

April 9, 2014

Department for Environmental ProtectionEnergy & Environment Cabinet

To Protect and Enhance Kentucky’s Environment

Topics• Drinking Water Laboratory Certification• Wastewater Laboratory Certification • Common Laboratory Findings• Laboratory Certification Program Update• Web Page Update

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Drinking Water Laboratory Certification Update

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Drinking Water Program Update

Program In-state Out-of-state

Chemistry Labs 15 27

Microbiology Labs 46 2

Cryptosporidium 2 1

Radionuclides 0 9

Dioxin 0 6

Asbestos 1 3

PCBs (EPA508A) 0 24

Certificate + Analyte-Method List• Certificates are valid January 1st – December

31st of each calendar year• Only one certificate for laboratories with both

Chemistry and Microbiology certification• Both Chemistry and Microbiology certificate

packages include an analyte-method list• Analyte-method lists must include Minimum

Reporting Limit (MRL)

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Compliance Sample Results• DOW continues using SDWIS filters which

will reject any results (analyte-method) that a certified laboratory is not certified for – this includes secondary contaminants

• SDWIS filters also include the KY MRL – any laboratory non-detect result not meeting the MRL is flagged by the database

• MRL must be < Required Reporting Limit

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On-site Laboratory Audits• Both Chemistry and Microbiology laboratories

will be audited at least twice every three years• Cryptosporidium audits have been completed

for upcoming LT-2. Laboratories will be audited at least once more during the upcoming LT-2 monitoring period (2015-17)

• Announced and Unannounced Audits

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Upcoming Cryptosporidium LT-2• All previously certified Cryptosporidium

certified laboratories must recertify for upcoming LT-2 period (2015-17)

• Check USEPA website for a list of currently certified Cryptosporidium laboratories

• Contact DOW if you have any questions regarding Cryptosporidium certification

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Laboratory Accountability Program• DOW will continue to utilize the Laboratory

Accountability Program for laboratory reporting errors that are submitted to the state

• First step in the process to downgrade/revoke a laboratory’s analyte-method certification

• Laboratory Accountability Program has contributed to the reduction of the number of violations issued to public water systems

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Proficiency Test Studies• Laboratories performing drinking water

analyses are required to successfully complete one PT Study per analyte-method each year

• Laboratories that fail two consecutive PT Study samples for the same contaminant must report to the state with a corrective action plan

• DOW is pursuing electronic tracking of all PT Study results – in place by end of 2014

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Wastewater Laboratory Certification Update

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Laboratory Applications Status

• Applications received = 36• In-state = 23• Out-of-state =13

• Certificates issued = 21

• Application deadline = October 1, 2014

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Effective Dates of Certification• General Laboratories

– January 1, 2014 – December 31, 2015–Compliance samples = by January 1, 2015

• Field-only Laboratories– January 1, 2015 – December 31, 2016–Compliance samples = by January 1, 2016

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Application Common Issues• Incomplete submissions• QAP and/or SOP missing key elements• Quality control acceptance criteria• Analyte-method list incomplete/inaccurate• Reference methods are no longer approved• PT Study reports reference incorrect methods

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Application Common Issues (cont)• Standard methods are not referenced properly:

–SM 1234 A-year• PT reports do not contain the complete

reference method (e.g. SM 2540 B-1997)• Colilert-18 for Fecal Coliform – must receive

written approval from EPA Region 4

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Audit Schedules• General Laboratories:

–Laboratory audits began in 2014–At least one audit each five years

• Field-only Laboratories:–First audit performed by DOW Laboratory

Certification Group and Field Inspector–All other audits performed by Field Inspectors

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Commonly Audit Findings

DRINKING WATER ONLY

General Findings

Chemistry

Microbiology

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General Audit Findings• KY regulation captures Standard Methods:

–Drinking Water:•18th, 19th, 20th, 21st and 22nd Editions

–SM 18th , 19th and 20th = contained in regulation and EPA manual

–SM 21st and 22nd = by ATP•SM 18th and 19th Editions are being phased out. Recommend 21st or 22nd Ed.

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General Audit Findings (cont)• Traceable back to NIST – whenever possible

–Eppendorf Pipets, Thermometers, Balances, Standards, Reagents, etc.

• Utilize control charts (trend analysis) or document quality control acceptance limits

• Notify DOW of key personnel changes• Utilize maintenance log books for instruments• Remember – document all observations!

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Chemistry Laboratory Audit Summary• Methods used must be published in 40CFR141

or an EPA signed ATP on file at laboratory• Method must be capable of meeting KY MRL• Laboratory must demonstrate KY MRLs

(e.g. reporting limit standard, RLS)• MDLs – annually (2-3 non-consecutive days)• IDC – performed by each analyst initially• ODC – performed by each analyst annually

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Chemistry Audit Findings (cont)• All drinking water methods must be performed

as written in the EPA approved method• All quality control samples must have an

acceptance criteria and associated corrective action for unacceptable results

• Documentation of preservation checks (VOCs)• Calibration curves – forced thru zero (0)

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Microbiology Program Update

DOW State Principle Microbiology Laboratory is MSU Water Quality Lab

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Microbiology Program Update• DOW has established:

– Initial Requirements for a Drinking Water Microbiology Laboratory

–Microbiology Analyst Approval Process–PT Study Requirements

• DOW does not track CEUs – laboratories are required to maintain all training records for review during on-site audit or upon request

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Microbiology Laboratory Audit Summary

• Perform EPA approved methods as written• Colilert-18 and 24 are treated as two methods• PT Studies – in accordance with EPA Manual• Colilert-18 for Fecal Coliform – must receive

written approval from EPA Region 4• Use bench sheets for analysis of PT Samples• Replace reference comparators when expired• Utilize internal sample tracking documents

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Microbiology Audit Summary (cont)• Supervisors and QA Managers must meet

credential requirements listed in EPA Manual• SOPs / QAPs must be reviewed/updated

annually – document date• BACT samples must be at least 100 mL• DOC must be performed and documented• Strikeouts/overwrites – single line, date/initial• Analyst Signature/Initials must be on file

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DOW Laboratory Certification Program Update

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Technical Assistance• Updated list of certified laboratories

–Hyperlink analyte-methods & status• Updated method – analyte code list• Fact Sheets• DOC Worksheet (IDC, MDL & RLS)• Control Charts – worksheet template

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Training• On-going Wastewater Laboratory Certification

Training:–Application Process–QAP–SOP

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Web Pages

DOW Main Pagehttp://water.ky.gov

Laboratory Certificationhttp://water.ky.gov/permitting/Pages/labcert.aspx

Drinking Waterhttp://water.ky.gov/DrinkingWater/Pages/CertifiedLaboratories.aspx

Wastewaterhttp://water.ky.gov/permitting/Pages/WasteWaterCertification.aspx

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General Email Address

dowlabcertification@ky.gov

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Drinking Water Website• Ongoing Improvements to the DOW website

http://water.ky.gov/DrinkingWater/Pages/CertifiedLaboratories.aspx

• Laboratory Certification Webpage Updates:–Useful information and documentation–DOC worksheets (IDC, MDL & RLS)–Minimum Reporting Limits listed–List of KY analyte codes and method codes–Approved PT Study Providers - Updated

Wastewater Website• KWLCP Application Form (6-13-2013)• KY Approved EPA Compliant Methods• Field Laboratory QAP and SOP• General Laboratory QAP and SOP• WW Analyte Method List TEMPLATE• KY WW Laboratory Certification Manual• Demonstration of Capability

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DOW Laboratory Audit TeamFrank Hall – Certification Program Manager

Patrick Garrity – Laboratory Certification Officer

Kevin Stewart – Certification Officer

Arianna Lageman – Certification Officer

Dr. Ted Pass – Certification Officer

Tiffany Nolan – Laboratory Auditor

Erich Cleaver – Laboratory Auditor

DOW Laboratory Audit Team (cont)John Williams – Laboratory Auditor

Tabitha Aldridge – Laboratory Auditor

Gabriel Tanner – Laboratory Auditor

Jack Wiedo – Laboratory Auditor

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Questions

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Contact InformationPatrick J. Garrity

Laboratory Certification OfficerDivision of Water

200 Fair Oaks Lane; 4th FloorFrankfort, KY 40601

Phone: (502) 564-3410Fax: (502) 564-2741

Email: patrick.garrity@ky.gov