Public Water System Supervision Program Quality Assurance Project Plan Requirements for Laboratories and Impacts on Public Water Systems (Part 1) Jessica Hoch Drinking Water Assessment Team Lead Lead and Copper Rule, Revised Total Coliform Rule, Groundwater Rule Jessica.Hoch@tceq.texas.gov 512-239-2353 2019 TCEQ Environmental Trade Fair

Presentation Goals QAPP Requirement Specific Scenarios to Consider Impacts on Public Water System (PWS) Compliance What can the lab do? To assist laboratories in understanding how QAPP requirements can impact customer/PWS compliance with the Safe Drinking Water Act. Emphasize open, cooperative communication Perspective

Protection of Public Health Public Water System Laboratory Protection of Public Health TCEQ

TNI Accreditation for Laboratories 290 TAC Rules for PWS Protection of Public Health QAPP

Quality Assurance Project Plan Quality Assurance (QA) and Quality Control (QC) processes related to environmental data collection activities. Includes 10 addenda addressing program-specific QA and QC Revised every 3 years with annual updates Last revision 11/4/2016 1st Annual update in 2017 EPA approval 12/20/2017 2nd Annual update in 2018 EPA approval 10/26/2018

For Discussion Today Addendum 3—Guidance for the Analysis and Reporting of Water Quality Parameters under the Lead and Copper Rule All three guidance documents primarily address laboratory requirements for sample receipt, analysis, and reporting. Requirements are program specific and reflect rules and regulations specific to the drinking water program. Laboratories need to be aware there situations in which drinking water rules and regulations applying to laboratories which are more stringent than the TNI Standards. I think most laboratories understand this, but there we received a few questions related to this issue. For example, the TNI specifies the sample label must have a unique identifier only. Appendix A, Figure A-1 of the Certification Manual for Laboratories analyzing Drinking Water has requirements for sample labels which include the sample location, date and time of sample collection, etc… This is more stringent than what the TNI Standard requires, which is why we included it. Addendum 2—Guidance for the Analysis and Reporting of Lead and Copper under the Lead and Copper Rule Addendum 4—Guidance for Analysis and Reporting under the Revised Total Coliform Rules

Quality Assurance Project Plan Addendum 2 – Laboratory Guidance for the Analysis and Reporting of Tap Water Samples under the Lead and Copper Rule Applies to labs analyzing PbCu tap samples Addendum 3 – Laboratory Guidance for the Analysis and Reporting of Water Quality Parameters Under the Lead and Copper Rule Applies to labs analyzing WQP samples Addendum 4 – Laboratory Guidance for Analysis and Reporting Under the Revised Total Coliform Rule Applies to labs analyzing microbial compliance samples

QAPP Addendum #2 LCR Tap Samples Lead and Copper Requirements for Laboratories Addenda #2 is Currently on Revision 2 LCR Chain of Custody Form 20683

QAPP Addendum #2 LCR Tap Samples Guidance for the Analysis and Reporting of Tap Water Samples under the Lead and Copper Rule Applies to the systems and the laboratories submitting data for compliance under the Lead and Copper Rule (LCR) Tap Samples Samples for public water system (PWS) compliance Includes regulatory program requirements

LCR Tap Sample QAPP Requirement Samples must be collected in 1 L lab-grade plastic bottles with a fill line Acid preserved upon receipt in the laboratory No later than 14 days after date of collection QAPP-Addendum 2-Table 2 Preservation and Containers for Lead and Copper Samples QAPP requirements related to sample receipt activities at the lab.

LCR Tap Sample Scenario Customer asks for lead and copper testing Doesn’t indicate for compliance with the LCR Samples received in insufficient sample bottles Material, volume, audit trail, etc. Noted on analytical report PWS receives violation letter Submits analytical report to TCEQ TCEQ reviews report Samples cannot be used for compliance

LCR Tap Sample Scenario Customer drops compliance samples late on a Friday Laboratory intends to preserve on Monday Customer delayed bringing samples to lab Some past hold-time Left messages and had no response from customer PWS receives violation letter Submits analytical report to TCEQ TCEQ reviews report Samples cannot be used for compliance Samples were collected at different times over past 2-13 days

LCR Tap Sample PWS Compliance Impact Samples that are analyzed using an unapproved method, collected in an inappropriate container, and/or samples that are not preserved within hold-time cannot be accepted for compliance Monitoring and Reporting (M/R) Violation Violations require Public Notice PWS will sample in the next monitoring period Monitoring results dictate sampling schedules Homeowners will have to participate again

LCR Tap Sample What Can The Lab Do? At sample receipt: Ask if samples are to be used for compliance with the Lead and Copper Rule and/or TCEQ Always check all collection dates Always preserve at time of receipt

LCR Tap Sample QAPP Requirement Samples that have been delivered to the laboratory and determined to be unsatisfactory must be reported to the TCEQ, in all cases Receive Reject Replace Report QAPP-Addendum 2-Table 6 Lead and Copper Rejection Codes

LCR Tap Sample Scenario Customer drops off inadequate compliance samples in late June Laboratory notices and tells customer the issue Customer leaves, no record of rejected sample Customer returns the next week with new sample PWS receives violation letter Submits analytical report to TCEQ TCEQ reviews report Sample cannot be used for monitoring period intended for

LCR Tap Sample PWS Compliance Impact Samples analyzed in the next monitoring period, that are lacking a tie to the previous monitoring period, cannot be accepted for compliance PWS must maintain accurate, defensible records Monitoring and Reporting (M/R) Violation Violations require Public Notice PWS will sample in the next monitoring period Monitoring results dictate sampling schedules Homeowners will have to participate again

LCR Tap Sample What Can The Lab Do? Reporting rejected and replacement samples can help prevent customers from receiving a violation Always reject inadequate samples at receipt Always report rejected and replacement samples Replacement samples tie to the rejected sample Receive – Reject – Replace - Report

LCR Tap Sample QAPP Requirement QAPP Addendum #2 LCR Tap Samples PWS must use the LCR Monitoring Form (LCRMF) Form #20683 Lab-modified forms must be approved by TCEQ LCRMF must be completed properly Samples must be labeled properly Samples must be collected from the approved sample site pool for the PWS

LCR Tap Sample Scenario Customer asks for lead and copper testing Doesn’t indicate for compliance with the LCR Received with private chain of custody (COC) Missing required information Noted on analytical report PWS receives M/R violation Submits analytical report and sample records to TCEQ TCEQ reviews report and records Samples may be used for compliance

LCR Tap Sample PWS Compliance Impact Samples collected without adequate documentation cannot be accepted for compliance PWS must maintain accurate, defensible records TCEQ can review and make corrections to documentation Potentially reject violation Monitoring results dictate sampling schedules

LCR Tap Sample What Can The Lab Do? At sample receipt: Ask if samples are to be used for compliance with the Lead and Copper Rule and/or TCEQ Ensure proper documentation if customer states samples are for compliance Train staff on sample acceptance criteria

LCR Tap Sample Reporting Reminders Frequent electronic data submittal DO NOT hold data until end of the monitoring period Prevents TCEQ from informing PWS of data issues Report regularly Corrections and resubmittal of data PWS works to correct issue with documentation Laboratory resubmits, uses new state notification date Potential for PWS to receive violation for late reporting even if the data originally reported on time. Utilize original state notification date

QAPP Addendum #3 Water Quality Parameters Water Quality Parameter Requirements for Laboratories (Under the Lead and Copper Rule) Addenda #3 is Currently on Revision 2 WQP Chain of Custody Form 20679

QAPP Addendum #3 Water Quality Parameters Guidance for the Analysis and Reporting of Water Quality Parameters (WQP) under the Lead and Copper Rule Applies to systems and laboratories submitting data for Water Quality Parameter compliance under the LCR Samples for PWS compliance Includes regulatory program requirements

Water Quality Parameters QAPP Requirement Samples must be analyzed by a laboratory that is accredited in the drinking water matrix using a method acceptable to EPA and/or approved by the Water Supply Division (WSD) Approved by WSD: temperature, pH, alkalinity, calcium, conductivity, ortho phosphate, silica Accredited by TCEQ: chloride, hardness, iron, manganese, sodium, sulfate, TDS QAPP-Addendum 3-Table 2 Allowable Methods for WQP Sample Analysis

Water Quality Parameters Scenario Customer drops off WQP compliance samples Laboratory analyzes Not accredited/approved for all analytes Not accredited in drinking water matrix PWS receives violation letter Submits analytical report to TCEQ TCEQ Reviews report Samples cannot be used for compliance

Water Quality Parameters PWS Compliance Impact Samples analyzed using an unapproved method or when lacking accreditation for the analyte in drinking water cannot be accepted for compliance Monitoring and Reporting (M/R) Violation Violations require Public Notice PWS will sample in the next monitoring period

Water Quality Parameters What Can The Lab Do? Ensure methods listed in QAPP are used QAPP-Addendum 3-Table 2 Review TNI Accreditation status regularly Plan for timeframes to obtain accreditation for new analytes Review TCEQ Lab Approval status regularly For most labs, TCEQ Approval expires 06/30/2019 Plan to update status prior to 07/01/2019

Water Quality Parameters QAPP Requirement PWS must use the Water Quality Parameter Monitoring Form (WQPMF) Form #20679 Modified forms must be approved by TCEQ WQPMF must be completed properly Samples must be labeled properly

Water Quality Parameter QAPP Requirement Samples must be collected in lab grade plastic bottles Volume should be sufficient to conduct all required analyses Acid preservation should be done in the lab No later than 14 days after collection Some analytes require thermal preservation Alkalinity, conductivity, sulfate, TDS, ortho phosphate

Water Quality Parameters QAPP Requirement Condition at receipt must be documented Preservation, ice, temperature QAPP-Addendum 3-Table 1 Sample Containers and Preservation QAPP requirements related to sample receipt activities at the lab.

Water Quality Parameters Scenario Customer drops off WQP compliance samples Sample custodian unfamiliar with Form #20679 Does not note condition at receipt Samples preserved and/or analyzed past hold times PWS receives violation letter Submits analytical report to TCEQ TCEQ Reviews report Samples cannot be used for compliance

Water Quality Parameters PWS Compliance Impact Samples that do not have documentation of the condition at time of receipt, are collected in an inappropriate container, and/or samples that are not preserved or analyzed within hold-time cannot be accepted for compliance Monitoring and Reporting (M/R) Violation Violations require Public Notice PWS will sample in the next monitoring period

Water Quality Parameters What Can The Lab Do? At sample receipt: Ensure staff are familiar with sample acceptance requirements Containers, hold-times, documentation Always check all collection dates Always preserve at time of receipt

Water Quality Parameters Reporting Reminders Subcontracting There should be two WQPMF-Form 20679 Initial receiving laboratory reports field measurements Results are reported by the laboratory that performed the analysis DO NOT hold data until end of the monitoring period Prevents TCEQ from informing PWS of data issues and their opportunity to recollect Report regularly

Water Quality Parameters Reporting Reminders Reporting Rejected Samples Rejected samples are reported with no result, using a rejection code QAPP-Addendum 3-Table 5 Sample Rejection Codes and Descriptions Individual Analytes cannot be rejected If subcontracted, rejecting lab should notify other lab as soon as possible

Water Quality Parameters Reporting Reminders Report data to: LCRDATA@tceq.texas.gov Do not send data to individuals in LCR Program Check EDD for typos Ensure PWS ID is correct Report results in mg/L ,not µg/L

QAPP Questions? Gary Regner PWSS Program QA Manager Gary.Regner@tceq.texas.gov 512-239-4528

Public Water System Supervision Program Quality Assurance Project Plan Requirements for Laboratories and Impacts on Public Water Systems (Part 2) Jessica Hoch Drinking Water Assessment Team Lead Lead and Copper Rule, Revised Total Coliform Rule, Groundwater Rule Jessica.Hoch@tceq.texas.gov 512-239-2353 2019 TCEQ Environmental Trade Fair

Presentation Goals QAPP Requirement Specific Scenarios to Consider Impact on Public Water System (PWS) Compliance Notice of Violation What can the lab do? To assist laboratories in understanding how QAPP requirements can impact customer/PWS compliance with the Safe Drinking Water Act.

Protection of Public Health Public Water System Laboratory Protection of Public Health TCEQ

TNI Accreditation for Laboratories 290 TAC Rules for PWS Protection of Public Health QAPP

Quality Assurance Project Plan Quality Assurance (QA) and Quality Control (QC) processes related to environmental data collection activities. Includes 10 addenda addressing program-specific QA and QC Revised every 3 years with annual updates Last revision 11/4/2016 1st Annual update in 2017 EPA approval 12/20/2017 2nd Annual update in 2018 EPA approval 10/26/2018

For Discussion Today Addendum 3—Guidance for the Analysis and Reporting of Water Quality Parameters under the Lead and Copper Rule All three guidance documents primarily address laboratory requirements for sample receipt, analysis, and reporting. Requirements are program specific and reflect rules and regulations specific to the drinking water program. Laboratories need to be aware there situations in which drinking water rules and regulations applying to laboratories which are more stringent than the TNI Standards. I think most laboratories understand this, but there we received a few questions related to this issue. For example, the TNI specifies the sample label must have a unique identifier only. Appendix A, Figure A-1 of the Certification Manual for Laboratories analyzing Drinking Water has requirements for sample labels which include the sample location, date and time of sample collection, etc… This is more stringent than what the TNI Standard requires, which is why we included it. Addendum 2—Guidance for the Analysis and Reporting of Lead and Copper under the Lead and Copper Rule Addendum 4—Guidance for Analysis and Reporting under the Revised Total Coliform Rules

Quality Assurance Project Plan Addendum 2 – Laboratory Guidance for the Analysis and Reporting of Tap Water Samples under the Lead and Copper Rule Applies to labs analyzing PbCu tap samples Addendum 3 – Laboratory Guidance for the Analysis and Reporting of Water Quality Parameters Under the Lead and Copper Rule Applies to labs analyzing WQP samples Addendum 4 – Laboratory Guidance for Analysis and Reporting Under the Revised Total Coliform Rule Applies to labs analyzing microbial compliance samples

QAPP Addendum #4 Microbial Compliance Microbial Compliance Requirements for Laboratories (Under the Revised Total Coliform Rule) Addenda #4 is Currently on Revision 2 Microbial Reporting Form (MRF) 10525

QAPP Addendum #4 Microbial Compliance Guidance for Analysis and Reporting Under the Revised Total Coliform Rule (RTCR) Applies to labs submitting data for compliance under RTCR Samples from public water systems Includes regulatory and program requirements

Microbial Compliance QAPP Requirement Reporting of Positive Samples Report on same day to TCEQ and PWS PWS must collect repeats within 24 hours of notification Submit Positive Result Report Form Email or Fax to TCEQ RTCRPOS@tceq.texas.gov Samples were collected at different times over past 2-13 days

Microbial Compliance Scenario Customer drops compliance samples late on a Friday Laboratory accepts and analyzes Results available on Saturday - E. coli positive No manager available to approve Lab analyst leaves result for Monday reporting Without notifying the customer of the result PWS eligible for EMCL violation? Failure to collect repeat samples? Samples were collected at different times over past 2-13 days

Microbial Compliance PWS Compliance Impact Failure to timely report a positive microbial result to the PWS, leaves public health at risk Especially true for E. coli that is detected in a distribution sample Failure to collect repeats Potential EMCL Potential Level 2 Assessment

Microbial Compliance What Can The Lab Do? Train laboratory staff on what to do after a positive result is determined Weekdays Weekends/Holidays Ensure customer contact information is correct at sample receipt

Microbial Compliance QAPP Requirement Samples that have been delivered to the laboratory and determined to be inadequate for analysis must be rejected Receive Reject Replace Report QAPP-Addendum 4-Table 2 Rejection Codes

Microbial Compliance Scenario Customer drops off inadequate compliance samples late in the month Laboratory notices and tells customer the issue Customer leaves, no record of rejected sample Customer returns the next week with new sample PWS receives violation letter Submits analytical report to TCEQ TCEQ reviews report Sample cannot be used for monitoring period intended

Microbial Compliance PWS Compliance Impact Samples analyzed in the next month, that are lacking a tie to the previous month, cannot be accepted for compliance PWS must maintain accurate, defensible records Monitoring and Reporting (M/R) Violation Violations require Public Notice

Microbial Compliance What Can The Lab Do? Reporting rejected and subsequent replacement samples can help prevent customers from receiving a violation Reject samples that are inadequate for analysis at receipt Report rejected and replacement samples Replacement samples tie to the rejected sample Receive – Reject – Replace – Report

Microbial Compliance What Can The Lab Do? Train sample custodians in acceptance requirements Inadequacy related to a documentation error Catch errors at sample receipt Address while customer still available Following TCEQ guidelines, make all attempts to correct Microbial samples are a capture of a moment in time that cannot be replicated Make all attempts to save microbial compliance samples, if possible

Microbial Compliance QAPP Requirement QAPP Addendum #2 LCR Tap Samples PWS must use the Microbial Reporting Form (MRF) Form #10525 Modified forms must be approved by TCEQ MRF must be completed properly Samples must be labeled properly

Microbial Compliance Scenario Customer asks for bacteriological testing Doesn’t indicate for compliance with the RTCR Received with private chain of custody (COC) Missing required information PWS receives M/R violation Submits analytical report and sample records (if any) to TCEQ TCEQ reviews report and records Samples may be used for compliance

Microbial Compliance PWS Compliance Impact Samples collected without adequate documentation cannot be accepted for compliance PWS must maintain accurate, defensible records TCEQ can review and make corrections to documentation Potentially reject violation

Microbial Compliance What Can The Lab Do? At sample receipt: Ask if samples are to be used for compliance with the Revised Total Coliform Rule and/or TCEQ Ensure proper documentation if customer states samples are for compliance Ensure laboratory uses MRF or receives approval for modifications made to form

Microbial Compliance Reporting Reminders Frequent electronic data submittal DO NOT hold data until end of the monitoring period Prevents TCEQ from informing PWS of data issues Report regularly Report sample ID exactly as noted on MRF Do not add abbreviations or hyphens if they are not included on the paper record Creates duplicate results in database

Microbial Compliance Sampling Reminders Licensing Requirements Samples for community and non-transient non-community water systems MUST be collected by an individual with a valid water operators license Not required for transient systems Field Measurements All samples must have a field measured chlorine residual DO NOT analyze, reject. Residual must not be filled in at time of receipt at the lab

Microbial Compliance Sampling Reminders Sample Labels Adhesive or written directly on bottle Must include: PWS ID number Date & Time of sample collection Sampler’s initials Address/location of collection Sampling SOP TCEQ has developed a sampling guidance SOP TCRDATA@tceq.texas.gov to ask for a copy

Compliance Sample Receipt Reminders Labs may not make corrections to PWS portion of any reporting form (LCRMF, WQPMF, MRF) Corrections must be made by the sampler before relinquishment to lab Only TCEQ can authorize changes after analysis and reporting Evaluated on a case-by-case basis See QAPP for specific conditions

QAPP Questions? Gary Regner PWSS Program QA Manager Gary.Regner@tceq.texas.gov 512-239-4528