1. DOW Laboratory Certification Program Update – 2014 Presentation to: KWWOA April 9, 2014 Department for Environmental Protection Energy & Environment Cabinet To Protect and Enhance Kentucky’s Environment

2. Topics Drinking Water Laboratory Certification Wastewater Laboratory Certification Common Laboratory Findings Laboratory Certification Program Update Web Page Update 2

3. Drinking Water Laboratory Certification Update 3

4. Drinking Water Program Update ProgramIn-stateOut-of-state Chemistry Labs 1527 Microbiology Labs462 Cryptosporidium21 Radionuclides09 Dioxin06 Asbestos13 PCBs (EPA508A)02 4

5. Certificate + Analyte-Method List Certificates are valid January 1 st – December 31 st 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) 5

6. 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 6

7. 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 7

8. 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 8

9. 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 9

10. 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 10

11. Wastewater Laboratory Certification Update 11

12. Laboratory Applications Status Applications received = 36 In-state = 23 Out-of-state =13 Certificates issued = 21 Application deadline = October 1, 2014 12

13. 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 13

14. 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 14

15. 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 15

16. 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 16

17. Commonly Audit Findings DRINKING WATER ONLY General Findings Chemistry Microbiology 17

18. General Audit Findings KY regulation captures Standard Methods: –Drinking Water: 18 th, 19 th, 20 th, 21 st and 22 nd Editions –SM 18 th, 19 th and 20 th = contained in regulation and EPA manual –SM 21 st and 22 nd = by ATP SM 18 th and 19 th Editions are being phased out. Recommend 21 st or 22 nd Ed. 18

19. 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! 19

20. 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 20

21. 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) 21

22. Microbiology Program Update DOW State Principle Microbiology Laboratory is MSU Water Quality Lab 22

23. 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 23

24. 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 24

25. 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 25

26. DOW Laboratory Certification Program Update 26

27. 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 27

28. Training On-going Wastewater Laboratory Certification Training: –Application Process –QAP –SOP 28

29. Web Pages DOW Main Page http://water.ky.gov Laboratory Certification http://water.ky.gov/permitting/Pages/labcert.aspx Drinking Water http://water.ky.gov/DrinkingWater/Pages/CertifiedLaboratories.aspx Wastewater http://water.ky.gov/permitting/Pages/WasteWaterCertification.aspx 29

30. General Email Address dowlabcertification@ky.gov 30

31. 31 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

32. 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 32

33. 33 DOW Laboratory Audit Team Frank 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

34. DOW Laboratory Audit Team (cont) John Williams – Laboratory Auditor Tabitha Aldridge – Laboratory Auditor Gabriel Tanner – Laboratory Auditor Jack Wiedo – Laboratory Auditor 34

35. Questions ? 35

36. 36 Contact Information Patrick J. Garrity Laboratory Certification Officer Division of Water 200 Fair Oaks Lane; 4 th Floor Frankfort, KY 40601 Phone: (502) 564-3410 Fax: (502) 564-2741 Email: patrick.garrity@ky.gov