DOW Laboratory Certification Program Update – 2013

1. DOW Laboratory Certification Program Update – 2013 Presentation to:KWWOA April 17, 2013 Department for Environmental ProtectionEnergy & Environment Cabinet To Protect and Enhance Kentucky’s Environment

2. Topics Program Update Microbiology Update Common Audit Findings Summary

3. Drinking Water Program Update Program In-state Out-of-state Chemistry Labs 15 36 Microbiology Labs 45 2 Cryptosporidium 2 0 Radionuclides 0 9 Dioxin 0 6 Asbestos 1 3 PCBs (EPA508A) 0 2

4. 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)

5. 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. On-site Laboratory Audits • Both Chemistry and Microbiology laboratories will be audited at least twice every three years • Cryptosporidium audits have been completed for 2013. Laboratories will be audited at least once during upcoming LT2 monitoring (2015) • Announced and Unannounced Audits

7. Upcoming Cryptosporidium LT2 • All previously certified Cryptosporidium certified laboratories must recertify for 2015 • Check USEPA website for a list of currently certified Cryptosporidium laboratories • Contact DOW if you have any questions regarding Cryptosporidium certification

8. Laboratory Accountability Program • DOW will continue to utilize the Laboratory Accountability Program for laboratory reporting errors that are submitted to the state • Laboratory Accountability Program has contributed to the reduction of the number of violations issued to public water systems

9. 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 2013

10. Technical Assistance • Updated list of certified laboratories • Updated method – analyte code list • DOC Worksheet (IDC, MDL & RLS) • Control Charts – worksheet template • Contact DOW with any ideas for future technical assistance tools

11. 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

12. Microbiology Program Update • Dr. Pass and Ms. Rita Wright are no longer associated with Morehead State University (MSU) • DOW stills utilizes MSU as State Principle Microbiology Laboratory • Dr. Pass is a contract employee with DOW • Ms. Rita Wright is affiliated with Fouser Environmental Services (Versailles, KY)

13. Microbiology Program Update • DOW has established: • Initial Requirements for a Drinking Water Microbiology Laboratory • Microbiology Analyst Approval Process • DOW does not track CEUs – laboratories are required to maintain all training records for review during on-site audit or upon request

14. Commonly Found Audit Findings General Findings Chemistry Microbiology

15. General Audit Findings • KY regs capture SM 18th, 19th, 20th & 21st Ed. • All methods must be performed as written, including all quality control criteria • Use of Standard Methods must include QC criteria from Chapters 1020, 2020, 3020, etc. • Maintain sample integrity at all times • Chain of Custody must be complete/signed • Internal laboratory sample tracking record

16. 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!

17. 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) • MDLs – annually (2-3 non-consecutive days) • IDC – performed by each analyst initially • ODC – performed by each analyst annually

18. 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) • Fluoride probe must be placed in sample before stirring begins – to reduce air bubbles

19. 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

20. Microbiology Audit Summary (cont) • Supervisors and QA Managers must meet credential requirements listed in EPA Manual • SOPs / QAMs 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

21. 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

22. Questions ?

23. Contact Information Patrick J. Garrity Laboratory Certification Officer Division of Water200 Fair Oaks Lane; 4th Floor Frankfort, KY 40601 Phone: (502) 564-3410 Fax: (502) 564-2741 Email: patrick.garrity@ky.gov