dow laboratory certification program update – 2014 presentation to: kwwoa april 9, 2014 department...
TRANSCRIPT
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 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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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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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 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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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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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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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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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: [email protected]