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

Topics

Program Update

Microbiology Update

Common Audit Findings Summary

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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 23

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 2013. Laboratories will be audited at least once during upcoming LT2 monitoring (2015)

• Announced and Unannounced Audits

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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

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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

• 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 2013

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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

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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

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)

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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

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Commonly Found Audit Findings

General Findings

Chemistry

Microbiology

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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

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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)• 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)• Fluoride probe must be placed in sample

before stirring begins – to reduce air bubbles

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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 / 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

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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

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