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LabCert Bulletin

EPA-815-N-00-001a, January 2000

In This Issue

Regs, Regs, and More Regs

Just in time for your New Year=s reading, the drinking water Laboratory Certification Team at TSC, in an ever continuing effort to keep the certifying community well informed, has published yet another Laboratory Certification Bulletin. In this issue you will find information on the Unregulated Contaminant Monitoring Rule (UCMR), the Stage 1 Disinfectants and Disinfection By-Products Rule (DBP), and the second Methods Update Federal Register Notice (MUFRN 2). There is also a revised table listing the current analytical methods for each regulated analyte.

If there are certification topics you would like to see discussed, please call, write, fax or e-mail the editors.

Ed Glick 513 569-7939, glick.ed@epa.gov
Pat Hurr 513 569-7678, hurr.pat@epa.gov
Carol Madding 513 569-7402, madding.caroline@epa.gov
USEPA
Technical Support Center (MS-140)
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
FAX: 513 569-7191

Colisure Certification

We have been asked if a laboratory is certified for the Colilert test and wants to use the Colisure test also, is the laboratory certified for the Colisure test?

Our microbiologist colleagues arrived at the following consensus: because of the similarity of these two chromogenetic/flourogenic methods, a laboratory certified for Colilert should be capable of performing Colisure and can be considered certified for both. The critical elements specific to Colisure are that the Colisure medium must be refrigerated until use and brought to room temperature before adding the sample; the samples must be incubated for 24 hours; and a positive total coliform test is indicated by a magenta color. The laboratory should be encouraged to analyze performance testing (PT) samples, run positive and negative controls, and analyze a series of samples by both Colilert and Colisure.

Drinking Water Regulations Affecting Certification

Three regulations which affect drinking water certification were passed recently. They are the Stage 1 Disinfectants and Disinfection By-Product (DBP) Rule, the Unregulated Contaminant Monitoring Rule (UCMR), and the Methods Update Federal Register Notice 2. This article gives an overview of the DBP, TOC rule. MUFRN 2 is discussed on the next page. For more detailed information, see the OGWDW website at www.epa.gov/safewater.

The DBP Rule is the first new drinking water standard in six years. It was promulgated in December 1998 and becomes effective for large surface water systems in December 2001, and for ground water systems and small surface water systems in December 2003. The Rule lowers the MCL for TTHMs to 0.08 mg/L and sets the MCL for HAA5 at 0.06 mg/L. Haloacetic acids (five) is the sum of the concentrations of mono-, di-, and trichloroacetic acids and mono- and dibromoacetic acids. It also sets MCLs of 0.01 mg/L for bromate and 1.0 mg/L for chlorite. The Rule requires that laboratories be certified for these analyses. Methods required for analysis of HAAs are EPA 552.1 or 552.2 or SM 6251B (552.2 is recommended over 552.1). Laboratories must use EPA Methods 300.0 or 300.1 to determine chlorite and Method 300.0 to determine bromate.

The UCMR was promulgated on September 17, 1999 and will take effect in 2001-2003. This is not a primacy rule, rather it is direct implementation. This means that USEPA will take the lead for implementing it, but we are counting on assistance from the states. It involves all large utilities (>10,000 population served) and 800 small utilities (<10,000 population served). Large utilities will be responsible for their own monitoring, but USEPA will be responsible for analyzing the samples from the 800 small utilities, which will be chosen at random. The Rule covers the contaminants currently on the Contaminant Candidate List (CCL) and is divided into 3 categories: Assessment, Screening and Prescreening.

The Assessment category contains 11 analytes that have currently approved methods, and perchlorate. Certification requirements are that samples must be analyzed by a laboratory already certified for the method which must be used to determine the contaminant. For perchlorate, USEPA will approve laboratories that currently are certified for any IC method and pass a PT sample.

Both Screening and Prescreening studies will be proposed and promulgated in future regulations.

Mea Culpa, Mea Culpa

We have just learned that Absolute Standards was accredited by NIST to provide TOC samples but was inadvertently left off of both the NIST list on the web and our list in the previous bulletin. Please revise your list.

It was noted in our list of providers that New York does not intend to sell PT samples to the public. New York became accredited to be able to supply PT samples to those wanting New York NELAC accreditation but does not wish to compete with private industry. However, New York will sell asbestos PT samples to the public since it is the only asbestos provider accredited by NIST.

Analytical Methods for Chemical and Microbiological Contaminants
and Revisions to Laboratory Certification Requirements - Final Rule
(MUFRN 2)

The Environmental Protection Agency (EPA) specifies analytical methods at Part 141 of Title 40 of the Code of Federal Regulations that are to be used in compliance monitoring of drinking water. Periodically, the Agency amends these regulations to revise or replace these methods based on user suggestions, changing regulatory needs or improvements in technology. On December 1, 1999 EPA published a final rule in the Federal Register (64 FR 67450) to approve several updated or new drinking water methods for chemical and microbiological contaminants, and to amend some laboratory certification and sample holding time requirements. Except for withdrawal of certain older methods, the effective date for these amendments is January 3, 2000.

The December 1, 1999 rule allows use of updated versions of several microbiology and chemistry methods for compliance with drinking water standards and monitoring requirements. These updated methods include 13 EPA methods that are published in Supplement III of "Methods for the Determination of Organic Compounds in Drinking Water," EPA/600/R-95/131, August 1995, NTIS PB95-261616; 25 American Society for Testing and Materials (ASTM) methods that are published in Vols. 11.01 and 11.02 of the 1996 Annual Book of ASTM Standards; and 54 methods that are published in the 19th edition of Standard Methods for the Examination of Water and Wastewater (1995). Compared to the currently approved versions, the new versions contain primarily editorial, technical or other changes that make the method easier to conduct or safer. EPA will withdraw earlier versions of the EPA methods on June 1, 2001, which is 18 months after publication of this rule. Earlier versions of approved methods published by ASTM and Standard Methods are not withdrawn and continue to be approved for compliance monitoring.

EPA is also approving two new methods, EPA 515.3 and ASTM D5317-93, for acid herbicides. EPA is not withdrawing approval of EPA 515.1 or 515.2 for determination of acid herbicides, because these methods are not obsolete. EPA will withdraw EPA 549.1 on June 1, 2001 for determinations of Diquat, because the method has been replaced with an improved version, EPA 549.2. Methods 515.3 and 549.2 are not published in an EPA manual. The methods are available from U.S. EPA, NERL-CI (MS 564), 26 West Martin Luther King Drive, Cincinnati, OH 45268.

EPA is approving the use of a new membrane filter medium, MI Agar, for the determination of the presence of total coliforms and E. Coli in drinking water under the Total Coliform Rule (TCR). MI Agar is also approved for the enumeration of total coliforms in source water under the Surface Water Treatment Rule (SWTR). EPA is approving two new tests, m-ColiBlue247 and E*Colite7, for the simultaneous detection of total coliform and E. coli in drinking water under the TCR. Because the latter two methods are presence/absence tests, they are not applicable for enumerations under the SWTR. The rule requires that microbiological source water samples collected under the SWTR for the determination of coliform and fecal coliform or for determination of heterotrophic bacteria in distribution system samples be held below 10EC during transit and storage.

EPA is allowing a choice of six methods (ASTM D 511-93 A and B, EPA 200.7, and SM 3111 B, 3120B and 3500 Mg E) for determination of magnesium. Magnesium determinations will be required of systems that elect to use the magnesium control alternative to the total organic carbon removal requirements of the 1998 Stage One Disinfection By-Products Rule.

EPA is approving use of Palintest Method1001 for determinations of total lead under the Lead and Copper Rule. The Palintest method uses a differential pulse anodic stripping voltammetry (DPASV) technique which requires an acid digestion regardless of the turbidity of the sample. Readers are reminded that there are now three technologies for which compliance determinations of total metals require an acid digestion of the sample even if the turbidity of the sample is less than 1 NTU. The three technologies and the applicable metals are DPASV (lead), cold vapor AA (mercury), and gaseous hydride AA (antimony, arsenic and selenium). For this reason, it will be difficult to conduct analyses in the field using these techniques.

This rule makes minor technical corrections and clarifications to the regulations. The rule: (1) clarifies that usually one may have up to 14-days from the date of the second analysis to report follow-up composite sample analyses, (2) amends the holding times for asbestos, nitrate and total nitrate that are specified in the table at '141.23(k)(2); (3) changes 2,4-D to A2,4-D as acid salt and ester@ in the table at '141.24(e), (4) clarifies that the acceptance limits for successfully measuring chemical analytes in a performance evaluation (PE) sample apply only if that analyte has been added to the PE sample, and (5) allows determinations of alkalinity, calcium, conductivity, orthophosphate and silica in drinking water samples by any person acceptable to the State to conduct these determinations. The rule also amends the regulations to codify some of the provisions in the 1997 Drinking Water Laboratory Certification Manual. These amendments include a requirement to demonstrate proficiency by successful analysis of a PE sample each year for chemical contaminants using the same analytical method that is used to report compliance monitoring results.

Finally, the rule amends the table at '143.4(b) to recommend additional methods for monitoring of chloride and sulfate. These chemicals are regulated under the National Secondary Drinking Water Regulations. The additional methods are ASTM D 512-89B and SM 4500-ClG B for chloride and ASTM D 516-90 and SM 4500-SO42G E for sulfate.

What is next? The next method approval actions may include additional or new methods for contaminants listed in the 1999 Unregulated Contaminants Monitoring Rule, and updated methods for chemical, microbiological and radionuclide contaminants. The update rule is expected to propose approval of both wastewater and drinking water methods that are published in the 1999 Annual Book of ASTM Standards, Vols. 11.01 and 11.02 and in the 20th edition of Standard Methods for Examination of Water and Wastewater (1998).

The complete rule can be found at: www.epa.gov/safewater/regs.html. Click on the blue HTML at the December 1, 1999 rule.

REGULATED DRINKING WATER CONTAMINANTS1

 

PARAMETER
REGULATED
MCL/ [SMCL]2
mg/L
MCLG2
mg/L

METHODS3,4

ACCEPTANCE LIMITS
inorganics Alkalinity5     D1067-92B, 2320B, I-1030-85  
Asbestos 7MF/L>10Fm 7MF/L>10Fm 100.1, 100.2 2SD
Residual Disinfectant6
Chlorine
Chloramines
Chlorine Dioxide
(MRDL)6
4 (as Cl2)
4 (as Cl2)
0.8 (as ClO2)
(MRDLG)6
4 (as Cl2)
4 (as Cl2)
0.8 (as ClO2)

4500-Cl D, F, G and H
4500-Cl D, E, F, G and I
4500-ClO2 C, D, E
 
Cyanide 0.2 0.2 335.4, D2036-91B, D2036-91A,
4500-CN C, G, E and F, I-3300-85
±25%
Fluoride7 4.0
[2.0]
  300.0, D4327-91, D1179-93B,
4110B, 4500F B, D, C and E,
Technicon 380-75WE and 129-71W
±10%
Nitrate (as N) 10 10 353.2, 300.0, D4327-91, D3867-90A&B
4110B, 4500-NO3 F, D and E,
Waters B-1011, ATI 601
±10%
Nitrite (as N) 1 1 353.2, 300.0, D4327-91, D3867-90A&B
4110B, 4500-NO3 F & E, 4500-NO2 B
Waters B-1011
±15%
Nitrate/Nitrite (as N) 10 10    
o-Phosphate5     365.1, 300.0, D515-88A, D4327-91,
4500-P F, 4500-P E, 4110 B,
I-1601-85, I-2601-90, I-2598-85
 
Turbidity Treatment   180.1, 2130B, G LI Method 2  
radio chemicals Adjusted Gross Alpha 15 pCi/L zero 900.0, 302, 7110 B, C ±50%
Beta Particle Emitters 4 mr ede/yr zero 900.0, 302, 7110 B ±30%
radioactive Cesium     901.0, 901.1, 7500-Cs B, 7120, D 2459-72,
D 3649-91
±30%
radioactive Iodine     901.1 902.0,7500-I B, C, D, 7120, D 3649-91, D 4785-88 ±30%
radioactive Strontium 89, 90     905.0, 303, 7500-Sr B ±30%
tritium     906.0, 306, 7500-3H B, D 4107-91 ±20%
gamma emitters     901.1, 902.0, 901.0, 7120, 7500-Cs B, 7500-I B, D3649-91, D 4785-88  
Radium-226 20 pCi/L zero 903.0, 903.1, 7500-Ra C 304,305, 7500-Ra B, D3454-91, D2460-90 ±30%
Radium-228 20 pCi/L zero 904.0, 7500-Ra D ±50%
Uranium 0.02 zero 908.0, 908.17500-U B, 7500-U C, D2907-91, D3972-90, D5174-91 ±30%
micro Total Coliform 100/100mL
5% positive samples/mo12
zero TCR (9221A,B,D, 9222A,B,C, E*Colite
9223, Colisure, CColiBlue24)
SWTR (9221A,B,C, 9222A,B,C, 9223)
 
E. coli '141.21(f)
(6&7)
zero Colilert, Colisure, EC-MUG
Nutrient Agar-MUG11
 
Fecal Coliform '141.21(f)(5)
'141.74(a)(1)
zero TCR (9221E Part 1)
SWTR (9221E Part 1&2, 9222D)
 
volitile organic compounds Benzene 0.005 zero 502.2, 524.2 ±20/40%8
Carbon tetrachloride 0.005 zero 502.2, 524.2, 551.1 ±20/40%8
Chlorobenzene 0.1 0.1 502.2, 524.2 ±20/40%8
p-Dichlorobenzene 0.075
[0.005]
0.075   502.2, 524.2 ±20/40%8
o-Dichlorobenzene 0.6 0.6 502.2, 524.2 ±20/40%8
1,2-Dichloroethane 0.005 zero 502.2, 524.2 ±20/40%8
1,1-Dichloroethylene 0.007 0.007 502.2, 524.2 ±20/40%8
c-1,2-Dichloroethylene 0.07 0.07 502.2, 524.2 ±20/40%8
t-1,2-Dichloroethylene 0.1 0.1 502.2, 524.2 ±20/40%8
Dichloromethane 0.005 zero 502.2, 524.2 ±20/40%8
1,2-Dichloropropane 0.005 zero 502.2, 524.2 ±20/40%8
Ethyl benzene 0.7 0.7 502.2, 524.2 ±20/40%8
Styrene 0.1 0.1 502.2, 524.2 ±20/40%8
Tetrachloroethylene 0.005 zero 502.2, 524.2, 551.1 ±20/40%8
Toluene 1 1 502.2, 524.2 ±20/40%8
1,2,4-Trichlorobenzene 0.07 0.07 502.2, 524.2 ±20/40%8
1,1,1-Trichloroethane 0.2 0.2 502.2, 524.2, 551.1 ±20/40%8
1,1,2-Trichloroethane 0.005 0.003 502.2, 524.2, 551.1 ±20/40%8
Trichloroethylene 0.005 zero 502.2, 524.2, 551.1 ±20/40%8
Vinyl chloride 0.002 zero 502.2, 524.2 ±20/40%8
Xylenes(Total) 10 10 502.2, 524.2 ±20/40%8
dbp's Trihalomethanes (total)9 0.08   502.2, 524.2, 551.1 95% CI11
Haloacetic Acid 5 (HAA5) (total)9,10 0.06   552.1, 552.2 SM 6251B 95% CI11
Bromate9,11 0.010 zero 300.1 95% CI11
Chlorite9,12 1.0 0.8 1300.0, 300.1 95% CI11
synthetic organic contaminants Alachlor 0.002 zero 505, 507, 508.1, 525.2, 551.1 ±45%
Atrazine 0.003 0.003 505, 507, 508.1, 525.2, 551.1 ±45%
Carbofuran 0.04 0.04 531.1, 6610 ±45%
Chlordane 0.002 zero 505, 508, 508.1, 525.2 ±45%
2,4-D (as acid salts and esters) 0.07 0.07 515.1, 515.2, 555, 515.3, D5317-93 ±50%
Dalapon 0.2 0.2 515.1, 552.1, 552.2, 515.3 2SD
Dibromochloropropane 0.0002 zero 504.1, 551.1 ±40%
Dinoseb 0.007 0.007 515.1, 515.2, 555, 515.3 2SD
Diquat 0.02 0.02 549.2 2SD
Endothall 0.1 0.1 548.1 2SD
Endrin 0.002 0.002 505, 508, 508.1, 525.2, 551.1 ±30%
Ethylenedibromide(EDB) 0.00005 zero 504.1, 551.1 ±40%
Glyphosate 0.7 0.7 547, 6651 2SD
Heptachlor 0.0004 zero 505, 508, 508.1, 525.2, 551.1 ±45%
Heptachlor epoxide 0.0002 zero 505, 508, 508.1, 525.2, 551.1 ±45%
Lindane 0.0002 0.0002 505, 508, 508.1, 525.2, 551.1 ±45%
Methoxychlor 0.04 0.04 505, 508, 508.1, 525.2, 551.1 ±45%
Oxamyl (Vydate) 0.2 0.2 531.1. 6610 2SD
Pentachlorophenol 0.001 zero 515.1, 515.2, 525.2, 555, 515.3, D5317-93 ±50%
Picloram 0.5 0.5 515.1, 515.2, 555, 515.3, D5317-93 2SD
Simazine 0.004 0.004 505, 507, 508.1, 525.2, 5551.1 2SD
Toxaphene 0.003 zero 505, 508, 525.2, 508.1 ±45%
2,4,5-TP(Silvex) 0.05 0.05 515.1, 515.2, 555, 515.3, D5317-93 ±50%
Hexachlorobenzene 0.001 zero 505, 508, 508.1, 525.2, 551.1 2SD
Hexachlorocyclopentadiene 0.05 0.05 505, 508, 508.1, 525.2, 551.1 2SD
Benzo(a)pyrene 0.0002 zero 550, 550.1, 525.2 2SD
PCBs (as Aroclors) (as decachlorobiphenyl) 0.0005 zero 505, 508, 508.1, 525.2, 508A  0-200%
2,3,7,8-TCDD( Dioxin) 3x10-8 zero 1613 2SD
Acrylamide Treatment zero    
Epichlorohydrin Treatment zero    
 Di(2-ethylhexyl)adipate 0.4 0.4 506, 525.2 2SD
Di(2-ethylhexyl)phthalate 0.006 zero 506, 525.2 2SD
metals Aluminum7 [0.05-0.2]   200.7,200.8,200.9,3120B,3113B,3111D  
Antimony 0.006 0.006 200.8, 200.9, D-3697-92, 3113-B ±15%
Arsenic 0.05   200.7, 200.8, 200.9, D-2972-93C,
3120B, 3113B, 3114B, D-2972-93B
 
Barium 2 2 200.7, 200.8, 3120B, 3111D, 3113B ±15%
Beryllium 0.004 0.004 200.7, 200.8, 200.9, D-3645-93B,
3120B, 3113B
±15%
Cadmium 0.005 0.005 200.7, 200.8, 200.9, 3113B ±20%
Calcium     200.7, D511-93A, D511-93B,
3500-Ca D, 3111B, 3120B
 
Chromium 0.1 0.1 200.7, 200.8, 200.9, 3120B, 3113B ±15%
Copper5,7 1.3/90%5
[1.0]
1.3 200.7, 200.8, 200.9, D1688-95C,
D1688-95A, 3113B, 3111B, 3120B
±10%
Iron7 [0.3]   200.7, 200.9, 3120B, 3111B, 3113B  
Lead5 0.015/90%5 zero 200.8, 200.9, D3559-95D, 3113B ±30%
Magnesium14     200.7, D 511-93 A,B, 3111B, 3120 B, 3500-Mg E  
Manganese7 [0.05]   200.7, 200.8, 200.9, 3120B, 3113B, 3111B  
Mercury 0.002 0.002 245.1, 245.2, 200.8, D3223-91, 3112B ±30%
Selenium 0.05 0.05 200.8, 200.9, D3859-93A, D3859-93B,
3114B, 3113B
±20%
Silica5     200.7, D859-95, 4500-Si D,E,& F,
3120B, I-1700-85, I-2700-85
 
Silver7 [0.1]   200.7, 200.8, 200.9,
3120B, 3111B, 3113B, I-3720-85
 
Sodium 20   200.7, 3111B, 3120B  
Thallium 0.002 0.0005 200.8, 200.9 ±30%
Zinc7 [5.0]   200.7, 200.8, 3120B, 3111B  

1. This method table is a convenient reference only; for details see the specific rule.
2. MCL=maximum contaminant level; SMCL=secondary maximum contaminant level; MCLG=maximum contaminant level goal.
3. Secondary contaminants may be analyzed using the recommended methods and do not have to be analyzed in a certified laboratory; primary, unregulated (monitoring only) and state discretionary contaminants must be analyzed using approved methods in laboratories certified by the States.
4. For method references, see 59 FR 62456, December 5, 1994 and Technical Notes on Drinking Water Methods, EPA-600/R-94-173, October, 1994.
5. Lead and Copper Rule - promulgated 6-7-91; lead and copper levels are Action Levels.
6. M-DBP Rule- MRDL=maximum residual disinfectant level; MRDLG=maximum residual disinfectant level goal.
7. Secondary Maximum Contaminant Level - non-enforcable federal guideline.
8. PE Acceptance Limits for VOCs are "20% at $10Fg/L and "40% at <10Fg/L.
9. M-DBP Rule - promulgated 12-16-98.
10. Includes 5 HAAs - monochloro, dichloro, trichloro, bromo, and dibromo acetic acids.
11. For plants that use ozone to disinfect.
12. For plants that use chlorine dioxide to disinfect.
13. Laboratories must achieve quantitative results within the acceptance limits on 80% of the analytes included in the PT sample. Acceptance is defined as within the 95% confidence interval around the mean of the PT study data.
14. M-DPR Rule allows Mg to be used as a surrogate for TOC.

Announcement of the Analytical Method (EPA Method 314.0)
and Laboratory Approval Process to Support Perchlorate
Monitoring for the Unregulated Contaminant Monitoring Rule

The Safe Drinking Water Act (SDWA), as amended in 1996, requires the U.S. Environmental Protection Agency (EPA) to establish criteria for a program to monitor unregulated contaminants and to publish a list of specific contaminants to be monitored. In fulfillment of this requirement, EPA published this list, which included the anion perchlorate, in the Revisions to the Unregulated Contaminant Monitoring Rule (UCMR) on September 17, 1999 (64 FR 50556).

At that time, perchlorate was placed on the UCMR (1999) List 1 for Assessment Monitoring, with the method listed as AReserved@. EPA has finalized the refinement and review of the analytical method for perchlorate and in November published EPA Method 314.0, ADetermination of Perchlorate in Drinking Water Using Ion Chromatography,@ Revision 1.0.

This method is available on-line at www.epa.gov/safewater/methods/sourcalt.html or by contacting the Safe Drinking Water Hotline at 1-800-426-4791.

As this article was being prepared, a Direct Final Rule was being finalized for subsequent publication in the Federal Register identifying this analytical method as the approved perchlorate method and describing the laboratory approval process. This Rule is tentatively scheduled to be published in 40 CFR Part 141 in early 2000 and is titled, AUnregulated Contaminant Monitoring Regulation for Public Water Systems; Analytical Methods for Perchlorate and Acetochlor; Announcement of Laboratory Approval and Performance Testing (PT) Program for the Analysis of Perchlorate.@ This Laboratory Certification Bulletin article provides notice of the availability of the approved method and also summarizes the pending requirements for attaining laboratory approval to perform this perchlorate analysis. Please look for a more detailed description of the Rule in the Federal Register which can be accessed from the OGWDW Regulation and Guidance web page on-line at www.epa.gov/safewater/regs.html.

Laboratories interested in becoming approved to perform this perchlorate analysis must: (1) Follow EPA Method 314.0; (2) be certified by the appropriate primacy agency for any inorganic anion(s) using an approved ion chromatographic method (such as nitrate analysis by EPA Method 300.0); and (3) attain EPA laboratory approval by participating and passing an EPA coordinated perchlorate Performance Testing (PT) Program.

Any laboratory wishing to participate in the perchlorate PT Program and subsequently obtain approval must submit a request letter to EPA by March 31, 2000. Any interested laboratory, which does not meet this deadline or fails to successfully pass the initial PT study but still wishes to be approved for this perchlorate analysis, will need to submit a request letter by September 1, 2000 in order to be eligible for a second PT study. EPA will not consider any laboratory request letters received after September 1, 2000. Any laboratory gaining approval in the first PT study will not be required to participate in the second PT study. These will be the only two perchlorate PT studies offered, through December 31, 2003. Any laboratory which does not request participation by September 1, 2000 or fails to pass one of these two PT studies can not be approved to analyze perchlorate under UCMR monitoring. The request letter must be signed by the laboratory manager with a statement that the laboratory is currently certified, by the appropriate primacy agency, to perform drinking water compliance monitoring using an approved ion chromatographic method. A copy of the letter or certificate issued by the state or primacy agency detailing this certification must also be submitted.

This request letter must include the following information:

(1) Laboratory Name
(2) Complete Laboratory Mailing Address
(3) Ion chromatography analytical method the laboratory is certified to perform
(4) Copy of the letter or certificate issued by the state or primacy agency which issued the certification to the laboratory
(5) Contact Person
(6) Contact Phone, FAX, and e-mail (if available)

The letter should be mailed to:

Perchlorate PT Program Coordinator
U.S.EPA, Rm.140
26 W. Martin Luther King Dr.
Cincinnati, Ohio 45268

Upon completion of the perchlorate PT Program, EPA will provide each successful laboratory with an approval letter identifying the laboratory by name and the approval date. This letter may then be presented to any Public Water System (PWS) as evidence of laboratory approval for perchlorate analysis supporting the UCMR. Laboratory approval is retained as long as the laboratory maintains certification to perform drinking water compliance monitoring using an approved ion chromatographic method. If a laboratory maintains this certification, the laboratory is approved for perchlorate analysis through January 28, 2004.

Drinking Water Laboratory Certification
and NELAC PT Requirements

Recently the Office of Ground Water and Drinking Water promulgated a rule (MUFRN 2) requiring laboratories to successfully analyze a PT sample once a year by the method they are using to report compliance data. The requirement does not extend to methods used for confirmation.

The Office believes this is simply good science and does not believe this is a change in drinking water certification policy. The Laboratory Certification Manual states this requirement in Chapter 3.

While EPA requires laboratories to successfully analyze a PT sample once a year for each method used for compliance data reporting, current NELAC standards require laboratories to successfully analyze a PT sample twice a year for each analyte by any method in use in the laboratory. If a laboratory uses two methods for an analyte, both NELAC and EPA requirements could be met if the laboratory uses a different method for each of the NELAC required studies Since there are few contaminants in the drinking water program that have more than two methods this would meet both drinking water and NELAC requirements .

Proficiency Testing (PT) Questions and Answers

It is a whole new world for proficiency testing and we are getting questions by the dozens. Here with the answers are two of the most frequently asked.

Question: Does the size of a provider=s study affect the acceptance criteria for that study?

Answer: Acceptance criteria are not generated from each provider=s current study, rather they are are based on regressions developed from results of studies conducted from 1993 thru 1997. The size of any provider=s study does not have an impact on these criteria.

Question: Whom should a laboratory contact regarding a PT provider=s performance and what issues may be addressed?

Answer: Users of accredited providers should first attempt to resolve issues/discrepancies directly with that provider, perhaps informally, or by filing a formal complaint with the provider in question. Accredited providers are required to have a formal complaints process which requires them to attempt to resolve all complaints. Should the user not be satisfied with the provider=s proposed resolution they may then contact the National Voluntary Laboratory Accreditation Program (NVLAP) for assistance. It is important to note that NVLAP is the responsible authority within the National Institute of Testing and Standards (NIST), not NIST in general. They should send a letter to NVLAP clearly identifying the provider, describing the problem/concern, etc., and details of all actions taken thus far. This would include copies of the formal complaint filed with the provider and any correspondence received from the provider in response.

It is understood that not all complaints can be resolved between the user and provider due to interpretations of the standard, scoring of analytes, and for many other reasons, but the complaint system is in place and should be used.

Users may also contact NVLAP directly if the issue/concern is not about, or related to, an individual provider but about the conduct or requirements of the program itself.

All inquiries should be addressed to:

NIST/NVLAP
Providers of Proficiency Testing Program
100 Bureau Drive, Stop 2140
Gaithersburg, MD 20899-2140

Question: Will any more providers be approved?

Answer: Yes, NIST will approve providers as they apply. In fact, another provider, NSI has just been approved. You can find more information on the NIST web site, http://ts.nist.gov/ts/htdocs/210/214/214.htm.

Definition: User - Any customer of a provider or others who depend on the results of the PT study.


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