EPA-815-N-00-001a, January 2000
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 |
|
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 |
|
|
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% |
|
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) |
|
|
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 |
|
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 |
|
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 |
|
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
.
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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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