United States
Environmental Protection
Agency
Office of Ground Water
and Drinking Water
Cincinnati, OH 45268
EPA-815-N-OQ-OO T a
January 2000
&EPA Labcert Bulletin
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
(DBF), 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. Again, we have included a FAX sheet to
update or add your name to our mailing list.
Ed Click 513 569-7939, glick.ed@epa.gov
Pat Hurr 513 569-7678, hurr.pat@epa.gov
Carol Madding 513569-7402,
madding.caroline@epa.gov
USEPA
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
FAX: 513 569-7191
In This Issue
Laboratory Certification
Requirements - Final Rule
Analytical Method EPA 314.0
Announced,
Latest Regulated Drinking Water
Contaminants Table
PT Q&A's
NELAC/EPA PT Requirements
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.
FAX IT TO US
Please add/change (circle one) my name to/on the
Lab Cert Bulletin mailing list.
Name
Company
Address
Telephone
Fax#
Email
Fax to:
Susan Hagedorn
USEPA-TSC
26 W. M.L. King Drive
Cincinnati, OH 45268
513-569-7191
Printed on Recycled Paper
-------
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 (DBF) Rule, the Unregulated
Contaminant Monitoring Rule (UCMR), and the
Methods Update Federal Register Notice 2. This
article gives an overview of the DBF, TOC rule.
MUFRN 2 is discussed on the next page. For more
detailed information, see the OGWDW website:
http://www.epa.gov/OGWDW.
The DBF 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 HAAS 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 625 IB (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 1C
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
(MUFRN2)
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 conforms 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-ColiBlue24® and E*Colite®, for the
simultaneous detection of total coliform and& 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 10°C
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 MethodlOOl 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 "2,4-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 hi 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-Cf B for chloride and
ASTM D 516-90 and SM 4500-SO42~ E for sulfate.
What is next? The next method approval actions
may include additional or new methods for
contaminants listed hi 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:
http://www.epa.gov/safewater/standards.html.
Click on "What's New", then on the blue type under
"December2, 1999."
-------
REGULATED DRINKING WATER CONTAMINANTS1
INORGANICS
RADIOCHEMICALS
MICRO
PARAMETER
REGULATED
Alkalinity5
Asbestos
Residual Disinfectant6
Chlorine
Chloramines
Chlorine Dioxide
Cyanide
Fluoride7
Nitrate (as N)
Nitrite (as N)
Nitrate/Nitrite (as N)
o-Phosphate5
Turbidity
Adjusted Gross Alpha
Beta Particle Emitters
radioactive Cesium
radioactive Iodine
radioactive Strontium 89, 90
tritium
gamma emitters
Radium-226
Radium-228
Uranium
Total Coliform
E. coli
Fecal Coliform
MCL/
[SMCL]2
mg/L
-
7MF/L>10//m
(MRDL)6
4 (as CI2)
4 (as CI2)
0.8 (as QOj)
0,2
4.0
[2.0]
10
1
10
Treatment
15pCi/L
4 mr ede/yr
-
'
'-
-
-
20 pCi/L
20pCi/L
0.02
100/lOOmL
5% positive
samples/mo12
§141.21(1)
(6&7)
§141.21(f)(5)
§141.74(a)(l)
MCLG2
mg/L
-
7MF/L>10^m
(MRDLG)6
4 (as C12)
4 (as Cy
0.8 (as C1O2)
0.2
"
10
1
10
"
zero
zero
- •'••"
-
-
-
•-
zero
zero
zero
zero
zero
zero
METHODS3'4 ACCEPTANCE
LIMITS
D1067-92B, 2320B, 1-1030-85
100.1, 100.2
4500-C1 D, F, G and H
4500-C1 D, E, F, G and I
4500-C1O2 C, D, E
335.4, D2036-91B, D2036-91A,
4500-CN C, G, E and F, 1-3300-85
300.0, D4327-91, D1179-93B,
4110B, 4500F B, D, C and E,
Technicon 380-75WE and 129-71W
353.2, 300.0, D4327-91, D3867-90A&B
4110B, 4500-NO3 F, D and E,
Waters B-1011, ATI 601
353.2, 300.0, D4327-91, D3867-90A&B
4110B, 4500-NO3 F & E, 4500-NO2 B
Waters B-1011
-
365.1, 300.0, D515-88A, D4327-91,
4500-P F, 4500-P E, 4110 B,
1-1601-85, 1-2601-90, 1-2598-85
180.1, 2130B, G LI Method 2
900.0, 302, 7110 B,C
900.0, 302, 7110 B
901.0, 901.1, 7500-Cs B, 7120, D 2459-72,
D 3649-91
901.1 902.0,7500-1 B, C, D, 7120, D 3649-91,
D 4785-88
905.0, 303, 7500-Sr B
906.0, 306, 7500-3H B, D 4107-91
901.1, 902.0, 901.0, 7120, 7500-Cs B, 7500-1
B, D3649-91, D 4785-88
903.0, 903.1, 7500-Ra C 304,305, 7500-Ra B,
D3454-91, D2460-90
904.0, 7500-Ra D
908.0, 908.17500-UB, 7500-U C, D2907-91,
D3972-90, D5174-91
TCR (9221A,B,D, 9222A,B,C, E*Colite
9223, Colisure, -CoIiBlue24)
SWTR (9221A,B,C, 9222A,B,C, 9223)
Colilert, Colisure, EC-MUG
Nutrient Agar-MUG"
TCR (9221E Part 1)
SWTR (9221E Part 1&2, 9222D)
2SD
±25%
±10%
±10%
±15%
±50%
±30%
±30%
±30%
±30%
±20%
±30%
±50%
±30%
-------
t/J
O
U
y
ii
g
1
£
£
CQ
Q
PARAMETER
REGULATED
Benzene
Carbon tetracliloride
Chlorobenzene
p-Dichlorobenzene
o-DicWorobenzenc
1 ,2-Dkhloroethane
1,1-Dichloroethylene
c-1 ,2-Dichloroethylene
t-l,2-D5chloroethylene
Dichloromethane
1,2-DIchloropropanc
Ethyl benzene
Styrene
Tetrachlorocthylene
Toluene
1,2,4-Trkblorobenzene
1, 1, 1-Trichloroelhane
1 , 1 ,2-TrichIoroethane
Trichloroethylene
Vinyl chloride
XylenesCTotal)
Trihalomethanes (total)'
Haloacetic Acid 5 (HAAS) (total)'-10
Bromate*1"
Chlorite''12
MCL/
[SMCL]2
mg/L
0.005
O.OOS
0.1
0.075
[0.005]
0.6
0.005
0.007
0.07
0.1
0.005
0.005
0.7
0.1
0.005
1
0.07
0.2
0.005
0.005
0.002
10
0.08
0.06
0.010
1.0
MCLG2
mg/L
zero
zero
0.1
0.075
0.6
zero
0.007
0.07
0.1
zero
zero
0.7
0.1
zero
1
0.07
0.2
0.003
zero
zero
10
zero
0.8
METHODS3'4 ACCEPTANCE
LIMITS
502.2, 524.2
502.2, 524.2, 551.1
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2, 551.1
502.2, 524.2
502.2, 524.2
502.2, 524.2, 551.1
502.2, 524.2, 551.1
502.2, 524.2, 551.1
502.2, 524.2
502.2, 524.2
502.2, 524.2, 551.1
552.1, 552.2 SM 6251B
300.1
1300.0, 300.1
±20/40%8
±20/40%"
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
+20/40%8
95% CI11
95% CI11
95% CI11
95% CI11
-------
SYNTHETIC ORGANIC CONTAMINANTS
REGULATED
\AIachlor
Atrazine
Carbofuran
Chlordane
2,4-D (as acid salts and esters)
Dalapon
Dibromochloropropane
» Dinoseb
Diquat
Endothall
Endrin
Ethylenedibromide(EDB)
Glyphosate
Heptacblor
Heptachlor epoxide
Lindane
Methoxychlor
Oxamyl (Vydate)
Pentachlofophenol
Picloram
Simazme
Toxaphene
2,4,5-TP(Savex)
Hexachlorobenzene
Hexachlorocyclopentadiene
Benzo(a)pyrene
PCBs (as Aroclors)
(as decacblorobiphenyl)
2,3,7,8-TCDD( Dioxin)
Acrylamide
Epichlorohydrin
Di(2-ethylhexyl)adipate
Di(2-ethylhexyl)phthalate
[SMCL]2
mg/L
0.002
0.003
0.04
0.002
0.07
0.2
0.0002
0.007
0.02
0.1
0.002
0.00005
0.7
0.0004
0.0002
0.0002
0.04
0.2
0.001
0.5
0.004
0.003
0.05
0.001
0.05
0.0002
0.0005
3x10^
Treatment
Treatment
0.4
0.006
mg/L
zero
0.003
0.04
zero
0.07
0.2
zero
0.007
0.02
0.1
0.002
zero
0.7
zero
zero
0.0002
0.04
0.2
zero
0.5
0.004 -
zero
0.05
zero
0.05
zero
zero
zero
zero
zero
0.4
zero
METHODS3'4 ACCEPTANCE
LIMITS
505, 507,' 508.1, 525.2, 551.1
505, 507, 508.1, 525.2, 551.1
531.1,6610
505, 508, 508.1, 525.2
515.1, 515.2, 555, 515.3, D5317-93
515.1, 552.1, 552.2, 515.3
504.1,551.1
515.1, 515.2, 555, 515.3
549.2
548.1
505, 508, 508.1, 525.2, 551.1
504.1,551.1
547, 6651
505, 508, 508.1, 525.2, 551.1
505, 508, 508.1, 525.2, 551.1
505, 508, 508.1, 525.2, 551.1
505, 508, 508.1, 525.2, 551.1
531.1. 6610
515.1, 515.2, 525.2, 555, 515.3, D5317-93
515.1, 515.2, 555, 515.3, D5317-93
505, 507, 508.1, 525.2, 5551.1
505,508,525.2,508.1
515.1, 515.2, 555, 515.3, D5317-93
505, 508, 508.1, 525.2, 551.1
505, 508, .508.1, 525.2, 551.1
550,550.1,525.2
505,508,508.1,525.2
508A
1613
506,525.2
506,525.2
±45%
±45%
+45%
±45%
. +50%
2SD
±40%
2SD
2SD
2SD
+30%
±40%
2SD
±45%
±45%
±45%
+45%
2SD
+50%
2SD
2SD
±45%
+50%
2SD
2SD
2SD
0-200%
2SD
2SD
2SD
-------
METALS
PARAMETER
REGULATED
Aluminum7
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Copper5*7
Iron7
Lead5
Magnesium14
Manganese7
Mercury
Selenium
Silica5
Silver7
Sodium
Thallium
Zinc7
MCL/
[SMCL]2
mg/L
[0.05-0.2]
0.006
0.05
2
0.004
0.005
-
0.1
1.3/90%5
[1.0]
[0.3]
0.015/90%s
-
[0.05]
0.002
0.05
-
[0.1]
20
0.002
[5.0]
MCLG2
mg/L
-
0.006
-
2
0.004
0.005
-
0.1
1.3
-
zero
-
-
0.002
0.05
-
-
0.0005
-
METHODS3'4 ACCEPTANCE
LIMITS
200.7,200.8,200.9,3120B,3113B,3111D
200.8, 200.9, D-3697-92, 3113-B
200.7, 200.8, 200.9, D-2972-93C,
3120B, 3113B, 3114B, D-2972-93B
200.7, 200.8, 3120B, 3111D, 3113B
200.7, 200.8, 200.9, D-3645-93B,
3120B, 3113B
200.7, 200.8, 200.9, 3113B
200.7, D511-93A, D511-93B,
3500-Ca D, 3111B, 3120B
200.7, 200.8, 200.9, 3120B, 3113B
200.7, 200.8, 200.9, D1688-95C,
D1688-95A, 3113B, 3111B, 3120B
200.7, 200.9, 3120B, 3111B, 3113B
200.8, 200.9, D3559-95D, 3113B
200.7, D 511-93 A,B, 3111B, 3120 B, 3500-Mg
E
200.7, 200.8, 200.9, 3120B, 3113B, 3111B
245.1, 245.2, 200.8, D3223-91, 3112B
200.8, 200.9, D3859-93A, D3859-93B,
3114B, 3113B
200.7, D859-95, 4500-Si D,E,& F,
3120B, 1-1700-85, 1-2700-85
200.7, 200.8, 200.9,
3120B, 3111B, 3113B, 1-3720-85
200.7, 3111B, 3120B
200.8, 200.9
200.7, 200.8, 3120B, 3111B
±15%
±15%
±15%
±20%
±15%
±10%
±30%
±30%
±20%
±30%
1 - Tills method table is a convenient reference only; for details see the specific rule.
2 - MCL=maxlmum contaminant level; SMCL=sccondary 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=maxinium residual disinfectant level goal
7 • Secondary Maximum Contaminant Level - non-enforcable federal guideline
8 - PE Acceptance Limits for VOCs are ±20% at alO^g/L and ±40% at < 10^g/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 9S% 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 "Reserved". EPA has
finalized the refinement and review of the
analytical method for perchlorate and hi
November published EPA Method 314.0,
"Determination of Perchlorate in Drinking Water
Using Ion Chromatography," Revision 1.0.
This method is available on-line at
www.epa.gov/safewater/methods/sotircah.htmlor
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, "Unregulated 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
CertificationBulletin article provides noticeofthe
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
OGWDWRegulation 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 gaming 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.
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This request letter must include the following
infonnation:
(1) Laboratory Name
(2) Complete Laboratory Mailing
Address
(3) Ion chromatography analytical
method the laboratory is certified
to perform
(4) A 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.l40
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 provid
affect the acceptance criteria for th
Answer: Acceptance criteria are
from each provider's current s
are are based on regressions
results of studies conducted
1997. The size of any provider's
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 formaj
complaints process which requires them t
attempt to resolve all complaints. Should th
user not be satisfied with the provider's
proposed resolution they may then contact
National Voluntary Laboratory Accredita
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 hi 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
cojrespondence received from the provider in
.se.
Jft is understood that not all complaints can be
resolved between the user and provider due
to interpretations of the standard, scoring of
janalytes, and for many other reasons, but the
complaint system is in place and should be
used.
may also contact NVLAP directly if
.e isWconcern is not about, or related to,
rndivjiual provider but about the conduct
ir requirements of the program itself.
[uiries should be addressed to:
ST/NVLAP
Aiders of Proficiency Testing Program
Lureau Drive, Stop 2140
iburg, MD 20899-2140
Will any more providers be
Answejf: Yes, NIST will approve providers as
rney J|>|feN %fact, another provider, NSI has
just Deenapproved. 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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