"Lighting the way
through the ICR."
ICR Update '97
ICR Update
Jim Walasek, Editor
Technical Support Center
June 1997
ICR Update ISSUe Number 3 - This information sheet, the ICR Update, is
the third one to be issued by the Technical Support Center (TSC) of the Office of Ground Water
and Drinking Water (OGWDW). Future issues will be distributed as needed to maintain
information flow related to the ICR.
Chem Lab Approval Nearing Completion - TSC is continuing
to process applications and as of May 27,1997, 332 labs had been approved for chemical
parameters other than TOC. The list contains 56 commercial, 15 state, 256 utility, and five labs
classified as "other." Recall that there are 20 different parameters for which approval is granted
with a total of 52 different method/analyte combinations (labs may not necessarily receive
approval for all parameters at the same time). Therefore, current approvals represent 3247
method/analyte group approval decisions. Remember, the list of approved labs is available from
the Safe Drinking Water Hotline (800-426-4791) or browse the OGWDW Home Page on the
Internet at http://www.epa.gov/OGWDW/regs.html (look for the Information Collection Rule
hypertext).
Finally, if you are a water utility and you have not yet applied for approval for the water
quality parameters, please contact the ICR Laboratory Coordinator at TSC Immediately (this is
important)! The only alternative is to contract with an ICR approved commercial lab to perform
these analyses on-site.
More Virus Laboratories Approved-The fmaiiist of virus
laboratories is not expected until mid-June when the last data are due from the second round of
performance evaluation (PE) samples. However, some laboratories got their data in early and
have already been approved. Currently, 21 analysts from eleven labs (3 commercial, 3 utility, 2
state/city, and 3 university labs) are approved. Approval is granted based on the completion of
an application, an on-site evaluation and successful analysis of PE samples. As always, the list of
laboratories will be available through the Safe Drinking Water Hotline and also appears on the
OGWDW Home Page.
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PrOtOZOa Laboratory Approval - ISC has completed a second round of
PE samples for protozoan laboratory approval. At this time fifty-one analysts from thirty
laboratories have been approved to perform protozoan analyses for the ICR. The list includes
nine commercial, sixteen utility, two state, and three city laboratories.
The approval process included submission of an application, an on-site lab evaluation,
and analysis of eight performance evaluation (PE) samples. The revised list of laboratories was
forwarded to the Safe Drinking Water Hotline (800-426-4791) on May 27th.
Deadline for Coliform Lab Approval Imminent -
Applications for Coliform laboratory approval will not be accepted after June 15th. And no
coJiform laboratories will be approved after the start of monitoring. Therefore, utilities which do
not have an approved laboratory in-house will be required to send their samples to an ICR
approved laboratory 'for analysis.
Approval letters were sent out on May 7th to twelve additional laboratories 'that have
been approved to perform coliform analyses for the ICR. This brings the total number of
approved labs to 298. The list of approved labs is available through the Safe Drinking Water
Hotline and is also accessible on the OGWDW Home Page.
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Antibody KltS - Ensys Environmental Products, Inc., maker of the Hydrofluor-
Combo kit for detecting Giardia cysts and Cryptosporidium oocysts hi water samples, has
changed owners and is now Strategic Diagnostics. They will continue to manufacture the
antibody kits. Strategic Diagnostics' toll-free phone number for ordering or technical
information is 800-544-8881.
Ongoing Lab Approval StatUS - Since it is possible that a lab could lose
its approval status sometime during the 18-month sampling period, it is important that you check
with your labs prior to each monthly sampling period to be sure that they are still approved. We
are hopeful that the labs will take the initiative and notify their clients if approval is "lost," but
better to be safe than sorry. The lab approval list on the Internet may also be used, but there is no
guarantee that it will always be "up to the minute" accurate.
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If it does become necessary to use another lab, enter that lab name and lab ID into the
utility software (Laboratory Identification List window). It is then a simple matter to reassign
the analyte groups to the new lab in the monthly sampling plan. Remember, EPA does not learn
which lab a utility has used until they submit a monthly data diskette approximately 4 months
after sampling.
Ongoing PE StlldieS - Ongoing performance evaluation situdies for protozoa and
virus laboratories consist of two PE samples per month per principal analyst (and per analyst
for virus labs) for the duration of ICR monitoring. Ongoing PE sample atiipments for protozoa
labs began in May '97; ongoing PE sample shipments for virus will begin in July '97.
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Ongoing PE studies for the disinfection byproducts, (DBFs) and surrogate parameters
consist of 6 quarterly sets of samples. The first of the six required studies (ICR Chemistry PE
Study 4) was sent to the laboratories in April and the results were due back to EPA in May. The
study samples were mailed only to laboratories that had submitted a completed application by the
February 14, 1997 deadline, because EPA is not reviewing late applications for the DBF and
surrogate parameters. Results of the study will be mailed to the labs early in June along with
"make-up" samples for any parameters that were failed by the lab.
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Calibration Mixes on Their Way - The calibration mixes to be used i
the upcoming ICR monitoring for the chemistry analytes are now being shipped to approved ICR
chemistry labs. You will soon be receiving the ampules for the analytes for which you are
approved as well as detailed instructions for their use. Note that solutions are only being
provided for the DBFs and surrogates, not water quality parameters. Questions regarding the
calibration mixes should be directed to Ed Glick at 513-569-7939 or faxed to 513-569-7191. E-
maii questions to Ed at glick.ed@epamail.epa.gov.
Protozoan Analysis Reagent Still Available - we have
received several inquiries regarding the availability of one of the reagents for the ICR protozoan
method. Which one you ask? Dibasic sodium phosphate with 12 waters of hydration (disodium
hydrogen phosphate, dodecahydrate) is available from J. T.: Baker, Inc., Catalog No.3822-01 for
a 500 gram bottle. The CAS number is 10039-32-4.
Four Digit ICR Numbers? - Yes, some utilities do have four digit ICR
Plant ID numbers assigned to their plants. These are ground water systems that serve a
combined population of between 50,000 and 99,999 people (with 50,000 or more served by
ground water). These plants do not have to conduct the 18 months of monitoring, rather they
only have to conduct 12 months of TOC monitoring to determine if it is necessary to conduct a
treatment study. This decision to use four digit numbers for these Category G systems was
made so that they would not inadvertently use the ICR. Utility software to enter their TOC data.
Some labs using the ICR Lab QC database software have also tried to enter Category G plant
TOC data and have discovered that the software won't accept the 4 digit plant ID number.
JM.Ore Dry RunS - Since the last ICR Update I have received comments from several
utilities saying that they have already conducted dry runs and that they were extremely helpful.
Many plan to conduct another dry run (or two) before the start of the "real" sampling in July.
One ICR contact, Mike Furirey at NJDWSC, has been running "Pre-ICR test runs" for
nearly 2 years. He is using his LIMS to simplify data entry into the ICR database. If you would
like details, give him a call at 201-616-2903.
Another utility contact, who would like to remain nameless, suggests that it would be an
"unfair expectation of operators to enter the G, T10 or T50 values" on the C.2 forms. For this
type of information and detention times, "it's better to have them (operators) just enter flow, and
have the data entry person use a chart that gives these values based on design and unit processes
in service."
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One large system, with multiple filtration plants, has been doing "practice runs" every
month since January 1997. Their first attempt was a "fiasco," but now the procedures are almost
routine. Looking back, they don't think that they started the practice runs a bit "too soon." Oh,
one other thing, their practice runs are not "dry runs." They actually do the analyses!
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Initial Sampling Plans Approved - Approval of Initial Sampling Plans
(ISP) is just about complete. You may have already received a "pre-approval" letter from EPA,
stating that your ISP was received and reviewed and was found to be acceptable. (As of the end
of May, 268 pre-approval letters had been sent.) The "formal" approval letters will be sent out
this month (June) and according to the rule [§141.141(f)(2-4)] your system must begin
monitoring the following month, which would be July 1997.
As a reminder, the Initial Sampling Plan did not require a valid ICR Lab ID number to
be entered into the software because a finalized list of approved labs was not yet available. If
you were among the "many" that did not enter a valid ICR Lab ID into the ISP then please do so
before generating your first monthly sampling plan. Neither the "revised" ISP nor the monthly
sampling plan should be submitted to EPA.
Monthly Sampling Plans "With the start of sampling just a month away,
now would be a good tune to review the monthly sampling procedures in the ICR Water Utility
Database System Users' Guide. Chapter 6 of the Users' Guide covers monthly sampling. The
first step in monthly sampling is to develop a Monthly Sampling Plan to provide your field
operators with a list of the treatment information they will need to gather and the samples they
will collect that month. A summary of the procedure for conducting monthly sampling is on
page 92 of the Users' Guide.
Reader Tip ~ One of our readers, who has been working with the ICR utility software
since last fall, provides some advice on the use of the D.I Report (Monthly Sample Allocation
to Laboratories) to help your laboratories get familiar with their QC software and data entry. The
way I understand it, the lab needs the D.I report because it contains the Sample ID Check Digit
that is required to proceed with data entry. Therefore, to generate a D.I report with check digits
before the start of sampling, first define a new sampling period with sampling dates, and then
copy data from the ISP/Design Period (or a previous sampling period) to the new sampling
period. Finally, generate the D.I report which will contain the Sample ID Numbers and the
Sample ID Check Digits for the new sampling period. Send this report to your lab so that they
have a valid check digit to enter into the "Add Utility Sample" window in the Lab QC software
(See pages 29-31 of the ICR Laboratory QC Database System Users' Guide).
Filter ClOgged, Bunky? -In the event of a clogged filter when collecting a
virus or protozoa sample, you should enter "Clogged Filter" into the comment field for the
sample collection data and set the QC flag to "A" for acceptable.
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Treatment Study Approval - Twelve "grandfathered" treatment study (TS)
applications were received before the February 14, 1997 deadline. Three were disapproved, and
nine (4 - GAC, 5 - membrane) were approved pending receipt of the study results by the
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November 14, 1997 deadline. In addition, 7 individual TS applications and 2 applications to
"avoid" the TS requirement have been approved. Finally, two "single-study for multiple plants
operated by a single PWS" (sounds like an Oscar nomination, doesn't it?) applications have been
received and will be reviewed upon submission of common source information.
Beat the LaSt Minute Rush - April 14,1998 is the deadline for plants
required to conduct treatment studies to begin their study. However, it is perfectly acceptable to
begin a treatment study prior to then, even if the applicability monitoring is not complete. For
example, if it is discovered that a treatment study will be required based on the first several
months of TOC results, the PWS may decide to begin the study early. But before beginning a
treatment study, the PWS must submit a study plan to the ICR Treatment Studies Coordinator.
Once the study plan is approved, the PWS may begin the study at any time prior to the deadline,
and can cease the TS applicability monitoring (unless the plant needs to demonstrate that it
shares a common water source with another plant for some of the other options). Seven utilities
have already begun their treatment studies! Friendly reminder: the deadline to apply for
treatment study options is November 14,1997!
SDS TeStS for TS - During the ICR Treatment Studies (TS), the formation of
THM4, HAA6, and TOX must be evaluated under Simulated Distribution System (SDS)
conditions using free chlorine. Some questions have been received lately regarding chlorination
procedures for the SDS test procedure. The following summary outlines the selection of the
four parameters which establish SDS conditions: ;
Incubation Time - representative of the average residence time in the distribution
system (DS) associated with the plant.
Eree Chlorine Residual at the end of incubation - equivalent to the free chlorine
residual in the DS at a point representative of the average residence time. (Should be
between 0.5 and 1.0 mg/L if chloramines are normally used in the DS.)
pH at the time of chlorination - equivalent to file pH in the DS at a point representative
, of the average residence time. :.
Temperature during incubation- equivalent to the temperature in the DS at a point
representative of the average residence time. • .
For more info see Sect. 4.6, Part 1 of the IC& Treatment Studies Manual (EPA 814-B-96-003).
Clarification on Booster Chlorination Stations -in the ICR,
the term "Booster Chlorination Station," refers to those chlorination facilities that are part of the
distribution system, while chlorination facilities located at individual wells are considered to be
associated with the "treatment plant" process train. See the Design Distribution System
window in the Initial Sampling Plan section of the ICR Water Utility Database, and page 68 of
the Users' Guide.
ICR Requirement Waived? - Don't get too excited, the only requirement
that has been waived is the one to analyze for bromide in the presence of chlorine. This only
applies to bromide analysis of chlorinated washwater return (and additional water sources added
to the process train after the TP influent). Since there is no dechlorination agent added to the
bromide sample, residual chlorine will continue to react with bromide during the holding period,
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making the bromide result meaningless. A Federal Register notice is planned as well as a
change to the ICR Sampling Manual.
"FREE" ICR ProdUCtS -The ICR Treatment Study Data Collection
Spreadsheets and accompanying User's Guide have been completed and are being mailed to
affected water systems and ICR approved DBF laboratories. A limited number of copies of the
spreadsheets and user's guide will also be available through the Safe Drinking Water Hotline
(800-426-4791) at no charge. These additional copies are intended for consultants involved hi
conducting treatment studies and other laboratories that are providing analytical support for the
studies.
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ICR On the Internet - There have been some recent changes to the OGWDW
Home Page on the Internet (http://www.epa.gov/OGWDW) that permit easier access to ICR
information. Click on the Regulations ssd-G.^l^s 22 button and you will find the Information
Collection Rule followed by an outline lu-; ,^ '.nost recent updates of everything we have
posted. Set a bookmark for http://www.epa:gov/OGWDW/regs.html for direct access to the
Regulations and Guidance page.
Sampling Begins Next Month - Yes, Virginia, ICR sampling will really
start in July! Hopefully, if you have taken the time to conduct some "Pre-ICR" test runs, there
shouldn't be too many surprises. See the item above on Monthly Sampling Plans.
Good LllCk - Remember to use the Safe Drinking Water Hotline (800-426-4791) for
your ICR questions. The Hotline will forward your question(s) to the appropriate contact in
TSC for a prompt answer to your question. Most of all, good luck and keep up the good work!
United States
Environmental Protection Agency
Office of Ground Water and Drinking Water
Cincinnati, OH 45268
Official Business
Penalty for Private Use
$300
BULK RATE
POSTAGE & FEES PAID
EPA
PERMIT No G-35
EPA815-N-97-003
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