vvEPA United States Environmental Protection Agency Microbial Laboratory Guidance Manual for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) June 2003 Draft ------- Office of Water (4607) EPA815-D-03-006 http://www.epa.gov/safewater/lt2/index.html June 2003 Printed on Recycled Paper ------- Disclaimer The Standards and Risk Management Division, of the Office of Ground Water and Drinking Water, has reviewed and approved this guidance for publication. Neither the United States Government nor any of its employees, contractors, or their employees make any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use of or the results of such use of any information, apparatus, product, or process discussed in this report, or represents that its use by such party would not infringe on privately owned rights. Mention of trade names or commercial products does not constitute endorsement or recommendation for use. Questions concerning this document or its application should be addressed to: Mary Ann Feige U.S. EPA Office of Ground Water and Drinking Water Technical Support Center Room 127 26 West Martin Luther King Drive Cincinnati, OH 45268-1320 (513)569-7944 (513) 569-7191 (facsimile) feige .maryann@epa.gov ------- TABLE OF CONTENTS Section 1: Introduction 1 1.1 Background 1 1.2 LT2 Rule Microbial Monitoring Requirements 2 1.3 Use of Cryptosporidium Data 3 1.3.1 Cryptosporidium Field Sample Data 3 1.3.2 Cryptosporidium Matrix Spike Data 4 1.4 Use of E. coli Data 4 Section 2: General MicrobialLaboratory Quality Assurance 6 2.1 Quality Assurance Plans 6 2.2 Sample Temperature Monitoring 8 Section 3: Guidance for Cryptosporidium Laboratories 10 3.1 LT2 Rule Cryptosporidium Sample Analysis Requirements 10 3. .1 Approved Laboratories 10 3. .2 Revised Cryptosporidium Method 10 3. .3 Minimum Sample Volume Analysis Requirements 11 3. .4 Spiking Suspensions Requirements for Spiked Quality Control Samples .... 12 3. .5 Acceptable Sample Results 12 3. .6 Cryptosporidium Oocyst Counts to Report 12 3.2 Laboratory Quality Assurance Evaluation Program 13 3.2.1 Application 13 3.2.2 Personnel Qualifications and Training 14 3.2.3 Initial Proficiency Testing 15 3.2.4 On-Site Evaluation 15 3.2.5 Ongoing Proficiency Testing 15 3.2.6 Changing Status 16 3.2.7 Notifying Utilities of Laboratory Status 17 3.3 Cryptosporidium Method Quality Control 17 3.3.1 Cryptosporidium Spiking Materials 19 3.3.2 Initial Precision and Recovery Test 19 3.3.3 Method Blank Test 20 3.3.4 Ongoing Precision and Recovery Test 20 3.3.5 Ongoing Precision and Recovery Control Charts 20 3.3.6 Quality Control Batches 21 3.3.7 Holding Time Requirements 21 3.3.8 Staining Controls 23 3.3.9 Examination Preparation 24 3.3.10 Ongoing Analyst Verification 24 3.3.11 Proficiency Testing Samples 24 3.3.12 Acceptance Criteria for Receipt of Field Samples 24 3.3.13 Matrix Spike Samples 25 3.3.14 QC Guidance for Method Modifications and Use of Multiple Method Variations 26 3.3.15 Guidance on QC Requirements for Different Sample Volumes 28 Draft June 2003 ------- 3.4 Sample Collection Procedures 29 3.5 Sample Processing and Analysis Procedures 29 3.6 Recordkeeping 29 3.7 Calculations for EPA Methods 1622/1623 32 3.7.1 Field Sample Calculations 32 3.7.2 Matrix Spike Sample Calculations 34 3.7.3 OPR Sample Calculations 35 3.8 Electronic Data Reporting 35 3.8.1 Data Entry/Upload 36 3.8.2 PWS Data Review 37 3.8.3 EPA/State Review 37 3.9 Data Archiving 37 3.9.1 Hardcopy Data 38 3.9.2 Slides 38 3.10 Equipment, Supplies, Reagents, and Standards 39 3.11 Vendor Contact List 39 3.11.1 Sample Collection and Filtration Supplies 39 3.11.2 Sample Concentration and Purification Supplies 40 3.11.3 Slides and Related Supplies 41 3.11.4 Antibody Stains 41 3.11.5 Microscope Equipment 42 3.11.6 Spiking Suspensions and Positive Staining Control Materials 42 3.11.7 Other Laboratory Supplies for EPA Method 1622/1623 43 Section 4: Guidance forE1. coli Laboratories 44 4.1 Laboratory Certification Program 44 4.2 Quality Assurance/Quality Control for E. coli Analyses 45 4.2.1 Quality Control Specifications Applicable to All E. coli Methods 46 4.2.2 Quality Control Specifications for Most Probable Number Methods 48 4.2.3 Quality Control Specifications for Membrane Filtration Methods 49 4.3 Sample Collection Procedures 50 4.3.1 Acceptance Criteria for Receipt of Field Samples 51 4.4 Sample Volume and Dilution Guidance 51 4.4.1 Sample Volume and Dilution Guidance for Multiple-Well Methods 51 4.4.2 Sample Volume and Dilution Guidance for Membrane Filtration 51 4.4.3 Sample Volume and Dilution Guidance for Multiple-Tube Methods 52 4.5 E. coli Data Recording and Calculations 52 4.5.1 Multiple-Well Data 53 4.5.2 Membrane Filtration Data 55 4.5.3 Multiple-Tube Data 59 4.6 Electronic Data Reporting 62 4.6.1 Data Entry/Upload 63 4.6.2 PWS Data Review 63 4.6.3 EPA/State Review 64 4.7 Vendor Contact List for E. coli Methods 64 Section 5: References 66 Section 6: Acronyms 67 Draft June 2003 ------- TABLES Table 1-1. LT2 Rule Monitoring Requirements 3 Table 1-2. Bin Classifications 3 Table 3-1. Laboratory QA Program Personnel Qualifications 14 Table 3-2. Cryptosporidium Holding Times for EPA Method 1622/1623 23 Table 3-3. Sample Receipt Data Elements to Record in the Laboratory for EPA Method 1622/1623 Cryptosporidium Analysis 31 Table 3-4. Primary Data Elements to Record in the Laboratory for EPA Method 1622/1623 Cryptosporidium Analysis 31 Table 3-5. QC Data Elements to Record in the Laboratory for EPA Method 1622/1623 Cryptosporidium Analysis 32 Table 4-1. Approved E. coli Methods for LT2 Rule and Corresponding Drinking Water Certification Program Techniques 45 Table 4-2. Quality Control Procedures for E. coli Methods 46 Table 4-3. Positive and Negative Control Cultures 48 Table 4-4. Incubation Time and Temperature Specifications for MPN Methods 49 Table 4-5. Incubation Time and Temperature Specifications for Membrane Filter Methods 50 Table 4-6. Minimum Sample ID Information and General Sample Data to Record 53 Table 4-7. Minimum Data to Record for Quanti-tray 2000® Colilert® and Colilert-18® Analyses 53 Table 4-8. Minimum Data to Record for Quanti-Tray® Colilert® and Colilert-18® Analyses ... 55 Table 4-9. Minimum Data Elements for Record for Membrane Filtration Analyses 56 Table 4-10. Minimum Data Elements to Record for 15-Tube MPN Methods 59 Table 4-11. Minimum Data Elements to Record for 15-Tube Fermentation Methods 60 Table 4-12. Examples of Different Combinations of Positive Tubes 61 FIGURES Figure 3-1. Process for Laboratory Approval and Changes in Laboratory Approval Status 18 Figure 3-2. Ongoing Precision and Recovery Control Chart Example 21 Draft June 2003 ------- APPENDICES Appendix A Laboratory Biosafety Guidelines Appendix B EPA Method 1622 for Cryptosporidium (June 2003) Appendix C EPA Method 1623 for Cryptosporidium and Giardia (June 2003) Appendix D Cryptosporidium Sample Results Acceptability Checklist for the LT2 Rule Appendix E Cryptosporidium Laboratory QA Program Application Appendix F Cryptosporidium Laboratory QA Program Audit Checklist Appendix G EPA Method 1622/1623 Bench Sheet Appendix H EPA Method 1622/1623 Cryptosporidium Examination Results Form Appendix I Standard Methods 9223B: Colilert® Appendix J Standard Methods 9223B: Colilert-18® Appendix K Standard Methods mEndo/LES-Endo-NA-MUG and mFC-NA-MUG Appendix L EPA Method 1103.1 Appendix M EPA Method 1603: Modified mTEC Appendix N EPA Method 1604: MI Medium Appendix O m-ColiBlue24® Broth Appendix P Standard Methods 9221B/9221F: LTB -EC-MUG Appendix Q . . . E. coll Most Probable Number Sample Results Acceptability Checklist for the LT2 Rule Appendix R E. coll Membrane Filtration Sample Results Acceptability Checklist for the LT2 Rule Appendix S E. coll Report Forms for Colilert™ 97-Well Procedures Appendix T E. coll Report Form for Colilert™ 51-Well Procedures Appendix U E. coll Report Form for Stamdard Methods 9222B/9222G Appendix V E. coll Report Form for Standard Methods 9222D/9222G Appendix W E. coll Report Form for Standard Methods 9213D mTEC Appendix X E. coll Report Form for EPA Method 1603 modified mTEC Appendix Y E. coll Report Form for EPA Method 1604 MI Medium Appendix Z E. coll Report Form for mColiBlue24® Broth Appendix AA E. coll Report Form for Multiple-Tube Fermentation Methods Appendix AB E. coll Report Form for Multiple-Tube Most Probable Number Methods Draft June 2003 ------- SECTION 1: INTRODUCTION The Long Term 2 Enhanced Surface Water Treatment Rule (LT2ESWTR or LT2 rule) requires public water systems (PWSs) that use surface water or groundwater under the direct influence of surface water to monitor their source water (influent water prior to treatment) for Cryptosporidium, E. coli, and turbidity for a limited period [40 CFRpart 141.701(a)-( h)]. In support of the monitoring requirements specified by the rule, three documents have been developed to provide guidance to the affected PWSs and the laboratories that support them: 1. Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule). This guidance manual for PWSs affected by the rule provides information on laboratory contracting, sample collection procedures, and data evaluation and interpretation advice. 2. Microbial Laboratory Guidance Manual for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) (this document). The goal of this manual is to provide Cryptosporidium and E. coli laboratories analyzing samples in support of the LT2 rule with guidance and detailed procedures for all aspects of microbial analyses under the rule to maximize data quality and consistency. 3. User's Manual for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) Data Collection System. This manual provides PWSs and laboratories with instructions on the entry, review, and approval of electronic data using the LT2 Data Collection System, and for generating reports using the system. All of these manuals are available at http://www.epa. gov/safewater/lt2/index.html. Responses to frequently asked questions (FAQs) on sampling, analysis, and data reporting questions for the LT2 rule also are available on this website. 777/5 guidance document is provided to help implement the LT2 rule. This guidance document does not, however, substitute for the LT2 rule or the analytical methods approved for use under the rule. The material presented is intended solely for guidance and does not alter any regulatory or analytical method requirements not altered by the LT2 rule itself. Sections 1 and 2 of the microbial laboratory LT2 manual provide LT2 background information and guidance on issues that apply to both Cryptosporidium and E. coli laboratories. Section 3 provides guidance specific to Cryptosporidium analyses for the LT2 rule, and Section 4 provides guidance for E. coli analyses performed in support of the LT2 rule. 1.1 Background The LT2 rule is a National Primary Drinking Water Regulation that requires monitoring, reporting, and public notification requirements for all PWSs that use surface water sources. The rule requires additional treatment techniques for some systems, based on Cryptosporidium monitoring results (40 CFR part 141.720 - 141.721). The LT2 rule was developed to improve control of microbial pathogens, including specifically the protozoan Cryptosporidium, in drinking water and to address risk trade-offs with disinfection byproducts. Draft 1 June 2003 ------- Section 1: Introduction The LT2 rule provides for increased protection against microbial pathogens in public water systems that use surface water sources. The rule focuses on Cryptosporidium, a protozoan pathogen that is widespread in surface waters. EPA is particularly concerned about Cryptosporidium because it is highly resistant to inactivation by standard disinfection practices. Ingestion of Cryptosporidium oocysts can cause acute gastrointestinal illness, and symptoms in sensitive subpopulations may be severe, including risk of mortality. Cryptosporidium has been identified as the pathogenic agent in a number of waterborne disease outbreaks. EPA convened a Federal Advisory Committee to develop recommendations for both the Stage 2 Disinfectants and Disinfection Byproducts Rule and the LT2 rule. As recommended by the Federal Advisory Committee, the LT2 rule requires public water systems that use surface water or ground water under the direct influence of surface water to monitor their source water (influent water prior to treatment plant) for Cryptosporidium, E. coll and turbidity [40 CFR part 141.701 (a)-(h)]. These data would be used to determine whether additional treatment is needed at PWSs and to assess whether a relationship could be established between the Cryptosporidium and E. coll levels in source water. A summary of the LT2 rule monitoring requirements is provided in Section 1.2. The use of Cryptosporidium data is discussed Section 1.3 and the use of E. coll data is discussed in Section 1.4. 1.2 LT2 Rule Microbial Monitoring Requirements Large systems (PWSs serve a population of at least 10,000 people) monitoring under the LT2 rule are required to collect and analyze source water samples for Cryptosporidium, E. coll and turbidity for a minimum of 2 years [40 CFR part 141.701 (b)]. Small systems (PWSs that serve fewer than 10,000 people) are required to monitor their source water for E. coll for a minimum of 1 year. A subset of small systems would then be required to conduct Cryptosporidium analyses over a 1-year period if they exceed E. coll trigger levels [40 CFR part 141.701 (c)]. Monitoring requirements for each system size, and the schedule for each stage of monitoring, is described in Table 1-1. Detailed guidance for sample collection during the LT2 rule, and procedures for sample collection, documentation, and shipment, are provided in Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) (at http://www.epa.gov/safewater/lt2/index.html). Cryptosporidium samples must be analyzed by a laboratory approved for analysis under the Laboratory Quality Assurance Evaluation Program for the Analysis of Cryptosporidium Under the Safe Drinking Water Act (Section 3.2, below) using EPA Method 1622/1623 [40 CFR part 141.706 (a)]. E. coll samples must be analyzed using methods approved under the LT2 rule for surface water monitoring (Section 4, below) [40 CFR part 141.705 (b)]. Source water turbidity must be measured when Cryptosporidium and E. coll samples are collected using methods approved under the LT2 rule [40 CFR part 141.705 (c)]. Draft 2 June 2003 ------- Section 1: Introduction Table 1-1. LT2 Rule Monitoring Requirements Public water system size Large systems (serving 10,000 or more people) Small systems (serving fewer than 10,000 people) Monitoring begins 6 months after promulgation of LT2 rule 30 months (2 1/2 years) after promulgation of LT2 rule Monitoring duration 2 years3 1 year3'" Monitoring parameters and sample frequency requirements Cryptosporidium minimum 1 sample/month0 see below5 £. co// minimum 1 sample/month11 1 every 2 weeks § Possible additional monitoring requirement for Cryptosporidium If small systems exceed £ co// trigger levels, then. . . Small systems (serving fewer than 10,000 people) 48 months (4 years) after promulgation of LT2ESWTR 1 year 2 sample/month N/A a PWSs may be eligible to use historical (grandfathered) data in lieu of these requirements if certain quality assurance and quality control criteria are met b Small systems may be required to monitor for Cryptosporidium for one year, beginning 6 months after completion of £ co// monitoring; Cryptosporidium monitoring required if the £. co// annual mean concentrations exceed 10/100 ml_ for systems using lakes/reservoirs or exceed 50/100 ml_ for systems using flowing streams c PWSs monitoring for Cryptosporidium may collect more than 1 sample per month if sampling is evenly spaced over the monitoring period d Not applicable to large, unfiltered systems because these systems are not required to monitor for £ co// or turbidity N/A = Not applicable; no monitoring required 1.3 Use of Cryptosporidium Data Two types of Cryptosporidium data are collected under the LT2 rule: Cryptosporidium occurrence data from the analysis of field samples, and method performance data from the analysis of matrix spike (MS) samples. The use of occurrence data from field samples is discussed in Section 1.3.1; the use of method performance data from MS samples is discussed in Section 1.3.2. 1.3.1 Cryptosporidium Field Sample Data The concentration of Cryptosporidium oocysts in source water samples analyzed during the LT2 rule will be used to calculate a mean Cryptosporidium concentration for a PWS and classify the PWSs into a treatment requirements "bin" (40 CFRpart 141.709). These bin classifications are provided in Table 1-2. The treatment bin classification established for each PWS will be used to determine whether additional treatment is needed. PWSs in Bin 1 are not required to implement additional treatment. PWSs in Bins 2 - 4 will be required to implement increasing levels of treatment and source water protection to address their higher risk for high Cryptosporidium source water concentrations. Table 1-2. Bin Classifications Cryptosporidium Bin Concentration Cryptosporidium < 0.075/L 0.075/L < Cryptosporidium < 1.0/L 1.0/L < Cryptosporidium < 3.0/L Cryptosporidium > 3.0/L Bin Classification Bin 1 Bin 2 Bin 3 Bin 4 Draft June 2003 ------- Section 1: Introduction The method used to average individual sample concentrations to determine a PWS's bin classification depends on the number of samples collected and the length of the sampling period. For PWS serving at least 10,000 people bin classification would be based on the following: • For PWSs that collect at least 48 samples during the required monitoring period, the Cryptosporidium bin calculation is equal to the mean of all sample concentrations • For PWSs that collect at least 24 samples, but not more than 47 samples, during the required monitoring period, the Cryptosporidium bin calculation is equal to the highest average of all sample concentrations in any 12 consecutive months in the monitoring period For PWSs serving fewer than 10,000 people, bin classification would be based on the highest running six month average because these systems collect samples twice a month for 1 year. 1.3.2 Cryptosporidium Matrix Spike Data During LT2 rule Cryptosporidium monitoring, PWSs are required to analyze, at a minimum, one MS sample for every 20 field samples from their source water [40 CFRpart 141.705 (a) (2)]. Details on MS sample requirements are provided in Section 3.3.13. For PWSs in the following categories, two MS samples will need to be analyzed during LT2 rule monitoring: • PWSs serving more than 10,000 people, that perform monthly monitoring for 2 years, and that collect 24 field samples • PWSs serving fewer than 10,000 people, that are triggered into monitoring for 1 year, and that collect 24 field samples For PWSs serving more than 10,000 people and that perform semi-monthly monitoring for 2 years and collect 48 or more samples, 3 MS samples will be analyzed. Although MS sample results will not be used to adjust Cryptosporidium recoveries at any individual source water, the results will be used collectively to assess overall recovery and variability for EPA Method 1622/1623 in source water. The descriptive statistics of the MS sample results will be compared to the performance of the methods during the Information Collection Rule Supplemental Surveys to verify the assumptions on method performance upon which the LT2 rule was based. When considering the method performance that could be achieved for analysis of Cryptosporidium under the LT2 rule, the Federal Advisory Committee evaluated the results of EPA Methods 1622/1623 in the ICRSS, which involved 87 PWSs sampling twice per month over 1 year for Cryptosporidium and other parameters. During the ICRSS, the mean Cryptosporidium recovery and mean relative standard deviation of the MS samples were 43% and 49%, respectively (Reference 5.1). 1.4 Use of E. coll Data E. coli data are being collected by large systems during LT2 rule monitoring to assess whether a relationship can be established between the Cryptosporidium and E. coli levels in source water and a microbial index developed to establish trigger levels for E. coli that would indicate high Cryptosporidium concentrations in a source water (40 CFRpart 141.701). If a relationship can be established, small systems initially will be permitted to monitor for E. coli, rather than more expensive Cryptosporidium analyses. Only those systems with E. coli levels above the trigger level established in the microbial index would then be required to monitor for Cryptosporidium to determine bin placement (40 CFR part 141.702). Draft 4 June 2003 ------- A preliminary index was developed during LT2 rule development using data from the Information Collection Rule (ICR) and ICRSS. These data were evaluated for parameters that could indicate the likelihood that a source water mean Cryptosporidium level would be above the Bin 2 threshold concentration of 0.075 oocysts/L. Initially, fecal coliforms, total coliforms, E. coli, viruses (ICR only), and turbidity were assessed for development of the microbial index. Data analyses placed greater emphasis on E. coli and fecal coliforms because of the direct relationship between these parameters and fecal contamination. E. coli was determined to provide the best performance as a Cryptosporidium indicator with the available data. After E. coli levels were developed as a screening tool, turbidity was considered in an effort to enhance the screening tool. However, turbidity was not found to improve accuracy. Based on the data from the ICR and ICRSS, the preliminary E. coli trigger levels were set at a mean of 50 E. colil 100 mL for flowing stream-type source waters and WE. coli/WO mL for reservoir/lake source waters. Draft 5 June 2003 ------- SECTION 2: GENERAL MICROBIAL LABORATORY QUALITY ASSURANCE All laboratories analyzing Cryptosporidium and E. coll samples for the LT2 rule should adhere to defined quality assurance (QA) procedures to ensure that analytical data generated under the rule are scientifically valid and are of known and acceptable quality. Detailed quality control (QC) requirements and recommendations specific to Cryptosporidium and E. coli analyses are discussed in Sections 3 and 4 of this manual, respectively. Two QA issues that apply to both analyses—quality assurance plans and sample temperature monitoring—are discussed below, in Sections 2.1 and 2.2. 2.1 Quality Assurance Plans As specified in both the Lab QA Program for Cryptosporidium laboratories (http://www.epa. gov/safewater/lt2/cla final .html and Section 3.2 of this manual) and the Laboratory Certification Manual (Chapter III, page III-4) for E. coli laboratories, each laboratory should operate a formal QA program and should document the scope of this program through a QA plan. The laboratory's QA plan should be a stand-alone document. However, some information can be incorporated into the document by reference, including laboratory standard operating procedures (SOPs), analytical methods, and quality control (QC) and calibration notebooks. Laboratories currently certified for coliform analysis under the drinking water laboratory certification program may use their current QA plan, however, this plan should be updated to address the specific requirements for LT2 rule monitoring. Topics that should be addressed in the QA plan are outlined below. Details on LT2 Cryptosporidium requirements are provided in Section 3 of this manual; details on LT2 E. coli analyses are provided in Section 4. For Cryptosporidium laboratories, this QA plan should be available for review during a laboratory's on- site audit, as part of the EPA's Cryptosporidium Laboratory Quality Assurance Evaluation Program (Section 3.2). For E. coli laboratories, this QA plan should be available for review during recertification audits as part of the National Primary Drinking Water Regulations. The following items should be addressed in each QA plan: 1. Laboratory organization and responsibility • Include a chart showing the laboratory organization and line authority, including QA Managers • List the key individuals who are responsible for ensuring the production of valid measurements and the routine assessment of QC measurements • Specify who is responsible for internal audits and reviews of the implementation of the QA plan and its requirements 2. Personnel • List each analyst's academic background and water analysis experience • List each analyst's training on the method • Describe training available to keep personnel up to date on methods and regulations Draft 6 June 2003 ------- Section 2: General Microbial Laboratory Quality Assurance 3. Facilities: • Arrangement and size of laboratory • Bench space • Storage space • Lighting • Air system • Lab reagent water system • Waste disposal system • Safety considerations. The laboratory should address biosafety in the laboratory when handling or processing Cryptosporidium samples and organism controls. Guidance on laboratory biosafety for Cryptosporidium is provided in Appendix A of this guidance manual. 4.Field sampling procedures (with SOP used by laboratory or sent to PWS clients) • Describe how samples are collected, sample containers, sample storage, transport times, and sample temperature • Describe sample identification and information recording system 5.Laboratory sample handling procedures • Describe sample storage conditions • Describe the laboratory's sample tracking system; specify procedures used to maintain the integrity of all samples, i.e., logging, tracking samples from receipt by laboratory through analysis to disposal • Describe sample acceptance criteria 6. Equipment • Specifications for each piece of equipment used for Cryptosporidium and/or E. coll analyses • Calibration procedures, frequency, standards for each piece of equipment used for Cryptosporidium and/or E. coll analyses • Quality control records for each piece of equipment used for Cryptosporidium and/or E. coll analyses • Preventative maintenance and schedules, documentation for each piece of equipment used for Cryptosporidium and/or E. coll analyses 7. Supplies • Laboratory glassware and plasticware acceptance conditions • Chemicals, reagents, dyes and culture media acceptance conditions • Chemicals, reagents, dyes, and culture media storage conditions • Filters acceptance conditions 8.Laboratory practices (may reference SOP) • Preparation of reagent-grade water • Glassware washing and preparation • Sterilization procedures 9. Analytical procedures • Describe all reference methods used • State that the analytical methods described in this manual will be followed • Identify available SOPs 10. Quality control (QC) checks • Confirmation/ verification procedures, frequency • Sterility controls • Replicate analyses; frequency • QC samples, source; frequency Draft 7 June 2003 ------- Section 2: General Microbial Laboratory Quality Assurance • Positive and negative controls proficiency testing (PT) samples, source; frequency • Spiked field samples • Between-analyst deviation 11. Data reduction, verification, validation, and reporting • Data reduction (conversion of raw data to Cryptosporidium oocysts/L and/or E. coli/100 mL) • Procedures to ensure the accuracy of data transcription and calculations • Validation (ensuring that QC steps associated with a field result are acceptable) • Reporting, including procedures and format for reporting data to utilities/EPA 12. Corrective actions • Define the laboratory response to unacceptable results from PT or QC samples and from internal QC checks • Identify persons with responsibility to take corrective action • Describe how the actions taken and the effectiveness of the actions taken will be documented 13. Recordkeeping • Describe how records are to be maintained (e.g., electronically, hard copy, etc.) • Describe how long records are to be kept • State where records are to be stored The laboratory QA plan should be concise, but responsive to the above-listed items. Additional guidance on developing QA plans is available in "Guidance on Quality Assurance Project Plans (G-5)," (EPA/600/R-98/018, February 1998), which is available as a download from http://www.epa.gov/qualitv/qa docs.html#noneparqt. However, the goals of a lab QA plan in general are different from the goals of a QAPP, and not all of the issues that should be addressed for laboratory QA during the LT2 rule are covered by this guidance (i.e., laboratory sample handling and record keeping). However, because the LT2 rule is a finite study on Cryptosporidium and E. coli levels in specific source waters, some of the concepts presented in the QAPP guidance that typically are not included in laboratory QA plans may aid the laboratory in updating their QA plan to address specific LT2 requirements. 2.2 Sample Temperature Monitoring Source water samples are dynamic environments and, depending on sample constituents and environmental conditions, Cryptosporidium oocysts present in a sample can degrade and E. coli present in a sample can grow or die off, biasing analytical results. Cryptosporidium and E. coli samples for LT2 rule monitoring that are not analyzed the same day they are collected must be maintained below 10°C to reduce biological activity. This is specified in Section 8.0 of the June 2003 versions of EPA Method 1622/1623 for Cryptosporidium samples and at 40 CFR part 705 (b) (1) and Chapter V, Section 6.3, of the Laboratory Certification Manual (Reference 5.2) for E. coli samples. Samples for all analyses should remain above freezing at all times. This is a requirement in Section 8.0 of the June 2003 versions of EPA Method 1622/1623. Although not a significant concern for 10-L water samples, this is a real concern for Cryptosporidium filters and 120- or 250-mL E. coli samples that are shipped off-site with coolant materials, such as wet ice, blue ice, or gel packs. E. coli holding time studies performed in support of the LT2 rule (Reference 5.4) demonstrated that E. coli samples can freeze under these conditions if samples are not packed properly. Draft 8 June 2003 ------- Section 2: General Microbial Laboratory Quality Assurance The sample collection protocols procedures discussed in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) provide sample packing procedures for E. coll and Cryptosporidium samples. Utility personnel should follow these procedures to ensure that samples remain at acceptable temperatures during shipment. Because Cryptosporidium samples collected for the LT2 rule must meet the QC criteria in the methods [40 CFRpart 705 (a) (3)], and because these QC criteria include receipt of samples at <10°C and not frozen, laboratories must reject LT2 Cryptosporidium samples that were not collected the same day they were received, and are received at >10°C or frozen (this is discussed further in Section 3.3.12 in this manual). In these cases, the PWS must re-collect and re-ship the sample. Several options are available to measure sample temperature upon receipt at the laboratory and, in some cases, during shipment: • Temperature sample. One option, for Cryptosporidium filtered samples (not for 10-L bulk samples) and E. coll 120- and 250-mL samples, is for the PWS to fill a small, inexpensive sample bottle with water and pack this "temperature sample" next to the field sample. The temperature of this extra sample volume is measured upon receipt to estimate the temperature of the field sample. Temperature sample bottles are not appropriate for use with bulk samples because of the potential effect that the difference in sample volume may have in temperature equilibration in the sample cooler. Example product: Cole Farmer cat. no. U-06252-20. • Thermometer vial. A similar option is to use a thermometer that is securely housed in a liquid-filled vial. Unlike temperature samples, the laboratory does not need to perform an additional step to monitor the temperature of the vial upon receipt, but instead just reads the thermometer. Example product: Eagle-Picher Sentry Temperature Vial 3TR-40CS-F or 3TR-40CS. • iButton. Another option for measuring the sample temperature during shipment and upon receipt is a Thermocron® iButton. An iButton is a small, waterproof device that contains a computer chip to record temperature at different time intervals. The information is then downloaded from the iButton onto a computer. The iButton should be placed in a temperature sample in the cooler, rather than placed directly in the cooler, where it may be affected by close contact with the coolant. Information on Thermocron® iButtons is available from http://www.ibutton.com/. Distributors include http://www.pointsix.com/. http://www.rdsdistributing.com. and http://www.scigiene.com/. • Stick-on temperature strips. Another option is for the laboratory to apply a stick-on temperature strip to the outside of the sample container upon receipt at the laboratory. This option does not measure temperature as precisely as the other options, but still mitigates the risk of sample contamination while providing an indication of sample temperature to verify that the sample temperature is acceptable. Example product: Cole Farmer cat. no. U-90316-00. As with other laboratory equipment, all temperature measurement devices should be calibrated routinely to ensure accurate measurements. See the EPA Lab Certification Manual (Reference 5.2) for more information. Draft 9 June 2003 ------- SECTION 3: GUIDANCE FOR CRYPTOSPORIDIUM LABORATORIES Cryptosporidium analyses conducted in support of the LT2 rule must be performed using EPA Method 1622 or EPA Method 1623 [40 CFRpart 141.705 (a)]. Guidance on the use of these methods during the LT2 rule are provided in this section of the manual. 3.1 LT2 Rule Cryptosporidium Sample Analysis Requirements LT2 rule requirements of particular significance to Cryptosporidium laboratories are summarized in Sections 3.1.1 through 3.1.6, below, and discussed in more detail in the remainder of Section 3. 3.1.1 Approved Laboratories Systems must have Cryptosporidium samples analyzed by a laboratory that has passed a quality assurance (QA) evaluation under EPA's Laboratory Quality Assurance Evaluation Program for Analysis of Cryptosporidium in Water or a laboratory that has been certified for Cryptosporidium analysis by an equivalent State laboratory certification program [40 CFRpart 141.706 (a)]. Details on the elements of the Lab QA Program QA evaluation are provided in Section 3.2. 3.1.2 Revised Cryptosporidium Method EPA has proposed the use of the April 2001 versions of EPA Methods 1622/1623 in the LT2 rule. However EPA has requested comment on the use of updated versions (dated June 2003) to consolidate several method-related changes EPA believes are necessary to address LT2 rule monitoring requirements. These changes include the following: • Increased flexibility in matrix spike (MS) and initial precision and recovery (IPR) requirements. The requirement that the laboratory must analyze an MS sample on the first sampling event for a new PWS has been changed to a recommendation; the revised method allows the IPR test to be performed across four different days, rather than restrict analyses to 1 day. • Clarification of some method procedures, including the spiking suspension vortexing procedure; the buffer volumes used during immunomagnetic separation (IMS); requiring (rather than recommending) that laboratories purchase HC1 and NaOH standards at the normality specified in the method; and the use of methanol during slide staining in Section 14.2 is per manufacturer's instructions. • Addition of recommendations for minimizing carry-over of debris onto microscope slides after IMS and information on microscope cleaning. • Clarification of the actions to take in the event of QC failures and clarifies that any positive sample in a batch associated with an unacceptable method blank is unacceptable and that any sample in a batch associated with an unacceptable ongoing precision and recovery (OPR) sample is unacceptable. • A change in the sample storage and shipping temperature to "< 10°C, and not frozen," for samples that are not processed the day they are collected, and provides additional guidance on sample storage and Draft 10 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories shipping procedures based on time of day of collection. The revision includes suggested options for monitoring sample temperature during shipment and/or upon receipt at the laboratory. • Addition of the requirement of examination using differential interference contrast (DIG) microscopy to the analyst verification procedure. • Addition of an approved method modification using the Pall Gelman Envirochek HV filter. This approval was based on an interlaboratory validation study demonstrating that three laboratories, each analyzing reagent water and a different source water, met all method acceptance criteria for Cryptosporidium (but not Giardia, however, individual laboratories are permitted to demonstrate acceptable performance in their laboratory). • Incorporation of detailed procedures for concentrating samples using and IDEXX Filta-Max™ foam filter. (A method modifications using this filter already is approved by EPA in the April 2001 version of the methods.) • Addition of BTF EasySeed™ irradiated oocysts and cysts as acceptable materials for spiking routine QC samples. EPA approved the use of EasySeed™ based on side-by-side comparison tests of method recoveries using EasySeed™ and live, untreated organisms. • Removal of the Whatman Nuclepore CrypTest™ cartridge filter. Although a method modification using this filter was approved by EPA in the April 2001 versions of the methods, the filter is no longer available from the manufacturer, and so is no longer an option for sample filtration. The changes in the June 2003 draft revisions of EPA Methods 1622 and 1623 reflect method-related clarifications, modifications, and additions that EPA believes should be addressed for LT2 rule Cryptosporidium monitoring. Alternatively, these issues could be addressed through regulatory requirements in the final LT2 rule, however, EPA believes that addressing these issues through a single source in updated versions of EPA Methods 1622 and 1623 (which could be approved in the final rule) may be more straightforward and easier for systems and laboratories to follow than addressing them in multiple sources (i.e., existing methods, the final rule, and laboratory guidance). This draft manual assumes that the June 2003 versions of EPA Methods 1622 and 1623 will be used for LT2 rule monitoring. The June 2003 versions of these methods are included as Appendix B and Appendix C of this guidance manual. If EPA determines that the updated methods will not be used, based on comments to the proposed rule, then the rule may be updated to include critical clarifications as requirements and this guidance document will be updated to include non-critical clarifications as guidance. 3.1.3 Minimum Sample Volume Analysis Requirements Under LT2 rule Cryptosporidium sample volume requirements [40 CFRpart 141.705 (a) (1)], PWSs are required to analyze, at a minimum, either: • 10 L of sample, or • 2 mL of packed pellet volume, or • As much volume as two filters can accommodate before clogging (this condition applies only to filters that have been approved by EPA for nationwide use with EPA Method 1622/1623—the Pall Gelman Envirochek™ and Envirochek™ HV filters, or the IDEXX FiltaMax™ foam filter) The LT2 rule sample volume analysis requirement of 10 L (rather than 10.0 or 10.00 L) accommodates the potential for imprecisely filled sample containers or filters. Sample volumes should be rounded to the Draft 11 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories nearest whole liter to determine compliance (e.g., 9.5 L would be rounded to 10 L, and would meet rule requirements). Systems may analyze larger volumes than 10 L, and larger volumes analyzed should increase analytical sensitivity (detection limit), provided method performance is acceptable. EPA encourages systems to analyze similar sample volumes throughout the monitoring period. However, data sets including different samples volumes will be accepted, provided the system analyzes the minimum sample volume requirements noted above. Additional guidance on sample volume and sample collection issues is provided in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule), available for download from http://www.epa.gov/safewater/lt2/index.html. 3.1.4 Spiking Suspensions Requirements for Spiked Quality Control Samples Flow cytometer-counted spiking suspensions must be used for ongoing precision and recovery (OPR) and matrix spike (MS) samples [40 CFRpart 141.705 (a)(3)]. The use of flow cytometer-counted spiking suspensions is a recommendation in EPA Method 1622/1623, but a requirement for the LT2 rule. Spiking suspensions are discussed in more detail in Section 3.3.1, below. 3.1.5 Acceptable Sample Results Cryptosporidium sample results reported under the LT2 rule must meet the quality control (QC) requirements specified in EPA Method 1622/1623 [40 CFRpart 141.705 (a)(3)]. These requirements include, but are not limited to, sample temperature requirements, minimum frequencies for ongoing precision and recovery (OPR), method blank, and matrix spike samples; acceptable OPR and method blank results; holding time requirements; and staining control frequency and results. A checklist for these requirements is provided as Appendix D. Guidance on implementing Cryptosporidium method QC requirements is provided in Section 3.3, below. These requirements are based on the June 2003 versions of EPA Methods 1622/1623, the use of which EPA has requested comment on in the LT2 rule proposal. 3.1.6 Cryptosporidium Oocyst Counts to Report Sample examination using EPA Method 1622/1623 includes an immunofluorescence assay using fluorescein isothiocyanate (FITC) as the primary antibody stain, 4',6-diamidino-2-phenylindole (DAPI) staining to detect nuclei, and differential interference contrast microscopy (DIC) to detect internal structures [40 CFRpart 141.705 (a)(4)]. Cryptosporidium oocysts to be reported using EPA Method 1622/1623 are defined as the following: 1. Those determined by brilliant apple green fluorescence under UV light, size (4 to 6 (im), and shape (round to oval) 2.Excluding atypical organisms specifically identified as other microbial organisms by FITC and DIC (for example, those possessing spikes, stalks, appendages, pores, one or two large nuclei filling the cell, red fluorescing chloroplasts, crystals, spores, etc.) The oocyst counts for a sample, based on the above definition, and the sample volume analyzed, based on the calculations specified in Section 3.7, will be used to calculate the oocyst concentration for each sample during the LT2 rule. Draft 12 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.2 Laboratory Quality Assurance Evaluation Program To improve Cryptosporidium data quality and consistency during LT2 rule monitoring, EPA requires that only qualified laboratories analyze Cryptosporidium samples. A laboratory's qualifications are determined through the Laboratory Quality Assurance Evaluation Program for Analysis of Cryptosporidium Under the Safe Drinking Water Act (Lab QA Program) (67 FR 9731, March 4, 2002) [40 CFRpart 141.706 (a)]. If laboratories are certified for Cryptosporidium analyses under equivalent State laboratory certification programs, EPA plans to include these laboratories in the list of approved laboratories posted at http://www.epa.gov/safewater/lt2/aprvlabs.html. The objectives of the Lab QA Program are to evaluate laboratories' capacity and competency to reliably measure for the occurrence of Cryptosporidium in surface water using EPA Method 1622/1623. Each laboratory participating in the program will be required to complete the following steps to be qualified through this program: • Complete an application (including a self-evaluation) • Perform initial proficiency testing (IPT) • Participate in an on-site evaluation • Perform ongoing proficiency testing (OPT) every four months Information on the Laboratory QA Program is available at http://www.epa.gov/safewater/lt2/index.html and summarized below, in Sections 3.2.1 - 3.2.7. 3.2.1 Application Applications for the program (Appendix E) are available on the website and also may be requested from the following address: EPA's Laboratory Quality Assurance Evaluation Program Coordinator c/o DynCorp/CSC Biology Studies Group 6101 Stevenson Avenue Alexandria, VA 22304 EPA reviews each application to verify that the laboratory has submitted the following information: • A completed self-evaluation checklist • Resumes of laboratory personnel • Standard operating procedures for each method version • Initial demonstration of capability (IDC) data, which consist of the following: • Acceptable initial precision and recovery (IPR) test results • Acceptable method blank result run with IPR test • Acceptable matrix spike/matrix spike duplicate (MS/MSD) results with results from the unspiked matrix sample analyzed at the same time • Table of contents from the laboratory's quality assurance plan • Documentation of personnel training and number of samples analyzed and duration of time using the method • Example of client data reporting form Draft 13 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Completed applications should be submitted to EPA's Laboratory Quality Assurance Evaluation Program Coordinator, c/o DynCorp/CSC Biology Studies Group, at the address listed above. 3.2.2 Personnel Qualifications and Training Laboratory personnel must meet the qualifications of the Lab QA Program in order to analyze Cryptosporidium samples for LT2 rule monitoring. Personnel qualifications for the Lab QA Program are provided in Table 3-1. Each laboratory must have at least one principal analyst. Table 3-1. Laboratory QA Program Personnel Qualifications Position Principal Analyst Analyst Technician Education BS/BA in Microbiology or closely related field 2 years college in Microbiology or equivalent No minimum requirement Experience with Crypto and IFA Microscopy 1 year continuous 6 months continuous No minimum required Experience Using Method 1622/1623 6 months 3 months 3 months with specific parts of procedure performing Number of Samples Analyzed Using Method 1622/1623 100 (50 if approved as an analyst during Information Collection Rule [ICR]) 50 (25 if approved as an analyst during ICR) 50 (25 if approved as an analyst during ICR) During the on-site evaluation (Section 3.2.4), laboratory records will be evaluated to verify that the personnel performing EPA Method 1622/1623 analyses meet the requirements of the Lab QA Program. For new staff that are added after the on-site evaluation, the laboratory should send a letter to EPA providing the following information on the new staff member: • Education • Number of samples analyzed using EPA Method 1622/1623 • Number of months of experience • Verification that analyst training followed the laboratory's training SOP In addition to meeting the qualifications of the Lab QA Program, the following steps should be completed by new personnel as part of their training prior to analyzing samples for LT2 (this should be specified in the laboratory's training SOP): • Review laboratory SOPs for analysis of samples using Method 1622/1623 • Observation of an experienced analyst performing the method • Performance of the method while being observed by an experienced analyst • Acceptable performance of a set of IPR samples using blind spikes If EPA determines that a laboratory is using personnel to analyze LT2 samples who do not meet the qualifications established in the Lab QA Program, the laboratory will be put on conditional status (Section 3.2.6). The laboratory must discontinue the use of the personnel in question until they have met the qualifications of the Lab QA Program, and must submit a signed letter to EPA confirming that this action has been taken, to be removed from conditional status. Draft 14 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.2.3 Initial Proficiency Testing After the laboratory's application has been reviewed and accepted, EPA will send the laboratory a set of eight initial proficiency testing (IPX) samples, which consist of a suspension of Cryptosporidium oocysts in a concentrated matrix. Laboratories will resuspend these spikes in reagent water to produce simulated source water samples, and analyze the samples using the version of EPA Method 1622/1623 that the laboratory plans to use for routine Cryptosporidium analyses. If a laboratory wishes to be evaluated for more than one version of the method, the laboratory will receive a set of eight PT samples for each version. Laboratory IPX data will be evaluated against the mean recovery and precision (as relative standard deviation [RSD]) criteria that EPA has established for IPX samples. Laboratories have two opportunities to pass the IPX test. If a laboratory fails two times, it will not be eligible for another set until after the laboratory staff has received additional training in performing the method and reapplied to the program (discussed further in Section 3.2.6). 3.2.4 On-Site Evaluation Each laboratory that passes the IPX will next participate in an on-site evaluation, which consists of two concurrently performed assessments: a data and QA evaluation and a technical evaluation. 3.2.4.1 Data and QA Evaluation During the data and QA evaluation, laboratory documentation will be evaluated to verify compliance with QA program requirements. Xhe evaluation will cover the following: • Equipment and personnel records • Data recording procedures, based on field sample data and quality control sample data • Quality control test frequency and acceptability • Quality assurance plans • Standard operating procedures Xo ensure consistency and thoroughness for all audits, the data auditor uses a detailed checklist (Appendix F) to evaluate specific factors under each of these categories. Xo prepare for the on-site evaluation, the laboratory should use the checklists provided with the program application to perform a self-audit. 3.2.4.2 Technical Evaluation During the technical evaluation, laboratory sample processing and analysis using EPA Method 1622/1623 will be evaluated. Xhe laboratory will be assessed on its capabilities including the following: • Sample processing and analyses • Microscopy Xo ensure consistency and thoroughness for all audits, the technical auditor uses a detailed checklist (Appendix F) to evaluate specific factors under each of these categories. 3.2.5 Ongoing Proficiency Testing Laboratories that meet the program performance criteria will also receive a set of three ongoing proficiency testing (OPX) samples approximately every four months that must be analyzed in the same Draft 15 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories manner as the IPX samples. EPA will evaluate the precision and recovery data for OPT samples to determine if the laboratory continues to meet the performance criteria of the Laboratory QA Program. 3.2.6 Changing Status Laboratories will be approved after they have submitted an acceptable application, passed the IPX and passed the on-site evaluation. Laboratories must be approved in order to analyze samples under LT2. To maintain approval the laboratory must successfully analyze a set of OPT samples once every fourth month. Details are provided below on what happens when a laboratory fails to meet the program requirements. The process for laboratory approval and changes in approval status is outlined in Figure 3-1. Laboratories that fail two rounds of IPT samples must do the following to be eligible to receive a third set of IPT samples: • Receive additional training • Analyze 25 additional practice samples • Repeat their IPR analysis and submit the results to EPA The additional practice samples should include method blanks, OPR samples, and at least 50% matrix samples including multiple matrix spike and matrix spike duplicate samples. Additional training can be received at EPA's Technical Support Center in Cincinnati or another approved laboratory. Laboratories that only have a few analysts/technicians may want to send all their staff involved in the method for training. For laboratories that cannot send their entire staff for training, they may elect to send the analysts normally responsible for training of other analysts/technicians in their laboratory. These analysts can then pass along the information they received during training at EPA to all of their staff. If the laboratory does not pass the third IPT following additional training, they will be removed from consideration for the program for 6 months, during which time they must analyze an additional 50 practice samples and repeat their IPR and submit the results to EPA. The additional practice samples should include method blanks, OPR samples, and at least 50% matrix samples including multiple matrix spike and matrix spike duplicate samples. After satisfying these requirements the laboratory may re-apply for ONE more set of IPT samples. If the laboratory fails this final IPT, then they will not be allowed to participate in analysis of samples for Cryptosporidium using EPA Method 1622/1623 under the LT2 rule. If a laboratory fails to meet the precision or recovery criteria for a set of OPT samples, the laboratory will be shipped a second set of samples. The laboratory's status changes to "conditional" but they are still permitted to analyze samples under LT2. • If the laboratory's next set of OPT data are acceptable, the laboratory will be returned to "approved" status. • If a laboratory fails the next set of OPT samples (two sets of OPTs in a row), the laboratory will be disapproved for analysis of LT2 samples and must get additional training. The laboratory must consult with EPA regarding the level and type of training required, and must submit to EPA proof of this training upon completion. If the laboratory's training is acceptable, the laboratory must repeat the IPT test before being re-approved. If the laboratory is disapproved a second time, the laboratory will no longer be allowed to participate in the program. Actions taken at this point are discussed in Section 3.2.7. Draft 16 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.2.7 Notifying Utilities of Laboratory Status Two actions are taken when a laboratory's status changes: • The laboratories must notify clients • EPA will post updates on http://www.epa.gov/safewater/lt2/index.html When a laboratory receives notice that they have been "disapproved," the laboratory must notify their clients of their status change within 2 weeks and work with their clients to finish up analysis of samples that they have in house. After the 2-week period the laboratory will no longer be able to analyze samples under LT2 until they have been reapproved. Laboratories should have a plan in place to divert samples to another laboratory in the event that this situation arises. All samples being processed by the laboratory at the time of the disapproval are considered acceptable, provided all QC and holding time requirements (detailed in EPA Methods 1622 and 1623 and Section 3.3 and summarized in Appendix D) are met. Analysis of these samples should be completed by the laboratory. However, no new LT2 samples may be processed; this includes samples that have been received by the laboratory, but that have not been filtered (for bulk samples) or eluted (for field-filtered samples). Any new samples processed after the laboratory has been disapproved will not be considered acceptable for monitoring under the LT2 rule. 3.3 Cryptosporidium Method Quality Control During the LT2 rule, Cryptosporidium samples must meet the quality control (QC) requirements listed in EPA Methods 1622/1623 [40 CFRpart 141.705 (a) (3)]. The requirements discussed in this guidance manual are based on the June 2003 versions of EPA Methods 1622/1623, the use of which EPA has requested comment on in the LT2 rule proposal (see Section 3.1.2 for details). Sections 3.3.1 through 3.3.14 provide guidance on the implementation of the QC requirements specified in the June 2003 version of EPA Method 1622/1623. Routine QC requirements that must be verified internally by the laboratory before reporting LT2 rule monitoring results are called out below, and included in checklist format as Appendix D. This guidance is provided to help implement the QC requirements in the methods and does not substitute for, or alter, the method requirements. Draft 17 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Figure 3-1. Process for Laboratory Approval and Changes in Laboratory Approval Status Submit Program Application Submit missing or incomplete information • Yes Lab must do the following: 1. Receive training on deficient areas 2. Analyze 25 samples 3. Repeat I PR analysis Yes Analyze Initial Performance Testing Samples (IPTs) Lab must wait 6 months to receive 4th set of IPTs and do the following: 1. Analyze 50 additional samples 2. Repeat I PR analysis Yes Laboratory can no longer participate in Lab QA Program Respond to any deficiencies cited in EPA audit report On-Site Evaluation Provide additional information to EPA Lab is "Disapproved," and must receive additional training and analyze IPT samples Analyze Ongoing Performance Testing Samples (OPTs) Laboratory can no longer participate in Lab QA Program Draft 18 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.3.1 Cryptosporidium Spiking Materials During LT2 Cryptosporidium monitoring, laboratories must analyze samples spiked with Cryptosporidium parvum oocysts to assess ongoing laboratory and method performance, per method QC requirements. These ongoing spiked sample analyses include ongoing precision and recovery samples (OPRs) (Section 3.3.4) and matrix spike samples (Section 3.3.13). Flow cytometer-counted spiking suspensions must be used for these QC samples [40 CFRpart 141.705 (a) (3)]. Sources of flow cytometer-counted Cryptosporidium spiking suspensions for use with routine, spiked Cryptosporidium QC samples include the following: I.Wisconsin State Laboratory of Hygiene Flow Cytometry Unit 2601 Agriculture Drive Madison, WI 53718 Phone: (608)224-6260 Fax: (608)224-6213 The Wisconsin State Laboratory of Hygiene prepares and distributes live Cryptosporidium parvum oocysts and Giardia intestinalis cysts that have not been treated to reduce viability. 2.BioTechnology Frontiers (BTF) www.biotechnologyfrontiers.com Unit 1 35-41 Waterloo Road North Ryde NSW Australia Fax: +61 2 9889 1805 Email: contact@biotechnologyfrontiers.com BTF prepares and distributes Cryptosporidium parvum oocysts and Giardia intestinalis cysts that have been irradiated to inactivate the organisms. Note: Irradiated, flow cytometer-counted spiking suspensions may be used for routine laboratory QC samples, including initial precision and recovery (IPR) samples, ongoing precision and recovery (OPR) samples, and matrix spike (MS) samples. Per EPA Method 1622/1623, Irradiated organisms may not be used for interlaboratory validation studies performed to seek nationwide approval of modified versions of the methods. Flow-cytometer-counted spiking suspensions used for spiked quality control (QC) samples must be used within the expiration date noted on the suspension. The laboratory should spike samples according to the procedures provided in Section 11.4 of EPA Method 1622/1623 or according to the procedures provided by the spiking suspension vendor. 3.3.2 Initial Precision and Recovery Test The initial precision and recovery (IPR) test required by EPA Method 1622/1623 consists of four reagent water samples spiked with 100 to 500 oocysts and is used to demonstrate initial acceptable performance with the method. Section 9 of EPA Method 1622/1623 also requires the IPR to be performed for each method modification (additional guidance on QC when using multiple method variations is provided in Section 3.3.14). The results of the four analyses are used to calculate the average percent recovery and the relative standard deviation (RSD) of the recoveries for Cryptosporidium (Section 3.7). For EPA Method 1622/1623, the mean Cryptosporidium recovery must be in the range of 24% to 100% and the RSD of the four recoveries must be less than 55%. Draft 19 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.3.3 Method Blank Test The method blank test required by EPA Method 1622/1623 consists of analysis of an unspiked reagent water sample to demonstrate freedom from contamination. Per the method, one method blank sample must be analyzed each week or every 20 field and matrix spike samples, whichever is more frequent. If more than one method variation will be used for filtration and/or separation of samples, a separate method blank may be required for each variation (see Section 3.3.14). If one or more Cryptosporidium oocysts (as defined in Section 3.1.6) are found in a blank, analysis of additional samples is halted until the source of contamination is eliminated and a blank shows no evidence of contamination. ,•' L T2 rule requirement: For each method blank, oocysts must not be detected [40 CFRpart 141.705 (a) (3)]. part \ 3.3.4 Ongoing Precision and Recovery Test The ongoing precision and recovery (OPR) in EPA Method 1622/1623 entails analysis of a reagent water sample spiked with 100 to 500 oocysts to demonstrate ongoing acceptable performance. One OPR sample must be analyzed each week or every 20 field and MS samples, whichever is more frequent. If more than one method variation will be used for filtration and/or separation of samples, a separate method blank may be required for each variation (see Section 3.3.14). OPR samples should be analyzed before any field samples in a batch are processed to verify acceptable performance. OPR Cryptosporidium recovery must be in the range of 11% to 100% to be considered acceptable. /* L T2 rule requirement: Ongoing precision and recovery results must be 11% to 100% [40 CFK part 141.705 (a) (3)]. 40 \ 3.3.5 Ongoing Precision and Recovery Control Charts As noted in Section 9.7.5 of the June 2003 version of EPA Method 1622/1623, laboratories should maintain a control chart of OPR recoveries, graphically displaying the results of continuing performance. The control chart should be developed using the most recent 20 to 30 test results. The control chart is developed by plotting percent recovery of each OPR sample over time. Based on the mean of the recoveries on the chart, the upper and lower control limits should be established as follows: • Upper control limit = x + 2 standard deviations • Lower control limit = x - 2 standard deviations An example of an OPR control chart is provided in Figure 3-2. After each 5 to 10 new recovery measurements, new control limits should be recalculated using the most recent 20 to 30 data points. These calculated control limits should not exceed the OPR criteria of 11% to 100%. Control charts can be used to track the laboratories performance and determine if any trends in recovery are occurring. If recovery measurements fall below the lower control limit or above 100%, laboratories should take corrective Draft 20 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories action, investigating potential causes of the outlying result. The troubleshooting guidance for OPR failures provided in Section 9.7.5 of EPA Method 1622/1623 also is useful for investigating the cause of acceptable, but outlying, OPR measurements identified through the use of control charts. 3.3.6 Quality Control Batches As noted in Appendix D and Sections 3.3.3 and 3.3.4, all LT2 Cryptosporidium samples must be associated with an acceptable OPR and method blank sample [40 CFR part 141.705 (a) (3)]. LT2 samples are associated with QC samples through a "QC batch." A QC batch consists of an OPR and method blank and the maximum of 20 field and MS samples that are eluted, concentrated, and purified in the same week as the OPR and method blank samples. If more than 20 field and MS samples are processed in a week, the OPR and method blank samples are associated with the field and MS samples eluted, concentrated, and purified in the same time period. Figure 3-2. Ongoing Precision and Recovery Control Chart Example 100% 90%- Recovery Mean + 2 Standard Deviations Mean - 2 Standard Deviations 0% 01/04/2001 02/01/2001 03/01/2001 03/29/2001 04/26/2001 05/24/2001 06/21/2001 07/19/2001 3.3.7 Holding Time Requirements During Cryptosporidium analyses for the LT2 rule, sample processing should be completed as soon as possible by the laboratory. The laboratory should complete sample filtration (if sample is received in bulk), elution, concentration, purification, and staining the day the sample is received wherever possible. However, the laboratory is permitted to split up the sample processing steps if processing a sample completely in one day is not possible. If this is necessary, sample processing can be halted after filtration, application of the purified sample onto the slide, or staining. Draft 21 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories The following holding times must be met for samples analyzed by EPA Method 1622/1623 during the LT2 rule: • Sample collection and filtration. Sample elution must be initiated within 96 hours of sample collection (if shipped to the laboratory as a bulk sample) or filtration (if filtered in the field). • Sample elution, concentration, and purification. The laboratory must complete the elution, concentration, purification, and application of the sample to the slide in one work day. It is critical that these steps be completed in one work day to minimize the time that any target organisms present in the sample sit in eluate or concentrated matrix. This process ends with the application of the purified sample on the slide for drying. • Staining. The sample must be stained within 72 hours of application of the purified sample to the slide. • Examination. Although immunofluorescence assay (FA) and 4',6-diamidino-2-phenylindole (DAPI) and differential interference contrast (DIG) microscopy examination and confirmation ideally should be performed immediately after staining is complete, laboratories have up to 7 days from completion of sample staining to complete the examination and confirmation of samples. However, if fading/diffusion of FITC or DAPI staining is noticed, the laboratory must reduce this holding time. In addition, the laboratory may adjust the concentration of the DAPI staining solution so that fading/diffusion does not occur. The laboratory also should evaluate the use of another mounting medium (one alternative is provided in Section 3.9.2, below). / L T2 rule requirement: Each sample must meet the QC criteria for the methods [40 CFK part 141.705 (a) (3)]. Per EPA Method 1622/1623, samples must be processed or examined within each of the holding times specif led by A breakdown of the holding times for each set of steps is provided in Table 3-2. Draft 22 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Table 3-2. Cryptosporidium Holding Times for EPA Method 1622/1623 Sample Processing Step Maximum Allowable Time between Breaks (Samples Should be Processed As Soon As Possible) Collection Filtration >• Up to 96 hours are permitted between sample collection (if shipped to the laboratory as a bulk sample) or filtration (if filtered in the field) and initiation of elution Elution Concentration Purification Application of purified sample to slide These steps must be completed in 1 working day Drying of sample > Up to 72 hours are permitted from application of the purified sample to the slide to staining Staining > Up to 7 days are permitted between sample staining and examination Examination 3.3.8 Staining Controls Positive staining controls are used to verify that the FITC and DAPI stains are fluorescing appropriately. Positive staining controls are prepared by applying positive antigen or 200 to 400 intact oocysts to a slide and staining the slide with the same reagents and staining procedure used to stain field samples. The analyst examines several fields of view to verify that the stain is fluorescing at the appropriate intensity and uniformity. Control slides and sample slides should be read on the same day. If sample slides from the same staining batch are read over multiple days, the control slide must be rechecked each day before examination of the sample slides. If the laboratory has a large batch of slides that will be examined over several days, and is concerned that a single positive control may fade, due to multiple examinations, the laboratory should prepare multiple control slides with the batch of field slides and alternate between the positive controls when performing the positive control check. Negative staining controls are used to verify that no oocysts or interfering particulates are present. Negative staining controls are prepared by staining and examining a slide with phosphate buffered saline solution. The analyst must indicate on each sample examination results form whether the positive staining control and negative staining control were acceptable. L T2 rule requirement: Each sample must meet the QC criteria for the methods [40 CFK part 141.705(a) (3)]. Per EPA Method1622/1623, positive and negative staining controls must be acceptable (Section 15.2.1) Draft 23 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.3.9 Examination Preparation To help the analyst identify the target analyte during field sample slide examination, each analyst must characterize a minimum of three Cryptosporidium oocysts on the positive staining control slide before examining field sample slides. This characterization must be performed by each analyst during each microscope examination session. FITC examination must be conducted at a minimum of 200X total magnification, DAPI examination must be conducted at a minimum of 400X, and DIC examination and size measurements must be conducted at a minimum of 1000X. Size, shape, and DIC and DAPI characteristics of the three Cryptosporidium oocysts must be recorded by the analyst in a microscope log. 3.3.10 Ongoing Analyst Verification Analyst verifications are ongoing comparisons of slide counts among multiple analysts in a laboratory to assess and maintain consistency in slide examination among analysts. At least monthly when microscopic examinations are being performed, the laboratory shall prepare a slide containing 40 to 100 oocysts. More than 50% of the oocysts must be DAPI positive and undamaged under DIC. For laboratories with multiple analysts, each analyst shall determine the total number of oocysts and cysts and the number that are DAPI positive and DAPI negative for the entire slide. For 10 oocysts and 10 cysts, each analyst shall determine the number of nuclei by DAPI and the DIC category (empty, containing amorphous structures, or containing identifiable internal structures) of each. The total number and the number of DAPI positive and DAPI negative oocysts and cysts determined by each analyst (Section 10.5.2.) must be within ±10% of each other. If the number is not within this range, the analysts must identify the source of any variability between analysts' examination criteria, prepare a new slide, and repeat the performance verification. Differences in the number of nuclei by DAPI and in DIC categorizations among analysts must be discussed and resolved, and these resolutions must be documented. Laboratories with only one analyst should maintain a protozoa library and compare the results of slide examinations to photographs of oocysts and cysts and interfering organisms to verify that examination results are consistent with these references. These laboratories also should perform repetitive counts of a single verification slide for FITC and DAPI. These laboratories should also coordinate with other laboratories to share slides and compare counts. 3.3.11 Proficiency Testing Samples As part of the Laboratory QA Program, laboratories must successfully analyze IPT samples initially, and OPT samples approximately every 4 months when provided by EPA. Proficiency testing samples required as part of the Laboratory QA Program are described in Sections 3.2.2 and 3.2.5. 3.3.12 Acceptance Criteria for Receipt of Field Samples Cryptosporidium samples for LT2 rule monitoring that are not analyzed the same day they are collected must be maintained below 10°C and not allowed to freeze to reduce biological activity. This is specified in Section 8.0 of the June 2003 versions of EPA Method 1622/1623. Because Cryptosporidium samples collected for the LT2 rule must meet the QC criteria in the methods [40 CFR part 705 (a) (3)], and because these QC criteria include receipt of samples at <10°C and not frozen, laboratories must reject LT2 Cryptosporidium samples received at >10°C or frozen. In these cases, the PWS must re-collect and re-ship the sample. Draft 24 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Several options are available to measure sample temperature upon receipt at the laboratory and, in some cases, during shipment, are provided in Section 2.2. X L T2 rule requirement: Each sample must meet the QC criteria for the methods [40 CFK part 141.705 (a) (3)]. Per EPA Method 1622/1623, samples not processed on the day of collection must be received at the laboratory at < 10°C and not frozen (Section 8.1) 3.3.13 Matrix Spike Samples The matrix spike (MS) in EPA Method 1622/1623 (Section 9.5 of the June 2003 version) entails analysis of a separate field aliquot spiked with 100 to 500 oocysts to determine the effect of the matrix on the method's oocyst recovery. During LT2 Cryptosporidium monitoring, PWSs are required, at a minimum, to analyze one MS sample for every 20 field samples from their source water. However, matrix spike samples may be analyzed more frequently to better characterize method performance in the matrix. Based on this requirement, the following PWS categories must analyze at least two MS samples during LT2 rule monitoring: • PWSs serving more than 10,000 people that perform monthly monitoring for 2 years and collect 24 field samples • PWSs serving fewer than 10,000 people that are triggered into monitoring for 1 year and collect 24 field samples For PWSs serving greater than 10,000 people that perform semi-monthly or more frequent monitoring for 2 years and collect 48 or more samples, a minimum three MS samples must be analyzed. S L T2 rule requirements: (1) The MS and field sample must be collected from the same sampling location by splitting the sample stream or collecting the samples sequentially. (2) The volume of the MS sample analyzed must be within 10% of the volume of the field sample analyzed. (3) The MS and field sample must be analyzed by the same procedure [40 CFRpart 141.705 (a) (2) (i)]. 3.3.13.1 Matrix Spike Frequency For all PWSs, the first MS sample should be collected and analyzed during the first sampling event under the monitoring program and at least 12 months must elapse between the first and last MS sample, per EPA Method 1622/1623 (Section 9.1.8). The PWS should evaluate the MS recoveries, as well as other attributes of sample processing and examination, and work with the laboratory to determine whether sample filtration and processing procedures are working acceptably, or need to be re-evaluated. If it is not possible to analyze an MS sample for the first sampling event due to laboratory sample processing burden or other reasons, the first MS sample should be analyzed as soon as possible to identify potential method performance issues with the matrix. The requirement that at least 12 months must elapse between the first and last MS sample still applies. For example, if a PWS that is monitoring monthly for 24 months is unable to process an MS sample until the 8th sampling event, due to laboratory sample processing load, the second MS sample can be processed no earlier than the 20th sampling event. Draft 25 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.3.13.2 Matrix Spikes for Field-Filtered Samples Matrix spike samples must be spiked and filtered in the laboratory. PWSs that field-filter 10-L sample may field filter the monitoring sample for a scheduled sampling event during which an MS is collected, but must collect and ship the MS sample in bulk to the laboratory for spiking, filtering, and analysis. PWSs that field-filter >10-L samples should follow the same procedure. As noted above, the volume of the MS sample analyzed must be within 10% of the volume of the associated field sample. However, if shipping the entire bulk sample is cost-prohibitive, the PWS is permitted to filter all but 10 L of the MS sample in the field, and ship the filtered sample and the remaining 10 L of source water to the laboratory to have the laboratory spike the remaining 10 L of water and filter it through the filter used to collect the balance of the sample in the field [40 CFRpart 141.705 (a)(2)(ii)]. 3.3.13.3 Matrix Spikes Across Multiple Method Variations Used for the Same Public Water System During the LT2 rule, each PWS must perform MS analyses at a frequency of 1 MS per 20 field samples, regardless of whether the analytical procedure is changed during the course of the analysis of the 20 field samples (such as changing from the use of one approved filter to another approved filter). EPA recommends, but does not require, that a PWS evaluate method performance using an additional MS sample if the PWS changes the filter used. 3.3.14 QC Guidance for Method Modifications and Use of Multiple Method Variations EPA Methods 1622/1623 are performance-based methods and, therefore, allow method modifications and the use of different method variations (including the original method and modifications of this method) if a laboratory can meet applicable QC criteria (EPA Method 1622/1623 [Section 9.1.2]) . A method variation is the complete set of sample processing components (including the filter, IMS, and stain) and sample processing procedures (including filtration, concentration, purification, and staining) used to process a bulk water sample for examination. The use of different sample processing components (such as different filters) or substantively different sample processing procedures (such as additional rinses and transfers to reduce carryover after IMS) are considered to be different method variations. The following are considered to be different method variations of EPA Method 1622/1623; this list is not exhaustive, and serves only to provide examples of different method variations: • Standard Envirochek™ filtration procedure using elution, centrifugation, IMS, and IFA • Envirochek™ HV filtration procedure using elution, centrifugation, IMS, and IFA • Standard Filta-Max™ procedure using elution tube and concentrator tube, IMS, and IFA • Filta-Max™ procedure using stomacher, concentrator tube, IMS, and IFA • Filta-Max™ procedure using stomacher, centrifugation, IMS, and IFA • Filta-Max™ procedure using elution tube and centrifugation, IMS, and IFA • Direct centrifugation, IMS, and IFA • The use of different IMS kits • The use of different antibody staining kits • The use of additional rinses and transfers to reduce carryover from IMS to the slide • The use of multiple filter membranes in the Filta-Max™ concentrator tube Draft 26 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Guidance on requirements for initial and ongoing demonstrations of acceptable laboratory performance for different method variations is provided in Sections 3.3.14.1 through 3.1.14.3, below. 3.3.14.1 Using Only One Method Variation Per EPA Method 1622/1623 (Section 9.1.2) and the Lab QA Program, if a laboratory uses the same method variation for all samples, then the laboratory is only required to demonstrate acceptable initial laboratory performance (through the IPR and IPX tests) once and demonstrate acceptable ongoing laboratory performance (through the OPR, method blank, and OPT tests) using that method variation. 3.3.14.2 Switching from One Method Variation to Another Per EPA Method 1622/1623 (Section 9.1.2) and the Lab QA Program, if a laboratory intends to switch completely from one method variation to another, then the laboratory must demonstrate acceptable initial laboratory performance (through the IPR and IPX tests) using the new method variation before implementing this procedure for the analysis of field samples. If the laboratory demonstrates acceptable initial laboratory performance and implements the new method variation and discontinues use of the old method variation, then the laboratory must demonstrate acceptable ongoing laboratory performance (through the OPR, method blank, and OPT tests) using the new variation. 3.3.14.3 Using Multiple Method Variations Per EPA Method 1622/1623 (Section 9.1.2) and the Lab QA Program, if a laboratory intends to use multiple method variations concurrently, then the laboratory must demonstrate acceptable initial laboratory performance (through the IPR and IPX tests) using each method variation before implementing this procedure for the analysis of LT2 rule samples. If the laboratory demonstrates acceptable initial laboratory performance and implements multiple method variations, then the laboratory must demonstrate acceptable ongoing laboratory performance (through the OPR, method blank, and OPT tests) using each method variation if the method variations differ through the use of different filters or IMS systems. The laboratory is not required to demonstrate acceptable ongoing laboratory performance using each method variation if the method variations differ through the use of different antibody stains, the use of additional rinses and transfers for some samples to reduce carryover from IMS onto the slide, or multiple membrane filters in the Filta-Max™ particle concentrator for some samples. • If a laboratory alternates among more than one antibody staining kit, the laboratory must perform positive and negative staining controls for each antibody kit for each batch of slides to which the kit is used and must alternate between the kits for ongoing demonstrations of acceptable laboratory performance. MS samples should be processed using the same method variation as the associated field sample, regardless of the method variation used to demonstrate ongoing acceptable laboratory performance. • If the laboratory uses additional rinses and transfers for some samples to reduce carryover from IMS onto the slide, the laboratory must use this procedure (which may reduce recoveries) to demonstrate acceptable ongoing laboratory performance. MS samples should be processed using the same method variation as the associated field sample, regardless of the method variation used to demonstrate ongoing acceptable laboratory performance. • If the laboratory uses multiple membrane filters in the Filta-Max™ particle concentrator for some samples, the laboratory must use this procedure (which may reduce recoveries) to demonstrate acceptable ongoing laboratory performance. MS samples should be processed using the same method variation as the associated field sample, regardless of the method variation used to demonstrate ongoing acceptable laboratory performance. Draft 27 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.3.15 Guidance on QC Requirements for Different Sample Volumes A laboratory with multiple PWS clients representing a range of sample volumes is not responsible for performing QC tests at all of the volumes. However, if the laboratory does analyze both 10-L and 50-L sample volumes for clients—or any volumes in between—then the laboratory should demonstrate acceptable performance in a manner representative of the sample volumes they process. Guidance on initial and ongoing demonstrations of acceptable laboratory performance is provided below, in Sections 3.3.15.1 through 3.3.15.3. 3.3.15.1 Guidance on Initial Precision and Recovery Tests for Different Sample Volumes A laboratory with multiple PWS clients representing a range of sample volumes should successfully perform the IPR and method blank test, as well as successfully analyze matrix spike/matrix spike duplicate (MS/MSD) and initial proficiency testing (IPX) samples (for the Lab QA Program's initial demonstration of capability [IDC]), at the largest (most challenging) volume. The laboratory should demonstrate acceptable performance for these tests using spikes of no greater than 500 oocysts (however, demonstrating acceptable performance at spikes of 100 - 200 is preferable). 3.3.15.2 Guidance on Ongoing Precision and Recovery Tests and Method Blank Tests for Different Sample Volumes A laboratory with multiple PWS clients representing a range of sample volumes is not responsible for performing ongoing precision and recovery (OPR) tests for each of the volumes. The following approaches should be used, depending on whether the laboratory analyzes more than 20 PWS samples per week: • A laboratory that processes different sample volumes and more than 20 PWS samples per week—and that would necessarily be required to process more than one set of OPR and method blank samples each week—should demonstrate ongoing acceptable performance at both extremes of the volume spectrum by performing one OPR and method blank at a volume consistent with the highest sample volume submitted by clients (e.g. 50 L) and performing a second OPR and method blank at a volume consistent with the lowest sample volume submitted by clients (but not less than 10 L). If more than 40 field samples are processed in a week, and more than two QC batches are required, the laboratory may use the volume at either extreme or a volume in between the two extremes. The laboratory should work with their PWS clients to attempt to schedule clients with different sample volume sizes for different periods during the week, so the field samples can be batched with QC samples of comparable volume. • Laboratories that process fewer than 20 PWS samples per week only need to analyze one set of QC samples per week, even if the laboratory processes samples of various volumes. However, the laboratory should perform the OPR and method blank test using the volume most representative of the anticipated sample volumes of the LT2 rule samples to be analyzed that week. The laboratory also should work with their PWS clients to schedule clients with different sample volume sizes for different weeks, so the field samples can be batched with QC samples of comparable volume. 3.3.15.3 Guidance on Ongoing Proficiency Tests for Different Sample Volumes Laboratories with multiple PWS clients representing a range of sample volumes are not required to analyze OPT samples at each sample volume. The laboratory should notify EPA of the sample volume most representative of the LT2 samples processed and perform the OPT test using this volume. Draft 28 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.4 Sample Collection Procedures Several options are available to the PWS in collecting untreated surface water samples for Cryptosporidium analysis, including the following. • Collection of bulk water samples for shipment to the laboratory for filtration and analysis. • On-site filtration of water samples from pressurized or unpressurized sources using the Pall Gelman Envirochek or Envirochek HV capsule filter. • On-site filtration of water samples from pressurized or unpressurized sources using the IDEXX Filta- Max foam filter. Detailed procedures for each of these options, as well as packing and shipping the samples from the PWS to the Cryptosporidium analysis laboratory, are provided as appendices in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule). As noted in the PWS guidance manual, EPA strongly recommends that the laboratory and PWS conduct at least one practice sampling and analysis event prior to starting official LT2 monitoring. Based on previous experiences in the Information Collection Rule (ICR) and ICR Supplemental Surveys, unanticipated problems are often encountered during the first sampling event, but are addressed in subsequent events. Rather than risking sampling problems during official LT2 monitoring, the PWS and laboratory should conduct at least one sampling event prior to monitoring to identify and resolve any problems. 3.5 Sample Processing and Analysis Procedures Although EPA has proposed the use of the April 2001 versions of EPA Methods 1622/1623 in the LT2 rule, EPA has requested comment on the use of updated versions (dated June 2003) to consolidate several method-related changes EPA believes are necessary to address LT2 rule monitoring requirements. These changes are summarized in Section 3.1.2. This draft manual assumes that the June 2003 versions of EPA Methods 1622 and 1623 will be used for LT2 rule monitoring. The June 2003 versions of these methods are included as Appendix B and Appendix C of this guidance manual. 3.6 Recordkeeping An acceptable record keeping system provides information on sample collection and preservation, analytical methods, raw data, calculations, reported results, and a record of persons responsible for sampling and analyses. For EPA Methods 1622 and 1623, data should be provided on bench sheets (Appendix G) and slide examination results forms (Appendix H). Original data, including microscope examination counts and notes, must be recorded on these forms. Data should be recorded in ink and a single line drawn through any change with an initialed, dated correction entered next to it. Data files may also be microfiche or electronic. Electronic data should be backed up by a protected tape or disk or hard copy. Microbiological analyses records must be kept for at least 5 years. Draft 29 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories As laboratories perform Cryptosporidium analyses during the LT2 rule, the following data recording practices should be followed: • Maintain sample identification information, including sample collection and receipt dates and conditions • Record all raw data (primary measurements) used to calculate final concentrations of oocysts/L for each sample • Record the date and time of each method step associated with a holding time to verify that all method holding times have been met • Record the name of the analyst performing each method step to verify that only qualified technicians and analysts are performing the method The minimum data elements that should be recorded for Cryptosporidium samples during the LT2 are discussed in detail below. These data elements are critical to ensuring that final sample concentrations can be verified using primary data, and are necessary to demonstrate that all method-specified holding times were met. Standardized bench sheets and examination results forms are available for download on the LT2 website http://www.epa.gov/safewater/lt2/index.html. Sampling records provided by the PWS with the sample should include the following information, at a minimum: • Public water system name and ID number* • Facility name and number* • Date and start/stop times of collection* • Sampler's name and phone number (or alternate contact for laboratory if problems are encountered) • Start and stop times of collection (if the sample was filtered in the field) • Volume filtered information (if the sample was filtered in the field) • Whether the filter clogged (if the sample was filtered in the field) • Analyses requested (e.g. routine field sample analysis or field sample + MS analysis) * Note: The combination of these three elements is the unique sample number used to identify the LT2 sample from sample collection, analysis, reporting, and use. Detailed guidance on sample collection data recording, as well as forms and sample collection and shipping procedures can be found in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule). This manual is available for download from http://www.epa. gov/safewater/lt2/index.html. Upon receipt of the sample at the laboratory, laboratory personnel should record, at a minimum, the information in Table 3-3. Draft 30 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Table 3-3. Sample Receipt Data Elements to Record in the Laboratory for EPA Method 1622/1623 Cryptosporidium Analysis Public water system name and ID Facility name and ID Sample collection point name and ID Date of sample collection Date and time of sample receipt by laboratory Name of laboratory person receiving the sample Temperature of sample upon receipt Any deficiencies (deficiencies may include but are not limited to: temperature exceeded 10°C, or sample leaked during transport) exceeded sample holding time, transport Laboratories analyzing samples for Cryptosporidium using EPA Method 1622/1623 in support of the LT2 rule should record the primary elements required to calculate the final concentrations and percent recoveries for matrix spike and ongoing precision and recovery samples. These primary data elements are provided in Table 3-4, and should be recorded on the EPA Method 1622/1623 bench sheet (Appendix G). Table 3-4. Primary Data Elements to Record in the Laboratory for EPA Method 1622/1623 Cryptosporidium Analysis Estimated number of oocysts spiked (MS and OPR samples), based on information provided by the flow-cytometry laboratory with the spiking suspension Samples volume spike, in L (MS and OPT samples) Sample volume filtered, to nearest 1/4 L Number of filters used (if the filter clogged) Pellet volume after concentration, to the nearest 0.1 ml_ Total volume of resuspended concentrate, in ml_ Volume of the resuspended concentrate transferred to IMS, in ml_ Number of subsamples analyzed Total number of oocysts detected in the sample To determine that all method QC requirements were met and that the samples was analyzed by qualified personnel according to the requirements of the Laboratory QA Program for the Analysis of Cryptosporidium the laboratory should record the elements in Table 3-5. Draft 31 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Table 3-5. QC Data Elements to Record in the Laboratory for EPA Method 1622/1623 Cryptosporidium Analysis Elution date and time (must be within 96 hours of sample collection) Slide preparation date and time (must be completed in same working day as elution) Sample staining date and time (must be completed within 72 hours of slide preparation) Sample examination date and time (must be completed within 7 days of sample staining) Analyst performing filtration Analyst performing elution Analyst performing IMS Analyst performing sample staining Analyst performing sample examination Results of the positive and negative staining controls The laboratory should also record any additional information that will support the results obtained or allow problems with sample results and laboratory performance to be identified. This additional information could include the following: • Information on the version of EPA Method 1622/1623 used to perform the analysis including; filter type, elution procedure, concentration procedure, IMS system used, detection kit used, and source of oocysts for spiking suspensions • Lot numbers of reagents and materials used during the analysis, including the filter, elution buffer, IMS system, detection kit, and spiking suspension • FITC, DAPI, and DIG information of all oocysts detected in the field samples using the examination results form This information should be recorded on the EPA Method 1622/1623 bench sheet (Appendix G) and slide examination results form (Appendix H), as appropriate. Size, shape, and DIG and DAPI characteristics of the three Cryptosporidium oocysts for ongoing analyst verification (Section 3.3.10) must be recorded by the analyst on a microscope log. 3.7 Calculations for EPA Methods 1622/1623 During LT2 rule monitoring, field sample results must be reported in oocysts/L and MS recoveries must be calculated and reported. In addition, laboratories must calculate recoveries for other QC samples [40 CFRpart 141.705 (a)]. Calculations for EPA Method 1622/1623 field and QC samples are provided below, in Sections 3.7.1 through 3.7.3. 3.7.1 Field Sample Calculations To calculate the concentration of Cryptosporidium in your field sample, reported as oocysts/L, the following information is needed: • Number of oocysts detected in the sample (recorded as a primary measurement from the examination results form) • Volume analyzed Draft 32 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Using these two data elements, the final concentration is calculated as: oocysts detected in the sample final concentration (oocysts/L) = volume analyzed (L) If 100% of the sample volume filtered is examined, then the volume analyzed equals the volume filtered. This applies whether one filter or more than one filter was used; if more than one filter was used, and all of the volume filtered through the multiple filters is processed through the remainder of the method, then the volume examined is simply the sum of the volumes filtered through each of the filters used. If < 100% of the volume filtered was processed through the remainder of the method, then additional calculations are needed to determine the volume analyzed. This is discussed in Section 3.7.1.1. 3.7.1.1 Determining Volume Analyzed when Less than 100% of Sample Was Examined When <100% of the sample filtered is processed through the remainder of the method and examined (such as when the volume filtered yields > 2 mL of packed pellet volume after centrifugation), then the volume analyzed must be determined using the following equations to determine the percentage of the sample that was examined. total volume of resuspended concentrate transferred to IMS (mL) (see Section 3.7.1.2) percent examined = total volume of resuspended concentrate produced (mL) volume analyzed (L) = percent examined * sample volume filtered (L) 3.7.1.2 Determining the Volume of Resuspended Concentrate to Use for Packed Pellets > 0.5 mL Packed pellets with a volume > 0.5 mL must be divided into subsamples. Use the formula below to determine the total volume of resuspension required in the centrifuge tube before separating the concentrate into two or more subsamples and transferring to IMS. pellet volume (mL) after centrifugation total volume of resuspended concentrate (mL) required = x 5 mL 0.5 mL 3.7.1.3 Example Calculation Example. A 10-L field sample was filtered and processed, producing a packed pellet volume of 2.7 mL. The laboratory transferred 20 mL of the total resuspended concentrate to IMS and examination. The laboratory detected 20 oocysts during examination. The following calculations were performed to determine the volume analyzed and final concentration. 2.7 mL total volume of resuspended concentrate (mL) required = x 5 mL = 27 mL 0.5 mL 20 mL percent examined = = 0.74 (74%) 27 mL Draft 33 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories volume analyzed (L) = 0.74 x 10 L = 7.4 L 20 oocysts final concentration (oocysts/L) = = 2.7 oocysts/L 7.4 L 3.7.2 Matrix Spike Sample Calculations To determine the percent recovery for a matrix spike (MS) sample the following information is needed: • The number of oocysts detected in the MS sample • The estimated number of oocysts spiked into the MS sample • The number of oocysts detected in the unspiked field sample (to correct for background concentration) oocysts counted in MS sample - oocysts counted in unspiked field sample percent recovery = x 100% oocysts spiked into MS sample If both a matrix spike (MS) and a matrix spike duplicate (MSB) are analyzed, then the mean recovery and relative percent difference (RPD) should be calculated and compared to the acceptance criteria in Section 21.0, Tables 3 and 4 of the June 2003 version of EPA Method 1623. The percent recovery for each sample should be calculated as described above to determine the mean recovery. To calculate the mean percent recovery, calculate the percent recovery for each sample, as described above, then use the following formula: percent recovery of MS sample + percent recovery of MSD sample mean percent recovery = To calculate the RPD, the absolute value (without sign) of the difference between the number of oocysts detected in the MS and MSD is divided by the mean of the oocysts detected in both samples to yield a percentage of the difference. oocysts detected in MS - oocysts detected in MSD RPD= xioo% ((oocysts detected in MS + oocysts detected in MSD)/2) Example. The laboratory prepared both the MS and MSD by spiking two 10-L samples with 100 oocysts each. For both the MS and MSD, the entire 10-L sample was filtered and 100% of the sample was examined. The laboratory detected 45 oocysts in the MS sample and 50 oocysts in the MSD. In the unspiked field sample only 2 oocysts were detected. To determine the percent recovery for each sample and the mean recovery and relative percent difference of the MS and MSD, the following calculations were performed. 45 oocysts - 2 oocysts MS percent recovery = x 100% = 43% 100 oocysts Draft 34 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 50 oocysts - 2 oocysts MSD percent recovery = x 100% = 48% 100 oocysts 43% + 48% mean recovery = x 100% = 45.5% 45 oocysts - 50 oocysts RPD = x 100% = 10.5% ((45 oocysts + 50 oocysts) / 2) 3.7.3 OPR Sample Calculations The percent recovery of an OPR sample is calculated using the following formula: oocysts detected percent recovery = x 100% oocysts spiked Example: The laboratory prepared the OPR sample by spiking 50 L with 150 oocysts. The entire sample was filtered and examined. The laboratory detected 76 oocysts. 76 oocysts percent recovery = x-|00% = 50.7% 150 oocysts OPR recoveries are compared to the limits for ongoing recovery in Table 3 and 4 in Section 21.0 of the June 2003 version of EPA Method 1623. These recoveries are tracked overtime using control charts to assess precision, as discussed in Section 3.3.5, above. 3.8 Electronic Data Reporting During the LT2 rule, laboratories will report Cryptosporidium data to their PWS clients electronically through EPA's LT2 Data Collection System. The LT2 Data Collection System is a web-based application that allows laboratory users to enter or upload data, then electronically "release" the data to the PWS for review, approval, and submission to EPA and the State. Although ownership of the data resides with the PWS throughout this process, the LT2 Data Collection System increases the ease and efficiency of the data entry and transfer process from one party to another by transferring the ability to access the data from the laboratory to the PWS to EPA and the State, and ensuring that data cannot be viewed or changed by unauthorized parties. A summary of the data entry, review, and transfer process through the LT2 Data Collection System is provided in Table 3-6, below. Draft 35 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Table 3-6. LT2 Data Collection System Data Entry, Review, and Transfer Process Laboratory actions • Laboratory posts analytical results to the LT2 Data Collection System • LT2 Data Collection System reduces data and checks data for completeness and compliance with LT2 rule requirements • Laboratory Principal Analyst confirms that data meet quality control requirements • Laboratory "releases" results electronically to the PWS for review • Laboratory user cannot edit data after it is released to the PWS ro T3 o o ro ro _c "o o T3 LU PWS actions • PWS cannot edit data - only review data and either return to laboratory to resolve errors or submit to EPA • PWS reviews electronic data through LT2 Data Collection System • PWS "releases" data back to the laboratory if questions • If no questions, PWS submits data to EPA as "approved" or "contested" (indicating that samples have been correctly analyzed, but that the PWS contends are not valid for use in LT2 binning) EPA and State actions • EPA and State users cannot edit data - only review data • EPA and State review data through LT2 Data Collection System The data reporting process is discussed in more detail below, in Sections 7.2.1 through 7.2.3, and discussed in detail in the Users' Manual for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) Data Collection System. The LT2 data system users' guide also provides detailed information on the PWS user registration process. Information on the LT2 Data Collection System, as well as a downloadable users' manual, is available at http://www.epa.gov/safewater/lt2/index.html. 3.8.1 Data Entry/Upload The analyst or another laboratory staff member enters a subset of the data recorded at the bench (Section 7.1) into the LT2 Data Collection System, either by entering the data using web forms or by uploading data in XML format. Per 40 CFRpart 141.707(e)(l), this information includes the following: • PWS ID • Facility ID • Sample collection point • Sample collection date • Sample type (field or MS) • Sample volume filtered (L), to nearest % L • Was 100% of filtered volume examined? • Number of oocysts counted • For samples in which less than 10 L is filtered or less than 100% of the sample volume is examined, the laboratory also must enter or upload the number of filters used and the packed pellet volume Draft 36 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories • For samples in which less than 100% of sample volume is examined, the laboratory also must report the volume of resuspended concentrate and volume of this resuspension processed through immunomagnetic separation • For matrix spike samples, the laboratory also must report the sample volume spiked and estimated number of oocysts; these data are not required for field samples The laboratory must verify that all holding times and other QC requirements were met. After the information has been entered or uploaded into the system, the system will reduce the data to yield final sample results, in oocysts/L, verify that LT2 rule Cryptosporidium sample volume analysis requirements were met for samples in which less than 10 L were analyzed, and calculate MS recoveries. The laboratory's Primary Analyst under the Lab QA Program is responsible for verifying the quality and accuracy of all sample results in the laboratory, and is required to review and approve the results before they are submitted to the PWS for review. If inaccuracies or other problems are identified, the primary analyst discusses the sample information with the analyst or data entry staff and resolves the issues before the data are approved for PWS review. If no inaccuracies or other issues are identified, the Primary Analyst approves the reported data for "release" to the PWS for review (EPA does not receive the data at this point). When the data are approved, the rights to the data are transferred electronically by the system to the PWS, and the data can no longer be changed by the laboratory. 3.8.2 PWS Data Review After the laboratory has released Cryptosporidium data electronically to the PWS using the LT2 Data Collection System, the PWS will review the results. The PWS user cannot edit the data, but if the PWS has an issue with the sample result, such as if the PWS believes that the sample collection point ID or collection date is incorrect, the PWS can release the results back to the laboratory for issue resolution. In addition to noting the reason in the LT2 Data Collection System for the return of the data to the laboratory, you also should contact the laboratory verbally to discuss the issue. If the PWS determines that the data are accurate, the PWS releases the results to EPA (and the State, if applicable) as "approved" results. If the PWS determines that the data are accurate, but believes that the data are not valid for LT2 binning purposes, the PWS can release the results to EPA and the State as "contested." Contested samples are those that have been correctly analyzed, but that you contend are not valid for use in LT2 binning, and have submitted to EPA for evaluation. 3.8.3 EPA/State Review After the PWS has released the results as approved or contested, they are available to EPA and State users to review through the LT2 Data Collection System. EPA and State users cannot edit the data. 3.9 Data Archiving he PWS is required to archive all original, hardcopy quality control data associated with LT2 sample analyses for 36 months after the end of the second round of Cryptosporidium monitoring (which is scheduled to take place 6 years after the start of the first round [40 CFRpart 141.731(a)]. Although it is the PWS's responsibility to meet LT2 rule data storage requirements for compliance monitoring samples, including MS samples, the PWS may designate this responsibility to the laboratory. Draft 37 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.9.1 Hardcopy Data The following data should be archived: • Bench sheets and examination results forms for all LT2 monitoring samples, including both field samples and MS samples • Bench sheets and examination results forms for all OPR samples and method blank samples, and records of the compliance monitoring samples associated with each OPR sample and blank sample • Spike enumeration information received from Cryptosporidium spiking suspension vendors • Bench sheets and examination results forms for all OPT samples As part of the Lab QA Program, the laboratory also must maintain the same documentation for their IPR and IPT data for each method variation used for LT2 samples. 3.9.2 Slides Although not required, laboratories also may want to archive slides and/or take photographs of slides to maintain for clients. Slides should be stored in a humid chamber in the dark at 0°C to 10°C. As an alternate to the DABCO/glycerol mounting medium currently specified in EPA Method 1622 and 1623, laboratories may wish to evaluate the use of the elvanol mounting medium, which hardens, and may be useful for archiving slides. Reagents for the mounting medium include the following: • 8.0 g elvanol—ICN Biomedicals cat. no. 151937, Aurora, Ohio, or equivalent • 48.0g(40mL)glycerol • 10%NaN3 • DABCO—Sigma Chemical Co. cat no. D-2522, or equivalent • Tris buffer—Dissolve 1.2 g Tris (Fisher cat. no. BP152) in 95 mL reagent water, adjust pH to 8.5 with 1NHC1 To prepare the medium, use the following procedure: • Add 48.0 g (40 mL) glycerol to 8.0 g elvanol and stir. • Add 49.0 mL of reagent water and 1.0 mL 10% NaN3 and stir. Let stand 4 hours at room temperature. • Add DABCO in Tris buffer (4.75 g of DABCO in 100 mL Tris buffer, adjusted to pH 8.5 with cone. HC1) and stir. • Place mixture in a boiling water bath until the mixture becomes homogenous. • Centrifuge mixture at 2000XG for 10 minutes. Centrifugation of entire mixture in one tube is preferable. • Dispense 3- to 5-mL aliquots of the mixture into tubes and store at 0°C to 10°C. If the mounting medium sets up in the tube during storage, re-heat in boiling water bath or microwave for a short time to restore mixture to liquid state. Make sure to test any new reagent first on QC samples to verify that the mounting medium performs properly before using the medium on any monitoring samples. Draft 38 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.10 Equipment, Supplies, Reagents, and Standards See Sections 6 and 7 of EPA Method 1622 (Appendix B) or EPA Method 1623 (Appendix C) for details on the materials needed to perform the Cryptosporidium analyses specified in the methods. Detailed information on vendors for these materials is provided in Section 3.11. 3.11 Vendor Contact List 3.11.1 Sample Collection and Filtration Supplies Alamo Water Treatment 13 700 Highway 90 West San Antonio, TX 78245 Phone: (800) 659-8400 ext. 2 Fax: (800) 659-8402 E-mail: scsales@alamowater.com BDH/Merck www.merckeurolab.ltd.uk Merck Eurolab Ltd. UK Headquarters Laboratory Supplies Merck House, Poole, Dorset BH15 1TD Sales: Phone: 01202669700 Fax: 01202665599 E-mail: info@merckeurolab.ltd.uk Technical Support: Phone: 01202669700 Fax: 01202665599 E-mail: info@merckeurolab.ltd.uk Bertram Controls Corporation LLC 5 Eastview Drive Farmington, CT 06032 Sales and Technical Support: Phone: (800) 243-2340 Fax: (800)243-7166 E-mail: techsupport@BertramContols .com Cole-Parmer www. coleparmer. com 625 East Bunker Court Vernon Hills, IL 60061 Sales: Phone: (800) 323-4340 Fax: (847) 247-2929 E-mail: sales@coleparmer.com Technical Support: Phone: (800) 323-4340 ext. 122 Fax: (847) 327-2987 E-mail: techinfo@coleparmer.com E. Clark and Associates www. devicelink.com/company9 8 10 Brent Drive Hudson, MA 01749 Sales and Technical Support: Phone: (800) 253-2497 Fax:(978)568-0060 Email: mail@clarksol.com Grainger www.grainger.com Contact sales rep. for local address and more contact info. Sales: Phone: (888) 361-8649 Technical Support: Phone: (800) 535-5400 Draft 39 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories Sample Collection and Filtration Supplies (Continued) IDEXX www.idexx.com Sales: Phone: (800) 321-0207 ext.l Fax: (207)856-0630 Technical Support: Phone: (800) 321-0207 ext.2 Fax: (207)856-0630 E-mail: water(g),idexx.com Pall Gelman Sciences www .pall. com/gelman 600 South Wagner Road Ann Arbor, MI 48103 Sales: Phone: (800) 521-1520 ext.2 Fax:(734)913-6495 Technical Support: Phone: (800) 521-1520 ext.3 Fax:(734)913-6495 PPG Industries www.ppg.com One PPG Place Pittsburgh, PA 15272 Sales and Technical Support: Phone: (412)434-3131 Tygon www.tygon.com Saint-Gobain Performance Plastics Corp. Distributor: Ryan Herco. Products 1501 Waco St. Richmond, VA 23244 Sales: Phone: (804)672-1158 Fax: (804) 672-0878 Technical Support: Saint-Gobain Phone: (800) 798-1539 Fax:(800) 488-9466 Email: linda.d.anderson@,saint-gobain.com 3.11.2 Sample Concentration and Purification Supplies Dynal, Inc. www.dynal.net 5 Delaware Drive Lake Success, NY 11042 Sales: Phone: (800) 638-9416 ext.l Fax: (516)326-3298 E-mail: uscustserv@dvnalbiotech.com Technical Support: Phone: (800) 638-9416 ext.2 Fax: (516)326-3298 E-mail: ustechserv@dvnalbiotech.com International Equipment Company www. labcentrifuge. com 300 Second Avenue Needham Heights, MA 02492 Sales and Technical Support: Phone: (800) 841-1113 ext.9723 Fax: (781)444-6743 E-mail: pat.webb@thermoiec.com Draft 40 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.11.3 Slides and Related Supplies Dynal, Inc. www. dynal .net 5 Delaware Drive Lake Success, NY 11042 Sales: Phone: (800) 638-9416 ext.l Fax: (516)326-3298 E-mail: uscustserv(g),dynalbiotech.com Technical Support: Phone: (800) 638-9416 ext.2 Fax: (516)326-3298 E-mail: ustechserv(g),dynalbiotech.com Mauser Scientific www.deltasci.com Distributed by Delta Scientific 1979 Stout Drive, Bldg. 5 Ivyland, PA 38974 Sales and Technical Support: Phone: (800) 428-9400 Fax: (800)428-3271 E-mail: dsirep@aol.com Meridian Diagnostics, Inc. 3471 River Hills Drive Cincinnati, OH 45244 Sales: Phone: (800) 543-1980 Fax: (513)271-0124 Technical Support: Phone: (800) 343-3858 Fax: (513)271-0124 PGC Scientifics www.pgcscientifics.com P.O. Box 7277 Gaithersburg, MD 20898-7277 Sales and Technical Support: Phone: (800) 424-3300 Fax: (800)662-1112 E-mail: cs(g),pgcscientifics.com Waterborne, Inc. www.waterborneinc.com 6047 Hurst Street New Orleans, LA 70118-6129 Sales and Technical Support: Phone: (504) 895-3338 Fax: (504) 895-3338 E-mail: custserv@waterborneinc.com 3.11.4 Antibody Stains BioTechnology Frontiers (BTF) www.biotechnologyfrontiers.com Unit 1 35-41 Waterloo Road North Ryde NSW Australia Fax: +61 2 9889 1805 Email:contact(gibiotechnologyfrontiers.com Meridian Diagnostics, Inc. 3471 River Hills Drive Cincinnati, OH 45244 Sales: Phone: (800)543-1980 Fax: (513)271-0124 Technical Support: Phone: (800) 343-3858 Fax: (513)271-0124 Waterborne, Inc. www.waterborneinc.com 6047 Hurst Street New Orleans, LA 70118-6129 Sales and Technical Support: Phone: (504) 895-3338 Fax: (504) 895-3338 E-mail: custserv@waterborneinc.com Draft 41 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.11.5 Microscope Equipment Chroma Technology Corp. www.chroma.com 74 Cotton Mill Hill Brattleboro, VT 05301 Sales: Phone: (800)824-7662 Fax: (802) 257-9400 Technical Support: Phone: (800)824-7662 Fax: (802) 257-9400 Nikon www .nikonusa. com NIKON 1300 Walt Whitman Road Melville, NY 11747 Customer Information: Phone: (800) 52-NIKON Email: Available through website Olympus www.olympusamerica.com Olympus America INC. 2 Corporate Center Drive, Melville, NY 11747- 3157, U.S.A. Product Support: Phone: (800) 446-5967 Email: Available through website Zeiss www.zeiss.com Carl Zeiss Microimaging, Inc. One Zeiss Drive Thornwood, N.Y. 10594 Sales and Technical Support: Phone: (800) 233-2343 Fax: (914) 684-7446 E-mail: micro(a),zeiss.com 3.11.6 Spiking Suspensions and Positive Staining Control Materials BioTechnology Frontiers (BTF) www.biotechnologyfrontiers.com Unit 1 35-41 Waterloo Road North Ryde NSW Australia Fax: +61 2 9889 1805 Email: contact(g),biotechnologyfrontiers.com Hyperion Research, Ltd. 1008 Allowance Avenue, SE Medicine Hat, Alberta TIA 3G8 Canada Sales and Technical Support: Peter Wallis Phone: (403) 529-0847 Fax: (403) 529-0852 E-mail: hvperion(g),telusplanet.net Waterborne, Inc. www.waterborneinc.com 6047 Hurst Street New Orleans, LA 70118-6129 Sales and Technical Support: Phone: (504) 895-3338 Fax: (504) 895-3338 E-mail: custserv@waterborneinc.com Sterling Parasitology Laboratory, University of Arizona, Tucson Building 90, Rm. 202 Tucson, AZ 85721 Sales and Technical Support: Marilyn Marshall Phone: (520) 621-4433 Fax: (520) 621-3588 E-mail: marshalm(g),u.arizona.edu Wisconsin State Laboratory of Hygiene, Flow Cytometry Unit 2601 Agriculture Drive Madison, WI 53718 Sales and Technical Support: Phone: (608) 224-6260 Fax: (608)224-6213 Draft 42 June 2003 ------- Section 3: Guidance for Cryptosporidium Laboratories 3.11.7 Other Laboratory Supplies for EPA Method 1622/1623 Fisher Scientific VWR www.fishersci.com www.vwr.com 9999 Veterans Memorial Drive 05 Heron Drive Houston, TX 77038 Bridgeport, NJ 08014 Sales: Sales: Phone: (800) 766-7000 Phone: (800) 932-5000 Fax: (800) 926-1166 Fax: (856) 467-3336 Technical Support: Technical Support: Phone: (800) 766-7000 Phone: (800) 932-5000 Fax: (800) 926-1166 Fax: (856) 467-3336 Sigma www. sigma-aldrich. com P.O. Box 14508 St. Louis, MO 63178 Sales: Phone: (800)325-3010 Fax: (800) 325-8070 E-mail: custserv@sial.com Technical Support: Phone: (800)325-5832 Fax: (314)286-7828 E-mail: techserv@sial.com Draft 43 June 2003 ------- SECTION 4: GUIDANCE FOR E. cou LABORATORIES Although public water system (PWS) treatment requirements will be determined from Cryptosporidium monitoring results, the Long-Term 2 Enhanced Surface Water Treatment (LT2) rule also requires that large PWSs (those serving > 10,000) perform E. coll and turbidity analyses on source water samples [40 CFR part 141.701 (b)]. The Cryptosporidium, E. coli, and turbidity data will be analyzed to evaluate whether E. coli and/or turbidity levels can be used as reliable indicators of Cryptosporidium occurrence in surface waters used as source waters for drinking water facilities. Depending upon the results of these analyses, EPA may permit small PWSs to use E. coli monitoring, or a combination of E. coli and turbidity monitoring, to determine the need for implementing more expensive Cryptosporidium monitoring or improved treatment. Cryptosporidium analysis requirements and recommendations are discussed in Section 3 of this guidance manual. Turbidity measurement requirements and recommendations are addressed in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) (available for download from http://www.epa. gov/safewater/lt2/index.html). E. coli analysis requirements and recommendations for the LT2 rule, including laboratory certification, quality assurance/quality control (QA/QC), and the procedures for each of the methods approved for use during LT2 E. coli monitoring, are presented below. All E. coli sample analyses performed under the LT2 rule must be quantitative [40 CFR 141.705 (b)]. Presence/absence data cannot be used to assess whether E. coli concentration can be used to indicate Cryptosporidium occurrence levels. 4.1 Laboratory Certification Program PWS laboratories and other laboratories performing LT2 rule E. coli analyses must be certified for coliform analyses under the drinking water certification program for a similar method type (e.g., membrane filtration, multiple-tube, multiple-well) [40 CFR part 141.706 (b)]. The drinking water certification program was established to fulfill requirements stipulated by the Safe Drinking Water Act (SDWA) and the requirements of the National Primary Drinking Water Regulations (NPDWR) (40 CFR 141.28). The certification program requires that all laboratories analyzing drinking water must be certified by EPA, including EPA's Regional labs, laboratories on Federal Indian Lands, principal state laboratories, and laboratories that perform analyses under the SDWA in states without primacy. States that have primary enforcement responsibility (primacy) are required to have laboratory facilities available which have been certified by EPA (see 40 CFR 142.10) or National Environmental Laboratory Accreditation Conference (NELAC). All labs that perform testing for compliance purposes must be certified by the state or EPA. Public water systems serving at least 25 persons or having at least 15 service connections must comply with the SDWA and the requirements of the NPDWR. The certification program consists of annual performance evaluation samples and on-site lab audits every three years by EPA or the state. During laboratory audits EPA or the state will evaluate the laboratory's Quality Assurance Plan (QAP), performance on routine water samples, and chain-of-custody procedures. The certification process and detailed specifications for certification are described in the EPA Manual for the Certification of Laboratories Analyzing Drinking Water Certification Manual) (Reference 5.2) (http://www.epa.gov/safewater/certlab/labindex.html) Draft 44 June 2003 ------- Section 4: E. coli Laboratory Guidance Laboratories analyzing E. coli samples for the LT2 rule must use an E. coli method approved for use under the rule and must be certified under the drinking water certification program for a similar method type (e.g., membrane filtration) corresponding to the method the laboratory plans to use for LT2 rule monitoring [40CFRpart 141.705 (b) and 141.706 (b)]. Approved E. coli methods and their corresponding drinking water certification program coliform techniques are provided in Table 4-1. Table 4-1. Approved E. coli Methods for LT2 Rule and Corresponding Drinking Water Certification Program Techniques E. coli Methods Approved for LT2 Rule Standard Methods 9223B (Colilert)® Standard Methods 9223B (Colilert-18)® Standard Methods 9222B/9222G1 (mEndo/LES-Endo-NA-MUG) Standard Methods 9222D/9222G (mFONA-MUG) Standard Methods 921 3D/ EPA Method 1103.1 (mTEC) EPA Method 1603 Modified mTEC EPA Method 1604 Ml medium 1 m-ColiBlue24® Broth 1 Standard Methods 9221B/9221F (LTB-EC-MUG) Appendix References for Methods Included in this Manual Appendix I Appendix J Appendix K Appendix L Appendix M Appendix N Appendix O Appendix P Corresponding Drinking Water Certification Program Coliform Analysis Technique Most probable number (MPN): Multiple-tube and multiple-well techniques Membrane filtration technique MPN: Multiple-tube fermentation technique 1 If high levels of non-E. coli total coliforms interfere with the ability to accurately enumerate E. coli despite additional dilutions, an alternate method should be used (i.e, SM 9222D/9222G, SM 9213D/EPA Method 1103.1, EPA Method 1603, SM9221B/9221F) 4.2 Quality Assurance/Quality Control for E. coli Analyses Laboratory QA for E. coli analyses during LT2 monitoring should meet the specifications in the Certification Manual (Reference 5.2) and Standard Methods for the Examination of Water and Wastewater, 20th Edition (1998) (Standard Methods) (Reference 5.3) for facilities, personnel, laboratory equipment, instrumentation, and supplies used for LT2 E. coli analyses. In addition, each laboratory should have implemented a written QA plan describing the QA program and QC activities necessary to meet the laboratory's specific needs. The program should address the following issues: personnel policies, equipment and instrument specifications, specifications for supplies, analytical methods and QC measures, standard operating procedures (SOPs), documentation specifications, performance evaluation samples, internal and external lab audits, and corrective actions. E. coli sample results reported under the LT2 rule should meet the quality control (QC) specifications set forth in the approved versions of the methods listed in Table 4.1 above. Section 4.2.1 describes overall quality control specifications for E. coli analyses performed under the LT2 rule. E. coli QC specifications specific to membrane filtration methods and MPN methods are provided in Sections 4.2.2 to 4.2.3. This guidance is provided to help implement the QC specifications in the methods and does not substitute for or alter the method specifications. Sample results that do not meet these specifications are not considered valid, and cannot be reported under the LT2 rule. A checklist for these specifications is provided as Appendices Q and R. Draft 45 June 2003 ------- Section 4: E. coli Laboratory Guidance Note: E. coli samples that do not meet the QCspecifications set forth in these sections are considered to be invalid, and may not be reported under the L T2 rule. Table 4-2. Quality Control Procedures for E. coli Methods are ^ Quality Control Procedure Reference All E. coli Methods Holding time and temperature requirements (Section 4. 2. 1.1) Dilution/rinse water sterility check (Section 4.2.1. 2) Media sterility check (Section 4.2.1. 3) Positive/negative controls (Section 4. 2. 1.4) Media storage (Section 4. 2. 1.5) LT2 Rule: Section IV.K.2 Certification Manual: Section 4.4.3 Certification Manual: Section 5.1.6.4 Certification Manual: Section 5.1.6.4 Certification Manual: Section 5.3.2.4 MPN Methods (includes multiple-tube and multiple-well techniques) Incubation time and temperature specifications (Section 4.2.2.1) MPN preparation blank (Section 4.2.2.2) Verification (Section 4.2.2.3) Specified in Method Recommended Specified in Method Membrane Filtration Methods Incubation time and temperature specifications (Section 4.2.3.1) Filtration unit sterilization (Section 4.2.3.2) Membrane filter preparation blank (Section 4.2.3.3) Verification (Section 4.2.3.4) Specified in Method Certification Manual: Section 4.1 Certification Manual: Section 5.2.1.3 Specified in Method 4.2.1 Quality Control Specifications Applicable to All E. coli Methods Independent of QC specifications for the type of method used for analysis, there are QC measures that should be taken by all laboratories performing E. coli analyses under the LT2 rule to ensure the laboratory is in control during the analysis of LT2 monitoring samples. Quality assurance/quality control procedures for all E. coli methods are summarized in Sections 4.2.1.1 through 4.2.1.5. 4.2.1.1 Holding Time and Temperature Requirements for Field Samples EPA strongly encourages laboratories to analyze samples as soon as possible after collection. However, due to the need by some utilities to ship samples overnight to an off-site laboratory for analysis, the holding time for E. coli sample analyses has been extended to 24 hours. Based on studies to assess the Draft 46 June 2003 ------- Section 4: E. coli Laboratory Guidance effect of increased sample holding time in E. coli analysis results, EPA has concluded that E. coli samples can be held for up to 24 hours prior to analysis without compromising the data quality objectives of the LT2 rule (Reference 5.4). Samples must be maintained between 0°C and 10°C during transit [CFRpart 141.705 (b) (1)] and should not be allowed to freeze. For samples shipped off-site, utilities should consider including a temperature blank along with the sample so that laboratories can measure the temperature of the sample upon receipt. Alternately, utilities could use Thermochron iButtons® or other measuring devices to record the temperature throughout transport (discussed in Section 2.2 in this manual). Additional information pertaining to temperature monitoring is provided in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule). 4.2.1.2 Dilution/Rinse Water Sterility Check QC specifications for dilution/rinse water checks are as follows: • Each batch (or lot, if commercially prepared) of dilution/rinse water should be checked for sterility by adding 50 mL of water to 50 mL of a double-strength non-selective broth (e.g., tryptic soy, trypticase soy, or tryptose broth). Incubate at 35°C ± 0.5°C, check for growth after 24 hours and 48 hours (or for the longest incubation time specified in the method), and record results. Discard batch if growth is detected. Note: These QC specif ications are meant to be performed routinely for all samples, at the frequency specif led in the Certification Manual. The QC specifications are not additional analyses specifically for LT2 E. coli samples. 4.2.1.3 Media Sterility Check To test sterility of newly prepared media prior to the analysis of field samples incubate one plate per each media batch at the appropriate temperature for 24 and 48 hours (or for the longest incubation time specified in the method) and observe for growth. If any contamination is observed, determine the cause, correct, and reject any data from samples tested with the media. Note: These QC specif ications are meant to be performed routinely for all samples, at the frequency specif led in the Certification Manual. The QC specif ications are not additional analyses specifically for LT2 E. coli samples. If any contamination is observed, determine the cause, correct, and reject any data from samples associated with: (1) dilution or rinse water, or (2) media. Draft 47 June 2003 ------- Section 4: E. coli Laboratory Guidance 4.2.1.4 Positive/Negative Controls For each new lot or batch of medium, check the analytical procedures and integrity of the medium before use by testing with known positive and negative control cultures. See Table 4-3 for examples of test cultures. Laboratories using commercially-prepared media with manufacturer shelf-lives of greater than 90 days should run positive and negative controls each quarter in addition to running the batch/lot-specific controls and sterility checks. Laboratories are encouraged to perform positive and negative control tests each day that field samples are analyzed. Table 4-3. Positive and Negative Control Cultures Positive Control Culture E. coli Negative Control Culture Enterobacter aerogenes (ATCC # 13048)1 Klebsiella pneumoniae (ATCC # 31488)2 1 E. aerogenes normally does not grow at 44.5°C; if growth occurs, the waterbath or incubator is not holding the 44.5°C temperature. The recommended strain is MUG negative and is notthermotolerant. 2 K. pneumoniae is MUG negative and should not fluoresce when transferred to NA-MUG. In addition, this strain is thermotolerant. Positive and negative controls should be chosen based on the method-specific requirements. For example if a 44.5°C waterbath is not required by the method, it is not necessary to include Enterobacter aerogenes as a negative control. Note: Additional QC analyses are not required for the analysis of E. coli samples under L T2, provided that laboratories perform required QC analyses at the frequency specified in the Certification Manual. 4.2.1.5 Media Storage The following media storage specifications should be met for E. coll analyses: Agar plates may be held for up to 2 weeks at 1°C to 5°C in plastic bags or containers. Protect media containing dyes from exposure to light. Broth in loose fitting caps (e.g., snap caps) should be stored at 1°C to <30°C for no more than 2 weeks Broth in tight fitting caps (e.g., screw caps) should be stored at 1°C to <30°C for no longer than 3 months All media should be at room temperature prior to use • Media exhibiting growth or gas should be discarded 4.2.2 Quality Control Specifications for Most Probable Number Methods In addition to the overall QC specifications set forth in Section 4.2.1, laboratories using MPN methods (e.g., multiple-tube, multiple-well) for LT2 rule E. coli analyses should meet method-specific incubation time and temperature specifications and method-specific E. coll verification specifications. Draft 48 June 2003 ------- Section 4: E. coli Laboratory Guidance 4.2.2.1 Incubation Time/Temperature Specifications for MPN Methods The required incubation times and temperatures for MPN methods are provided in Table 4-4. Table 4-4. Incubation Time and Temperature Specifications for MPN Methods Method Standard Methods 9223B Standard Methods 9221B/9221F Media Colilert® Coliert-18® LIB EC-MUG Incubation Time/Temperature 24-28hoursat35°C±0.5°C 18-22hoursat35°C±0.5°C 22-51 hoursat35±0.5°C 22 - 26 hours at 44.5°C ± 0.2°C 4.2.2.2 Most Probable Number Preparation Blank EPA recommends that a volume of sterilized, buffered water be analyzed exactly like a field sample each day samples are analyzed. The preparation blank should be incubated with the sample batch and observed for growth of the target organism. If the control indicates contamination with the target organism, all data from affected samples should be rejected. 4.2.2.3 Verification Verification specifications are detailed in the Certification Manual (Reference 5.2), Standard Methods (Reference 5.3), and Appendices I and J of this document. Verifications should be performed in accordance with method-specific requirements. Note: Additional QC analyses are not required for the analysis of E. coli samples under L T2, provided that laboratories perform the verifications at the frequency specif led in //?< Certification Manual. 4.2.3 Quality Control Specifications for Membrane Filtration Methods In addition to the overall QC specification in Section 4.2.1, laboratories using membrane filtration methods should meet method-specific incubation times and temperatures, and should perform additional QC steps to demonstrate that membrane filtration equipment is free from contamination and cross-over. Note: Additional QC analyses are not required for the analysis ofE. coli samples under LT2, provided that laboratories perform required QC analyses at the frequency specified in the Certification Manual. 4.2.3.1 Incubation Time and Temperature The required incubation times and temperatures for membrane filtration methods are provided in Table 4- 5. Draft 49 June 2003 ------- Section 4: E. coli Laboratory Guidance Table 4-5. Incubation Time and Temperature Specifications for Membrane Filter Methods Method Standard Methods 9222B/9222G Standard Methods 921 3D EPA 1603 EPA 1604 Other Membrane Filter Methods Media mENDO-NA-MUG Les-ENDO-NA-MUG mFONA-MUG mTEC agar Modified mTEC Ml agar m-ColiBlue24 Broth Incubation Time/Temperature 22 - 26 hours at 35°C ± 0.5°O 4 hours at 35°C ± 0.5°C 22 - 26 hours at 35°C ± 0.5°O 4 hours at 35°C ± 0.5°C 22 - 26 hours at 44.5°C ± 0.2°O 4 hours at 35°C ± 0.5°C 2 hours at 35°C ± 0.5°C - 22 - 24 hours at 44.5°C ± 0.2°C 2 hours at 35°C ± 0.5°C - 22 - 24 hours at 44.5°C ± 0.2°C 24 hours at 35°C ± 0.5°C 24 hours at 35°C ± 0.5°C 4.2.3.2 Filtration Unit Sterilization Membrane filter equipment should be autoclaved before the beginning of a filtration series. A filtration series ends when 30 minutes or longer elapses after a sample is filtered. Ultraviolet (UV) light (254 nm) may be used to sanitize equipment (after initial autoclaving for sterilization), if all supplies are pre- sterilized. UV light can also be used to reduce bacterial carry-over between samples during a filtration series. The UV lamp should be tested quarterly with a UV light meter or an agar plate. Appropriate corrective actions should be taken, if necessary. 4.2.3.3 Membrane Filter Preparation Blank If membrane filtration is used, an MF preparation blank is performed at the beginning and the end of each filtration series by filtering 20-30 mL of dilution water through the membrane filter and testing for growth. If the control indicates contamination with the target organism, all data from affected samples should be rejected. A filtration series ends when 30 minutes or more elapse between sample filtrations. 4.2.3.4 Verification Verification specifications are detailed in the Certification Manual (Reference 5.2), Standard Methods (Reference 5.3), and in Appendices K through O of this document. Verifications should be done in accordance with method-specific requirements. Note: Additional verifications are not required for the analysis ofE. coli samples under LT2, provided that laboratories perform verifications at the frequency specified in the Certification Manual. 4.3 Sample Collection Procedures During the LT2 rule, PWSs must take source water samples at a location prior to any treatment and where the water is no longer subject to surface runoff [40 CFR part 141.704 (a)]. Guidance on sample collection locations and detailed procedures for collecting E. coli samples for on-site analysis and for shipment to an off-site laboratory for analysis are provided in the Source Water Monitoring Guidance Manual for Public Water Systems for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule). This manual is available for download from http://www. epa. gov/safewater/lt2/index.html. Draft 50 June 2003 ------- Section 4: E. coli Laboratory Guidance 4.3.1 Acceptance Criteria for Receipt of Field Samples Source water samples are dynamic environments and, depending on sample constituents and environmental conditions, E. coli present in a sample can grow or die off, biasing analytical results. Samples that are not analyzed immediately after sample collection during LT2 rule monitoring must be chilled to reduce biological activity, and preserve the state of source water samples between collection and analysis. Samples for E. coli analyses must be maintained between 0°C and 10°C if they are shipped [40 CFR 141.705 (b)(l)]. Samples should not be allowed to freeze. Given the importance of maintaining sample temperatures for E. coli, laboratories approved for performing E. coli analyses during the rule should establish acceptance criteria for receipt of E. coli samples transported to their laboratory. Several options are available to measure sample temperature upon receipt at the laboratory and, in some cases, during shipment are provided in Section 2.2. 4.4 Sample Volume and Dilution Guidance Because E. coli analyses will be performed on source waters, rather than finished drinking waters, multiple sample/volumes dilutions may necessary to assess high E. coli levels. Initially all PWSs will be required to analyze four sample volumes (100, 10, 1.0, and 0.1 mL) for all methods except MTF. For MTF methods the PWS will be initially required to analyze five sample volumes of 10, 1.0, 0.1, 0.01, and 0.001 mL. Sample volumes may need to be adjusted based on confounding conditions (e.g., high turbidity, heavy rainfall, etc.). If the PWS has historical data demonstrating that E. coli levels are consistently low, they may drop the smaller sample volumes. However, if the PWS decides to eliminate any of the required volumes due to historical data, it should be noted that changes in conditions (e.g., increased precipitation, seasonality, etc.) may impact water quality. As a result, sample volumes may need to be adjusted on a per sampling event basis. For example, if there has been a substantial rainfall in the 24 hours prior to sample collection causing runoff, sample volumes would need to be adjusted in order to obtain valid results and avoid data that are above the analytical range of the method. This could also be a concern if the PWS eliminates the 100 mL sample volume due to historical data indicating that values tend to be very high and the E. coli levels are lower than anticipated, forcing the PWS to report data that are below the analytical range of the method. EPA recommends bracketing the target sample volume (i.e., analyzing a sample volume above and below the sample volume expected to yield useable data) to account for potential variability. 4.4.1 Sample Volume and Dilution Guidance for Multiple-Well Methods The analysis of water samples under LT2 using multiple-well methods generally requires the use of four aliquots of samples (100, 10, 1.0, and 0.1 mL). Sample volumes may need to be adjusted based on confounding conditions (e.g., high turbidity, heavy rainfall, etc.). Because a 100-mL volume is necessary to fill all of the wells, it will be necessary to add the aliquots of sample to sterile reagent water blanks. The total volume after the sample aliquot is added to the reagent water blank should be approximately 100 mL (i.e., a 90-mL blank should be used for the 10-mL sample volume, a 99- mL reagent water blank should be used for the 1.0 mL aliquot). 4.4.2 Sample Volume and Dilution Guidance for Membrane Filtration The analysis of water samples under LT2 requires four different aliquots of sample (100, 10, 1.0, and 0.1 mL) for membrane filtration methods. Iternate sample volumes may be used if necessary. To ensure adequate distribution of bacteria during filtration, dispense aliquots of the sample, with the exception of the 100 mL volume, into sterile buffered water blanks (at least 30 mL, depending on the sample volume Draft 51 June 2003 ------- Section 4: E. coli Laboratory Guidance analzyed). Alternately, 10 mL of sterile buffer may be added to the filter apparatus prior to adding the sample. The buffered water minimizes clumping of the bacteria on the filter surface. 4.4.3 Sample Volume and Dilution Guidance for Multiple-Tube Methods The analysis of water samples by a multiple-tube technique (e.g., Colilert® in a multiple-tube format, SM 9222B LTB/EC-MUG) under LT2 requires the use of a 15-tube most probable number format (i.e., 5 tubes at each of three dilutions, 10.0 mL, 1.0 mL, and 0.1 mL). Five tubes must be inoculated for each sample volume. Initially, the PWS will be required to analyze four sample volumes (10.0, 1.0, 0.1, and 0.01 mL). Additional guidance on selection of dilutions for multiple-tube methods is available in Standard Methods 9221 (Reference 5.3). 4.5 E. coli Data Recording and Calculations Laboratories performing E. coli analyses during the LT2 rule must be certified for the analytical technique used for LT2 E. coli analyses under the drinking water certification program, and therefore the data recording practices required under the drinking water certification program should be followed [40 CFRpart 141.706 (b)]. These practices include the following: Maintaining sample identification information (e.g., including sample collection and receipt dates, times, and conditions) Recording all raw data (i.e., primary measurements) used to calculate final sample concentration for each sample • Recording the incubation/read times for each method to verify that method specifications were met Recording the name of the analyst performing the sample analysis At a minimum, the data elements discussed in detail below should be recorded for E. coli samples during LT2 monitoring. These data elements are critical to ensure that final sample results can be verified using primary data, if necessary, and to demonstrate that sample analyses were performed within method- specified holding times and incubation times. Standardized bench sheets are available for download on the LT2 website (http://www.epa. gov/safewater/lt2/index.html). Please note that, while E. coli laboratories should record the data elements discussed in this section to comply with certification manual specifications, not all of the recorded data will be reported in the LT2 data system. E. coli data reporting under the LT2 rule is discussed in Section 4.6. In addition to data elements, this section also provides standardized procedures for determining E. coli concentration for LT2 samples for the various analytical techniques that are approved for use under the rule. Because these analyses will be performed on source waters rather than finished drinking waters, and multiple dilutions may be necessary to assess higher E. coli levels, it is critical that laboratories follow the same procedures for determining E. coli sample concentrations to reduce variability in reporting. Table 4-6 specifies the minimum sample ID information that must be recorded for each E. coli sample, either on a sample collection form used in the field and maintained in the same file as the E. coli laboratory data, or on the laboratory data form (examples of all forms are provided Appendices S through AB) [40 CFRpart 141.707 (2)]. Draft 52 June 2003 ------- Section 4: E. coli Laboratory Guidance Table 4-6. Minimum Sample ID Information and General Sample Data to Record PWS ID Facility ID Sample collection point Sample collection date Analytical method number Method type Source type E. co///100mL Turbidity Method-specific data to record for each of the individual method types, as well as standardized calculations for each method type, are discussed in Sections 4.5.1 to 4.5.3. 4.5.1 Multiple-Well Data In addition to the data elements listed in Table 4-6, laboratories using Colilert® and Colilert-18® methods for E. coli sample analyses in support of the LT2 rule should record the data elements specific to multiple-well techniques. Data elements to be recorded for the 97-well format (Quanti-Tray 2000®) are noted in Table 4-7; data to be recorded for the 51-well format (Quanti-Tray®) are noted in Table 4-8. These elements include the primary measurements needed to calculate the E. coli concentration in the sample as well as all method-required incubation and read times needed to verify that the sample analyses were conducted under analytical control. Calculations for determining the E. coli concentration using the Quanti-Tray 2000® (97-well) and Quanti-Tray® (51-we 11) formats are provided after each table. 4.5.1.1 Data Elements for Quanti-Tray 2000® (97-well) Analyses Table 4-7. Minimum Data to Record for Quanti-tray 2000® Colilert® and Colilert-18® Analyses Primary Measurements ml_ of sample added to tray (does not include reagent water volume) Large wells positive: Total coliform positive and UV fluorescence Small wells positive: Total coliform positive and UV fluorescence Holding Time / Incubation Time Information Incubation start/read date Incubation start/read time Incubation start/read temperature Additional incubation start/read date Additional incubation start/read time Draft 53 June 2003 ------- Section 4: E. coli Laboratory Guidance 4.5.1.2 Determining E. coli Concentration Using Colilert® and Colilert-18® Quanti-Tray 2000® Data A. Select appropriate dilution to yield countable results. If multiple dilutions are used, the tray exhibiting positive wells in the 40% to 80% range (39 to 78 total positive large and small wells) should be used to determine MPN value. Note: The analytical result can be automatically calculated using the LT2 Data Collection System. See Section 4.6 for additional information. B. Determine MPN. Using the number of large positive wells and small positive wells from the appropriate dilution, identify the corresponding MPN/100 mL in the table provided by the vendor. Large well values are located in the left column; small well values are located in the top row. For example, if a 100-mL sample was analyzed, and there were 29 large positive wells and 5 small positive wells, the corresponding MPN would be 49.6 MPN/100 mL. C. Adjust for dilution factor. Because the MPN/100 mL values in the table are based on 100-mL samples, the MPN value should be adjusted if less than 100-mL of sample volume was analyzed. Use the following calculation to adjust the MPN to account for the dilution: 100 Analytical result = MPN value x — mL of sample analyzed Example: Volume analyzed =10 mL of sample (in 90 mL of dilution water) Large wells positive = 39 Small wells positive = 5 The MPN value calculated based on the intersection of 10 and 2 in the table. MPN = 81.3 100 Analytical result = 81.3 x = 813 £. coli MPN/100 mL 10 4.5.1.3 Data Elements for Quanti-Tray® (51-well) Analyses The recommended data elements to record for Quanti-Tray® (51-well) analyses are provided in Table 4- 8. Draft 54 June 2003 ------- Section 4: E. coli Laboratory Guidance Table 4-8. Minimum Data to Record for Quanti-Tray® Colilert® and Colilert-18® Analyses Primary Measurements ml_ of sample added to tray (does not include reagent water volume) Number of wells positive: Total coliform positive and UV fluorescence Holding Time / Incubation Time Information Incubation start/read date Incubation start/read time Incubation start/read temperature Additional incubation start/read date Additional incubation start/read time Additional incubation start/read temperature 4.5.1.4 Determining E. coli Concentration Using Colilert® and Colilert-18® (51-well) Data A. Select appropriate dilution. If multiple dilutions are used, the tray exhibiting 80% positive wells (41 positive wells) should be used to determine MPN value. Note: The analytical result can be automatically calculated using the LT2 Data Collection System. See Section 4.6 for additional information. B. Determine MPN. Using the number of positive wells from the appropriate dilution, identify the corresponding MPN/100 mL in the table provided by the vendor. For example, if a 100-mL sample was analyzed, and there were 41 positive wells, the corresponding MPN would be 83.1 MPN/100 mL C. Adjust for dilution factor. Because the MPN/100 mL values in the table are based on 100-mL samples, the MPN value should be adjusted if less than 100-mL of sample volume was analyzed. Use the following calculation to adjust the MPN to account for the dilution: 100 MPN value x = £. coli MPN/100 mL mL sample analyzed Example: Volume analyzed (mL) = 10 mL (in 90 mL of dilution water) Number of positive wells = 41 MPN = 83.1 The analytical result is calculated as follows: 100 83.1 x = 831 E. coli MPN/100 mL 10 4.5.2 Membrane Filtration Data In addition to the general sample data listed in Table 4-6, laboratories using membrane filtration methods for E. coli sample analyses in support of the LT2 rule should record the data elements specific to this technique. These are noted in Table 4-9, and include the primary measurements needed to calculate the E. Draft 55 June 2003 ------- Section 4: E. coli Laboratory Guidance coll concentration in the sample, as well as all method-required incubation and read times needed to verify that the sample analyses were conducted under analytical control. 4.5.2.1 Data Elements for Membrane Filtration Analyses Table 4-9. Minimum Data Elements for Record for Membrane Filtration Analyses Primary Measurements Filter 1 volume (ml_) (e.g., 100 ml_) CPU on Filter 1 Filter 2 volume (ml_) (e.g., 10 ml_) CFUon Filter 2 Filter 3 volume (ml_) (e.g., 1.0 ml_) CFUon Filters Filter 4 volume (ml_) (e.g., 0.1 ml_) CFUon Filter4 Holding Time / Incubation Time Information Primary isolation medium (e.g., mENDO, mFC) incubation start/read date Primary isolation medium (e.g., mENDO, mFC) incubation start/read time Primary isolation medium (e.g., mENDO, mFC) incubation start/read temperature Secondary isolation medium (e.g, NA-MUG) incubation start/read date Secondary isolation medium (e.g, NA-MUG) incubation start/read time Secondary isolation medium (e.g, NA-MUG) incubation start/read temperature 4.5.2.2 Determining E. coli Concentrations Using Membrane Filter Data1: A. E. coll counts should be determined from the volume(s) filtered that yielded 20 to 80 E. coll colonies (20-60 for mFC-NA-MUG), and not more than 200 total colonies per plate. (Guidance for samples that do not yield countable plates is provided in Sections E and F) Note: The analytical result can be automatically calculated using the LT2 Data Collection System. See Section 4.6 for additional information. B. If there are greater than 200 colonies per membrane, even for the lowest dilution, the result is recorded as "too numerous to count" (TNTC). These results cannot be reported for LT2 monitoring, as they cannot be used for the required data analyses. During the next sampling event, analyze an additional, lower dilution volume (the highest dilution volume may be omitted) unless conditions were unusual (e.g., heavy rains, flooding, etc.) during the sampling event yielding TNTC for all dilutions. C. If colonies are not sufficiently distinct for accurate counting, the result is recorded as "confluent growth" (CNFG). To prevent CNFG from occurring, smaller sample aliquots should be filtered. For example, if sample volumes of 100, 10, 1 and 0.1 mL are analyzed and even the 0.1-mL plate results in CNFG, then potentially 0.01 mL should be analyzed during the next sampling event. For sample volumes less than 1 mL, serial dilutions should be used, and 1-mL volumes of the dilutions should be filtered. The 100-mL volume can be eliminated. Note: If growth is due to high levels of total coliforms but low E. coli then another method should be chosen for analyses that does not rely on total coliform determination prior to or simultaneously with E. coli determination. Adapted from Standard Methods for the Examination of Water and Wastewater, APHA, AWWA, WEF (20th Edition) Draft 56 June 2003 ------- Section 4: E. coli Laboratory Guidance Note: Results that are TNTC or CNFG are not appropriate for L T2 microbial data analysis, and cannot be entered into the L T2 Data Collection System. These results should not be reported. D. Using the E. coli counts from the appropriate dilution, E. coli CPU/100 mL is calculated based on the following equation: 100 £ coli CPU x = £ coli CFU/100 mL mL sample filtered Example 1: Filter 1 volume = 100 mL CPU = TNTC Filter 2 volume = 10 mL CPU = 40 Filter 3 volume = 1.0 mL CPU = 9 Filter 4 volume = 0.1 mL CPU = 0 Using the guidance on countable colonies in Step A, the counts from the 10-mL plate will be used to calculate the E. coli concentration for the sample: 100 40 £ coli CPU x = 400 £ coli CFU/100 mL 10 mL E. If no E. coli colonies are present, the detection limit is calculated as < largest volume filtered per 100 mL. Example 2: Filter 1 volume (mL) = 100 mL CPU = 0 Filter 2 volume (mL) = 10 mL CPU = 0 Filter 3 volume (mL) = 1.0 mL CPU = 0 100mL Detection limit = = £ coli CFU/100 mL Largest volume filtered 100mL = <1 £ co//7100 mL 100 mL Draft 57 June 2003 ------- Section 4: E. coli Laboratory Guidance Example 3: Filter 1 volume (mL) =100 mL CPU = Lab accident, no data available Filter 2 volume (mL) = 10 mL CPU = 0 Filter 3 volume (mL) = 1.0 mL CPU = 0 Calculation of E. coli/100 mL: 100mL = <10£. coli CPU /100mL 10ml F. If there are no filters with E. coli counts in the 20-80 colony range (20-60 for mFC-NA-MUG), sum the E. coli counts on all filters, divide by the volume filtered and report as number per 100 mL. Example 4: Filter 1 volume (mL) = 50 mL CPU =15 Filter 2 volume (mL) = 25 mL CPU = 6 Filter 3 volume (mL) = 10 mL CPU = 0 The analytical result is calculated as: 100 (15 + 6 + 0)x =25£. co//CFU/100ml (50+25+10) Example 5 Filter 1 volume (mL) = 50 mL CPU =105 Filter 2 volume (mL) = 25 mL CPU = 92 Filter 3 volume (mL) = 10 mL CPU = 85 The analytical result is calculated as: 100 (105 + 92 + 85) x = 332 E. coli CFU/100 mL (50 + 25 + 10) Example 6: Filter 1 volume (mL) = 100 mL CPU = 82 Filter 2 volume (mL) = 10 mL CPU = 18 Filter 3 volume (mL) = 1.0 mL CPU = 0 The analytical result is calculated as: 100 (82 + 18 + 0) x = 90 E. coli CFU/100 mL (100+ 10+ 1) Draft 58 June 2003 ------- Section 4: E. coli Laboratory Guidance Example 7 Filter 1 volume (mL) = 50 mL CPU = TNTC Filter 2 volume (mL) = 25 mL CPU = TNTC Filter 3 volume (mL) = 10 mL CPU = 83 The analytical result is calculated as: 100 83 x = 830 E. co// CFU/100 mL 10 4.5.3 Multiple-Tube Data In addition to the general sample data listed in Table 4-6, laboratories using multiple-tube methods for E. coli sample analyses in support of the LT2 rule should record the data elements specific to these techniques. These data elements are noted in Table 4-10 for 15-tube most probable number methods and Table 4-11 for 15-tube multiple-tube fermentation methods. The data elements include the primary measurements needed to calculate the E. coli concentration in the sample, as well as all method-required incubation and read times needed to verify that the sample analyses were conducted under analytical control. Calculations for determining the E. coli concentration using multiple tube formats are provided in Section 4.5.3.2. 4.5.3.1 Data Elements for Multiple-Tube Analyses Table 4-10. Minimum Data Elements to Record for 15-Tube MPN Methods Primary Measurements Number of positive 10.0 mL tubes: Total coliform positive and UV fluorescence Number of positive 1.0 mL tubes: Total coliform positive and UV fluorescence Number of positive 0.1 mL tubes: Total coliform positive and UV fluorescence Number of positive 0.01 mL tubes: Total coliform positive and UV fluorescence Number of positive 0.001 mL tubes: Total coliform positive and UV fluorescence Holding Time / Incubation Time Information Incubation start/read date Incubation start/read time Incubation start/read temperature Additional incubation start/read date Additional incubation start/read time Additional incubation start/read temperature Draft 59 June 2003 ------- Section 4: E. coli Laboratory Guidance Table 4-11. Minimum Data Elements to Record for 15-Tube Fermentation Methods Primary Measurements Number of positive tubes 10.0 ml_ Number of positive tubes 1.0 ml_ Number of positive tubes 0.1 ml_ Number of positive tubes 0.01 ml_ Number of positive tubes 0.001 ml_ Number of positive tubes 0.0001 ml_ Holding Time / Incubation Time Information LIB incubation start date LIB incubation start time LIB incubation start temperature LIB 24-hour incubation read date LIB 24-hour incubation read time LIB 24-hour incubation read temperature LIB 48-hour incubation read date LIB 48-hour incubation read time LIB 48-hour incubation read temperature EC-MUG incubation 24-hour read date (from 24-hour LIB) EC-MUG incubation 24-hour read time (from 24-hour LIB) EC-MUG incubation 24-hour read temperature (from 24-hour LIB) EC-MUG incubation 24-hour read date (from 48-hour LIB) EC-MUG incubation 24-hour read time (from 48-hour LIB) EC-MUG incubation 24-hour read temperature (from 48-hour LIB) 4.5.3.2 Determination of E. coli Concentrations Using Multiple-Tube Methods2: The guidance and examples for determining E. coli concentrations using multiple-tube methods are based on the revision of Standard Methods 9221C included in the 2001 Supplement to the 20th Edition of Standard Methods, approved by the Standard Methods Committee in 1999. Note: The analytical result can be automatically calculated using the LT2 Data Collection System. See Section 4.6 for additional information. A. For each sample volume (e.g., 10, 1, 0.1, and 0.01 mL or additional sample volumes as necessary), determine the number of positive tubes out of five. B. A dilution refers to the volume of original sample that was inoculated into each series of tubes. Only three of the dilution series will be used to estimate the MPN. The three selected dilutions are called Adapted from 2001 Supplement to the 20th Edition of Standard Methods 9221 C: Explanation of Bacterial Density. This supplement is available for download at http://www.techstreet.com/cgi-bin/detail7product id=923645 (Accessed April 7, 2003). Draft 60 June 2003 ------- Section 4: E. coli Laboratory Guidance significant dilutions and are selected according to the following criteria. Examples of significant dilution selections are provided in Table 4-12, below. • Choose the highest dilution (the most dilute, with the least amount of sample) giving positive results in all five tubes inoculated and the two succeeding higher (more dilute) dilutions. (Table 4-12, Example A). • If the lowest dilution (least dilute) tested has less than five tubes with positive results, select it and the two next succeeding higher dilutions (Table 4-12, Examples B and C). • When a positive result occurs in a dilution higher (more dilute) than the three significant dilutions selected according to the rules above, change the selection to the lowest dilution (least dilute) that has less than five positive results and the next two higher dilutions (more dilute) (Table 4-12, Example D). • When the selection rules above have left unselected any higher dilutions (more dilute) with positive results, add those higher-dilution positive results to the results for the highest selected dilution (Table 4-12, Example E). If there were not enough higher dilutions tested to select three dilutions, then select the next lower dilution (Table 4-12, Example F). C. MPN values need to be adjusted based on the significant dilutions series selected above. Because the MPN/100 mL values in the table are based on the 10 mL, 1 mL, and 0.1 mL dilution series, per method requirements, the MPN value must be adjusted if these are not the significant dilution series selected. Use the following calculation to adjust the MPN when the 10 mL, 1 mL, and 0.1 mL dilution series are not the significant dilution series selected: MPN value Analytical result = # of mL in middle dilution = £. co//MPN/100 mL Table 4-12. Examples of Different Combinations of Positive Tubes (Significant Dilution Results Are in Bo/dand Underlined) Example A B C D E F Least dilute | S Most dilute (Lowest) (Highest) 10 mL 5 4 0 5 5 5 1 mL 5 5 0 4 4 5 0.1 mL 1 1_ 1_ 4 4 5 0.01 mL 0 0 0 1 0 5 0.001 mL 0 0 0 0 1 2 Combination of positives 5-1-0 4-5-1 0-0-1 4-4-1 4-4-1 5-5-2 MPN Index from Standard Methods 33 48 1.8 40 40 540 £. co/;7100 mL (after adjustment) 330 48 1.8 400 400 54,000 Draft 61 June 2003 ------- Section 4: E. coli Laboratory Guidance Example A: The significant dilution series for the 5-1-0 combination of positives includes the 1 mL, 0.1 mL, and 0.01 mL dilutions. Since the 10 mL, 1 mL, and 0.1 mL dilutions were not selected, an adjustment is necessary to account for the dilutions selected: 33 Analytical result = = 330 E. coli 1100 mL 0.1 Example B: Since the 10 mL, 1 mL, and 0.1 mL dilutions are the significant dilutions, no adjustment is necessary and the result is 48 E. coli/100 mL. Example C: Since the 10 mL, 1 mL, and 0.1 mL dilutions are the significant dilutions, no adjustment is necessary and the result is 1.8 E. coli/WO mL. Examples D and E: The significant dilution series for the 4-4-1 combination of positives includes the 1 mL, 0.1 mL, and 0.01 mL dilutions. Since the 10 mL, 1 mL, and 0.1 mL dilutions were not selected, an adjustment is necessary to account for the dilutions selected: 40 Analytical result = = 400 E. coli 1100 mL 0.1 Example F: The significant dilution series for the 5-5-2 combination of positives includes the 0.1 mL, 0.01 mL and .001 mL dilutions. Since the 10 mL, 1 mL, and 0.1 mL dilutions were not selected, an adjustment is necessary to account for the dilutions selected: 540 Analytical result = = 54,000 E. coli 1100 mL 0.01 4.6 Electronic Data Reporting During the LT2 rule, laboratories will report E. coli data electronically through EPA's LT2 Data Collection System to the PWS staff responsible for approving and submitting monitoring results to EPA. The LT2 Data Collection System is a web-based application that allows laboratory users to enter or upload data, then electronically "release" the data to the appropriate PWS staff for review, approval, and submission to EPA and the State. Although ownership of the data resides with the PWS throughout this process, the LT2 Data Collection System increases the ease and efficiency of the data entry and transfer process from one party to another by transferring the ability to access the data from the laboratory to the PWS to EPA and the State, and ensuring that data cannot be viewed or changed by unauthorized parties. A summary of the data entry, review, and transfer process through the LT2 Data Collection System for both Cryptosporidium and E. coli samples is provided in Table 3-6, in Section 3.8, above. The data reporting process is summarized below, in Sections 4.6.1 through 4.6.3, and discussed in detail in the Users' Manual for the Long Term 2 Enhanced Surface Water Treatment Rule (LT2 Rule) Data Collection System. The LT2 data system users' guide also provides detailed information on the laboratory registration process. Information on the LT2 Data Collection System, as well as a downloadable users' manual, is available at http://www.epa.gov/safewater/lt2/index.html. Draft 62 June 2003 ------- Section 4: E. coli Laboratory Guidance 4.6.1 Data Entry/Upload The analyst or another laboratory staff member enters a subset of the data recorded at the bench (Section 4.5) into the LT2 Data Collection System either by entering the data using web forms or by uploading data in XML format [40 CFRpart 141.707 (2)]. This information includes the following: • Sample ID (optional) • PWS ID • Facility ID • Sample collection point ID • Sample collection date Analytical method number Method type • Source water type (provided by PWS on sample collection form) • E. CO///100 mL (see note below) Turbidity result (provided by PWS on sample collection form) Note: The laboratory may enter the final result for the E. coli sample or may enter the primary measurements recorded at the bench, and have the LT2 Data Collection System automatically calculate the final E. coli concentration. Because this information is specific to method type (membrane filtration, multiple-tube, 51-well, and 97-well), the system provides different entry screens for each method type. The laboratory should verify that all holding times and other QC specifications were met. The laboratory's official contact is responsible for verifying the quality and accuracy of all sample results in the laboratory, and is required to review and approve the results before they are submitted to the PWS for review. If inaccuracies or other problems are identified, the official contact discusses the sample information with the analyst or data entry staff and resolves the issues before the data are released to the PWS for review. If no inaccuracies or other issues are identified, the laboratory's official contact approves the data for "release" to the PWS for review (EPA does not receive the data at this point). When the data are approved by the laboratory, the rights to the data are transferred electronically by the system to the PWS, and the data can no longer be changed by the laboratory. 4.6.2 PWS Data Review After the laboratory has released E. coli data electronically to the PWS using the LT2 Data Collection System, the PWS will review the results. The PWS user cannot edit the data, but if the PWS has an issue with the sample result, such as if the PWS believes that the sample collection point ID or collection date is incorrect, the PWS can release the results back to the laboratory for issue resolution. In addition to noting the reason in the LT2 Data Collection System for the return of the data to the laboratory, you also should contact the laboratory verbally to discuss the issue. If the PWS determines that the data are accurate, the PWS releases the results to EPA (and the State, if applicable) as "approved" results. If the PWS determines that the data are accurate, but believes that the data are not valid for other reasons, the PWS can release the results as "contested." Draft 63 June 2003 ------- Section 4: E. coli Laboratory Guidance 4.6.3 EPA/State Review After the PWS has released the results as approved or contested, they are available to EPA and State users to review through the LT2 Data Collection System. EPA and State users cannot edit the data. 4.7 Vendor Contact List for E. coli Methods Contact information for the vendors for materials used in the methods described in Section 4 is provided below. Footnotes indicate which vendors are associated with each method. American Type Culture Collection1 www.atcc.org P.O. Box 1549 Manassas, VA 20108 Sales: Phone:(800) 638-6597 Fax: (703) 365-2750 Technical Support: Phone:(800) 638-6597 E-mail: tech@atcc.org Becton, Dickinson and Company2 www.bd.com 1 Becton Drive Franklin Lakes, NJ 07417 Sales: Phone: (800) 675-0908 Fax:(410)316-4723 Technical Support: Phone:(800) 638-8663 Fax: (410) 527-0244 E-mail: rep .technical services@ibd.com bioMerieux6 www.biomerieux.com 595 Anglum Drive Hazelwood, MO 63042 Sales: Phone: (800)638-4835 Fax: (800) 657-3053 Technical Support: Phone: (800)638-4835 Fax: (800) 657-3053 Cole-Parmer1 www. coleparmer. com 625 East Bunker Court Vernon Hills, IL 60061 Sales: Phone: (800)323-4340 Fax: (847) 247-2929 E-mail: sales(g),coleparmer.com Technical Support: Phone: (800) 323-4340 ext.122 Fax: (847) 327-2987 E-mail: techinfo(gicoleparmer.com Fisher Scientific1 www.fishersci.com 9999 Veterans Memorial Drive Houston, TX 77038 Sales: Phone: (800) 766-7000 Fax:(800)926-1166 Technical Support: Phone: (800) 766-7000 Fax:(800)926-1166 Hach5 www.hach.com P.O. Box 389 Loveland, CO 80539 Sales: Phone: (800) 227-4224 Fax: (970) 669-2932 Technical Support: Phone: (800) 227-4224 Fax: (970) 669-2932 E-mail: techhelp@hach.com Biosynth International Inc.2 www.biosynth.com 1665 West Quincy Avenue Naperville, IL 60540 Sales: Phone: (800) 270-2436 Fax: (800) 276-2436 Technical Support: Phone: (800) 270-2436 Fax: (800) 276-2436 E-mail: craig@,biosvnth.com Draft 64 June 2003 ------- Section 4: E. coli Laboratory Guidance Hardy Diagnostics 2 www.hardvdiagnostics.com 1430 West McCoy Lane Santa Maria, CA 93455 Sales: Phone: (800) 266-2222 Fax: (805)346-2760 E-mail: sales@hardvdiagnostics.com Technical Support: Phone: (800) 266-2222 ext 5658 Fax: (805)346-2760 IDEXX 4 www.idexx.com Sales: Phone: (800) 321-0207 ext. 1 Fax: (207) 856-0630 Technical Support: Phone: (800) 321-0207 ext.2 Fax: (207) 856-0630 E-mail: water@idexx.com Pall Gelman Sciences 3 www .pall. com/gelman 600 South Wagner Road Ann Arbor, MI 48103 Sales: Phone: (800) 521-1520 ext.2 Fax: (734) 913-6495 Technical Support: Phone: (800) 521-1520 ext.3 Fax: (734) 913-6495 Oxoid Inc.2 www. oxoid. com Suite 100, 1926 Merivale Road Nepean, Ontario K2G1E8, Canada Sales: Phone:(613)226-1318 Fax:(613)226-3728 E-mail: oxoid(g),oxoid.com Technical Support: Phone: (800) 521-1520 ext.3 Fax: (734) 913-6495 E-mail: oxoid@,oxoid.com 1 Possible vendors for all E. coli methods 2 Vendors for methods: 9221B/9221F, 9222B/9222G, 9222D/9222G, 9213D, EPA Method 1603, EPA Method 1604 3 Vendors for methods: 9222B/9222G, 9222D/9222G, 9213D, EPA Method 1603, EPA Method 1604 4 Vendor for methods: 9221F, 9223B 5 Vendor for method: m-ColiBlue24 broth 6 Vendor for API 20E for EPA Method 1604 Millipore3 www .millipore. com 80 Ashby Road Bedford, MA 01730 Sales: Phone: (800) 645-5476 Fax:(781)533-3110 Technical Support: Phone: (800) 645-5476 Fax:(781)533-3110 Sigma2 www. sigma-aldrich. com P.O. Box 14508 St. Louis, MO 63178 Sales: Phone: (800) 325-3010 Fax: (800)325-8070 E-mail: custserv(g),sial.com Technical Support: Phone: (800) 325-5832 Fax:(314)286-7828 E-mail: techserv@sial.com VWR1 www.vwr.com 405 Heron Drive Bridgeport, NJ 08014 Sales: Phone: (800) 932-5000 Fax: (856) 467-3336 Technical Support: Phone: (800) 932-5000 Fax: (856) 467-3336 Draft 65 June 2003 ------- SECTION 5: REFERENCES 5.1 Cornell, Kevin, et al. 2000. ICRSS - Building a Better Protozoa Data Set, J. AWWA. 91(10): 30 -43. 5.2 USEPA. 1997. Manual for the Certification of Laboratories Analyzing Drinking Water; Criteria and Procedures; Quality Assurance: Fourth Edition. EPA 815-B-97-001. 5.3 APHA. 1998. Standard Methods for the Examination of Water and Wastewater; 20th Edition. American Public Health Association, American Waterworks Association, Washington, D.C. 5.4 Pope, M., et al. 2002. Assessment of the effects of holding time and temperature on E. coll concentrations in surface water samples. Appl. Environ. Micro, (submitted). Draft 66 June 2003 ------- SECTION 6: ACRONYMS CPU CNFG DAPI DIG EPA FA FITC ICR IDC IFA IMS IPR IPX L LT2 rule MPC MPN MS MS/MSD NA-MUG NELAC NPDWR OPR OPT PBMS PT PWS QA QAP QC Colony-forming unit Confluent growth 4, 6-diamidino-2-phenylindole Differential interference contrast microscopy U.S. Environmental Protection Agency Immunofluorescense assay Fluorescien isothiocyanate Information Collection Rule Initial demonstration of capability Immunofluorescence assay Immunomagnetic separation Initial precision and recovery Initial proficiency test Liter Long Term 2 Enhanced Surface Water Treatment Rule Magnetic particle concentrator Most probable number Matrix spike Matrix spike/matrix spike duplicate Nutrient Agar (NA) with 4-methylumbelliferyl-beta-D-glucuronide (MUG) National Environmental Laboratory Accreditation Conference National Primary Drinking Water Regulations Ongoing precision and recovery Ongoing proficiency testing Performance-based measurement system Proficiency testing Public water system Quality assurance Quality Assurance Plan Quality control Draft 67 June 2003 ------- Section 4: E. coli Laboratory Guidance RSD Relative standard deviation SDWA Safe Drinking Water Act SOP Standard operating procedure TNTC Too numerous to count UV Ultraviolet Draft 68 June 2003 ------- |