Laboratory Certification Bulletin, January 2000
United States
Environmental Protection
Agency
Office of Water (MLK 140) EPA 815-N-OO-OO1 a January 2000 www.epa.gov/safewater
-------
TABLE OF CONTENTS
LabCert Bulletin 3
In This Issue 3
Regs, Regs, and More Regs 3
Colisure Certification 3
Drinking Water Regulations Affecting Certification 4
MeaCulpa, MeaCulpa 5
Analytical Methods for Chemical and Microbiological Contaminants and
Revisions to Laboratory Certification Requirements - Final Rule 5
Regulated Drinking Water Contaminants 7
Announcement of the Analytical Method (EPA Method 314.0) and Laboratory
Approval Process to Support Perchlorate Monitoring for the Unregulated
Contaminant Monitoring Rule 12
Drinking Water Laboratory Certification and NELAC PT Requirements 14
Proficiency Testing (PT) Questions and Answers 14
-------
LabCert Bulletin
EPA-815-N-00-001a
January 2000
In This Issue
Laboratory Certification Requirements - Final Rule
Analytical Method EPA 314.0 Announced
Latest Regulated Drinking Water Contaminants Table
PT Q&As
Regs, Regs, and More Regs
Just in time for your New Year's reading, the drinking water Laboratory Certification Team at
TSC, in an ever continuing effort to keep the certifying community well informed, has published
yet another Laboratory Certification Bulletin. In this issue you will find information on the
Unregulated Contaminant Monitoring Rule (UCMR), the Stage 1 Disinfectants and Disinfection
By-Products Rule (DBF), and the second Methods Update Federal Register Notice (MUFRN 2).
There is also a revised table listing the current analytical methods for each regulated analyte.
If there are certification topics you would like to see discussed, please call, write, fax or e-mail
the editors.
Ed Glick 513 569-7939, glick.ed@epa.gov
PatHurr 513 569-7678, hurr.pat@epa.gov
Carol Madding 513 569-7402, madding.caroline@epa.gov
USEPA
Technical Support Center (MS-140)
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
FAX: 513 569-7191
Colisure Certification
We have been asked if a laboratory is certified for the Colilert test and wants to use the Colisure
test also, is the laboratory certified for the Colisure test?
Our microbiologist colleagues arrived at the following consensus: because of the similarity of
these two chromogenetic/flourogenic methods, a laboratory certified for Colilert should be
capable of performing Colisure and can be considered certified for both. The critical elements
specific to Colisure are that the Colisure medium must be refrigerated until use and brought to
-------
room temperature before adding the sample; the samples must be incubated for 24 hours; and a
positive total coliform test is indicated by a magenta color. The laboratory should be encouraged
to analyze performance testing (PT) samples, run positive and negative controls, and analyze a
series of samples by both Colilert and Colisure.
Drinking Water Regulations Affecting Certification
Three regulations which affect drinking water certification were passed recently. They are the
Stage 1 Disinfectants and Disinfection By-Product (DBF) Rule, the Unregulated Contaminant
Monitoring Rule (UCMR), and the Methods Update Federal Register Notice 2. This article gives
an overview of the DBF, TOC rule. MUFRN 2 is discussed on the next page. For more detailed
information, see the OGWDW website at www.epa.gov/safewater.
The DBF Rule is the first new drinking water standard in six years. It was promulgated in
December 1998 and becomes effective for large surface water systems in December 2001, and
for ground water systems and small surface water systems in December 2003. The Rule lowers
the MCL for TTHMs to 0.08 mg/L and sets the MCL for HAAS at 0.06 mg/L. Haloacetic acids
(five) is the sum of the concentrations of mono-, di-, and trichloroacetic acids and mono- and
dibromoacetic acids. It also sets MCLs of 0.01 mg/L for bromate and 1.0 mg/L for chlorite. The
Rule requires that laboratories be certified for these analyses. Methods required for analysis of
HAAs are EPA 552.1 or 552.2 or SM 625 IB (552.2 is recommended over 552.1). Laboratories
must use EPA Methods 300.0 or 300.1 to determine chlorite and Method 300.0 to determine
bromate.
The UCMR was promulgated on September 17, 1999 and will take effect in 2001-2003. This is
not a primacy rule, rather it is direct implementation. This means that USEPA will take the lead
for implementing it, but we are counting on assistance from the states. It involves all large
utilities (>10,000 population served) and 800 small utilities (<10,000 population served). Large
utilities will be responsible for their own monitoring, but USEPA will be responsible for
analyzing the samples from the 800 small utilities, which will be chosen at random. The Rule
covers the contaminants currently on the Contaminant Candidate List (CCL) and is divided into
3 categories: Assessment, Screening and Prescreening.
The Assessment category contains 11 analytes that have currently approved methods, and
perchlorate. Certification requirements are that samples must be analyzed by a laboratory already
certified for the method which must be used to determine the contaminant. For perchlorate,
USEPA will approve laboratories that currently are certified for any 1C method and pass a PT
sample.
Both Screening and Prescreening studies will be proposed and promulgated in future regulations.
-------
Mea Culpa, Mea Culpa
We have just learned that Absolute Standards was accredited by NIST to provide TOC samples
but was inadvertently left off of both the NIST list on the web and our list in the previous
bulletin. Please revise your list.
It was noted in our list of providers that New York does not intend to sell PT samples to the
public. New York became accredited to be able to supply PT samples to those wanting New
York NELAC accreditation but does not wish to compete with private industry. However, New
York will sell asbestos PT samples to the public since it is the only asbestos provider accredited
by NIST.
Analytical Methods for Chemical and Microbiological Contaminants
and Revisions to Laboratory Certification Requirements - Final Rule
(MUFRN2)
The Environmental Protection Agency (EPA) specifies analytical methods at Part 141 of Title 40
of the Code of Federal Regulations that are to be used in compliance monitoring of drinking
water. Periodically, the Agency amends these regulations to revise or replace these methods
based on user suggestions, changing regulatory needs or improvements in technology. On
December 1, 1999 EPA published a final rule in the Federal Register (64 FR 67450) to approve
several updated or new drinking water methods for chemical and microbiological contaminants,
and to amend some laboratory certification and sample holding time requirements. Except for
withdrawal of certain older methods, the effective date for these amendments is January 3, 2000.
The December 1, 1999 rule allows use of updated versions of several microbiology and
chemistry methods for compliance with drinking water standards and monitoring requirements.
These updated methods include 13 EPA methods that are published in Supplement III of
"Methods for the Determination of Organic Compounds in Drinking Water," EPA/600/R-95/131,
August 1995, NTIS PB95-261616; 25 American Society for Testing and Materials (ASTM)
methods that are published in Vols. 11.01 and 11.02 of the 1996 Annual Book of ASTM
Standards; and 54 methods that are published in the 19th edition of Standard Methods for the
Examination of Water and Wastewater (1995). Compared to the currently approved versions, the
new versions contain primarily editorial, technical or other changes that make the method easier
to conduct or safer. EPA will withdraw earlier versions of the EPA methods on June 1, 2001,
which is 18 months after publication of this rule. Earlier versions of approved methods published
by ASTM and Standard Methods are not withdrawn and continue to be approved for compliance
monitoring.
EPA is also approving two new methods, EPA 515.3 and ASTM D5317-93, for acid herbicides.
EPA is not withdrawing approval of EPA 515.1 or 515.2 for determination of acid herbicides,
because these methods are not obsolete. EPA will withdraw EPA 549.1 on June 1, 2001 for
determinations of Diquat, because the method has been replaced with an improved version, EPA
549.2. Methods 515.3 and 549.2 are not published in an EPA manual. The methods are available
from U.S. EPA, NERL-CI (MS 564), 26 West Martin Luther King Drive, Cincinnati, OH 45268.
-------
EPA is approving the use of a new membrane filter medium, MI Agar, for the determination of
the presence of total coliforms and E. Coli in drinking water under the Total Coliform Rule
(TCR). MI Agar is also approved for the enumeration of total coliforms in source water under
the Surface Water Treatment Rule (SWTR). EPA is approving two new tests, m-ColiBlue247
and E*Colite7, for the simultaneous detection of total coliform and E. coli in drinking water
under the TCR. Because the latter two methods are presence/absence tests, they are not
applicable for enumerations under the SWTR. The rule requires that microbiological source
water samples collected under the SWTR for the determination of coliform and fecal coliform or
for determination of heterotrophic bacteria in distribution system samples be held below 10EC
during transit and storage.
EPA is allowing a choice of six methods (ASTM D 511-93 A and B, EPA 200.7, and SM 3111
B, 3120B and 3500 Mg E) for determination of magnesium. Magnesium determinations will be
required of systems that elect to use the magnesium control alternative to the total organic carbon
removal requirements of the 1998 Stage One Disinfection By-Products Rule.
EPA is approving use of Palintest MethodlOOl for determinations of total lead under the Lead
and Copper Rule. The Palintest method uses a differential pulse anodic stripping voltammetry
(DPASV) technique which requires an acid digestion regardless of the turbidity of the sample.
Readers are reminded that there are now three technologies for which compliance determinations
of total metals require an acid digestion of the sample even if the turbidity of the sample is less
than 1 NTU. The three technologies and the applicable metals are DPASV (lead), cold vapor AA
(mercury), and gaseous hydride AA (antimony, arsenic and selenium). For this reason, it will be
difficult to conduct analyses in the field using these techniques.
This rule makes minor technical corrections and clarifications to the regulations. The rule: (1)
clarifies that usually one may have up to 14-days from the date of the second analysis to report
follow-up composite sample analyses, (2) amends the holding times for asbestos, nitrate and total
nitrate that are specified in the table at '141.23(k)(2); (3) changes 2,4-D to A2,4-D as acid salt
and ester@ in the table at '141.24(e), (4) clarifies that the acceptance limits for successfully
measuring chemical analytes in a performance evaluation (PE) sample apply only if that analyte
has been added to the PE sample, and (5) allows determinations of alkalinity, calcium,
conductivity, orthophosphate and silica in drinking water samples by any person acceptable to
the State to conduct these determinations. The rule also amends the regulations to codify some of
the provisions in the 1997 Drinking Water Laboratory Certification Manual. These amendments
include a requirement to demonstrate proficiency by successful analysis of a PE sample each
year for chemical contaminants using the same analytical method that is used to report
compliance monitoring results.
Finally, the rule amends the table at '143.4(b) to recommend additional methods for monitoring
of chloride and sulfate. These chemicals are regulated under the National Secondary Drinking
Water Regulations. The additional methods are ASTM D 512-89B and SM 4500-C1G B for
chloride and ASTM D 516-90 and SM 4500-SO42G E for sulfate.
-------
What is next? The next method approval actions may include additional or new methods for
contaminants listed in the 1999 Unregulated Contaminants Monitoring Rule, and updated
methods for chemical, microbiological and radionuclide contaminants. The update rule is
expected to propose approval of both wastewater and drinking water methods that are published
in the 1999 Annual Book of ASTM Standards, Vols. 11.01 and 11.02 and in the 20th edition of
Standard Methods for Examination of Water and Wastewater (1998).
The complete rule can be found at: www.epa.gov/safewater/regs.html. Click on the blue HTML
at the December 1, 1999 rule.
Regulated Drinking Water Contaminants1
PARAMETER
REGULATED
Alkalinity5
Asbestos
Residual Disinfectant
Chlorine
Chloramines
Chlorine Dioxide
Cyanide
Fluoride
Nitrate (as N)
Nitrite (as N)
Nitrate/Nitrite (as N)
o-Phosphate5
Turbidity
Adjusted Gross Alpha
Beta Particle Emitters
MCL/ [SMCL]2
mg/L
7MF/L>10Fm
(MRDL)6
4 (as C12)
4 (as C12)
0.8 (as C1O2)
0.2
4.0
[2.0]
10
1
10
Treatment
15 pCi/L
4 mr ede/yr
MCLG2
mg/L
7MF/L>10Fm
(MRDLG)6
4 (as C12)
4 (as C12)
0.8 (as C1O2)
0.2
10
1
10
zero
zero
METHODS3'4
D1067-92B, 2320B, 1-1030-85
100.1, 100.2
4500-C1 D, F, G and H
4500-C1 D, E, F, G and I
4500-C1O2 C, D, E
335.4, D2036-91B, D2036-91A,
4500-CN C, G, E and F, 1-3300-85
300.0, D4327-91, Dl 179-93B,
4110B, 4500FB,D, CandE,
Technicon 380-75WE and 129-71W
353.2, 300.0, D4327-91, D3867-90A&B
4110B, 4500-NO3 F, D and E,
Waters B-1011, ATI 601
353.2, 300.0, D4327-91, D3867-90A&B
4110B, 4500-NO3 F & E, 4500-NO2 B
Waters B-1011
365. 1, 300.0, D5 15-88A, D4327-91,
4500-PF, 4500-PE, 4110B,
1-1601-85, 1-2601-90, 1-2598-85
180.1, 2130B, G LI Method 2
900.0, 302, 7110 B, C
900.0,302,71106
ACCEPTANCE LIMITS
2SD
±25%
±10%
±10%
±15%
±50%
±30%
-------
radioactive Cesium
radioactive Iodine
radioactive Strontium 89, 90
tritium
gamma emitters
Radium-226
Radium-228
Uranium
Total Coliform
E. coli
Fecal Coliform
Benzene
Carbon tetrachloride
Chlorobenzene
p-Dichlorobenzene
o-Dichlorobenzene
1,2-Dichloroethane
1 , 1 -Dichloroethy lene
c-l,2-Dichloroethylene
20 pCi/L
20 pCi/L
0.02
100/lOOmL
5% positive
samples/mo12
'141.21(f)
(6&7)
'141.21(f)(5)
'141.74(a)(l)
0.005
0.005
0.1
0.075
[0.005]
0.6
0.005
0.007
0.07
zero
zero
zero
zero
zero
zero
zero
zero
0.1
0.075
0.6
zero
0.007
0.07
901.0, 901.1, 7500-Cs B, 7120, D 2459-72,
D 3649-91
901.1 902.0,7500-1 B, C, D, 7120, D 3649-91, D
4785-88
905.0, 303, 7500-SrB
906.0, 306, 7500-3H B, D 4107-91
901.1, 902.0, 901.0, 7120, 7500-Cs B, 7500-1 B,
D3649-91, D 4785-88
903.0, 903.1, 7500-Ra C 304,305, 7500-Ra B,
D3454-91, D2460-90
904.0, 7500-Ra D
908.0, 908.17500-UB, 7500-U C, D2907-91,
D3972-90, D5 174-91
TCR (9221A,B,D, 9222A,B,C, E*Colite
9223, Colisure, CColiBlue24)
SWTR (9221A,B,C, 9222A,B,C, 9223)
Colilert, Colisure, EC-MUG
Nutrient Agar-MUG11
TCR (9221E Parti)
SWTR (9221E Part 1&2, 9222D)
502.2, 524.2
502.2,524.2,551.1
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
±30%
±30%
±30%
±20%
±30%
±50%
±30%
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
-------
t-l,2-Dichloroethylene
Dichloromethane
1,2-Dichloropropane
Ethyl benzene
Styrene
Tetrachloroethylene
Toluene
1,2,4-Trichlorobenzene
1,1,1 -Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
Vinyl chloride
Xylenes(Total)
Trihalomethanes (total)9
Haloacetic Acid 5 (HAA5)
(total)9'10
Bromate9'11
Chlorite9'12
Alachlor
Atrazine
Carbofuran
Chlordane
2,4-D (as acid salts and esters)
0.1
0.005
0.005
0.7
0.1
0.005
1
0.07
0.2
0.005
0.005
0.002
10
0.08
0.06
0.010
1.0
0.002
0.003
0.04
0.002
0.07
0.1
zero
zero
0.7
0.1
zero
1
0.07
0.2
0.003
zero
zero
10
zero
0.8
zero
0.003
0.04
zero
0.07
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2, 524.2
502.2,524.2,551.1
502.2, 524.2
502.2, 524.2
502.2,524.2,551.1
502.2,524.2,551.1
502.2,524.2,551.1
502.2, 524.2
502.2, 524.2
502.2,524.2,551.1
552.1, 552.2 SM 625 IB
300.1
1300.0,300.1
505,507,508.1,525.2,551.1
505,507,508.1,525.2,551.1
531.1,6610
505,508,508.1,525.2
515.1, 515.2, 555, 515.3, D5317-93
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
±20/40%8
95% CI11
95% CI11
95% CI11
95% CI11
±45%
±45%
±45%
±45%
±50%
-------
Dalapon
Dibromochloropropane
Dinoseb
Diquat
Endothall
Endrin
Ethylenedibromide(EDB)
Glyphosate
Heptachlor
Heptachlor epoxide
Lindane
Methoxychlor
Oxamyl (Vydate)
Pentachlorophenol
Picloram
Simazine
Toxaphene
2,4,5-TP(Silvex)
Hexachlorobenzene
Hexachlorocyclopentadiene
Benzo(a)pyrene
PCBs (as Aroclors) (as
decachlorobiphenyl)
0.2
0.0002
0.007
0.02
0.1
0.002
0.00005
0.7
0.0004
0.0002
0.0002
0.04
0.2
0.001
0.5
0.004
0.003
0.05
0.001
0.05
0.0002
0.0005
0.2
zero
0.007
0.02
0.1
0.002
zero
0.7
zero
zero
0.0002
0.04
0.2
zero
0.5
0.004
zero
0.05
zero
0.05
zero
zero
515.1,552.1,552.2,515.3
504.1,551.1
515.1,515.2,555,515.3
549.2
548.1
505,508,508.1,525.2,551.1
504.1,551.1
547,6651
505,508,508.1,525.2,551.1
505,508,508.1,525.2,551.1
505,508,508.1,525.2,551.1
505,508,508.1,525.2,551.1
531.1.6610
515.1, 515.2, 525.2, 555, 515.3, D5317-93
515.1, 515.2, 555, 515.3, D5317-93
505,507,508.1,525.2,5551.1
505,508,525.2,508.1
515.1, 515.2, 555, 515.3, D5317-93
505,508,508.1,525.2,551.1
505,508,508.1,525.2,551.1
550,550.1,525.2
505, 508, 508.1, 525.2, 508A
2SD
±40%
2SD
2SD
2SD
±30%
±40%
2SD
±45%
±45%
±45%
±45%
2SD
±50%
2SD
2SD
±45%
±50%
2SD
2SD
2SD
0-200%
10
-------
2,3,7,8-TCDD( Dioxin)
Acrylamide
Epichlorohydrin
Di(2-ethylhexyl)adipate
Di(2-ethylhexyl)phthalate
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Copper5'7
Iron7
Lead5
Magnesium14
Manganese
Mercury
Selenium
Silica5
3xlO'8
Treatment
Treatment
0.4
0.006
[0.05-0.2]
0.006
0.05
2
0.004
0.005
0.1
1.3/90%5
[1.0]
[0.3]
0.015/90%5
[0.05]
0.002
0.05
zero
zero
zero
0.4
zero
0.006
2
0.004
0.005
0.1
1.3
zero
0.002
0.05
1613
506, 525.2
506, 525.2
200.7,200.8,200.9,3 120B,3 1 13B,3 1 1 ID
200.8, 200.9, D-3697-92, 3113-B
200.7, 200.8, 200.9, D-2972-93C,
3 120B, 3 1 13B, 3 1 14B, D-2972-93B
200.7, 200.8, 3120B, 3111D, 3113B
200.7, 200.8, 200.9, D-3645-93B,
3120B, 3113B
200.7,200.8,200.9,31136
200.7, D5 1 1-93 A, D5 1 1-93B,
3500-CaD, 3111B, 3120B
200.7, 200.8, 200.9, 3120B, 3113B
200.7, 200.8, 200.9, D1688-95C,
D 1688-95A, 3 1 13B, 3 1 1 IB, 3 120B
200.7, 200.9, 3 120B, 3 1 1 IB, 3 1 13B
200.8, 200.9, D3559-95D, 3113B
200.7,0511-93 A,B, 31116,3120 B, 3500-Mg
E
200.7, 200.8, 200.9, 3120B, 3113B, 3111B
245.1, 245.2, 200.8, D3223-91, 3112B
200.8, 200.9, D3859-93A, D3859-93B,
3114B, 3113B
200.7, D859-95, 4500-Si D,E,& F,
2SD
2SD
2SD
±15%
±15%
±15%
±20%
±15%
±10%
±30%
±30%
±20%
11
-------
Silver7
Sodium
Thallium
Zinc
[0.1]
20
0.002
[5.0]
0.0005
3120B, 1-1700-85, 1-2700-85
200.7, 200.8, 200.9,
3 120B, 3 1 1 IB, 3 1 13B, 1-3720-85
200.7, 3111B, 3120B
200.8, 200.9
200.7, 200.8, 3120B, 3111B
±30%
1. This method table is a convenient reference only; for details see the specific rule.
2. MCL=maximum contaminant level; SMCL=secondary maximum contaminant level; MCLG=maximum contaminant level goal.
3. Secondary contaminants may be analyzed using the recommended methods and do not have to be analyzed in a certified laboratory; primary,
unregulated (monitoring only) and state discretionary contaminants must be analyzed using approved methods in laboratories certified by the States.
4. For method references, see 59 FR 62456, December 5, 1994 and Technical Notes on Drinking Water Methods. EPA-600/R-94-173, October, 1994.
5. Lead and Copper Rule - promulgated 6-7-91; lead and copper levels are Action Levels.
6. M-DBP Rule- MRDL=maximum residual disinfectant level; MRDLG=maximum residual disinfectant level goal.
7. Secondary Maximum Contaminant Level - non-enforcable federal guideline.
8. PE Acceptance Limits for VOCs are "20% at $10Fg/L and "40% at <10Fg/L.
9. M-DBP Rule - promulgated 12-16-98.
10. Includes 5 HAAs - monochloro, dichloro, trichloro, bromo, and dibromo acetic acids.
11. For plants that use ozone to disinfect.
12. For plants that use chlorine dioxide to disinfect.
13. Laboratories must achieve quantitative results within the acceptance limits on 80% of the analytes included in the PT sample. Acceptance is defined as
within the 95% confidence interval around the mean of the PT study data.
14. M-DPR Rule allows Mg to be used as a surrogate for TOC.
Announcement of the Analytical Method (EPA Method 314.0) and
Laboratory Approval Process to Support Perchlorate Monitoring for
the Unregulated Contaminant Monitoring Rule
The Safe Drinking Water Act (SDWA), as amended in 1996, requires the U.S. Environmental
Protection Agency (EPA) to establish criteria for a program to monitor unregulated contaminants
and to publish a list of specific contaminants to be monitored. In fulfillment of this requirement,
EPA published this list, which included the anion perchlorate, in the Revisions to the
Unregulated Contaminant Monitoring Rule (UCMR) on September 17, 1999 (64 FR 50556).
At that time, perchlorate was placed on the UCMR (1999) List 1 for Assessment Monitoring,
with the method listed as AReserved@. EPA has finalized the refinement and review of the
analytical method for perchlorate and in November published EPA Method 314.0,
ADetermination of Perchlorate in Drinking Water Using Ion Chromatography,@ Revision 1.0.
This method is available on-line at www.epa.gov/safewater/methods/ or by contacting the Safe
Drinking Water Hotline at 1-800-426-4791.
As this article was being prepared, a Direct Final Rule was being finalized for subsequent
publication in the Federal Register identifying this analytical method as the approved perchlorate
method and describing the laboratory approval process. This Rule is tentatively scheduled to be
published in 40 CFR Part 141 in early 2000 and is titled, "Unregulated Contaminant Monitoring
12
-------
Regulation for Public Water Systems; Analytical Methods for Perchlorate and Acetochlor;
Announcement of Laboratory Approval and Performance Testing (PT) Program for the Analysis
of Perchl orate." This Laboratory Certification Bulletin article provides notice of the availability
of the approved method and also summarizes the pending requirements for attaining laboratory
approval to perform this perchlorate analysis. Please look for a more detailed description of the
Rule in the Federal Register which can be accessed from the OGWDW Regulation and Guidance
web page on-line at www.epa.gov/safewater/regs.html.
Laboratories interested in becoming approved to perform this perchlorate analysis must: (1)
Follow EPA Method 314.0; (2) be certified by the appropriate primacy agency for any inorganic
anion(s) using an approved ion chromatographic method (such as nitrate analysis by EPA
Method 300.0); and (3) attain EPA laboratory approval by participating and passing an EPA
coordinated perchlorate Performance Testing (PT) Program.
Any laboratory wishing to participate in the perchlorate PT Program and subsequently obtain
approval must submit a request letter to EPA by March 31, 2000. Any interested laboratory,
which does not meet this deadline or fails to successfully pass the initial PT study but still wishes
to be approved for this perchlorate analysis, will need to submit a request letter by September 1,
2000 in order to be eligible for a second PT study. EPA will not consider any laboratory request
letters received after September 1, 2000. Any laboratory gaining approval in the first PT study
will not be required to participate in the second PT study. These will be the only two perchlorate
PT studies offered, through December 31, 2003. Any laboratory which does not request
participation by September 1, 2000 or fails to pass one of these two PT studies can not be
approved to analyze perchlorate under UCMR monitoring. The request letter must be signed by
the laboratory manager with a statement that the laboratory is currently certified, by the
appropriate primacy agency, to perform drinking water compliance monitoring using an
approved ion chromatographic method. A copy of the letter or certificate issued by the state or
primacy agency detailing this certification must also be submitted.
This request letter must include the following information:
(1) Laboratory Name
(2) Complete Laboratory Mailing Address
(3) Ion chromatography analytical method the laboratory is certified to perform
(4) Copy of the letter or certificate issued by the state or primacy agency which issued the
certification to the laboratory
(5) Contact Person
(6) Contact Phone, FAX, and e-mail (if available)
The letter should be mailed to:
Perchlorate PT Program Coordinator
U.S.EPA, Rm.140
26 W. Martin Luther King Dr.
Cincinnati, Ohio 45268
13
-------
Upon completion of the perchlorate PT Program, EPA will provide each successful laboratory
with an approval letter identifying the laboratory by name and the approval date. This letter may
then be presented to any Public Water System (PWS) as evidence of laboratory approval for
perchlorate analysis supporting the UCMR. Laboratory approval is retained as long as the
laboratory maintains certification to perform drinking water compliance monitoring using an
approved ion chromatographic method. If a laboratory maintains this certification, the laboratory
is approved for perchlorate analysis through January 28, 2004.
Drinking Water Laboratory Certification and NELAC PT Requirements
Recently the Office of Ground Water and Drinking Water promulgated a rule (MUFRN 2)
requiring laboratories to successfully analyze a PT sample once a year by the method they are
using to report compliance data. The requirement does not extend to methods used for
confirmation.
The Office believes this is simply good science and does not believe this is a change in drinking
water certification policy. The Laboratory Certification Manual states this requirement in
Chapter 3.
While EPA requires laboratories to successfully analyze a PT sample once a year for each
method used for compliance data reporting, current NELAC standards require laboratories to
successfully analyze a PT sample twice a year for each analyte by any method in use in the
laboratory. If a laboratory uses two methods for an analyte, both NELAC and EPA requirements
could be met if the laboratory uses a different method for each of the NELAC required studies
Since there are few contaminants in the drinking water program that have more than two
methods this would meet both drinking water and NELAC requirements .
Proficiency Testing (PT) Questions and Answers
It is a whole new world for proficiency testing and we are getting questions by the dozens. Here
with the answers are two of the most frequently asked.
Question: Does the size of a provider's study affect the acceptance criteria for that study?
Answer: Acceptance criteria are not generated from each provider's current study, rather they are
are based on regressions developed from results of studies conducted from 1993 thru 1997. The
size of any provider's study does not have an impact on these criteria.
Question: Whom should a laboratory contact regarding a PT provider's performance and what
issues may be addressed?
Answer: Users of accredited providers should first attempt to resolve issues/discrepancies
directly with that provider, perhaps informally, or by filing a formal complaint with the provider
in question. Accredited providers are required to have a formal complaints process which
requires them to attempt to resolve all complaints. Should the user not be satisfied with the
provider's proposed resolution they may then contact the National Voluntary Laboratory
14
-------
Accreditation Program (NVLAP) for assistance. It is important to note that NVLAP is the
responsible authority within the National Institute of Testing and Standards (NIST), not NIST in
general. They should send a letter to NVLAP clearly identifying the provider, describing the
problem/concern, etc., and details of all actions taken thus far. This would include copies of the
formal complaint filed with the provider and any correspondence received from the provider in
response.
It is understood that not all complaints can be resolved between the user and provider due to
interpretations of the standard, scoring of analytes, and for many other reasons, but the complaint
system is in place and should be used.
Users may also contact NVLAP directly if the issue/concern is not about, or related to, an
individual provider but about the conduct or requirements of the program itself.
All inquiries should be addressed to:
NIST/NVLAP
Providers of Proficiency Testing Program
100 Bureau Drive, Stop 2140
Gaithersburg, MD 20899-2140
Question: Will any more providers be approved?
Answer: Yes, NIST will approve providers as they apply. In fact, another provider, NSI has just
been approved. You can find more information on the NIST web site,
http: //ts. ni st. gov/standards/accreditati on/index. cfm.
Definition: User - Any customer of a provider or others who depend on the results of the PT
study.
15
------- |