Archives
November 29, 2007 State-wide Meeting
A State-wide laboratory meeting was held November 29, 2007 in Columbia. To review presentations offered at this meeting, click here.
Methods Update Rule (MUR) Changes
On March 12, 2007, the long awaited Methods Update Rule was published in the Federal Register. This rule modified the approved methodology for the Clean Water Act and the Safe Drinking Water Act at 40 CFR Parts 122, 136, 141, 143, 430, 455, and 465. The addition of new and updated methods to the wastewater and drinking water regulations provides increased flexibility to the regulated community and laboratories in the selection of analytical methods. Click here for the link to the Methods Update Rule (MUR) effective April 11, 2007. Also on March 26, 2007, the Biological Rule was promulgated. This rule became effective April 25, 2007 and addresses changes to 40 CFR Parts 136 and 503. Click here for a link to the Biological Rule.
Correspondence sent from our office on April 12, 2007 with the 2007 Certification Fee Pre-bill addressed the actions necessary by laboratories. We requested updates of method references along with SOPs reflecting the updated methods. As stated in the correspondence, an application is not required if the method is considered equivalent and there is not a change in the chemistry. For laboratories using Standard Methods as a reference, the SOP must document the Edition of Standard Methods in use. For example, for Biochemical Oxygen Demand analyses, if a laboratory uses Standard Methods 5210B from the 18th Edition of Standard Methods, SOP will document the method reference as SM 5210B 18th Edition. If using EPA Methods, the year of revision must be documented with the EPA Method. For example, the method reference for Total Hardness is EPA Method 130.1 (1971). The MUR became effective April 11th and we are aware that it will take some time to work through the changes addressed by this rule.
We are in the process of adding the Standard Methods Editions to everyone's certification. If a lab does not provide us with a Standard Methods Edition reference, the default will be the 18th Edition, unless the 18th is not an EPA approved method. Laboratories should refer to the Methods Update Rule for the list of approved methods for the Clean Water Act and the Safe Drinking Water Act. Since several of the older EPA methods are no longer approved, the laboratory can reference an equivalent method using the same chemistry and determinative technique or apply for certification for a new method. When submitting the SOPs, labs should document in a letter those method references that will need to be updated on their certificate. We would like to complete this process as soon as possible.
Questions concerning the approved methodology and updates to certification should be addressed to a Laboratory Certification Officer at (803) 896-0970.
Out-of-State Laboratory Renewal Procedure
Out-of-state laboratories’ certificates reflect the expiration date of their accrediting authority. Upon expiration, our office sends a letter to the laboratory with a checklist of required items that must be submitted for renewal of their certification. For a copy of this checklist, please click here. If you have any questions concerning out-of-state laboratory certification renewal, please contact our office and ask to speak with a Laboratory Certification Officer at (803) 896-0970.
New PT Requirements
There are additional PT samples that are included on the NELAC PT Tables,
which have been adopted and approved by the EPA. The acceptance criteria for
some compounds have been updated and the Approved Proficiency Testing Providers
are using the new criteria. Also additional compounds are included in the
tables. Some new compounds are already incorporated in to the DMR-QA Study
26. Our office will incorporate the analysis of the new compounds for the
WS and WP studies in 2007. We will keep labs updated on the new changes. A
list of the new proficiency testing compounds will be posted on our Web site
in November.
To maintain certification in South Carolina,
acceptable PT sample results for a laboratory must be received by December
31 each year for the Water Supply (WS) and/or Water Pollution (WP) studies.
This means that the study the laboratory participates in must begin in the
calendar year and end in the calendar year with the results received in our
office by December 31. The PT provider must submit these studies to this office.
We cannot accept PT results faxed from laboratories. Also labs must remember to document
their EPA Lab code on the results to your provider. If they do not have an EPA
Lab code, they should contact our office and we will tell them how to
obtain one.
Studies received in January will not be accepted for meeting the annual PT
requirement. If acceptable PT Studies are not received by December 31st, decertification
may be initiated. The laboratory will be decertified upon receipt of the decertification
letter.
PLEASE NOTE: We no longer send out annual reminders of the PT Studies. All
certified labs are required to participate in annual studies as required by
Regulation 61-81. Our Web site has information on the PT Studies and laboratories can
call DHEC with specific questions.
Enterococci
Some NPDES (wastewater) permits are now being issued with enterococci monitoring required. If your laboratory is interested in becoming certified for enterococci testing, please contact this Office at (803) 896-0970. There are guidance documents and checklists labs may use to become certified for these methods. They can be found by clicking here.
Discrete Analyzers
A discrete analyzer is an instrument that provides multiple automated chemical analyses simultaneously on any given sample using micro-volumes of both sample and reagent. We have received several inquires from laboratories and instrument manufacturers regarding the equivalency of the discrete analyzer methods to EPA-approved methodology. The Methods Update Rule published on March 12, 2007 includes a provision that allows the regulated laboratories some flexibility to automate the analysis procedure of approved Clean Water Act (CWA) methods using a discrete analyzer. An Alternative Test Procedure (ATP) approval is no longer required from EPA to implement this change. An EPA memo from Richard Reding of the Engineering and Analytical Support Branch was released on April 2, 2007 to address the flexibility to modify Clean Water Act methods. A copy of this memo can be downloaded by clicking here. An additional memo published on January 27, 2005 from the EPA Office of Water also addresses the use of discrete analyzer methods for compliance monitoring. Since this memo is referenced in the April 2, 2007 memo, a copy of that document can be downloaded by clicking here.
Although the laboratories no longer have to obtain an ATP approval from EPA, the task of demonstrating equivalency of a discrete analyzer method to an approved CWA method must be performed in order to be approved to use a discrete analyzer for compliance monitoring. The second page of the above-mentioned memo details the information that must be provided from the discrete analyzer developer and the regulated laboratory in order to obtain DHEC approval. A new discrete analyzer certification checklist that summarizes the required information can be downloaded by clicking here. Laboratories already certified for the EPA-approved method that they wish to automate can submit the required equivalency data without an application. All other laboratories must submit the equivalency data with an application.
If you have any questions regarding the use and approval of discrete analyzers, please contact this office at (803) 896-0970.
For additional information, contact: (803) 896-0970