1. Public Water System Supervision Program Quality Assurance Project Plan Requirements for Laboratories and Impacts on Public Water Systems (Part 1)
Jessica Hoch
Drinking Water Assessment Team Lead
Lead and Copper Rule, Revised Total Coliform Rule, Groundwater Rule
2019 TCEQ Environmental Trade Fair

2. Presentation Goals QAPP Requirement Specific Scenarios to Consider
Impacts on Public Water System (PWS) Compliance
What can the lab do?
To assist laboratories in understanding how QAPP requirements can impact customer/PWS compliance with the Safe Drinking Water Act.
Emphasize open, cooperative communication
Perspective

3. Protection of Public Health
Public Water System
Laboratory
Protection of Public Health
TCEQ

4. TNI Accreditation for Laboratories 290 TAC Rules for PWS
Protection of Public Health
QAPP

5. Quality Assurance Project Plan
Quality Assurance (QA) and Quality Control (QC) processes related to environmental data collection activities.
Includes 10 addenda addressing program-specific QA and QC
Revised every 3 years with annual updates
Last revision 11/4/2016
1st Annual update in 2017
EPA approval
12/20/2017
2nd Annual update in 2018
EPA approval
10/26/2018

6. For Discussion Today
Addendum 3—Guidance for the Analysis and Reporting of Water Quality Parameters under the Lead and Copper Rule
All three guidance documents primarily address laboratory requirements for sample receipt, analysis, and reporting. Requirements are program specific and reflect rules and regulations specific to the drinking water program. Laboratories need to be aware there situations in which drinking water rules and regulations applying to laboratories which are more stringent than the TNI Standards. I think most laboratories understand this, but there we received a few questions related to this issue. For example, the TNI specifies the sample label must have a unique identifier only. Appendix A, Figure A-1 of the Certification Manual for Laboratories analyzing Drinking Water has requirements for sample labels which include the sample location, date and time of sample collection, etc… This is more stringent than what the TNI Standard requires, which is why we included it.
Addendum 2—Guidance for the Analysis and Reporting of Lead and Copper under the Lead and Copper Rule
Addendum 4—Guidance for Analysis and Reporting under the Revised Total Coliform Rules

7. Quality Assurance Project Plan
Addendum 2 – Laboratory Guidance for the Analysis and Reporting of Tap Water Samples under the Lead and Copper Rule
Applies to labs analyzing PbCu tap samples
Addendum 3 – Laboratory Guidance for the Analysis and Reporting of Water Quality Parameters Under the Lead and Copper Rule
Applies to labs analyzing WQP samples
Addendum 4 – Laboratory Guidance for Analysis and Reporting Under the Revised Total Coliform Rule
Applies to labs analyzing microbial compliance samples

8. QAPP Addendum #2 LCR Tap Samples
Lead and Copper Requirements for Laboratories
Addenda #2 is Currently on Revision 2
LCR Chain of Custody
Form 20683

9. QAPP Addendum #2 LCR Tap Samples
Guidance for the Analysis and Reporting of Tap Water Samples under the Lead and Copper Rule
Applies to the systems and the laboratories submitting data for compliance under the Lead and Copper Rule (LCR)
Tap Samples
Samples for public water system (PWS) compliance
Includes regulatory program requirements

10. LCR Tap Sample QAPP Requirement
Samples must be collected in 1 L lab-grade plastic bottles with a fill line
Acid preserved upon receipt in the laboratory
No later than 14 days after date of collection
QAPP-Addendum 2-Table 2
Preservation and Containers for Lead and Copper Samples
QAPP requirements related to sample receipt activities at the lab.

11. LCR Tap Sample Scenario
Customer asks for lead and copper testing
Doesn’t indicate for compliance with the LCR
Samples received in insufficient sample bottles
Material, volume, audit trail, etc.
Noted on analytical report
PWS receives violation letter
Submits analytical report to TCEQ
TCEQ reviews report
Samples cannot be used for compliance

12. LCR Tap Sample Scenario
Customer drops compliance samples late on a Friday
Laboratory intends to preserve on Monday
Customer delayed bringing samples to lab
Some past hold-time
Left messages and had no response from customer
PWS receives violation letter
Submits analytical report to TCEQ
TCEQ reviews report
Samples cannot be used for compliance
Samples were collected at different times over past 2-13 days

13. LCR Tap Sample PWS Compliance Impact
Samples that are analyzed using an unapproved method, collected in an inappropriate container, and/or samples that are not preserved within hold-time cannot be accepted for compliance
Monitoring and Reporting (M/R) Violation
Violations require Public Notice
PWS will sample in the next monitoring period
Monitoring results dictate sampling schedules
Homeowners will have to participate again

14. LCR Tap Sample What Can The Lab Do?
At sample receipt:
Ask if samples are to be used for compliance with the Lead and Copper Rule and/or TCEQ
Always check all collection dates
Always preserve at time of receipt

15. LCR Tap Sample QAPP Requirement
Samples that have been delivered to the laboratory and determined to be unsatisfactory must be reported to the TCEQ, in all cases
Receive
Reject
Replace
Report
QAPP-Addendum 2-Table 6
Lead and Copper Rejection Codes

16. LCR Tap Sample Scenario
Customer drops off inadequate compliance samples in late June
Laboratory notices and tells customer the issue
Customer leaves, no record of rejected sample
Customer returns the next week with new sample
PWS receives violation letter
Submits analytical report to TCEQ
TCEQ reviews report
Sample cannot be used for monitoring period intended for

17. LCR Tap Sample PWS Compliance Impact
Samples analyzed in the next monitoring period, that are lacking a tie to the previous monitoring period, cannot be accepted for compliance
PWS must maintain accurate, defensible records
Monitoring and Reporting (M/R) Violation
Violations require Public Notice
PWS will sample in the next monitoring period
Monitoring results dictate sampling schedules
Homeowners will have to participate again

18. LCR Tap Sample What Can The Lab Do?
Reporting rejected and replacement samples can help prevent customers from receiving a violation
Always reject inadequate samples at receipt
Always report rejected and replacement samples
Replacement samples tie to the rejected sample
Receive – Reject – Replace - Report

19. LCR Tap Sample QAPP Requirement QAPP Addendum #2 LCR Tap Samples
PWS must use the LCR Monitoring Form (LCRMF)
Form #20683
Lab-modified forms must be approved by TCEQ
LCRMF must be completed properly
Samples must be labeled properly
Samples must be collected from the approved sample site pool for the PWS

20. LCR Tap Sample Scenario
Customer asks for lead and copper testing
Doesn’t indicate for compliance with the LCR
Received with private chain of custody (COC)
Missing required information
Noted on analytical report
PWS receives M/R violation
Submits analytical report and sample records to TCEQ
TCEQ reviews report and records
Samples may be used for compliance

21. LCR Tap Sample PWS Compliance Impact
Samples collected without adequate documentation cannot be accepted for compliance
PWS must maintain accurate, defensible records
TCEQ can review and make corrections to documentation
Potentially reject violation
Monitoring results dictate sampling schedules

22. LCR Tap Sample What Can The Lab Do?
At sample receipt:
Ask if samples are to be used for compliance with the Lead and Copper Rule and/or TCEQ
Ensure proper documentation if customer states samples are for compliance
Train staff on sample acceptance criteria

23. LCR Tap Sample Reporting Reminders
Frequent electronic data submittal
DO NOT hold data until end of the monitoring period
Prevents TCEQ from informing PWS of data issues
Report regularly
Corrections and resubmittal of data
PWS works to correct issue with documentation
Laboratory resubmits, uses new state notification date
Potential for PWS to receive violation for late reporting even if the data originally reported on time.
Utilize original state notification date

24. QAPP Addendum #3 Water Quality Parameters
Water Quality Parameter Requirements for Laboratories (Under the Lead and Copper Rule)
Addenda #3 is Currently on Revision 2
WQP Chain of Custody
Form 20679

25. QAPP Addendum #3 Water Quality Parameters
Guidance for the Analysis and Reporting of Water Quality Parameters (WQP) under the Lead and Copper Rule
Applies to systems and laboratories submitting data for Water Quality Parameter compliance under the LCR
Samples for PWS compliance
Includes regulatory program requirements

26. Water Quality Parameters QAPP Requirement
Samples must be analyzed by a laboratory that is accredited in the drinking water matrix using a method acceptable to EPA and/or approved by the Water Supply Division (WSD)
Approved by WSD: temperature, pH, alkalinity, calcium, conductivity, ortho phosphate, silica
Accredited by TCEQ: chloride, hardness, iron, manganese, sodium, sulfate, TDS
QAPP-Addendum 3-Table 2
Allowable Methods for WQP Sample Analysis

27. Water Quality Parameters Scenario
Customer drops off WQP compliance samples
Laboratory analyzes
Not accredited/approved for all analytes
Not accredited in drinking water matrix
PWS receives violation letter
Submits analytical report to TCEQ
TCEQ Reviews report
Samples cannot be used for compliance

28. Water Quality Parameters PWS Compliance Impact
Samples analyzed using an unapproved method or when lacking accreditation for the analyte in drinking water cannot be accepted for compliance
Monitoring and Reporting (M/R) Violation
Violations require Public Notice
PWS will sample in the next monitoring period

29. Water Quality Parameters What Can The Lab Do?
Ensure methods listed in QAPP are used
QAPP-Addendum 3-Table 2
Review TNI Accreditation status regularly
Plan for timeframes to obtain accreditation for new analytes
Review TCEQ Lab Approval status regularly
For most labs, TCEQ Approval expires 06/30/2019
Plan to update status prior to 07/01/2019

30. Water Quality Parameters QAPP Requirement
PWS must use the Water Quality Parameter Monitoring Form (WQPMF)
Form #20679
Modified forms must be approved by TCEQ
WQPMF must be completed properly
Samples must be labeled properly

31. Water Quality Parameter QAPP Requirement
Samples must be collected in lab grade plastic bottles
Volume should be sufficient to conduct all required analyses
Acid preservation should be done in the lab
No later than 14 days after collection
Some analytes require thermal preservation
Alkalinity, conductivity, sulfate, TDS, ortho phosphate

32. Water Quality Parameters QAPP Requirement
Condition at receipt must be documented
Preservation, ice, temperature
QAPP-Addendum 3-Table 1
Sample Containers and Preservation
QAPP requirements related to sample receipt activities at the lab.

33. Water Quality Parameters Scenario
Customer drops off WQP compliance samples
Sample custodian unfamiliar with Form #20679
Does not note condition at receipt
Samples preserved and/or analyzed past hold times
PWS receives violation letter
Submits analytical report to TCEQ
TCEQ Reviews report
Samples cannot be used for compliance

34. Water Quality Parameters PWS Compliance Impact
Samples that do not have documentation of the condition at time of receipt, are collected in an inappropriate container, and/or samples that are not preserved or analyzed within hold-time cannot be accepted for compliance
Monitoring and Reporting (M/R) Violation
Violations require Public Notice
PWS will sample in the next monitoring period

35. Water Quality Parameters What Can The Lab Do?
At sample receipt:
Ensure staff are familiar with sample acceptance requirements
Containers, hold-times, documentation
Always check all collection dates
Always preserve at time of receipt

36. Water Quality Parameters Reporting Reminders
Subcontracting
There should be two WQPMF-Form 20679
Initial receiving laboratory reports field measurements
Results are reported by the laboratory that performed the analysis
DO NOT hold data until end of the monitoring period
Prevents TCEQ from informing PWS of data issues and their opportunity to recollect
Report regularly

37. Water Quality Parameters Reporting Reminders
Reporting Rejected Samples
Rejected samples are reported with no result, using a rejection code
QAPP-Addendum 3-Table 5
Sample Rejection Codes and Descriptions
Individual Analytes cannot be rejected
If subcontracted, rejecting lab should notify other lab as soon as possible

38. Water Quality Parameters Reporting Reminders
Report data to:
Do not send data to individuals in LCR Program
Check EDD for typos
Ensure PWS ID is correct
Report results in mg/L ,not µg/L

39. QAPP Questions? Gary Regner PWSS Program QA Manager

40. Public Water System Supervision Program Quality Assurance Project Plan Requirements for Laboratories and Impacts on Public Water Systems (Part 2)
Jessica Hoch
Drinking Water Assessment Team Lead
Lead and Copper Rule, Revised Total Coliform Rule, Groundwater Rule
2019 TCEQ Environmental Trade Fair

41. Presentation Goals QAPP Requirement Specific Scenarios to Consider
Impact on Public Water System (PWS)
Compliance
Notice of Violation
What can the lab do?
To assist laboratories in understanding how QAPP requirements can impact customer/PWS compliance with the Safe Drinking Water Act.

42. Protection of Public Health
Public Water System
Laboratory
Protection of Public Health
TCEQ

43. TNI Accreditation for Laboratories 290 TAC Rules for PWS
Protection of Public Health
QAPP

44. Quality Assurance Project Plan
Quality Assurance (QA) and Quality Control (QC) processes related to environmental data collection activities.
Includes 10 addenda addressing program-specific QA and QC
Revised every 3 years with annual updates
Last revision 11/4/2016
1st Annual update in 2017
EPA approval
12/20/2017
2nd Annual update in 2018
EPA approval
10/26/2018

45. For Discussion Today
Addendum 3—Guidance for the Analysis and Reporting of Water Quality Parameters under the Lead and Copper Rule
All three guidance documents primarily address laboratory requirements for sample receipt, analysis, and reporting. Requirements are program specific and reflect rules and regulations specific to the drinking water program. Laboratories need to be aware there situations in which drinking water rules and regulations applying to laboratories which are more stringent than the TNI Standards. I think most laboratories understand this, but there we received a few questions related to this issue. For example, the TNI specifies the sample label must have a unique identifier only. Appendix A, Figure A-1 of the Certification Manual for Laboratories analyzing Drinking Water has requirements for sample labels which include the sample location, date and time of sample collection, etc… This is more stringent than what the TNI Standard requires, which is why we included it.
Addendum 2—Guidance for the Analysis and Reporting of Lead and Copper under the Lead and Copper Rule
Addendum 4—Guidance for Analysis and Reporting under the Revised Total Coliform Rules

46. Quality Assurance Project Plan
Addendum 2 – Laboratory Guidance for the Analysis and Reporting of Tap Water Samples under the Lead and Copper Rule
Applies to labs analyzing PbCu tap samples
Addendum 3 – Laboratory Guidance for the Analysis and Reporting of Water Quality Parameters Under the Lead and Copper Rule
Applies to labs analyzing WQP samples
Addendum 4 – Laboratory Guidance for Analysis and Reporting Under the Revised Total Coliform Rule
Applies to labs analyzing microbial compliance samples

47. QAPP Addendum #4 Microbial Compliance
Microbial Compliance Requirements for Laboratories
(Under the Revised Total Coliform Rule)
Addenda #4 is Currently on Revision 2
Microbial Reporting Form (MRF) 10525

48. QAPP Addendum #4 Microbial Compliance
Guidance for Analysis and Reporting Under the Revised Total Coliform Rule (RTCR)
Applies to labs submitting data for compliance under RTCR
Samples from public water systems
Includes regulatory and program requirements

49. Microbial Compliance QAPP Requirement
Reporting of Positive Samples
Report on same day to TCEQ and PWS
PWS must collect repeats within 24 hours of notification
Submit Positive Result Report Form
or Fax to TCEQ
Samples were collected at different times over past 2-13 days

50. Microbial Compliance Scenario
Customer drops compliance samples late on a Friday
Laboratory accepts and analyzes
Results available on Saturday - E. coli positive
No manager available to approve
Lab analyst leaves result for Monday reporting
Without notifying the customer of the result
PWS eligible for EMCL violation?
Failure to collect repeat samples?
Samples were collected at different times over past 2-13 days

51. Microbial Compliance PWS Compliance Impact
Failure to timely report a positive microbial result to the PWS, leaves public health at risk
Especially true for E. coli that is detected in a distribution sample
Failure to collect repeats
Potential EMCL
Potential Level 2 Assessment

52. Microbial Compliance What Can The Lab Do?
Train laboratory staff on what to do after a positive result is determined
Weekdays
Weekends/Holidays
Ensure customer contact information is correct at sample receipt

53. Microbial Compliance QAPP Requirement
Samples that have been delivered to the laboratory and determined to be inadequate for analysis must be rejected
Receive
Reject
Replace
Report
QAPP-Addendum 4-Table 2
Rejection Codes

54. Microbial Compliance Scenario
Customer drops off inadequate compliance samples late in the month
Laboratory notices and tells customer the issue
Customer leaves, no record of rejected sample
Customer returns the next week with new sample
PWS receives violation letter
Submits analytical report to TCEQ
TCEQ reviews report
Sample cannot be used for monitoring period intended

55. Microbial Compliance PWS Compliance Impact
Samples analyzed in the next month, that are lacking a tie to the previous month, cannot be accepted for compliance
PWS must maintain accurate, defensible records
Monitoring and Reporting (M/R) Violation
Violations require Public Notice

56. Microbial Compliance What Can The Lab Do?
Reporting rejected and subsequent replacement samples can help prevent customers from receiving a violation
Reject samples that are inadequate for analysis at receipt
Report rejected and replacement samples
Replacement samples tie to the rejected sample
Receive – Reject – Replace – Report

57. Microbial Compliance What Can The Lab Do?
Train sample custodians in acceptance requirements
Inadequacy related to a documentation error
Catch errors at sample receipt
Address while customer still available
Following TCEQ guidelines, make all attempts to correct
Microbial samples are a capture of a moment in time that cannot be replicated
Make all attempts to save microbial compliance samples, if possible

58. Microbial Compliance QAPP Requirement QAPP Addendum #2 LCR Tap Samples
PWS must use the Microbial Reporting Form (MRF)
Form #10525
Modified forms must be approved by TCEQ
MRF must be completed properly
Samples must be labeled properly

59. Microbial Compliance Scenario
Customer asks for bacteriological testing
Doesn’t indicate for compliance with the RTCR
Received with private chain of custody (COC)
Missing required information
PWS receives M/R violation
Submits analytical report and sample records (if any) to TCEQ
TCEQ reviews report and records
Samples may be used for compliance

60. Microbial Compliance PWS Compliance Impact
Samples collected without adequate documentation cannot be accepted for compliance
PWS must maintain accurate, defensible records
TCEQ can review and make corrections to documentation
Potentially reject violation

61. Microbial Compliance What Can The Lab Do?
At sample receipt:
Ask if samples are to be used for compliance with the Revised Total Coliform Rule and/or TCEQ
Ensure proper documentation if customer states samples are for compliance
Ensure laboratory uses MRF or receives approval for modifications made to form

62. Microbial Compliance Reporting Reminders
Frequent electronic data submittal
DO NOT hold data until end of the monitoring period
Prevents TCEQ from informing PWS of data issues
Report regularly
Report sample ID exactly as noted on MRF
Do not add abbreviations or hyphens if they are not included on the paper record
Creates duplicate results in database

63. Microbial Compliance Sampling Reminders
Licensing Requirements
Samples for community and non-transient non-community water systems MUST be collected by an individual with a valid water operators license
Not required for transient systems
Field Measurements
All samples must have a field measured chlorine residual
DO NOT analyze, reject. Residual must not be filled in at time of receipt at the lab

64. Microbial Compliance Sampling Reminders
Sample Labels
Adhesive or written directly on bottle
Must include:
PWS ID number
Date & Time of sample collection
Sampler’s initials
Address/location of collection
Sampling SOP
TCEQ has developed a sampling guidance SOP
to ask for a copy

65. Compliance Sample Receipt Reminders
Labs may not make corrections to PWS portion of any reporting form (LCRMF, WQPMF, MRF)
Corrections must be made by the sampler before relinquishment to lab
Only TCEQ can authorize changes after analysis and reporting
Evaluated on a case-by-case basis
See QAPP for specific conditions

66. QAPP Questions? Gary Regner PWSS Program QA Manager