How to Avoid Noncompliance

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How to Avoid Noncompliance

• KWWOA
• Louisville
• March 26, 2007
• Presented by Frank Hall,
• Supervisor of Compliance

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Outline

• Compliance Program Updates
• Common Reporting Errors
• Common Lab Errors
• Monitoring Schedules
• Electronic Submittals
• MORs
• Inventory Reporting

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ProgramUpdates
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Compliance Update

• Rule Name Ext.
• MOR, SWTR, Amber Vaughn 417
• Turbidities
• Micro Lab Certs,TCR Ellie Petzinger 505
• PN/CCR Natalie Perry 504
• Pb/Cu, Inventory, Todd Ritter 586
• Chemicals/Rads Brian Chitti 555
• DBPs Kellee Husband 422
• Electronic Submittals Jerry Pike 516
• SNCs Sara Goes 658
• Supervisor Frank Hall 542

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CommonReportingErrors
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Common Reporting Errors

• Missing/Incorrect PWSID
• Missing/Incorrect Plant ID
• Missing/Incorrect Location Code
• Missing/Incorrect Sample Type
• Missing/incorrect Lab Id.
• Duplicate Laboratory Sample Numbers
• Missing Laboratory Sample Numbers
• Missing/incorrect Method codes

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Common Reporting Errors
KY followed by 7 digits
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Common Reporting Errors
A, B, C depending on which plant the sample is
from.
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Common Reporting Errors
Always 3 digits.
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Common Reporting Errors
This is usually TPA, TPB, TPC for all entry point
samples.
A water system should maintain a current sample
site plan at all times.
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Common Reporting Errors

• Location Codes
• How often have you updated your sampling plans?
• When is the last time you reviewed your sample
  site plans?
• Does the DWB have a current site map?
• Does your lab have your current sample plans and
  site codes?

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Common Reporting Errors
RT or SP are the only acceptable codes in this
field.
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Common Reporting Errors
This is a 5 digit number and must be filled in
even if the water system ran the analysis.
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Common Reporting Errors
This MUST be a unique number. If the number is
repeated on any other analysis the second set of
results will be rejected as invalid.
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Common Lab Errors
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Common Lab Errors

• Missed hold times.
• http//www.water.ky.gov/NR/rdonlyres/C5A481F5-A221
  -4CB5-A8D5-3188513482B9/0/REPORTING_LIMITS.xls
• Know the hold times of each test.
• Review your report.
• Switched sample bottles.
• Review your report and be familiar with your
  normal results.

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Common Lab Errors

• Duplicate lab numbers.
• Invalid Analysis Codes
• http//www.water.ky.gov/NR/rdonlyres/17BDACB3-B5E1
  -405F-9FE6-268018726AFA/0/KY_METHOD_CODES.xls

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Common Lab Errors
The Lab MUST be unique to each sample. This
means you cant report IOC, VOC, SOC, and
Secondaries all collected the same day all with
the same lab number.
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Common Lab Errors
The analysis code is always a 3 digit number
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Common Lab Errors

• Failed QC.
• QC outside acceptance limits.
• Detects in analysis blanks.
• When in doubt about a lab comment on failed QC,
  call the DWB to see if the results are valid.
• Lab reporting limit not at or below federal
  detection limit.
• This could result in a VOC/SOC detect even if the
  lab list the results as

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Tips for Report Review
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Tips for Report Review

• Be familiar with every report you lab sends.
• Compare those with the DWBs report forms.
• Make a cheat sheet for review.
• Cheat sheet should include MCLs, your labs
  correct analysis method codes, required Minimum
  Reporting Limits, and analysis hold times.
• Use these sheets to compare with your data each
  time a copy is sent to you from your lab.

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Tips for Report Review

• What happens when you find an error?
• Contact the DWB immediately.
• All errors found by Water System before
  compliance is ran may be corrected.
• Notify your lab that an error was found.
• Be certain to send the DWB a revised report ASAP.

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Monitoring Schedules
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Monitoring Schedules

• How many of you depend completely on your lab to
  schedule all your monitoring?
• How many of you know when your monitoring is
  scheduled for?
• How many you follow up with your lab to be sure
  the monitoring was completed?
• Labs do not receive Monitoring and Reporting
  (M/R) violations. Water Systems do!
• EPA considers a monitoring violation and a
  reporting violation the same thing.
• It is the Water Systems responsibility to make
  certain all monitoring is performed on time.
• It is the Water Systems responsibility to make
  certain all the monitoring results are submitted
  to the state on time.

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Monitoring Schedules

• It is the Water Systems responsibility to make
  certain all the monitoring result forms are
  submitted correctly to the state.
• Results are due to the state BY the 10th of the
  following month, not mailed by the 10th of the
  following month.

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Electronic Submittals
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Electronic Submittals

• 17 certified bacteriological labs submitting
• Two certified chemical labs submitting
• MOR
• Currently have 7 pilot systems
• Need Contracts for submitting
• New ePortal being tested

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MORs
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MOR

• Two new pages added at the back the MOR call the
  Summary Sheet and Plant Summary Sheet
• Information on these Summary Sheets are data that
  is keyed or downloaded into database
• Summaries come from data reported throughout the
  MOR.
• Revised version on DW website.

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Inventory Reporting
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Inventory Reporting

• Form for public water systems to report inventory
  information to DOW due December!
• Information includes
• Population changes
• Meter connections
• Contact information
• Most of information required by US EPA or state
  regulation.
• Submit on annual bases at minimum

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Questions?? Comments??

• Franklin C. Hall, Jr.
• Compliance Supervisor
• Drinking Water Branch
• KY Division of Water
• [phone] extension 542
• frank.hall_at_ky.gov