Title: How to Avoid Noncompliance
1 How to Avoid Noncompliance
- KWWOA
- Louisville
- March 26, 2007
- Presented by Frank Hall,
- Supervisor of Compliance
2Outline
- Compliance Program Updates
- Common Reporting Errors
- Common Lab Errors
- Monitoring Schedules
- Electronic Submittals
- MORs
- Inventory Reporting
3ProgramUpdates
4Compliance 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
5CommonReportingErrors
6Common 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
7Common Reporting Errors
KY followed by 7 digits
8Common Reporting Errors
A, B, C depending on which plant the sample is
from.
9Common Reporting Errors
Always 3 digits.
10Common 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.
11Common 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?
12Common Reporting Errors
RT or SP are the only acceptable codes in this
field.
13Common Reporting Errors
This is a 5 digit number and must be filled in
even if the water system ran the analysis.
14Common 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.
15Common Lab Errors
16Common 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.
17Common 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
18Common 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.
19Common Lab Errors
The analysis code is always a 3 digit number
20Common 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
21Tips for Report Review
22Tips 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.
23Tips 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.
24Monitoring Schedules
25Monitoring 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.
26Monitoring 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.
27Electronic Submittals
28Electronic 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
29MORs
30MOR
- 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.
31Inventory Reporting
32Inventory 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
33Questions?? Comments??
- Franklin C. Hall, Jr.
- Compliance Supervisor
- Drinking Water Branch
- KY Division of Water
- (502)564-3410 extension 542
- frank.hall_at_ky.gov