Many of you are used to the annual Mayflower testing procedures and may have wondered what happened to them. I have also had a few plants contact me questioning things they heard, such as, “you have to be laboratory certified to record pH readings or you have to be certified on specific laboratory equipment”. (Ya’ll know I don’t speak Labaneeze) So I reached out to Becky Ruark, Wastewater Facilities Inspector/Laboratory Proficiency Coordinator, Office of Water Quality, IDEM and here is what is happening:
The laboratories operated by Indiana facilities holding a NPDES permit are neither permitted nor certified; rather the discharger holds a permit, and operates or contracts a laboratory as part of its implementation of its permit. The IDEM Wastewater Compliance program requires permitted facilities to comply with the testing requirements/methods listed in 40 CFR 136. IDEM wastewater compliance inspectors check for compliance with these standards as part of each routine inspection; comparing the facility’s laboratory bench notes to their monthly discharge monitoring reports (DMR) to identify inconsistencies.
The laboratory of each permitted facility, whether a contractor, municipality, or simply an industrial discharger conducting routine pH analysis, is required to participate in the EPA’s DMRQA (DMR quality assurance) proficiency testing (PT) program. Majors dischargers must participate in DMRQA annually, and minor dischargers once every three years. The study involves ordering samples from a PT provider, analyzing those samples at the lab, and reporting the findings back to the PT provider, who sends graded results back to the lab and to IDEM wastewater compliance staff.
Each permit holder then reports to IDEM wastewater compliance summarizing the PT success or failure of each lab doing work for them. Laboratories failing one or more testing parameters must order a follow up PT and try again, hopefully doing some remedial work in between (like ordering new calibration buffers, checking age/condition of equipment, etc.). Laboratories that successfully complete corrective action are not required to take any further action. Facilities failing either the PT test(s) and/or subsequent corrective actions receive a reminder of the requirements to complete corrective action(s). Failing laboratories also must conduct re-training, which IDEM may make available through its operator assistance program.
Laboratory technical assistance with NPDES approved test methods or other laboratory issues is available. The DMRQA Laboratory Quality Assurance Program is administered by the Office of Water Quality Compliance Branch. All major dischargers must participate annually in a DMRQA study. Minor dischargers must participate on a three-year rotating schedule. Information is distributed by U.S. EPA each year in January or February. The rotating schedule for minors is:
- Industrial NPDES (including some water treatment plants (WTPs)) Permit holders
- Industrial Pretreatment Permit holders
- Municipal WWTPs
- Municipal WTPs with an NPDES discharge
- Semi-publics (such as schools, campgrounds, and mobile home parks)
- State and federal facilities (including rest areas and state parks)
For more information, contact IDEM’s Office of Water Quality, by phone, at (317) 232-8488, or via email at firstname.lastname@example.org.
Please find the Discharge Monitoring Report – Quality Assurance Study 37 paperwork below: