Dear Aqua Answers,
Please help! I have multiple compliance and reporting questions.
Thanks,
Cam Pliance
Dear Cam,
I have listed your questions and the answers below:
Question 1:
I sampled for my radionuclides early but the lab didn't submit the results in time. Will I still get a violation?
Any sample results submitted after the reporting deadline is a candidate violation. Radionuclides samples have long holds times and laboratories may not prioritize analysis. Suppliers need to coordinate with their laboratories to ensure that samples are analyzed and that results are reported to the department within the specified regulatory time frame.
Question 2:
I sampled early but the lab didn't submit the results in time because I did not fill out the chain of custody form correctly. Will I still get a violation?
Any sample results submitted after the reporting deadline is a candidate violation. Please note that many of these issues can be avoided if the supplier provides the correct PWSID, Facility ID, and Sample Point ID information on the chain of custody to the certified laboratory. Separate chain of custody forms should be provided for samples collected from different facility locations or sample points, (i.e entry point vs distribution system). Suppliers will need to coordinate with their laboratories if the chain of custody form does not clearly provide a location for the PWSID, Facility ID, and Sample Point ID. The department expects the supplier to identify the Facility ID and Sample Point ID (listed on the online monitoring schedule) when submitting sample results. Facility and Sample Point IDs are needed to identify the exact sample site locations and demonstrate compliance.
Question 3:
When am I supposed to report compliance samples and compliance actions to the department?
Section 11.35(2)(a)(ii) of Regulation 11 requires the submission of sample results no later than the first 10 calendar days following the end of the monitoring period specified by the Department which is generally no later than the 10th of the month following the end of the monitoring period. (Example: Monitoring period ending June 30 - results required to be received by July 10). Similarly, Regulation 11 also has submission deadlines for lead consumer notice, CCRs, public notices, seasonal start-ups documentation, and others. Please sample early. This will give you time to correct issues and will afford your laboratory enough time to analyze and report your results. We recommend that you discuss the reporting deadlines with your laboratory to ensure they understand your reporting requirements and expectations.
Question 4:
How do I correct a misreported sample result?
Sample reporting errors with facility ID, sample point ID, chlorine residual type, or incorrect measurements can be corrected by resubmitting a revised CSV, creating and submitting a Sample Correction Form, or submitting a copy of sample results with corrected information clearly indicated, via the Drinking Water Portal, fax, or mail or by having your lab resubmit corrected results. Any corrections must be received by the applicable reporting deadline. The collection date, lab name or ID, lab sample ID, analyte, facility ID, sample point ID, and residual must be submitted correctly or the requested correction will not be processed, resulting in a monitoring and reporting violation. Updated CSVs with the same Lab ID, Lab Sample ID, and Analyte are considered revisions, and the most recent submission is used.
Sincerely,
Aqua Answers
