Anonymous public comment
AnonymousOtherIndividual
Summary: The commenter suggests that the current proficiency testing requirements are not very useful for permittees. They argue that a more effective requirement would be for laboratories to provide permittees with their scope of accreditation and specific method detection and reporting limits.
It is my understanding that the DMR-QA is used to monitor that laboratories are capable in the tests they perform for permittees. For NPDES permits, the permittee should be sending the tests to accredited labs. Proficiency tests are part of the accreditation requirements. Obtaining results of these tests is not very useful for the permittee. A more useful requirement would be for labs to supply the permittee with their scope of accreditation and the method detection limits and reporting limits for each accredited parameter. This would ensure the lab is not only capable, but can meet the needs of the permit limits, particularly since these limits can change in accordance with 40 CFR 136 appendix B, and labs don't always notify the permittees. Thank you.