Agency Information Collection Activities; Proposals, Submissions, and Approvals: Performance Evaluation Studies on Wastewater Laboratories (Renewal)

The commenter, a licensed wastewater operator, expresses support for the permit system but suggests that the agency should create a less arduous process for treatment facilities to dispute or eliminate insignificant pollutants from their permits. They argue that this would reduce costs and stress for municipalities and laboratories without compromising environmental safety.

The commenter supports granting Florida a DMRQA exemption because the state's existing NELAP accreditation program already requires proficiency testing and provides sufficient regulatory oversight. They argue that the current DMRQA reporting process creates a duplicative administrative burden without providing additional quality assurance benefits.

The commenter opposes the renewal of the Performance Evaluation Studies on Wastewater Laboratories, arguing that the program is a burdensome and costly waste of resources for laboratories. They contend that existing accreditation requirements already ensure competency and that the specific tests required by the study are often niche or irrelevant to their primary operations.

The commenter opposes the proposed information collection, arguing that the DMR-QA program creates an undue burden on permit holders. They suggest that the agency should rely on existing TNI laboratory certifications from accrediting bodies instead of collecting additional DMR-QA information.

The commenter opposes the proposed DMRQA requirement, arguing that it is not beneficial in its current form. They suggest that requirements should be tailored to the specific laboratory's permit, scope of knowledge, and technician abilities rather than using anonymous ranges.

A commercial laboratory representative argues that wastewater laboratories should have more flexibility to choose and schedule performance testing (PT) studies to support their DMRQA reporting. They suggest this change would align WET laboratory requirements with analytical parameter requirements and help reduce laboratory certification costs.

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.

The commenter argues that the current DMR-QA program places a disproportionate financial and operational burden on small publicly owned treatment works (POTWs) without providing direct benefits. They recommend a more flexible, risk-based approach that includes tiered requirements, reduced participation frequency, and financial support for smaller facilities.

The commenter, a former lab personnel member and current superintendent, argues that the DMRQA is a vital tool for ensuring laboratory operational competency and accuracy. They contend that the requirement is necessary for establishing a minimum standard of data quality and that the costs associated with it are minimal compared to its regulatory benefits.