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HomeMy WebLinkAbout#5550_2017_0712_TLH_FINALTo be attached to all inspection reports in-house only. Laboratory Cert. #: 5550 Laboratory Name: Currituck Mainland Water Plant Inspection Type: Field Municipal Maintenance Inspector Name(s): Tom Halvosa, Todd Crawford and Gary Francies Inspection Date: July 12, 2017 Date Forwarded for Initial Review: July 24, 2017 Initial Review by: Tonja Springer Date Initial Review Completed: July 25, 2017 Cover Letter to use: ❑ Insp. Initial ❑Insp. No Finding ❑Corrected ® Insp. Reg ❑Insp. CP ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: July 26, 2017 Date Forwarded to Admin.: July 27, 2017 Date Mailed: August 2, 2017 Special Mailing Instructions: �f L wf t te, li f'soui`ce `> ENVIR<a INFINTAI 1'R)AI. I'r'e August 2, 2017 5550 Mr. Yama Jones Currituck Mainland Water Plant 444 Maple Road Maple, NC 27956 ROY COOPER Governor MICHEAL S. REGAN Secrelnl)' S. JAY ZIMMERMAN Director Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Jones: Enclosed is a report for the inspection performed on July 12, 2017 by Tom Halvosa. Where Finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this office with a written item for item description of how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. If the Finding(s) cited in the enclosed report are not corrected, enforcement actions may be recommended. For Certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 21-1.0800. A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by email or if you have questions or need additional information, please contact me at (919) 733-3908 ext. 251. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Dana Satterwhite, Tom Halvosa, Master File #5550 Water Sciences Section NC WastewaterlGroundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-733-39081 FAX: 919-733-6241 Internet: http://deg.nc.govlabout/division s/water-resources/water-resources-datalwater-sciences-home-page/laboratory-certification-branch wf t te, li f'soui`ce `> ENVIR<a INFINTAI 1'R)AI. I'r'e August 2, 2017 5550 Mr. Yama Jones Currituck Mainland Water Plant 444 Maple Road Maple, NC 27956 ROY COOPER Governor MICHEAL S. REGAN Secrelnl)' S. JAY ZIMMERMAN Director Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Jones: Enclosed is a report for the inspection performed on July 12, 2017 by Tom Halvosa. Where Finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this office with a written item for item description of how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. If the Finding(s) cited in the enclosed report are not corrected, enforcement actions may be recommended. For Certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 21-1.0800. A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you wish to obtain an electronic copy of this report by email or if you have questions or need additional information, please contact me at (919) 733-3908 ext. 251. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Dana Satterwhite, Tom Halvosa, Master File #5550 Water Sciences Section NC WastewaterlGroundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-733-39081 FAX: 919-733-6241 Internet: http://deg.nc.govlabout/division s/water-resources/water-resources-datalwater-sciences-home-page/laboratory-certification-branch • IMPTOTIV LABORATORY NAME: Currituck Mainland Water Plant ► 190 - V 11 I I IF51IIIIIIIIIIIIIIIIIIII11:: • 1 ADDRESS: 444 Maple Road Maple, NC 27956 CERTIFICATE #: 5550 DATE OF INSPECTION: July 12, 2017 TYPE OF INSPECTION: Field Municipal Maintenance AUDITOR(S): Tom Halvosa, Todd Crawford and Gary Francies LOCAL PERSON(S) CONTACTED: Yama Jones and Linda Skinner I. INTRODUCTION: This laboratory was inspected by a representative(s) of the North Carolina Wastewater/ Groundwater Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The facility is neat and well organized and has all the equipment necessary to perform the analyses. Benchsheets are well designed, easy to follow and concise. Records are well organized and easy to retrieve. Staff were forthcoming and seemed eager to adopt necessary changes. All required Proficiency Testing (PT) Samples for the 2017 PT Calendar Year have not yet been analyzed. The laboratory is reminded that results must be received by this office directly from the vendor by September 30, 2017. Contracted analyses are performed by Environmental Chemists, Inc. (Envirochem) (Certification # 94). Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the analysis of the facility's currently certified Field Parameters were provided at the time of the inspection. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Proficiency Testing A. Finding: The preparation of PT Samples is not documented. Page 2 #5550 Currituck Mainland Water Plant Requirement: PT Samples received as ampules are diluted according to the Accredited PT Sample Provider's instructions. It is important to remember to document the preparation of PT Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a routine Compliance Sample and is added to a routine sample batch for analysis. No documentation is needed for whole volume PT Samples which require no preparation (e.g., pH), but it is recommended that the instructions be maintained. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0. Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT Sample would satisfy the documentation requirement. Quality Control B. Finding: The auto-pipettor has not been calibrated annually as required. Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at least every twelve months and documented. Each liquid - dispensing device must meet the manufacturer's statement of accuracy. For variable volume devices used at more than one setting, check the accuracy at the maximum, middle and minimum values. Testing at more than three volumes is optional. When a device capable of variable settings is dedicated to dispense a single specific volume, calibration is required at that setting only. Ref: Quality Assurance Policies for Field Laboratories. Comment: The use of a Class A volumetric pipette instead of an automatic pipettor is acceptable for the sample preparation of the annual PT Sample for Total Residual Chlorine. Chlorine, Total Residual — Hach 10014 ULR (Aqueous) Comment: The laboratory was not verifying the Gel® Standard concentration initially and every 12 months. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily standard curve verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. When this is done, these standards may be used after the manufacturer's expiration date. Acceptable corrective action (i.e., Six months' worth of check standard analyses were reviewed and found to vary by ±1 pg/L. The data was averaged and a true value of 175 tag/L was assigned.) was performed by the laboratory and approved by the auditor during the inspection. No further response is necessary for this Finding. Comment: The true value of the check standard was not documented. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states: The following must be documented in indelible ink whenever sample analysis is performed: True value of the check standard. Acceptable corrective action (i.e. true value was added to benchsheet) was performed by the laboratory and approved by the auditor during the inspection. No further response is necessary for this Finding. C. Finding: Values less than the established reporting limit are being reported on the electronic Discharge Monitoring Report (eDMR). Page 3 #5550 Currituck Mainland Water Plant Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The laboratory last established a lower reporting limit of 20 tag/L by analyzing that concentration when verifying the latest calibration curve. The facility's permitted discharge limit is 13 tag/L, compliance cannot be demonstrated with a reporting limit of 20 pg/L. Recommendation: When the new calibration curve verification is performed, compliance samples with concentrations less than the lowest standard on the calibration curve must be reported as less than that value on the eDMR. For example, if the lowest standard concentration in the calibration curve verification is 10 tag/L, results would be reported as "<10 tag/L" in the daily cell of the eDMR. It is recommended that the laboratory verify the internal calibration using the concentrations: 10, 20, 50, 200 and 400 tag/L. This will verify the analytical range used to measure gel standards, compliance samples as well as PT samples. Recommendation: It is recommended that, when possible, the laboratory upgrade their Hach DR 2700 Spectrophotometer as Hach will no longer be supporting this instrument after next year. Conductivity — Standard Methods, 2510 B-1997 (Aqueous) D. Finding: The Automatic Temperature Compensator (ATC) has not been verified prior to initial use. Requirement: The ATC must be verified prior to initial use and annually (i.e., 12 months) thereafter at two temperatures by analyzing a standard or sample at 25°C (i.e., the temperature to which conductivity values are reported) and a temperature(s) that brackets the temperature ranges of the environmental samples routinely analyzed. This may require the analysis of a third temperature reading that is > 25°C. As the temperature increases or decreases, the value of the conductivity standard or sample must be within ±10% of the true value of the standard or ±10% of the value of the sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity). pH — Standard Methods, 4500 H+ B-2000 (Aqueous) E. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 PH unit. Ref: Standard Methods, 4500 H+ B-2000. (6). Page 4 #5550 Currituck Mainland Water Plant Chlorine, Total Residual — Hach 10014 ULR (Aqueous) Conductivity — Standard Methods, 2510 B-1997 (Aqueous) pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Dissolved Oxygen — ASTM D 888-09 C (LDO) (Aqueous) F. Finding: The laboratory benchsheet was lacking pertinent data: Instrument Identification. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity) IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Currituck Mainland Water Plant (NPDES permit # NC0088650) for January, March and April, 2017. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above -cited Findings and implementing the Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation and implementation dates for each corrective action. 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