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HomeMy WebLinkAbout#178_2011 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 178 Laboratory Name: City of Rockingham WWTP Inspection Type: Municipal Maintenance Inspector Name(s): Tonja Springer Inspection Date: May 25, 2011 Date Report Completed: June 6, 2011 Date Forwarded to Reviewer: June 30, 2011 Reviewed by: Todd Crawford Date Review Completed: July 1, 2011 Cover Letter to use: ___ Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: July 1, 2011 Date Forwarded to Alberta: July 13, 2011 Date Mailed: July 13, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: City of Rockingham WWTP NPDES Permit #: NC0020427 ADDRESS: 514 Rockingham Road Rockingham, NC 28379 CERTIFICATE #: 178 DATE OF INSPECTION: May 25, 2011 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Tonja Springer and Chet Whiting LOCAL PERSON(S) CONTACTED: Larry Cobler I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The laboratory was well equipped, neatly organized and clean. Findings B, D, G, H, K, and L are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Temperature corrections were not posted on the DO meter, pH meters and the refrigerator. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: Document any correction that applies (even if zero) on both the thermometer and meter and on a separate sheet to be filed. Temperature corrections were posted at time of inspection. This adequately addresses this finding. This requirement is a new policy that has been implemented by our program since the last inspection. No further response is necessary for this finding. A. Finding: The use of Wite-Out®, as well as, several instances of writing over a number as a means of error correction, and corrections without dates and initials were observed. Requirement: All documentation errors must be corrected by drawing a single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write the correction adjacent to the error. T he correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Page 2 #178 City of Rockingham WWTP B. Finding: Proficiency Testing (PT) samples were not documented in the same manner as routine environmental samples. Requirement: The analysis of PT samples is designed to evaluate the entire process used to routinely report environmental analytical results; therefore, PT samples must be analyzed and the process documented in the same manner as environmental samples. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. General Quality Control C. Finding: No acceptance criteria have been established to evaluate the precision of sample duplicate analyses. Requirement: Any time quality control results indicate an analytical problem, the problem must be resolved and any samples involved must be rerun if the holding time has not expired. Ref: 15A NCAC 2H .0805 (a) (7) (F). Comment: For low level results, using a default Relative Percent Difference (RPD) may not provide an adequate evaluation of precision of samples. An example is Total Suspended Solids (TSS) results below 10 mg/L. In this example, TSS results yielding 4 mg/L for the parent sample and 2 mg/L for the duplicate is a reasonable difference in raw sample concentrations; however, the RPD presents a different picture. The RPD is calculated as follows: RPD = 2[A-B] x 100 = 2[4 mg/L - 2 mg/L] x 100 = 66% (RPD) A+B 4 mg/L + 2 mg/L The RPD looks excessive, yet an examination of the raw results indicates good precision. In such cases, we recommend a two-tiered evaluation system (i.e., using one acceptance criterion for low concentration samples and another acceptance criterion for high concentration samples). For example, the TSS duplicate acceptance criterion for sample concentrations below 10 mg/L might be set at a maximum 3 mg/L absolute difference and the TSS duplicate acceptance criterion for sample concentrations equal to 10 mg/L or higher might be set at a maximum default RPD of 20%. Please contact this office if you need additional guidance in establishing duplicate acceptance criteria. D. Finding: The reagent log does not include all the pertinent information required and there is no system for tracing standards and reagents used in a particular analysis. Requirement: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date received, Date Opened (in use), Vendor, Lot Number, and Expiration Date (where specified). A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information to analytical batches in which the solutions are used. Documentation of solution preparation must include the analyst’s initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Comment: Guidance materials for documenting traceability of purchased and prepared standards and reagents were provided to the laboratory at the time of the inspection. Page 3 #178 City of Rockingham WWTP E. Finding: There was no documentation for the National Institute of Standards and Technology (NIST) traceable digital thermometer to show when the calibration was due. Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a) (7) (A). Requirement: All thermometers must meet National Institute of Standards and Technology (NIST) specifications for accuracy or checked, at a minimum annually, against a NIST traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (O). Requirement: Obtain a NIST traceable thermometer with a current calibration certificate and repeat the temperature checks on all thermometers as well as the sensor checks on the DO and pH meters. Send copies of the calibration documentation for the NIST thermometer, the laboratory thermometers and the DO and pH meter sensors with your response to this report. Comment: You may have trouble getting your NIST thermometer re-certified. As part of an initiative to reduce the use of mercury in products, EPA is working with stakeholder s to reduce the use of mercury-containing non-fever thermometers in industrial and commercial settings. The National Institute of Standards and Technology (NIST), which is working with EPA on this effort, announced on February 2, 2011 that it will no longer calibrate mercury-in-glass thermometers for traceability purposes beginning on March 1, 2011. Other vendors may follow this lead. Additional information on the phase-out of mercury-filled thermometers and selecting alternatives to mercury-filled thermometers can be found on the following EPA website: http://www.epa.gov/hg/thermometer.htm. F. Finding: Standard Operating Procedures (SOPs) have not been updated with current quality control requirements for all of the parameters included on the laboratory’s certificate attachment. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laborat ory. Ref: 15A NCAC 2H .0805 (a) (7). Submit the updated SOPs for review by November 25, 2011. A written response is required. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G Recommendation: It is recommended that the laboratory consider switching to another source of standard material for Total Residual Chlorine (TRC) internal curve verification and mid-range standard. Range standards may be less accurate especially where large dilution factors are involved. It is recommended that potassium permanganate standards be used. They are less prone to degradation and more economical. Recommendation: It is recommended that the laboratory verify the internal calibration using the concentrations: 25, 35, 50, 200, 400 µg/L. This will verify the analytical range used to measure Proficiency Testing (PT) samples as well as environmental samples. The current curve range is 28, 56, 112, 224, 448 µg/L. Comment: A second source standard is no longer required if a factory set calibration curve is being used. Page 4 #178 City of Rockingham WWTP G. Finding: A calibration blank and/or calibration verification standard (mid-range) are not analyzed at the end of the sample group. Requirement: The calibration blank and calibration verification standard (mid-range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each sample group to check for carry over and calibration drift. If either fall outside established quality control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since the last acceptable calibration verification, repeating the initial calibration, etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2). H. Finding: The auto-pipette has not been calibrated. Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable auto- pipettors, bottle-top dispensers, etc.) must be calibrated at least twice per year, approximately six months apart and documented. Each liquid-dispensing device must meet the manufacturer’s statement of accuracy. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Comment: A minimum of 5 aliquots dispensed from the pipette should be weighed and averaged in order to determine the volume dispensed. Guidance information was provided at the time of the inspection. Comment: The auto-pipette is only used for the liquid chlorine standards. If the laboratory switches to the potassium permanganate solution and uses the Class A glass pipettes to make the annual verification standards and the daily check standard, then this pipette will no longer be needed. I. Finding: The preparation of the calibration standards are only documented on the standard bottle. Requirement: All analytical records must be available for a period of five years. Ref: 15A NCAC 2H .0805 (a) (7) (g). pH – Standard Methods, 18th Edition, 4500 H+ B Comment: Verification of the pH meter Automatic Temperature Compensator (ATC) is no longer required. pH – Standard Methods, 18th Edition, 4500 H+ B DO – Standard Methods, 18th Edition, 4500 O G J. Finding: Calibration time is not documented. This is considered pertinent information. Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a) (7) (A). DO – Standard Methods, 18th Edition, 4500 O G Comment: Units were not documented on the benchsheet. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (H) states: All laboratories must use printed laboratory bench worksheets Page 5 #178 City of Rockingham WWTP that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. Units were documented on the benchsheet at the time of the inspection. No further response is necessary for this finding. Residue, Suspended – Standard Methods, 18th Edition, 2540 D K. Finding: The laboratory is using an incorrect reporting limit. Requirement: The minimum weight gain allowed by any approved method is 2.5 mg. Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete filtration takes more than 10 minutes increase filter diameter or decrease sample volume. In instances where the weight gain is less than the required 2.5 mg, the value must be reported as less than the appropriate value based upon the volume used. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 21st Editions, 2540 D. (3) (b). Comment: For example, if 500 mL of sample is analyzed and < 2.5 mg of dried residue is obtained, the value reported would be < 5 mg/L. Recommendation: It is recommended that the laboratory increase the sample volume to one that can still be filtered in less than 10 minutes and yield the required 2.5 mg of dried residue. L. Finding: Filters are not weighed to constant weight prior to sample analysis, nor is a dry filter blank is not analyzed with each set of samples. Requirement: If pre-prepared filters are not used, the method requires that filters must be weighed to a constant weight after washing. Repeat cycle of drying, cooling, desiccating, and weighing until a constant weight is obtained or until weight change is less than 4% of the previous weighing or 0.5 mg, whichever is less. In lieu of this process, it is acceptable to analyze a single daily dry filter blank to fulfill the method requirement of drying all filters to a constant weight prior to analysis. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods 20th Edition 2540 D. (3) (a). Coliform, Fecal – Standard Methods, 18th Edition, 9222 D (MF) Comment: Sample analysis should begin immediately, preferably within 2 hours of collection. The maximum transport time to the laboratory is 6 hours, and samples should be processed within 2 hours of receipt at the laboratory. Ref: Code of Federal Reg ulations, Title 40, Part 136.3; Federal Register Vol. 72, No 47, March 26, 2007; Table II, Footnote 22. M. Finding: The pH of the prepared fecal coliform media is not documented to show that it is within method specifications (i.e., pH 7.4). Requirement: Final pH should be 7.4. Ref: Standard Methods, 18th Edition, 9222 D (1) (a). Requirement: Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H .0805 (a) (7). Page 6 #178 City of Rockingham WWTP Recommendation: It is recommended that a small amount of the media be poured out to check the pH. N. Finding: No comparison test is conducted before a new lot of media and filters are put into use. Requirement: When a new lot of culture medium, membrane filters or a new source of reagent-grade water is to be used, make comparison tests of the current lot in use (reference lot) against the new lot (test lot). As a minimum, make single analyses on five positive samples. Ref: Standard Methods, 18th Edition, 9020 B. (3) (d). Recommendation: It is recommended that the laboratory obtain some fecal plates from another municipality which has been verified as suitable and perform a comparison against their own media currently in use. Recommendation: It is recommended that the comparison tests be performed with a culture positive sample that will yield the desired 20 to 60 colonies. The culture positive sample should be analyzed the day prior to the comparison testing to determine the appropriate dilution to yield 20 – 60 colonies. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for City of Rockingham WWTP (NPDES permit #NC0020427) for January, February and March 2011. No transcription errors were detected. 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 lab 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. Report prepared by: Tonja Springer Date: June 6, 2011 Report reviewed by: Todd Crawford Date: July 1, 2011