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Home My WebLink About#5292_2011 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5292 Laboratory Name: Anson County WTP Inspection Type: Field Maintenance Inspector Name(s): Tonja Springer Inspection Date: March 30, 2011 Date Report Completed: April 8, 2011 Date Forwarded to Reviewer: April 8, 2011 Reviewed by: Jason Smith Date Review Completed: April 12, 2011 Cover Letter to use: Insp. Initial x Insp. Reg. Insp. No Finding Insp. CP ___Corrected Unit Supervisor: Dana Satterwhite Date Received: April 15, 2011 Date Forwarded to Alberta: April 28, 2011 Date Mailed: April 29, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Anson County WTP NPDES PERMIT #: NC0074390 ADDRESS: 567 Filtration Plant Road Lilesville, NC 28091 CERTIFICATE #: 5292 DATE OF INSPECTION: March 30, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: John Turner 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 clean and well organized. The facility has all the equipment necessary to perform the analyses. Proficiency testing samples have been analyzed for all certified parameters for the 2010 proficiency testing calendar year and the graded results were 100% acceptable. The laboratory was given a packet containing technical assistance documents describing individual parameter requirements, North Carolina Wastewater/Groundwater Laboratory Certification quality control requirements and policy changes during the inspection. Finding A is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Comment: The laboratory is no longer required to monitor for Settleable Residue and would like to voluntarily discontinue certification for this parameter. The laboratory will need to submit an amendment form or other written request in order to drop this parameter from the certificate attachment. Documentation Comment: The laboratory needs to increase the documentation of purchased materials and reagents. The Quality Assurance Policies for Field Laboratories states: 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. This information must be retained for chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre-made standards are included in this requirement. This is a Page 2 #5292 Anson County WTP new policy that has been implemented by our program since the last inspection. An example benchsheet with all the required documentation was sent to Anson County WTP on April 4, 2011. Anson County WTP indicated in an email on April 5, 2011 that they will implement this benchsheet. This adequately addresses this finding. No further response is necessary for this finding. Comment: The benchsheet used for Total Residual Chlorine did not contain all of the necessary documentation. The analysis time of the daily check standard was not being documented. The Technical Assistance for Field Analysis of Total Residual Chlorine document states: Instruments are to be calibrated or a calibration check must be performed prior to analysis of samples each day compliance monitoring is performed. Calibration checks must be for the curve and/or program used for sample analysis. The time the calibration check was performed must be documented. An example benchsheet with all the required documentation was sent to Anson County WTP on April 4, 2011. Anson County WTP indicated in an email on April 5, 2011 that they will implement this benchsheet. This adequately addresses this finding. No further response is necessary for this finding. A. Finding: Proficiency Testing (PT) samples are not documented in the same manner as 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: Quality Assurance Policies for Field Laboratories. pH – Standard Methods, 18th Edition, 4500 H+ B B. Finding: The laboratory is not posting NIST temperature corrections on the pH meter. Requirement: The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of pH. C. Finding: The NIST traceable thermometer used in verifying the pH instrument’s temperature sensor had expired. The thermometer was last certified on 3/22/2006 and did not list a recalibration date. Requirement: NIST traceable thermometers used for temperature measurement must be recalibrated in accordance with manufacturer’s recalibration date. If no date is given, the NIST traceable thermometer must be recalibrated annually. Ref: North Carolina Wastewater/ Groundwater Laboratory Certification Policy. Please submit a copy of the certificate of the new NIST traceable or certified thermometer. Requirement: All temperature sensing devices on meters must be calibrated against a NIST certified or NIST traceable thermometer annually (every 12 months) and proper corrections made and documented. The meter reading must be less than 1ºC from the NIST certified reading to be acceptable. Document the serial number and manufacturer of the NIST thermometer that was used in the comparison. Document any correction that applies (even if zero) on both the meter and on a separate sheet to be filed. Ref: Technical Assistance for Field Analysis of pH. Please submit a copy of the temperature sensor verification with the reply to this report. Comment: As preventative maintenance, thermometers should be stored in such a way as to minimize risk of breakage or damage. Liquid filled thermometers should be stored vertically or Page 3 #5292 Anson County WTP at an angle (i.e., bulb down) in a thermometer rack immediately before and after calibration. They should be stored in a cool place out of direct sunlight. 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 stakeholders 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. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G Comment: The laboratory was using expired color indicators and buffer solutions. The Quality Assurance Policies for Field Laboratories states: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specif ic day of the month), the last day of the month will be considered the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes may indicate potential contamination and the item should be discarded, even if the expiration date is not exceeded. If no expiration date is given, the laboratory must have a policy for assigning an expiration date. If no date received or expiration date can be determined, the item should be discarded. The laboratory has switched to DPD powder pillows with an expiration date of 7/2015 which adequately addresses this finding. No further response is necessary for this finding. D. Finding: The HACH DR2500 Chlorine meter and gel standard were verified by a contract laboratory on program 80 instead of program 86. Requirement: Each facility must have glassware, chemicals, supplies, equipment, and a source of distilled or deionized water that will meet the minimum criteria of the approved methodologies. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Calibration checks must be for the curve and/or program used for sample analysis. 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. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please submit a copy of the curve verification with the reply to this report. Recommendation: The laboratory has a permit limit of 17 µg/L. It is recommended that the laboratory instruct the contract laboratory to verify the internal calibration using the concentrations: 15, 30, 50, 200 and 400 µg/L. This will verify the analytical range used to measure PT samples as well as environmental samples. Recommendation: The contract laboratory documented the absorbance of the standards when verifying the manufacturer’s internal curve. It is recommended that the laboratory instruct the contract laboratory to document the standard values obtained in µg/Lin order to better evaluate the curve. Page 4 #5292 Anson County WTP 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 NPDES #NC0074390 for August and November, 2010 and January, 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: April 8, 2011 Report reviewed by: Jason Smith Date: April 12, 2011