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HomeMy WebLinkAbout#5417 - 11 - 2011 - FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #1 5417 Laboratory Name: Wilkes County Airport WWTP Inspection Type: Field Maintenance Inspector Name(s): Jason Smith Inspection Date: November 17 2011 Date Report Completed: December 15, 2011 Date Forwarded to Reviewer: December 15 2011 Reviewed by: Jeffrev R. Adams Date Review Completed: December 16 2011 Cover Letter to use: _ Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected Unit Supervisor: Gary Francies Date Received: 12/16/2011 Date Forwarded to Linda: 12/28/2011 Date Mailed:, 4s� NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director December 28, 2011 5417 Mr. David Prevette Wilkes County Airport WWTP 640 Wood Wallace Dr. North Wilkesboro, NC 28659 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Prevette: Enclosed is a report for the inspection performed on November 17, 2011 by Jason Smith. I apologize for the delay in getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30 days of receipt, please supply this office with a written item for item description of how these finding(s) were corrected. For certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A NCAC 2H .0800. 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 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section CC: Chet Whiting Gary Francies Master files DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-3908 \ FAX: 919.733-6241 Internet: www.dwglab.org An Equal Opportunity \ Affirmative Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org North Carolina LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: II Z•lme] Kom 1 • - • 9 Wilkes County Airport WWTP NC0075078 640 Wood Wallace Dr. North Wilkesboro, NC 28659 5417 November 17, 2011 Field Maintenance Jason Smith David Prevette and Jimmy Martin This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded results were 100% acceptable. Current technical assistance and quality assurance policy documents were provided to the laboratory at the time of the inspection. Documentation Comment: Error corrections were not made properly. The Quality Assurance Policies for Field Laboratories document states: 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. The 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., that all staff have been advised of this policy) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. Comment: The laboratory needed to increase the documentation of purchased materials and reagents. The Quality Assurance Policies for Field Laboratories document 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. 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 Page 2 #5417 Wilkes County Airport WWTP 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 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 requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a log recording all required information has been put into use) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. Comment: PT samples were not documented on laboratory benchsheets in the same manner as environmental samples. The Quality Assurance Policies for Field Laboratories document states: 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., all PT samples will be analyzed and documented in the same manner as environmental samples) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. Total Residual Chlorine — Standard Methods, 18t" Edition, 4500 Cl G pH — Standard Methods, 181" Edition, 4500 H+ Comment: Proper units of measure were not documented for pH and Total Residual Chlorine (TRC). The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., benchsheets which include units of measure) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. Total Residual Chlorine — Standard Methods, 18t" Edition, 4500 Cl G A. Finding: The check standard (gel standard) was not at the mid -range of the curve. Requirement: The check standard concentration must be at mid range and recovery must be within 10% of the known value. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please submit a copy of the new curve verification with the reply to this report. Comment: The laboratory verified the curve using the following standard concentrations: 10, 25, 50, 100, and 200 pg/L. The gel standard concentration is approximately 200,ug/L. Recommendation: It is recommended that the curve be verified using the following standard concentrations: 25, 40, 50, 200, and 400 /jg/L. B. Finding: The gel standard has not been assigned a true value. Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily calibration verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. Immediately following curve verification: 1. Zero the instrument with the gel blank. 2. Read and record gel standard values. 3. Assign the obtained values as the true value. Page 3 #5417 Wilkes County Airport WWTP The assigned values will be used for the next twelve months, or until a new curve verification is performed. The gel/liquid standard verification must be performed for each instrument on which they are to be used. If multiple instruments and/or standard sets are used, each must have assigned values specific for the instrument and standard set. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please submit a copy of the gel standard value assignment, which must be done following the curve verification, with the reply to this report. C. Finding: The time of analysis of the calibration check (gel standard) is not documented. Requirement: The time the calibration check was performed must be documented whenever sample analysis is performed. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Comment: The sample location was not documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., benchsheets which include sample location) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. pH — Standard Methods, 18th Edition, 4500 H+ B D. Finding: The temperature sensor of the pH meter has not been checked against a National Institute of Standards and Technology (NIST) certified or traceable thermometer. Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a NIST certified or NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature results. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST certified or NIST traceable thermometer and record the two temperatures. The thermometer/meter readings must be less than or equal to 10C from the NIST certified or NIST traceable thermometer reading. The documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was used in the comparison. Also document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. (NOTE: Other certified laboratories may provide assistance in meeting this requirement.) Ref: Technical Assistance for Field Analysis of pH. Comment: Data values were not reported to one decimal place. Standard Methods, 18th Edition, 4500 H+ B. (6) states: A variance of ± 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., all pH results will be rounded to 0.1) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. Temperature — Standard Methods, 18th Edition, 2550 B E. Finding: The temperature correction is not posted on the thermometer. In Page 4 #5417 Wilkes County Airport WWTP 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 Temperature. Comment: Temperature sample collection times were not documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., benchsheets which include time of collection) was received by electronic mail on November 22, 2011. No further response is necessary for this finding. Recommendation: Since there is no holding time times will be the same. The benchsheet may "collection/analysis time" if the laboratory chooses. per sample. PAPER TRAIL INVESTIGATION: for temperature, the sample collection and analysis be further edited to label the column header as This would allow for the documentation of one time The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for April, May, June, and July, 2011. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DR 4/1/11 Total Residual Chlorine Effluent 55,ug/L 45 pg/L 6/30/11 BOD Effluent 2.8 mg/L* 2.1 mg/L 6/30/11 TSS Effluent 10 mg/L* 15 mg/L *contract lab results In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be forwarded to the Regional Office. Comment: The laboratory indicated, by electronic mail on November 22, 2011, that amended DMRs would be submitted. Correcting the above -cited findings and implementing the recommendation 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: Jason Smith Date: December 15, 2011 Report reviewed by: Jeffrey R. Adams Date: December 16, 2011