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Home My WebLink About#5516 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5516 Laboratory Name: Orange-Alamance Water System, inc. Inspection Type: Field Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: February 22, 2011 Date Report Completed: March 07, 2011 Date Forwarded to Reviewer: March 07, 2011 Reviewed by: Todd Crawford Date Review Completed: March 15, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: March 15, 2011 Date Forwarded to Alberta: March 17, 2011 Date Mailed: March 17, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Orange-Alamance Water System, Inc. NPDES PERMIT #: NC0082759 ADDRESS: P.O. Box 187 Mebane, NC 27302 CERTIFICATE #: 5516 DATE OF INSPECTION: February 22, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Christopher Dale Hamby and Jamie Durham 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. Performance testing samples have been analyzed for all certified parameters for the 2010 proficiency testing calendar year and the graded results were 100% acceptable. We are concerned that there is no supporting documentation of instrument calibration, or documentation of sample and quality control analyses, for the field parameter compliance monitoring data reported on the monthly Discharge Monitoring Reports. Compliance monitoring data, reported without these supporting records, may be viewed as falsification. 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 B is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: The laboratory is not documenting field testing results and maintaining records for 5 years. No raw field data was available for review to support the Discharge Monitoring Report (DMR) data at the time of the inspection. Requirement: 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 Page 2 #5516 Orange – Alamance Water System, Inc. proper units of measure for all analyses. A record of instrument calibration where applicable, must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 02H .0805 (g) (1) and (g) (2). Comment: An example field parameter benchsheet was left with the laboratory at the time of the inspection. Traceability B. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as, documentation of standards and reagents prepared in the laboratory. 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: Quality Assurance Policies for Field Laboratories. Comment: The laboratory is recording the date that a chemical or reagent is received and opened on the containers, but is not maintaining a record once the container is discarded. pH – Standard Methods, 18th Edition, 4500 H+ B C. Finding: The laboratory is not checking the temperature sensor on the pH meter annually against a National Institute of Standards and Technology (NIST) or NIST traceable thermometer and posting corrections on meter. Requirement: The temperature sensor in the meter must be checked every 12 months against an NIST certified or NIST traceable thermometer and the process documented even if the instrument is not used for reporting temperature results. The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be r etained for 5 years). Ref: Technical Assistance for Field Analysis of pH. 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 D. Finding: The laboratory is not analyzing a check standard each day that samples are analyzed. Page 3 #5516 Orange – Alamance Water System, Inc. Requirement: When a factory-set calibration is used, the laboratory must check the calibration curve each analysis day. To do this, the laboratory must analyze a blank to zero the instrument and analyze a check standard each day that samples are analyzed. If compliance samples are analyzed throughout the day, a post calibration check (mid-range) must be analyzed mid-day and at the end of the run (i.e., roughly every 4 hours based on an eight hour day). 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. Recommendation: It is recommended that the laboratory use a 200 µg/L gel-type standard for the daily calibration verification check. The instructions for using a Gel Standard are included in the Technical Assistance for Field Analysis of Total Residual Chlorine document left for the analyst during the inspection. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Orange-Alamance Water System, Inc. (NPDES permit #NC0082759) for October, November, and December, 2010. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. As stated in Finding A, there were no supporting records for field parameters to review at the time of the inspection. In order to avoid questions of legality, it is recommended that you contact the appropriate regional office for guidance. A copy of this report will be forwarded to the Regional Office. V. CONCLUSIONS: 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: Jeffrey R. Adams Date: March 7, 2011 Report reviewed by: Todd Crawford Date: March 8, 2011