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HomeMy WebLinkAbout#5256_01_2014_FINALFebruary 11, 2014 5256 Mr. Chuck Baxley Rockfish Creek Water Reclamation Facility PO Box 1089 Fayetteville, NC 28302 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Baxley: Enclosed is a report for the inspection performed on January 28, 2014 by Nick Jones. Since the finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the findings in such a timely manner. 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 electronic mail, or if you have questions or need additional information please contact me at (828) 296-4677. Sincerely, Gary Francies Technical Assistance/Compliance Specialist Laboratory Section Enclosure cc: master file Nick Jones DENR DWR 4'JQE Laboratory Section NC WastewaterlHroundwater Laboratory Certification Branch 1623 Mai! Service Center, Raleigh, North Caroli to 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phonei 919-733-3908 t, FAK 919-733-6241 Internet: www.dwg1ab.org Ar, Equal `ipporiur:,q Adinnauve kfior� Fmployer INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed: Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor/Chemist III: 5256 Rockfish Creek Water Reclamation Facility Field Maintenance Nick Jones January 28, 2014 January 30. 2014 January 30, 2014 Todd Crawford January 31, 2014 ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected Gary Francies Date Received: 2/6/2014 Date Forwarded to Linda: 2/10/2014 VL, Date Mailed: a I o I( On -Site Inspection Report LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: Rockfish Creek Water Reclamation Facility NC0050105 PO Box 1089 Fayetteville, NC 28302 5256 January 28, 2014 Field Maintenance Nick Jones Chuck Baxley, Scott McCoy This laboratory was inspected by a representative 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload and holding times. Contracted analyses are performed by Meritech, Inc. (Certification #165). Current quality assurance policies for Field Laboratories and approved procedures for the analysis of the facility's currently certified parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS Quality Control Comment: The laboratory needs to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. The NC WW/GW LC 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. 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 analvst'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 aH buffers and lots of pre -made standards are included in this requirement. Demonstration of acceptable corrective action (i.e., a standard/reagent preparation log) was received by email on 1/30/2014. Notification of acceptable corrective action (i.e., a statement that Page 2 #5256 Rockfish Creek Water Reclamation Facility a traceability log which documents all consumables has been implemented) was received by e-mail on 1/30/2014. No further response is necessary for this finding. PH — SM 4500 H+B-2000 Comment: The facility name and time of meter calibration are not documented on the benchsheet. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (2) states: A record of instrument calibration where applicable, must be filed in an orderly manner so as to be readily available for inspection upon request. The NC WW/GW LC Approved Procedure for Analysis of pH states: Document facility name and meter calibration time. Demonstration of acceptable corrective action (i.e., a benchsheet documenting the facility name and time of meter calibration) was received by email on 1/30/2014. No further response is necessary for this finding. Comment: The facility is reporting averaged pH results. The Directions for Completing Monthly Discharge Monitoring Reports Policy, (II)(8) states: Please note no average is to be calculated for pH. . Notification of acceptable corrective action (i.e., a statement that duplicates for pH will no longer be analyzed and subsequently not averaged) was submitted by email on 2/5/2014. Analyzing pH samples in duplicate is not a requirement. No further response is necessary for this finding. Total Residual Chlorine — SM 4500 CI G-2000 Comment: It would be more economical, in terms of cost and time, if the facility used the factory supplied stored calibration curve (stored under program #86), instead of each individual operator creating their own user defined curves. An annual curve verification is still required, but only the program #86 curve verified by one analyst would need to be performed. All of the operators could use the stored curve (program #86) after it has been verified. Prepare a curve (with your current standard) with the following concentrations: 20, —35, 50, 200 and 400 µg/L. Analyze them on program #86. Enter the true values and actual results into the Total Residual Chlorine (TRC) spreadsheet you received from the inspector via email on January 30, 2014 to determine if the curve and individual standard recoveries meet the acceptance criteria. It would also be more economical, in terms of cost and time, if the lab implemented the use of gel standards instead of liquid standards for the daily calibration verification, and switched from liquid reagents to DPD powder pillows. Comment: Neither the value nor acceptance criterion of the Reagent Blank are documented on the benchsheet. The NC WW/GW LC Approved Procedure for Analysis of Total Residual Chlorine states: Document the value obtained for the reagent blank, when prepared standards are used (verification of <% the concentration of the lowest calibration standard). Demonstration of acceptable corrective action (i.e., a benchsheet documenting the value obtained for the reagent blank) was received by email on 1/30/2014. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: A paper trail was not performed. V. CONCLUSIONS: All findings noted during the inspection were adequately addressed prior to the completion of this report. The inspector would like to thank the staff for its assistance during the inspection and data review process. No response is required. Page 3 #5256 Rockfish Creek Water Reclamation Facility Report prepared by: Nick Jones Date: January 30, 2014 Report reviewed by: Todd Crawford Date: January 31, 2014