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HomeMy WebLinkAboutNC0081825_Lab Certification Inspection_20081031Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources --1 Coleen H. Sullins, Director Division of Water Quality October 31, 2008 5242 Mr. Frankie Roberts Town of Ansonville WWTP PO Box 437 Ansonville, NC 28007- DENR-FRO NOV 0 7 2008 DWQ SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Laboratory Certification Maintenance Inspection Dear Mr. Roberts : Enclosed is a report for the inspection performed on September 23, 2008 by Ms. Tonja Springer. Where finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply this office with a written item for itemdescription of how these finding(s) were corrected. If the finding(s) cited in the enclosed report are not corrected, enforcement actions may be recommended. 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 us at 919-733-3908. Sincerely, Dana Sattehite Certification Unit Supervisor Laboratory Section Enclosure cc: Tonja Springer Fayetteville Regional Office Noe aturallff North Carolina Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 Phone (919) 733-3908 Customer Service Internet: www.dwglab.org Location: 4405 Reedy Creek Rd Raleigh, NC 27607 Fax (919) 733-6241 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper On -Site Inspection Report LABORATORY NAME: Town of Ansonville WWTP NPDES PERMIT #: NC0081825 ADDRESS: P.O. Box 437 Ansonville, NC 28007 CERTIFICATE #: 5242 DATE OF, INSPECTION: September 23, 2008 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: .Frankie Roberts I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. 11. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses: Some further quality control procedures are needed. Comment: The following findings: D and H 'are new policies that have been implemented by our program since the last inspection. Comment: The laboratory indicated that blind performance evaluation samples have not been analyzed for the parameters on their attachment. The laboratory must submit the results of blind performance evaluation samples for - Total Residual Chlorine (TRC), pH, and Settleable Residue by October 31, 2008. Failure to do so will be considered a first unacceptable resultforcertification purposes. I11. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: aH — Standard Methods,18th Edition, 4500 H+B Comment: Since the time of the inspection, the Technical Assistance Document for Field Analysis of pH has .been revised. A copy of the revised document is attached. ' - A. Finding: The Automatic Temperature Compensator (ATC) has not been verified. Requirement: The ATC must be verified annually (i.e., every twelve months) by analyzing a buffer at 25°C (the temperature that pH values are compensated to) and a temperature(s) that bracket the temperature ranges of the samples to be analyzed.. This may require the analysis of a third temperature reading that is > 25°C. Ref: North Carolina Wastewater/Groundwater. Laboratory Certification (NC. WW/GW LC) Policy, 09/17/2008. Please submit a copy of the ATC verification with the inspection report response. Comment: See attached Technical Assistance Document for Field Analysis of pH for further guidance on performing the ATC verification. B. Finding: Proper units of measure (S.U.) are not documented on the benchsheet. Page 2 #5242 Town of Ansonville WWTP Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected,' time collected, samples site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1) and Technical Assistance for Field Analysis of pH, Rev. 10/2008. — Standard Methods, 18th Edition, 4500 H+ B Temperature — Standard Methods, 18th Edition, 2550 B Dissolved Oxygen — Standard Methods, 18th Edition, 4500 0 G Recommendation: The measurements for pH, Temperature and Dissolved Oxygen (DO) are taken directly in the stream; therefore, add a statement on the benchsheet stating that the parameter analyses are performed "in situ". C. Finding: The temperature sensing devices on the pH and DO meters have not been calibrated against an NIST certified or traceable thermometer annually (every 12 months). 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 1 °C 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, Rev. 10/2008, Technical Assistance for DO, Rev. 07/2008, and Technical Assistance for Temperature, Rev. 07/2008. Please submit a copy of the temperature calibration with the inspection report response. Dissolved Oxygen — Standard Methods, 18th Edition, 4500 0 G D. Finding: The calibration time of the meter is not documented. Requirement: 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 2H .0805 (g) (2) and Technical Assistance for Field Analysis of DO, Rev. 07/2008. Total Residual Chlorine — Standard Methods, 18th Edition, 4500 CI G Comment: When reporting data on the Discharge Monitoring Report (DMR), report less than the lowest standard from the annual verification curve. For example, if the annual verification curve's lowest standard was 15 pg/L, then 12 pg/L would be reported as < 15 pg/L. Comment: The spectrophotometer's internal calibration curve was verified on 12/10/2007. The lowest verified standard of the calibration curve was not clearly stated. It appeared that the lowest standard may have been 12 pg/L. Recommendation: It is recommended that the laboratory re -analyze the annual verification with the assistance of another laboratory. Recommendation: It is recommended that an annual verification curve be analyzed in the range of 25 pg/L — 400 pg/L. E. Finding: A gel standard is analyzed each analysis day; however; the true value of the gel standard has not been established. Requirement:. Establish the true value of the gel standard by reading the gel standard on a meter that has .just had the internal curve verified. Assign that reading as the true value of the gel standard. Document this procedure. This procedure must be performed annually (every 12 months) to verify gel standards that have exceeded the documented expiration date. Each gel standard must be verified specifically to each meter. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine, Rev. Page 3 , #5242 Town of Ansonville WWTP 09/2008. Please submit a copy of the gel standard verification against the curve with - the inspection report response. Comment: It is only necessary to verify the gel or sealed liquid standard, which falls within the concentration range of the curve used to measure sample concentrations. For • example, if you are measuring samples against a low range curve, a 200 pg/L standard would be verified, and not the 800 pg/L standard since the 800 pg/L standard would be measured using a high range curve. Recommendation: The facility should document the verified values of the gel standard used to check calibration, the obtained reading of the gel standard and the percent difference between the two on the bench sheet. This will allow the operator to easily monitor the performance of the meter and determine if corrective action is required. Corrective action should be taken if the value obtained from the standard varies by more than ± 10% from the verified values of the standard. F. Finding: The DPD Indicator solution and the buffer solution were expired. The expiration date for both was July 2008. Requirement: Adherence to manufacturer expiration dates is required. Materials exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specific 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 material is considered stable if stored appropriately, but should be discarded if any changes are noted. Ref: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) policy, 09/17/2008; based upon Standard Methods, 18th Edition - Method 1070 C. (3) (c). Settleable Residue — Standard Methods, 18th Edition, 2540F G. Finding: The 45 minute stir time is not documented. Requirement: Document the 45 minute stir time on the benchsheet. Ref: Technical Assistance for Field Analysis of Settleable Residue, Rev. 05/2008. 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 January 2008. 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: October 13, 2008 Report reviewed by: Jason Smith Date: October 20, 2008 Automatic Temperature Compensator (ATC) Check Procedure for pH meter: The following must be performed on an annual (i.e., 12 month) basis: 1. Pour an adequate amount of buffer into a beaker or other container and analyze at 25°C. Document thetemperatureand pH value. Since the pH 7 buffer represents the isopotential ,point (Le., the electrode potential does not vary with temperature), it can not be used to perform the ATC check. Note: Most pH electrode manufacturers design their isopotential point to 0 mV at pH 7 to correspond with the temperature compensation software. It is recommended that a pH 4 buffer be used for this procedure since the pH 10 buffer is more susceptible to drift due to CO2 absorption. 2. Lower the temperature of the buffer by placing the container in cool water or a refrigerator to less - .than the lowest anticipated sample temperature and 'analyze. Document the temperature and pH value. 3. If samples- greater. than 25°C are to be analyzed, perform the following additional step: Place the container in warm water, or a water bath and raise the temperature above 25°C to greater than the highest anticipated sample temperature and analyze. Document the temperature and pH value. As the temperature increases or decreases, the value of the buffer must be within ± 0.1 S.U. of the tile value of the buffer. Comment: Anticipated temperatures can be obtained from a review of the Discharge Monitoring Reports (DMRs), from; the peak summer and winter months. Historical data should provide a. reasonably'accurate estimation of ranges that will bracket the expected sample temperatures. TECHNICAL ASSISTANCE FOR FIELD ANALYSIS OF pH This document is intended to provide technical assistance and guidance for the measurement of pH. This isnot meant to be a substitute for the method, but is offered as a guide to the method. HOLDING TIME: • Samples must be analyzed within 15 minutes of collection. METER CALIBRATION: • The meter must be calibrated prior to the analysis of samples. • If compliance samples are analyzed throughout the day, a post calibration check (e.g., 7 buffer) must be analyzed mid -day and at the end of the run (i.e., roughly every 4 hours based on an eight hour day). • For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers' recommendations for the calibration of the meter each analysis day. In all cases, the meter must be calibrated with at -least two buffers. Calibrating with the pH 4 and pH 10 buffers meets standard methods requirements and brackets the pH range for most monitoring (with the exception of sludge) scenarios. The calibration; however, must bracket the range of the samples being analyzed. In addition to the calibration standards, the meter must be verified with a third calibration standard (e.g., pH 7 buffer). • In order to meet the above -specified criteria, the standard must read within a range of pH 6.9 to 7.1 to be acceptable. General Information: • Samples shall be gently stirred during measurement. • The electrode must be rinsed and blotted dry between measurements. • The temperature sensor in the meter 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. The meter temperature reading must be less than 1°C from the NIST certified or NIST traceable thermometer reading. (NC WW/GW LC Policy). (NOTE: Other certified laboratories may provide assistance in meeting this requirement.) • The internal Automatic Temperature Compensator (ATC) must be verified every 12 months and the process documented. (NOTE: Other certified' laboratories may provide assistance in meeting this requirement.) The ATC must be verified by analyzing a buffer at 25°C (the temperature that pH values are compensated to) and a temperature(s) that brackets the temperature ranges of the samples to be analyzed. This -may require the analysis of a third temperature reading that is > 25°C. Automatic Temperature Compensator (ATC) Check for pH meter: 1. Pour an adequate amount of buffer into a beaker or other container and analyze at 25°C. Document the temperature and pH value. Since the pH 7 buffer represents the isopotential point (i.e., the electrode potential does not vary with temperature), it can not be used to perform the ATC check. Note: Most pH electrode manufacturers design their isopotential point to 0 mV at pH 7 to correspond with the temperature compensation software. It is recommended that a pH 4 buffer be used for this procedure since the pH 10 buffer is more susceptible to drift due to CO2 absorption. 2. Lower the temperature of the buffer by placing the container in cool water or a refrigerator to less than the lowest anticipated sample temperature and analyze. Document the temperature and pH value. 3. If samples greater than 25°C are to be analyzed, perform the following additional step: Place the container in warm water, or a water bath and raise the temperature above 25°C to greater than the highest anticipated sample temperature and analyze. Document the temperature and pH value. As the temperature increases or decreases, the value of the buffer must be within ± 0.1 S.U. of the true value of thetuffer. Comment: Anticipated temperatures can be obtained from a review of the Discharge 'Monitoring Reports (DMRs) from the peak summer -and winter months. Historical data should provide a reasonably accurate estimation of ranges that will bracket the expected sample temperatures. Ref: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) 9/17/2008 Equipment types vary. If this presents problems, please contact this office for technical assistance. DOCUMENTATION:. The following must be documented whenever sample analysis is performed. 1. Time and date of sample collection 2. Time of calibration 3. Time and date of analysis (to verify 15 minute holding time is met) 4. _ Collector's/analyst's name 5. Value of buffers used for calibration 6. Value obtained for check buffer (e.g., pH 7 buffer). 7. .Sample location/site 8. Temperature of the sample at the time of analysis 9. Post calibration checks (if applicable) 10. Report all data values to the nearest 0.1 pH unit. 11. 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). Recommendation: Maintain a log of all chemicals, reagents and standards to include vendor, lot numbers, and expiration date. Ref: Standard Methods, 18th Edition - Method 4500-H+ B. Ref: Standard Methods, 18th Edition - Method 2550 B. Rev. 10/2008