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.
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#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.
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#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