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HomeMy WebLinkAboutNC0005762_Lab Inspection_20020506William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Gregory J. Thorpe, Ph.D. Acting Director Division of Water Quality May 6, 2002 156 Mr. Yancy Helton WestPoint Stevens Wastewater Laboratory P.O. Box 388 Wagram, NC 28396 SUBJECT: Wastewater/Groundwater Laboratory Certification Dear Mr. Helton: We have scheduled an on -site inspection of your laboratory for approximately 9:30 a.m., July 31, 2002. The scope of the inspection will include all methods marked on Attachment I of the laboratory's current North Carolina Wastewater. /Groundwater Certificate and /or marked on the application for NC Wastewater/Groundwater Laboratory Certification. A copy of the current Attachment I is enclosed for your reference. The purpose ofthe inspection will be to verify the laboratory's documented quality control/quality. assurance procedures and adequacy in meeting the requirements of 15A NCAC 2H .0800. Enclosed are inspection checklists for the upcoming inspection. Prior to the on -site inspection, excluding the data review sections, please have your analysts complete each checklist. Any checklists that your laboratory is unable to complete, or any specific items that you do not understand, will be completed during the inspection. Completion of these_ checklists prior to the on -site audit, with comments by analysts relating to specific procedural differences, will help avoid any unnecessary interruption of the analyst's schedule. Please return these completed checklists, with 5 copies of completed benchsheet data for each inorganic parameter listed on your Attachment I. The checklists and requested data are to be received by this office on or before July 17, 2002. Please have available the DMR report sheets and corresponding bench data available for the months of October and December 2001 and February 2002 for us to review. If further data or report sheets are required, we will notify you during the inspection. These data sets will be used to assess the quality of your data during the inspection. Review your last inspection report to assure that all deficiencies have been corrected. If the deficiencies cited in the inspection report have not been corrected, enforcement action will be recommended. Thank you for your time and cooperation. I can be contacted at (919) 733-3908 (extension 273), if you have questions. Enclosures cc: James W. Meyer Fayetteville Regional Office Sincerely, z rederick L. Bone Laboratory Section Laboratory Section FAX: 919-733-6241 Internet: www.esb.enr.state.nc.us/lab NCDENR N. C. Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 (919) 733-3908 Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality August 8, 2002 156 Mr. Yancy Helton WestPoint Stevens Wastewater Laboratory P.O. Box 388 Wagram, NC 28396 SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Helton: Enclosed is a report for the inspection performed on July 31,2002 by Mr. Frederick L. Bone. Where deficiencies are cited in this report, a response is required as well as for all lettered comments and/or recommendations. Within thirty days of receipt, please supply this office with a written item for item description of how these deficiencies, comments and/or recommendations were corrected. We are seriously concerned about the CITED PREVIOUSLY deficiency(ies) found during the inspection. If the deficiencies cited in the enclosed report are not corrected, enforcement actions will 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. Please contact us at. 919-733-3908 if you have questions or need additional information. Sincerely, 7c24ne44Uames W. Meyer Laboratory Section Enclosure cc: Frederick L. Bone Fayetteville Regional Office SNA NCDENR Laboratory Section N. C. Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 (919) 733-3908 FAX: 919-733-6241 Internet: www.esb.enr.state.nc.us/lab , On -Site Inspection Report LABORATORY NAME: WestPoint Stevens Wastewater Laboratory ADDRESS: P.O. Box 3888 Airbase Road Wagram, NC 28396 CERTIFICATE NO: 156 DATE OF INSPECTION: July 31, 2001 TYPE OF INSPECTION: Maintenance EVALUATOR: Frederick L. Bone LOCAL PERSON(S) CONTACTED: George Brown, Roy Guinn, and Herman Benton 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 is spacious and well equipped. All facilities and equipment are well maintained. Records are well kept and most data looked good. Some further quality control procedures need to be implemented. III. DEFICIENCIES, RECOMMENDATIONS, REQUIREMENTS, AND COMMENTS: General: 1. DEFICIENCY: The laboratory is not performing sufficient quality control for it's duplicate sample analyses. The laboratory must calculate either the relative percent difference, or the absolute difference for each duplicate pair analyzed. This value is then used to establish control charts or other appropriate acceptance criteria. This type of data is necessary to demonstrate that the data is within acceptable control limits. The %RPD must be listed on the inorganic benchsheets so that the analyst will be able to immediately confirm whether or not the data falls within acceptable limits. Note: The laboratory currently has space provided on the benchsheet for some of this data. In the cases of pH and BOD the benchsheet data is not always recorded. Each item on the laboratory benchsheet must be fully completed. For the parameters of Color and Residual Chlorine, no duplicate comparison information is listed on the benchsheet. The laboratory may wish to implement a peer review system in order to ensure that every item on the laboratory benchsheet is fully completed. REQUIREMENT: Any time quality control results indicate an. analytical problem, the problem must be resolved, and any samples involved must be rerun if the holding time has not expired. Ref: 15A NCAC 2H .0805 (a) (7) (f). CITED PREVIOUSLY (In the previous inspection report the laboratory was not performing any quality control measures for duplicates. In this inspection cycle the laboratory does have quality control information listed for most of the parameters, but the laboratory is not consistently calculating and reporting the data on the laboratory benchsheet.) Page 2 A. COMMENT: The laboratory does not keep an adequate log for the preparation of standards and reagents. The laboratory is currently keeping a log for standard preparation, but does not record all of the necessary preparation information. Information on precisely how each standard and reagent is prepared, the lot number associated with each purchased standard and reagent, and other information concerning the preparation of these standards is not listed on the laboratory preparation lag. The current "log" used by the laboratory simply lists the date, what was prepared, and who prepared it. Information was provided during the audit concerning the required information that must be contained in a standard preparation logbook. CITED PREVIOUSLY REQUIREMENT: The laboratory must have a written record of all standards and reagents on file for a period of at least five years. A standard and reagent logbook will help the laboratory to meet this requirement. A standards logbook will also enable the laboratory to document exactly when, by whom, and how each reagent was prepared. Total Suspended Solids: 2. DEFICIENCY: The laboratory is not analyzing water blanks for the Total Suspended Solids analysis. The laboratory must filter a volume of DI water (equal to the maximum sample volume used) as a method blank each analysis day. CITED PREVIOUSLY REQUIREMENT: Blanks must be analyzed in order to determine bias in each sample batch. Ref: Standard Methods 18th Edition - Method 1020B pg. 1-5. pH and Residual Chlorine: 3. DEFICIENCY: The laboratory does not meet the 15 minute holding time for Residual Chlorine and pH analysis. REQUIREMENT: The maximum holding time for Residual Chlorine and pH samples is 15 minutes. Ref: 40CFR Ch.1(7-1-95) p. 644 table II. Residual Chlorine: 4. DEFICIENCY: The laboratory does, not analyze second source QC standards daily for this ,certified parameter. CITED PREVIOUSLY (this item was cited previously in the last inspection report in the general comments section). REQUIREMENT: Analyze one known standard in addition to calibration standards each day that samples are analyzed to document accuracy. This laboratory control standard must be from a second source. For held curves for colorimetric methods, it must be analyzed after the calibration verification standard is analyzed. It is recommended that this laboratory control standard, like the calibration verification standard, have a mid- range concentration and not vary by more than ± 10%. If it does the analysis is out of control. The analysis must be terminated and the problem corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B), (F), and Standard Methods, 18th Edition - Method 1020 B.3. 5. DEFICIENCY: The laboratory is not recording the time sampled and the time analyzed for Residual Chlorine samples on the General Worksheets. CITED PREVIOUSLY REQUIREMENT: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor, and final value to be reported, and each item must be recorded each time samples are analyzed. Ref: 15A NCAC 2H .0805 (a) (7) (h). Note: This information is important to document that the holding times were met for these, analyses. Page 3 B. COMMENT: The laboratory does not list the acceptance ranges of quality control samples on the laboratory benchsheets. CITED PREVIOUSLY (this item was cited previously in the last inspection report in the general comments section) RECOMMENDATION: It is strongly recommended that the laboratory list the acceptance ranges for each quality control sample on the bench sheet. This will enable the analyst to be able to compare the analytical result to the acceptable range in a timely fashion. If the sample is out of the acceptable range, it can then be reanalyzed immediately and within all holding times. Color: C. COMMENT: The laboratory is analyzing their quality control check standards and the end of each analytical batch. The laboratory analyzes a baseline blank check, followed by the effluent samples, followed by the daily calibration check standards. REQUIREMENT: The laboratory must demonstrate that the instrument is operating within proper calibration criteria, prior to analysis of samples. Good laboratory practice requires that a laboratory demonstrate proper calibration prior to sample analysis. Should the calibration criteria not be within acceptable parameters, all data analyzed prior to that sample would be invalid. IV. PAPER TRAIL INVESTIGATION: This consisted of comparing data reported on DMR's submitted to this Division with the values obtained on laboratory bench worksheets. Data reviewed for the months of October and December 2001 and February 2002 indicated no problems in proper data reporting. V. CONCLUSIONS: We are concerned with the deficiencies that were cited previously and not corrected. Failure to correct the deficiencies and comments cited in this report will lead to enforcement action. Ref: 15A NCAC 2H .0807 (a) (1) and (14) Laboratory Decertification: A laboratory may be decertified for any or all parameters for up to one year for any or all of the following infractions: (1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control program as set forth in the application, and these Rules; or (14) Failing to comply with any other terms, conditions, or requirements of this Section or of a Laboratory certification. Correcting the above deficiencies and comments should help them to produce quality data and meet certification requirements. Please respond to all numbered Deficiencies and lettered Comments cited in this report. Report prepared by: Frederick L. Bone Date: August 2, 2001