HomeMy WebLinkAboutNC0024571_Lab Inspection_20071016O. y\ A T`C9 Michael F. Easley, Governor
Q. William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
1.
October 16, 2007
131 •
Ms. Tammy Smith
City of Lumberton WWTP Laboratory
P.O. Box 1388
Lumberton, NC 28359
SUBJECT: Laboratory Certification Maintenance,lnspection
Dear Ms. Smith :
Coleen H. Sullins, Director
Division of Water Quality
DENR-FRO
OCT 18 2007
DWO
Enclosed is a report for the inspection performed on September 6, 2007 by Mr. David
Livingston . 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 item description 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,
a7 A-et-frt
Gary Francies
Laboratory Section
Enclosure
cc: David Livingston
Fayetteville Regional Office
NorthCarolina
• Nat/trey
North Carolina Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 Phone (919) 733-3908 Customer Service
Internet: www.dwgiab.org Location: 4405 Reedy Creek Rd Raleigh, NC 27607 Fax (919) 733-6241 I-877-623-6748
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
On -Site inspection Report
LABORATORY NAME: City of Lumberton WWTP Lab
NPDES PERMIT #: NC0024571
ADDRESS: PO Box 1388
Lumberton, NC 28359
CERTIFICATE #: 131
DATE OF INSPECTION: September 6, 2007
TYPE OF INSPECTION: Municipal Maintenance
AUDITOR(S): David Livingston
LOCAL PERSON(S) CONTACTED: Tammy Smith and Kerdette Lowry
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. Some further quality control procedures need to be implemented. A Technical Assistance
document on how to check the ATC of the laboratory's pH meter is attached to this report.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
— Standard Methods, 18th Edition, 4500 H B
A. Finding: The laboratory has not verified the Automatic Temperature Compensator (ATC) of the
pH meter.
: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 bracket the temperature ran�esof the :;
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- 25°..C..The. following -must --be- performed -on -an annual-(i:e., -.42--month)-basis;--Ref:.-North.... •
Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Policy Statement
February 2006.
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.
Ammonia — Standard Methods, 18th Edition, 4500 NH3 F
B. Finding: The laboratory has done a distillation study but the study is unacceptable.
t
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#131 City of Lumberton WWTP Laboratory
Requirement: Laboratories shall analyze initially four samples distilled and undistilled from
each discharge and, thereafter, analyze two samples a year from each effluent. Additional
samples must be analyzed comparatively if the above samples results do not indicate
approximately the same values for distilled and undistilled samples. Ref: Federal Register,
March 12, 2007; 40 CFR 136.3 (a) Table -18. - List of Approved Inorganic Test Procedures;
Ammonia Footnote 6.
Recommendation: It is recommended that the samples be spiked to a concentration of at least
1 to 5 mg/I. It appears that the distillation study failed due to the low concentration of the
samples used.
Requirement: Redo the distillation study and send a copy of the study with your response to
this report.
Total Suspended Solids — Standard Methods, 18th Edition, 2540D
C. Finding: The laboratory did a drying time study but the drying times were not documented to be
at least one hour in the oven for the reweighing.
Requirement: Dry evaporated sample for at least 1 hour in an oven at 103 the 105°C, cool in
desiccator to balance temperature, and weigh. Repeat cycle of drying (at least one hour),
cooling, desiccation, and weighing until a constant weight is obtained, or until weight change is
Tess than 4% of previous weight or 0.5 mg, whichever is less. Ref: Standard Methods 18th
Edition 2540 D. 3. c.
Comment: The laboratory is writing up a hand written benchsheet and then filling out a computer -
benchsheet. The laboratory can just do the computer benchsheet as long as the analyst signs or
initials the benchsheet.
Total Residual Chlorine — Standard Methods, 18th Edition, 4500CL G
D. - Finding: The Total Residual Chlorine benchsheet has the sampler's initials but not the analyst's
initials or signature.
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).
tandard Methods, 18`" Edition, 5220 D
E. Finding: The laboratory is not analyzing a mid range check standard each analysis day.
Requirement: For analytical Procedures requiring analysis of a series of standards, the
concentrations of these standards must bracket the concentration of the samples analyzed. One of the
standards must have a concentration equal to the laboratory's lower reporting concentration for the
parameter involved. For colorimetric analyses, a series of five standards for a curve prepared annually
or three standards for curves established each day or standards as set forth in the analytical procedure
must be analyzed to establish a standard curve. The curve must be updated as set forth in the
standard procedures, each time the slope changes by more than 10 percent at midrange, each time a
new stock standard is prepared, or at least every twelve months. Each analyst performing the
analytical procedure must produce a standard curve. Ref 15A NCAC 2H .0805 (a) (7) (I)
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#131 City of Lumberton WWTP Laboratory
F. Finding: No second source standard being analyzed with COD samples.
Requirement: Excluding Oil and Grease, all residue parameters, TCLP extractions, residual
chlorine, and coliform, analyze one known standard in addition to calibration standards each
day samples are analyzed to document accuracy. Analyze one suspended residue, one
dissolved residue, one residual chlorine and one oil and grease standard quarterly. For
residual chlorine, all calibration standards required by the approved procedure in use and by
the EPA must be analyzed. Ref: 15A NCAC 2H .0805(a) (7) (B).
G. Finding: The laboratory is not .documenting the temperature of the hot block during digestion.
Requirement: Document the temperature of the block heater/reactor to meet method
requirements. Block heater or oven to operate at 150 +/- 2°C. Ref: Standard Methods 18th Edition
5520 C. 2. c.
BOD — Standard Methods, 181h Edition, 5210 B
H. Finding: The laboratory is not averaging all acceptable seed corrections for their seed control.
Requirement: If more than one sample dilution meets the criteria of a residual DO of at least
1 mg/L and a DO depletion of at least 2 mg/ L and there is no evidence of toxicity at higher
sample concentrations or the existence of an obvious anomaly, average results in the
acceptable range..Ref: Standard Methods 18th Edition 5210 B. 5. page 5-5.
Comment: The DO meter is capable of reading to two decimal _places. but the lab is rounding
the readings of the seed corrections to one decimal place. Calculate the seed corrections, just
as all other samples are calculated, to two decimal places. Do not round seed corrections to
one decimal place.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory bench sheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for the City of Lumberton (NPDES permit #NC0024571) for May, June and July 2007. No
transcription or other 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 meetcertification requirements. The inspector would Like to thank the staff for
its assistance during the inspection and data review process. Please respond to the lettered
findings.
Report prepared by: David Livingston Date: September 24, 2007
Report reviewed by: Tony Hatcher Date: September 24, 2007
Technical Assistance
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.
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 the buffer.