HomeMy WebLinkAboutNC0024571_Lab Inspection_20020807W TF Michael F. Easley, Govemor
0�1'9 ' William G. Ross Jr., Secretary
Q North Carolina Department of, Environment and Natural Resources
G
r _ Alan W. Klimek, P.E. Director
Division of Water Quality
August 7, 2002
131
Ms. Karen H. Lewis
Lumberton Public Util. Lab.
P.O. Box 1388
700 Lafayette Street
Lumberton, NC 28359
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Ms. Lewis:
Enclosed is a report for the inspection performed on July 17, 2002 by Mr. Frederick
L. Bone. Where deficiencies are cited inthis 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 writtenitem for item description of how these deficiencies,
comments and/or recommendations were corrected. 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 for.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,
1/L J' l
James W. Meyer
Laboratory Section
Enclosure
cc: Frederick L. Bone
Fayetteville Regional Office
AMA
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: Lumberton Public Utilities Lab.
ADDRESS:
P.O. Box 1388
700 Lafayette Street
Lumberton, NC 28359
ti.
CERTIFICATE NO: 131
DATE OF INSPECTION: July 17, 2002
TYPE OF INSPECTION: Maintenance
EVALUATOR: Frederick L. Bone
LOCAL PERSON(S) CONTACTED: Karen Lewis 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 facilitiesandequipment 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 reporting values for Temperature and Dissolved Oxygen (DO) on the
Discharge Monitoring Report (DMR). The laboratory is not currently certified for these parameters.
REQUIREMENT: Any value reported on the Discharge Monitoring Report must be performed by a certified
laboratory. The laboratory must obtain certification for these two parameters.
2. DEFICIENCY: The laboratory is performing analysis and reporting results under the 503 regulations, without
having proper certification for some of the parameters.
Note: One item discussed during the audit concerned class A: Biosolids. If the laboratory is using the
membrane filter technique only, Class A Biosolids may not be reported. "The membrane filter method is not
allowed for Class A because, at . the low fecal coliform densities expected, the filter would have too high a
loading of sewage sludge solids to permit a reliable count of the number of fecal coliform colonies." (White
House Book 4.3 p.27)
The contact person that I suggested for information on the 503 regulations is Shannon Thornburg (919) 733 —
5083 extension 353.
REQUIREMENT: The laboratory must obtain certification for the parameters that are being reported to the
state of North Carolina under the 503 regulations. All data reported must be performed by certified laboratory.
Page 2
A. COMMENT: The laboratory does not analyze a second source QC standard daily for some parameters. (COD
and Residual Chlorine)
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.
B. COMMENT: The laboratory is using a stated temperature range for laboratory refrigerators of 1 to 4.4 °C.
Several of the values obtained since January are 4.5°C. The thermometer used in the sample refrigerators
measures in 0.5 °C. The values of 4.5°C would exceed. the temperature storage requirements in the
laboratory.
RECOMMENDATION: It is recommended that the laboratory modify the acceptance limits for sample storage
refrigerators to be 1 to 4°C. This will allow the laboratory to continue using thermometers that are graduated
in 0.5 °C. increments.
Total Suspended Solids:
C. Comment: The laboratory uses a volume of 100m1 for each blank and a volume of 250m1 for each effluent
sample.
REQUIREMENT: The laboratory must filter the same volume for both blanks and samples. The laboratory
must increase the volume of the blank to an amount equal to the highest amount of sample filtered.
Residual Chlorine:
D. COMMENT: The benchsheets used for residual chlorine did not have proper units of measure associated
with each number listed. The laboratory must label every entry with a unit of measure.
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, andfinal value to be reported, and each item must be
recorded each time samples are analyzed. Ref: 15A NCAC 2H 0800 (a) (7) (h).
Conductivity:.
E. COMMENT: The laboratory does not verify that the a .temperature compensation device on the conductivity
meter is performing properly on an annual. basis. The laboratory is using an older conductivity meter that does
not display temperature measurements.
RECOMMENDATION: Is recommended that the laboratory verify that the temperature compensation device is
performing adequately on an annual basis. Conductivity is a temperature sensitive measurement and for this
reason, the meter must be able to properly compensate for variances in temperature.
COD:
3. DEFICIENCY: The laboratory is not analyzing and recording a standard at the mid -range of the calibration
curve daily for this analytical method.
Page 3
COMMENT:. As was discussed at the time of the audit the mid -range is to be defined as one half the
concentration of the high standard.
Note: The mid -range check standard must be prepared from the same stock standards as the analytical curve.
A second source laboratory control standard (LCS) must be analyzed in addition to the mid -range check
standard daily. A second source LCS sample does not constitute daily mid -range verification.
The laboratory is currently analyzing a 300 mg/L standard daily. The laboratory's analytical curve is 15 to 150
mg/L. The 300mg/L standard is diluted by a factor of 2, therefore; it is being read at the extreme top end of the
analytical curve. In order for the laboratory to meet the midpoint requirements, the standard must be diluted to
be approximately 75 mg/L. This 75 mg/L standard must then the recovered within 10 percent of the 75mg/L
value.
REQUIREMENT: Verify the standard curve daily by analyzing one or more standards within the linear range,
as specified in the individual method. The curve must be updated as set forth in the standard procedures,
each time the slope changes by more than 10 percent at midrange. Ref: Standard Methods 18th Edition 1020
B. Quality Control section 5 p. 1-5, and Ref: 15A NCAC 2H .0805 (a) (7) (i).
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
indicated no problems in proper data reporting.
V. CONCLUSIONS:
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: July 19, 2002
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September 5, 2002
Mr. James W. Meyer
Laboratory Certification
N. C. Division of Water Quality
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
SER 9 2002
SUBJECT: Laboratory Certification Maintenance Inspection Response
Enclosed is a written response, with an item for item description of deficiency corrections for deficiencies
and comments and/or recommendations that were cited and by Frederick L. Bone during the Maintenance
Inspection performed on July 17, 2002.
GENERAL DEFICIENCIES
1. DEFICIENCY: The laboratory is reporting values for Temperature and Dissolved Oxygen (DO) on
the Discharge Monitoring Report (DMR). The laboratory is not currently certified for these
parameters. .
RESPONSE: On 8/22/02, the laboratory completed and mailed an Amendment to Environmental
Laboratory Certification Application for Dissolved Oxygen (DO) and Temperature Analytical Field
Parameters. On .9/5/02, an email was received from Fred. Bone stating that he had made the
modifications that I requested on my Amendment form.
2. DEFICIENCY: The laboratory is performing analysis and reporting results under 503 regulations,
without having proper certification for some of the parameters.
RESPONSE: During the audit, it was assumed that Lumberton was considered a Class A Biosolids
facility under the 503 regulations and using the membrane filter method for fecal coliform, which is
not acceptable. Lumberton WWTP is classified as a Class B, Alternative 1 Biosolid facility, therefore,
under 503 regulations, the membrane filtration method for fecal coliform analysis is required and this
laboratory is certified by NC for this analysis. I also spoke to Fred Bone on 8/14/02 and he gave the
OK for this method.
A. Comment: The laboratory does not analyze a second source QC standard for some parameters. (COD
and Residual Chlorine).
Response: The laboratory is in the process of obtaining a mid -range concentration second source
known control standard in addition to the daily calibration verification standard for Residual Chlorine.
Potassium Permanganate will be used. A 75 mg/1 mid -range concentration, diluted from a 1000 mg/1
second source known control standard, is now being used in addition .to the daily 75 mg/I calibration
verification standard diluted from a 300 mg/1 known control stock standard and will not vary by ±
10%.
B. Comment: The .laboratory is , using _ a _stated_ temperature range for laboratory refrigerators of 1 to
4.4`Tveral of the, values obtained. since January are 4.5°C..The thermometer used in the sample
refrigerators measures in 0.5°C. The values 'of. 4.5°C would exceed the temperature storage
requirements in the laboratory.
Response: The laboratory modified the acceptance limits for sample storage refrigerators to- 1 to 4°C
on 7/17/02. The laboratory will continue using thermometers that are graduated in 0.5°C increments.
1
1130x 1388, Ltim .Eton, SVottl eatoLina 28359 • 91 o-671-3858 • 91 0-671-3889 • 9ax 91 0-671-381 a
TOTAL SUSPENDED SOLIDS
C. Comment: The laboratory uses a volume of 100m1 for each blank and a volume of 250m1 for each
effluent sample.
Response: The laboratory now filters the same volume for both blanks and samples. The laboratory
increased the volume of the blank to an amount equal to the highest amount of sample filtered, which
is, at the present time, 250m1s.
RESIDUAL CHLORINE
D. Comment: The benchsheets used for residual chlorine did not have proper units of measure associated
with each number listed. The laboratory must label every entry with a unit of measure.
Response: On 8/14/02, the laboratory updated the printed laboratory bench worksheet to include the
value from the measurement system for every entry.
CONDUCTIVITY
E Comment: The laboratory does not verify that the temperature compensation device on the
conductivity meter is performing properly on an annual basis. The laboratory is using an older
conductivity meter that does not display temperature measurements.
Response: The laboratory is in the process of ordering a conductivity probe for the Fisher AR50 meter
that displays temperature measurements. The temperature compensation will be verified annually by a
NIST traceable thermometer.
COD
3. DEFICIENCY: The laboratory is not analyzing and recording a standard at the mid -range of the
calibration curve daily for this analytical method.
RESPONSE: The laboratory is now analyzing and recording a 75mg/1 mid -range standard daily
prepared from the same stock standard as the 15 to 150mg/1 analytical curve and is recovered within
10% of the 75mg/1 standard.
In conclusion, the City of Lumberton Laboratory has implemented changes to correct the above cited
deficiencies and comments. The recommendations are being implemented into our quality assurance
program to assure that our laboratory is producing quality data and meeting certification requirements.
Thank you very much for your assistance. If you have any questions or any father comments, please
contact me at (910) 671-3858.
Sincerely,
Karen H. Lewis
Laboratory Supervisor
cc: Jim Walters
Fayetteville Regional Office
Fredrick L. Bone
131
William 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
Ms. Karen H. Lewis
Lumberton Public Util. Lab.
P.O. Box 1388
700 Lafayette Street
Lumberton, NC 28359
SUBJECT: Wastewater/Groundwater Laboratory Certification
Dear Ms. Lewis:
MAY 8 2002
fly
We have scheduled an on -site inspection of your laboratory for approximately 9:30 a.m., July 17,
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 of theinspection 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 3, 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
Laboratory Section
FAX: 919-733-6241 Internet: www.esb.enr.state.nc.us/lab
Sincerely,
Frederick L. Bone
Laboratory Section
ITCDENR
N. C. Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 (919) 733-3908