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HomeMy WebLinkAbout#5705_2022_0629_TS_FINAL NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch 4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623 919-733-3908 August 8, 2022 5705 Mr. J. Dirk Cartner City of Durham South Durham Water Reclamation Facility 6605 Farrington Road Chapel Hill, NC 27517 Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) Maintenance Inspection Dear Mr. Cartner: Enclosed is a report for the inspection performed on June 29, 2022 by Tonja Springer. Where Finding(s) are cited in this report, a response is required. Within thirty days, please supply this office with a written item for item description of how these Finding(s) were corrected. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. 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 02H .0800. A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. If you have questions or need additional information, please contact me at (919) 733- 3908 Ext. 259. Sincerely, Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Tonja Springer, Todd Crawford, #5705 On-Site Inspection Report LABORATORY NAME: City of Durham South Durham Water Reclamation Facility WATER QUALITY PERMIT #: WQ0033445 ADDRESS: 6605 Farrington Road Chapel Hill, NC 27517 CERTIFICATE #: 5705 DATE OF INSPECTION: June 29, 2022 TYPE OF INSPECTION: Field Municipal Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: J. Dirk Cartner I. INTRODUCTION: This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of 15A NCAC 02H .0800 for the analysis of compliance monitoring samples. II. GENERAL COMMENTS: Staff was forthcoming and responded well to suggestions from the auditor. All required Proficiency Testing (PT) Samples have been analyzed for the 2022 PT Calendar Year and the graded results were 100% acceptable. The laboratory is reminded that any time changes are made to laboratory procedures, QA/SOP document(s) must be updated and relevant staff retrained. Staff must acknowledge that they have read and understand the changes as part of the documented training program. The same requirements apply when changes are made in response to Findings, Recommendations or Comments listed in this report, to ensure the methods are being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with each approved practice, test, analysis, measurement, monitoring procedure or regulatory requirement being used in the laboratory. In some instances, the laboratory may need to create an SOP to document how new functions or policies will be implemented. Revisions to the SOPs, based on the Findings, Comments and Recommendations within this report must be submitted to this office by November 30, 2022. The laboratory is also reminded that SOPs are required to be reviewed at least every two years and are intended to describe procedures exactly as they are to be performed. Use of the word “should” is not appropriate when describing requirements (e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper use of the word “should”. Page 2 #5705 City of Durham South Durham Water Reclamation Facility Contracted analyses are performed by Pace Analytical Services LLC - Huntersville NC (Certification #12), City of Durham Water & Wastewater Laboratory (Certification # 176) and Environmental Conservation Laboratories, Inc. – Cary (Certification # 591). Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Comment: The facility utilizes UV disinfection. The permit only requires Total Residual Chlorine (TRC) measurement once per reclaimed water distribution event. There is no Daily Maximum Limit for TRC for this permit. No reclaimed water distribution events have occurred in the last year. Only Proficiency Testing (PT) data were available for review. Recommendation: The laboratory historically analyzed TRC for the City of Durham Water & Wastewater Laboratory (Certification #176) NPDES permit NC0047597, which has a limit of 17 µg/L. Consequently, the annual 5-standard calibration verification was performed on the low- level program and low-level PT Samples were analyzed. The laboratory no longer analyzes TRC for the city of Durham Water & Wastewater Laboratory since the facility now solely uses a UV disinfection system. It is recommended that the curve in the “regular level” program (i.e., program 80) be verified prior to analyzing the 2023 TRC PT Sample. A regular level TRC PT Sample would be analyzed in this case. Documentation A. Finding: All original records are not being maintained for five years. Requirement: The laboratory shall retain all records necessary to facilitate historical reconstruction of the analysis and reporting of analytical results for PT Samples. This means the laboratory must have available and retain for five years [pursuant to 15A NCAC 02H .0805 (a) (7) (E) and (g) (1)] all of the raw data, including benchsheets, instrument printouts and calibration data, for all PT Sample analyses and the associated QC analyses conducted by all parameter methods. Ref: Proficiency Testing Requirements, February 19, 2020, Revision 5, Section 4.0. Comment: The TRC PT result is documented on a scrap piece of paper and reported online to the PT vendor. The scrap piece of paper is not always saved. Comment: The laboratory does not currently have a benchsheet for TRC since no compliance samples have been analyzed. All documentation required for compliance samples analysis is required for PT Sample analysis. Proficiency Testing B. Finding: The laboratory is not documenting the preparation of TRC PT Samples. Requirement: PT Samples received as ampules are diluted according to the Accredited PT Sample Provider’s instructions. It is important to remember to document the preparation of PT Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a routine Compliance Sample and is added to a routine sample batch for analysis. No documentation is needed for whole volume PT Samples which require no preparation; however, the instructions must be maintained. Ref: Proficiency Testing Requirements, February 19, 2020, Revision 5, Section 3.6. Page 3 #5705 City of Durham South Durham Water Reclamation Facility Comment: Dating and initialing the instruction sheet for each prepared PT Sample would satisfy the documentation requirement. QA/QC C. Finding: The laboratory is not calibrating the mechanical volumetric liquid-dispensing devices used for critical measurements at least once every twelve months. Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable auto-pipettors and bottle-top dispensers) shall be calibrated at least once every twelve months. Ref: 15A NCAC 02H .0805 (g) (10). Comment: An adjustable pipettor is used to prepare the annual TRC PT Sample. Alternatively, the laboratory could use a 1-mL Class A volumetric pipette and forgo the use of the adjustable pipettors when preparing the annual TRC PT. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract laboratory reports to DMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for City of Durham South Durham Water Reclamation Facility (Water Quality permit # WQ0033445) for November 2021, February 2022 and May 2022. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above-cited Findings and implementing the Recommendation(s) will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for their assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation, implementation dates and steps taken to prevent recurrence for each corrective action. Report prepared by: Tonja Springer Date: July 26, 2022 Report reviewed by: Tom Halvosa Date: July 29, 2022 Certificate Number:5705 Effective Date:1/1/2022 Expiration Date:12/31/2022 Lab Name:City of Durham South Durham Water Reclamation Facility Address:6605 Farrington Road Chapel Hill, NC 27517 North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment: The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below. CERTIFIED PARAMETERS INORGANIC CHLORINE, TOTAL RESIDUAL SM 4500 Cl G-2011 (Aqueous) This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 2H.0807.