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HomeMy WebLinkAbout#5285_2021_0603_TS_FINAL July 9, 2021 5285 Mr. David W. Lorbacher Arclin 790 Corinth Rd. Moncure, NC 27559- Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Lorbacher: Enclosed is a report for the inspection performed on June 3, 2021 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 mu st continue to carry out the requirements set forth in 15A NCAC 2H .0800. A copy of the laboratory’s Certified Paramete r 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: Todd Craw ford, Tonja Springer, File #5285 On-Site Inspection Report LABORATORY NAME: Arclin NPDES PERMIT #: NC0000892 ADDRESS: 790 Corinth Rd. Moncure, NC 27559 CERTIFICATE #: 5285 DATE OF INSPECTION: June 3, 2021 TYPE OF INSPECTION: Field Industrial Maintenance AUDITOR: Tonja Springer LOCAL PERSON(S) CONTACTED: Chris Lamm I. INTRODUCTION: This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements of 15A NCAC 02H .0800 for the analysis of compliance monitoring samples. II. GENERAL COMMENTS: The inspection was performed remotely due to the coronavirus pandemic. The laboratory submitted the requested documentation and pictures of their reagents and instruments electronically on May 13, 20 2 1 and June 1, 2021. The inspection was performed via WebEx on June 3, 2021 and from a series of emails. Staff were forthcoming and seemed eager to adopt necessary changes. All required Proficiency Testing (PT) Samples for the 2021 Calendar Year have not yet been analyzed. The laboratory is reminded that results must be received by this office directly from the vendor by September 30, 2021. Contracted analyses are performed by Pace Analytical Services LLC - Asheville NC (Certification #40) and Pace Analytical Services LLC - Eden NC (Certification #633). Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters were provided electronically prior to the inspection. The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedure (SOP) documents in advance of the inspection. These documents were reviewed and editorial and substantive revision requirements and recommendations were made by this program outside of this formal report process. Although subsequent revisions were not requested to be submitted, they must be completed by January 1 , 2022. Page 2 #5285 Arclin The laboratory is reminded that any time changes are made to laboratory procedures, the laboratory must update the QA/SOP document(s) and inform relevant staff. Any changes made in response to the pre-audit review or to Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is 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. 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”. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: During the months that data were reviewed (November 2020, January 2021 and February 2021) pH values were being reported to 0.01 units. The supervisor noted that this was corrected beginning in March 2021. It was verified by the auditor that the March and Apr i l 2021 Discharge Monitoring Reports (DMRs ) included pH values reported to 0.1 units as required by the method [i.e., SM 4500 H+ B-2011 . (6)]. A. Finding: The laboratory needs to increase the traceability documentation of purchased materials and reagents. Requirement: 15A NCAC 02H .0805 (a)(7)(K) and (g)(7) requires laboratories to have a documented system of traceability for the purchase, preparation, and use of all chemicals, reagents, standards, and consumables. That system must include documentation o f the following information: Date received, Date Opened (in use), Vendor, Lot Number, and Expiration Date (where specified). A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information to analytical batches i n which the solutions are used. Documentation of solution preparation must include the analyst’s initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre-made standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref: NC WW/GW LC Policy. Comment: A label is placed on the pH buffer boxes that contains the vendor, date opened, expiration date and lot number. While this can provide a traceability link to analyses by looking at the dates that the chemicals were in use, that link is lost once the boxes are discarded. The lot number and a date are documented on the benchsheet, but it is not clear what “date” is being documented. B. Finding: Documentation of the cali bration variables for the Dissolved Oxygen (DO) me t er does not include all pertinent data. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Page 3 #5285 Arclin Requirement: The following must be documented in indelible ink whenever sample analysis is per formed: Calibration variables (temperature, elevation or barometric pressure [in mmHg], and salinity). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO). Comment: Only Temperature is documented. Comment: The other calibration variables, altitude and salinity, that are on the meter’s display after the calibration will need to be documented. These variables may have been programmed in the meter initially. Comment: Per NC WW/GW LC Branch policy, facilities may use a default value of zero ppt for Salinity when calibrating the DO meter unless it is known or suspected that the Salinity value of the samples being analyzed is > 9 ppt. In those situations, actual Salinity values must be used. Regardless of which value is used, it must be documented. Proficiency Testing C. Finding: The laboratory is not documenting PT Sample analyses in the same manner as routine Compliance Samples. Requirement: All PT Sample analyses must be recorded in the daily analysis records as for any Compliance Sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 19, 2020, Revision 5, Section 3.6. 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 PT Sample results are not documented in an anal y sis record in enough detail to demonstrate that all calibration and QC requirements are met. The laboratory only documents PT Sample results on the PT vendor form with no additional information. Reporting D. Finding: The laboratory does not report results of all tests on the characteristics of the effluent when duplicate sample analyses are performed. Requirement: The results of all tests on the characteristics of the effluent, including but not limited to NPDES permit monitoring requirements, shall be reported on the monthly report forms. Ref: 15A NCAC 2B .0506 (b) (3) (J). Comment: The laboratory is performing duplicate analysis on pH and DO samples and only reports one of the values on the DMR . The following convention must be followed when decidi ng which pH value to report in the daily cell: - Any value in violation of permit limits must be reported in the daily cell. If multiple samples yielded noncompliant results, the most extreme noncompliant value must be reported in the daily cell. Page 4 #5285 Arclin -I f al l values taken during the day were compliant with the permit limits, the value closest to the bounds of the limit range (high or low) must be reported in the daily cell. -The other value not reported in the daily cell must be reported in the comment section. DO values may be averaged and reported in the daily cell. If the values are not averaged, follow the same convention as specified for pH to decide which DO value to report in the daily cell. Comme nt: Sample duplicates are not a required quality control element for Field parameters. Recommendation: It is recommended that the laboratory no longer analyze duplicates for pH and DO. E.Finding: Data qualifiers from the contract laboratory reports are not being transferred to the DMR. Requirement: Reported data associated with quality control failures, improper sample collection, holding time exceedances, or improper preservation shall be qualified as such. Ref: 15A NCAC 02H .0805 (e) (5). C omment: Se e the second table in the Paper Trail Investigation section. IV.PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laborato ry benchsheets, logbooks, etc.) and contract laboratory reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Arclin (NPDES permit # NC0000892) for November 2020, January 2021 and February 2021. The following errors wer e noted: *Contract Laboratory Data The pH and DO values from the benchsheet include a duplicate value. T he TSS valu e reported on the client report was 14.9 mg/L. The permit requires the TSS value to be reported as lbs/day. The formula for converting to lbs/day is: concentration (in mg/L) x daily flow (in MGD) x 8.34 (a constant, in lb/gal ) The flow value on 2/11/2021 was reported on the DMR as 0.046786 MGD . The result from the conversion is 5.8 lbs/day. It was reported on the DMR as 5.2 lbs/day . Date Parameter Location Value on Benchsheet Value on DMR 1/7/2021 pH Effluent 6.90 S.U./6.88 S.U. 7.98 S.U. 1/7/2021 DO Effluent 9.71 mg/L/9.71 mg/L 8.95 mg/L 2/11/2021 TSS Effluent *14.9 mg/L 5.2 lbs/day Page 5 #5285 Arclin Sample Collection Date Parameter Location Contract Lab Report Qualifier 2/25/2021 BOD Effluent B1 : “Less than 1.0 mg/L DO remai ned for all dilutions set. The reported value is an estimated greater than value and is calculated for the dilution using the least amount of sample.” 1/7/2021 BOD Effluent B2 : “Oxygen usage is less than 2.0 mg/L for all dilutions set. The reported value is an estimated less than value and is calculated for the dilutions using the most amount of sample .” 11/5/2020 1/14/2021 Fecal Effluent D6: The precision between the samp le and sample duplicate exceeded laboratory control limits 11/5/2020 11/23/2020 1/14/2021 2/25/2021 BOD Effluent L1: Analyte recovery in the laboratory control sample (LCS) was above QC limits results. Results for this anal yte in associated samples may be biased high 1/14/2021 Ammonia Effluent M6: Matrix spike and mat rix duplicate recovery not evaluated against control limits due to sample dilution 11/12/2020 Nitrate/Nitrite Effluent M6: Matrix spike and mat rix duplicate recovery not evaluated against control limits due to sample dilution 11/23/2020 TKN Effluent M6: Matrix spike and mat rix duplicate recovery not evaluated against control limits due to sample dilution 11/12/2020 Nitrate/Nitrite Effluent R1: “RPD value was outside control limits.” 11/23/2020 1/21/2021 1/28/2021 2/11/2021 2/18/2021 BOD Effluent R6: “The RPD between valid sample dilutions exceeded 30%.” To avo id questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended DMR(s) will be required. A copy of this report will be made available to the Regional Office. V. CONCLUSIONS: Correcting the above-cited Findings and implementing the Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspector woul d like to thank the staff for their assistance during the inspection and data revie w 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 : June 15, 2021 Report reviewed by: Jason Smith Date : June 17, 2021 Certificate Number:5285 Effective Date:1/1/2021 Expiration Date:12/31/2021 Lab Name:Arclin Address:790 Corinth Rd. Moncure, NC 27559- North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment:10/26/2016 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 DISSOLVED OXYGEN Hach 10360-2011, Rev. 1.2 (LDO) (Aqueous) pH SM 4500 H+B-2011 (Aqueous) TEMPERATURE SM 2550 B-2010 (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.