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HomeMy WebLinkAbout#614_2018_0821_JS_FINALLaboratory Cert. #: 614 Laboratory Name: Corpening Creek City of Marion WWTP Inspection Type: Municipal Maintenance Inspector Name(s): Jason Smith Inspection Date: August 21, 2018 Date Forwarded for Initial Review: September 18, 2018 Initial Review by: Tom Halvosa Date Initial Review Completed: September 21, 2018 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg ❑Insp. No Finding❑Corrected ❑Insp. CP (to use: rt click, properties, chocks ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: September 25, 2018 Date Forwarded to Admin.: September 28, 2018 Date Mailed: September 28, 2018 Special Mailing Instructions: Water 1?esources N V 1Gt G N N! E N T A!_ UAL!'Y September 28, 2018 614 Mr. Larry Carver Corpening Creek City of Marion WWTP P.O. Box 700 Marion, NC 28752 ROY COOPER MICHEAL S. REGAN LINDA CULPEPPER Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Carver: Enclosed is a report for the inspection performed on August 21, 2018 by Jason Smith. 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. 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 21-1 .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 wish to obtain an electronic copy of this report by email or if you have questions or need additional information, please contact me at (828) 296-4677. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Dana Satterwhite, Jason Smith, Master File #614 Water Sciences Section NC Wastewa€erlGroundwater Laboratory Certification Branch 11623 "u'as_ S Ace Center, R.a!e Ioh ' oqh Car i'i n . 27699- j623 ,a`icr 44055 Reedy Creek Road, Ral&gh, North Car�dira 27607 Pnone 919 ,3.-39"-,� AAA 3-624`; r urnct r :f! .nc gw1atrouVdivis i ono/water-resources/water-resou€ces-datalwater-sciences_ho ne�pace/{a€raratca-_!cer ificatlo on, LABORATORY NAME: NPDES PERMIT : ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: • ` • ` 4 0 Corpening Creek City of Marion WWTP NC0031879 and NC0055221 3982 Hwy 226 S. Marion, NC 28752 614 August 21, 2018 Municipal Maintenance Jason Smith Revonda Carter and Tim Horton 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 2H .0800 for the analysis of compliance monitoring samples. 111. GENERAL COMMENTS: The facility is neat and well organized and has all the equipment necessary to perform the analyses. Benchsheets are well designed, easy to follow and concise. Records are well organized and easy to retrieve. The laboratory has been proactive in keeping up with updates and changes required by this Program by regularly attending Western North Carolina Laboratory Analyst Association meetings. All required Proficiency Testing (PT) Samples have been analyzed for the 2018 PT Calendar Year and the graded results were 100% acceptable. The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedures (SOP) document(s) 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 October 1, 2019. 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 Page 2 #614 Corpening Creek City of Marion WWTP 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 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". Laboratory Fortified Matrix (LFM) and Laboratory Fortified Matrix Duplicate (LFMD) are also known as Matrix Spike (MS) and Matrix Spike Duplicate (MSD) and may be used interchangeably in this report. The laboratory analyzes Turbidity and Suspended Residue samples for the Marion Water Treatment Plant in addition to their own. Contracted analyses are performed by Environmental Testing Solutions, Inc. (Certification # 600). Quality Assurance Policies for Field Laboratories and 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: Proficiency Testing A. Finding: The laboratory is not documenting the preparation of 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 (e.g., pH), but it is recommended that the instructions be maintained. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0. Comment: Dating and initialing the instruction sheet for each prepared PT Sample would satisfy the documentation requirement. Standard Operating Procedures B. Finding: The laboratory does not have SOPs for PT procedures and Vector Attraction Reduction Options 1, 4 and 6. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7). Requirement: Laboratories must have a documented plan (this is usually detailed in the laboratory's Quality Assurance Manual or may be a separate Standard Operating Procedure (SOP)) of how they intend to cover the applicable program requirements for Proficiency Testing per their scope of accreditation. This plan shall cover any commercially available PT Samples and any inter -laboratory organized studies, as applicable. The Page 3 #614 Corpening Creek City of Marion WWTP laboratory must also be able to explain when PT Sample analysis is not possible for certain methods and provide a description of what the laboratory is doing in lieu of Proficiency Testing. This shall be detailed in the plan. The plan must also address the laboratory's process for submission of PT results and related Corrective Action Reports (CARs). Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0. C. Finding: The laboratory is not following their SOP for post -analysis calibration verification of the Dissolved Oxygen meter. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Ref: 15A NCAC 2H .0805 (a) (7). Requirement: When performing DO analyses at multiple sample sites, a post -analysis calibration verification must be analyzed at the end of the run for all types of DO probes, unless the meter is recalibrated at each sample site. Below is a procedure for verifying the calibration of a DO probe. 1) Follow the manufacturer's instructions for meter operation. 2) Place probe in a plastic bag, the probe storage cup, the storage well of the meter (each containing a wet sponge), or a BOD bottle partially filled with water. Allow appropriate instrument warm up time. 3) Read DO and temperature. 4) Check the reading vs. the solubility table below and apply appropriate atmospheric (barometric) pressure or altitude correction factor. 5) Calculated DO value must verify meter reading within ± 0.5 mg/L (do NOT calculate and apply a correction factor to calculated DO). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Comment: The SOP includes the proper requirement/procedure; however, the meter is being recalibrated prior to post -analysis verification. Post -analysis calibration verification must be performed with the calibration that was used for sample analyses in order to demonstrate that the calibration is still valid. Comment: If the meter is recalibrated at each site prior to sample analysis, a post - analysis verification is not required. Quality Assurance D. Finding: Precision (e.g., relative percent difference) of QC results are not calculated, documented and evaluated to demonstrate the analytical process is in control and the established acceptance criteria are met. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7). Comment: The laboratory calculates the relative percent difference of samples annually to obtain the acceptance criteria but does not use these criteria to evaluate the duplicate results each time samples are analyzed. Page 4 #614 Corpening Creek City of Marion WWTP E. Finding: The laboratory is not verifying the thermometers in the fecal coliform and biochemical oxygen demand incubators quarterly. Requirement: Digital temperature -measuring devices and temperature -measuring devices used in incubators must be verified at least quarterly (i.e., every 3 months) (or sooner if the temperature -measuring device has been exposed to temperatures beyond the manufacturer's recommended range of use or other stresses) against a Reference Temperature -Measuring Device with the appropriate accuracy and the process documented. Ref: NC WW/GW LC Policy. Comment: The laboratory is verifying all thermometers annually and this was most recently performed on March 24, 2018. Quarterly verification of incubator thermometers is a new requirement. BOD — Standard Methods, 5210 B-2011 (Aqueous) F. Finding: The laboratory is not seeding samples analyzed more than 6 hours after collection. Requirement: Some samples (for example, some untreated industrial wastes, disinfected wastes, high -temperature wastes, wastes having pH values less than 6 or greater than 8, or wastes stored more than 6 h after collection) do not contain a sufficient microbial population. Seed such samples by adding a population of suitable microorganisms. Ref: Standard Methods 5210 B-2011. (4) (d). Nitrogen, Ammonia — Standard Methods, 4500 NH3 D-2011 (Aqueous) G. Finding: The laboratory is not analyzing a Method Blank (MB). Requirement: Include at least one MB daily or with each batch of 20 or fewer samples, whichever is more frequent. Ref: Standard Methods, 4020 B-2010. (2) (d) and Table 4020:1. Requirement: A reagent blank (method blank) consist of reagent water (see Section 1080) and all reagents (including preservatives) that are normally in contact with a sample during the entire analytical procedure. Ref: Standard Methods, 1020 B-2011. (5). H. Finding: Preservative is not being added to laboratory fortified blanks (LFB). Requirement: A laboratory fortified blank [laboratory control standard (LCS)] is a reagent water sample (with associated preservatives) to which a known concentration of the analyte(s) of interest has been added. An LFB is used to evaluate laboratory performance and analyte recovery in a blank matrix. Ref: Standard Methods, 1020 B-2011. (6). IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Corpening Creek WWTP (NPDES permit # NC0031879) for January, March and May 2018. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. Page 5 #614 Corpening Creek City of Marion WWTP Correcting the above -cited Findings 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: Jason Smith Date: September 18, 2018 Report reviewed by: Tom Halvosa Date: September 21, 2018 0 0 0 m«/ m)@ m« M 0 7«- «) « 0 e> d 7 J 2 0= 2 _@� ) _ k m K � o � o m / ƒ / \ Fi 0 M ) E ) 9 f» o-° o m o / § � § ( 9 - § 8 m o< o z o © m n 2- z f > m = % _) e & I _ z Z o § 0 = 0 Cl ] a ® § § ) § \ ) m 3 > o o o 0 § \ G > M » \0 o \ §) § ® �i—$��> ± / j> i /z° OD3 > ] ' z 0 $ m \ ® / / \ \ \ 2 0 [%/= k \ % 2 m �c=§± a e c m c> ® § — — © /0 $ > } / e # z ƒ . 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