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HomeMy WebLinkAbout#5044_2017_0606_TLH_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5044 Laboratory Name: Farmville UWVfP Inspection Type: Field Municipal Maintenance Inspector Name(s): Tom Halvosa, Gary Francies, Dana Satterwhite and Todd Crawford Inspection Date: June 6, 2017 Date Forwarded for Initial June 14, 2017 Review: Initial Review by: Beth Swanson Date Initial Review June 14, 2017 Completed: ❑ Insp. Initial ® Insp. Reg Cover Letter to use: ❑Insp. No Finding ❑Corrected ❑Insp. CP ❑Insp. Reg. Delay (to use: rt click, properties, check) Unit Supervisor/Chemist III: Todd Crawford Date Received: June 15, 2017 Date Forwarded to Admin.: June 19, 2017 Date Mailed: June 20, 2017 Special Mailing Instructions: ROY COOPER Tj �s o k-� WaterResources ENVIRONMENTAL QUALITY June 20, 2017 5044 Mr. James Shoulders Farmville WWTP P.O. Box 102 Farmville, NC 27828 MICHEAL S. REGAN "J PY; S. JAY ZIMMERMAN Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Shoulders: Enclosed is a report for the inspection performed on June 6, 2017 by Tom Halvosa. 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 (919) 733-3908 ext. 251. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Dana Satterwhite, Tom Halvosa, Master File # 5044 Water Sciences Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-733-3908', FAX: 919-733-6241 Internet: htti):Ildeci.nc.goviaboutidivisions/water-resourcestwater-resources•data/water-sciences-home-pagetlaborator -certification-branch a• • LABORATORY NAME: Farmville WWTP NPDES PERMIT #: NC0029572 WATER QUALITY PERMIT : WQ0008778 ADDRESS: 2884 Chiquapin Rd. Farmville, NC 27828 CERTIFICATE #: 5044 DATE OF INSPECTION: June 6, 2017 TYPE OF INSPECTION: Field Municipal Maintenance AUDITOR(S): Tom Halvosa, Gary Francies, Dana Satterwhite and Todd Crawford LOCAL PERSON(S) CONTACTED: James Shoulders and Greg Sugg INTRODUCTION: This laboratory was inspected by representatives 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 environmental samples. II. 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. Staff were forthcoming and seemed eager to adopt necessary changes. The laboratory is commended for having Standard Operating Procedures (SOPs), which are not yet required for Field Laboratories. The system of chemical and reagent traceability to source materials was thorough and easy to follow. All required Proficiency Testing (PT) Samples for the 2017 PT 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, 2017. Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst and proper units of measure for all analyses", are intended to be a requirement to document all pertinent information for historical reconstruction of data. It is not intended to imply that existing records are not adequately maintained unless the Finding speaks directly to that. Contracted analyses are performed by Environment 1, Inc. (Certification # 10). Page 2 #5044 Farmville VWVTP Current 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: Quality Control Comment: The laboratory was calibrating the National Institute of Standards and Testing (NIST) thermometer used to verify the temperature sensors of laboratory meters more often than required. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states that NIST traceable thermometers used to verify the calibration of other thermometers or temperature sensors (i.e., limited use only) must be recalibrated in accordance with the manufacturer's recalibration date and the process documented. If no recalibration date is given, the NIST traceable thermometer must be recalibrated every 5 years. Documentation . A. Finding: All original records are not being maintained for five years. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). Comment: The testing data for Dissolved Oxygen and Temperature is initially written on a piece of paper, transported back to the laboratory, and transferred to the benchsheet. It was the laboratory's intent to maintain this original paperwork, however; because these were individual, loose sheets of paper, much of it was unintentionally discarded. Recommendation: It is recommended that if this system of documentation is maintained, that the data be recorded on some type of bound notebook to conveniently keep pages together and ensure the 5-year record retention requirement is met. Total Residual Chlorine — Standard Methods, 4500 CI G-2000 (Aqueous) Comment: As stated in the Approved Procedure for the Analysis of Total Residual Chlorine document, it is permissible to use gel -type standards after the manufacturer's stated expiration date if their true values are verified and documented, every 12 months. B. Finding: Values less than the established reporting limit are being reported on the electronic Discharge Monitoring Report (eDMR). Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The laboratory currently has established a lower reporting limit of 15 pg/L by having verified that concentration when verifying the latest calibration curve. Compliance samples with concentrations less than that must be reported as < 15 lag/L on the eDMR. Page 3 #5044 Farmville VWVTP C. Finding: The calibration check standard observed concentration column heading specifies pg/L, but the value is documented in mg/L. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Recommendation: It is recommended that the observed values be documented in pg/L, as opposed to changing the column heading units to mg/L. Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Recommendation: It was recommended that the benchsheet be amended to state that the calibration is based on an altitude of 10 feet. The benchsheet was amended during the inspection and immediately put into use. pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Conductivity — Standard Methods, 2510 B-1997 (Aqueous) Comment: Lot numbers of pH buffers and Conductivity standards were hard -printed onto benchsheets. When the latest lots of pH 4 buffer and 447 pmho/cm Conductivity standard were put into use, the benchsheet was not updated. However, all reagents and standards are also documented on a reagent receipt log and it indicated the correct lot numbers by the date opened/put in use. The Quality Assurance Policies for Field Laboratories document states: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date Received, Date Opened (in use), Vendor, Lot Number, and Expiration Date. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Acceptable corrective action (i.e., All hard -printed lot numbers were removed from the benchsheet. The revised benchsheet was reprinted and immediately put into use. Traceability is now maintained solely through the reagent receipt log.) was performed by the laboratory and approved by the auditor during the inspection. No further response is necessary for this Finding. Conductivity —Standard Methods, 2510 B-1997 (Aqueous) Comment: Cell constant determination is not required for the meter in use. Temperature — Standard Methods, 2550 B-2000 (Aqueous) Comment: The thermometer identification was incorrectly listed on the laboratory benchsheet. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Acceptable corrective action (i.e., the benchsheet was updated to show that the DO meter is used to measure temperature, then reprinted and immediately put into use) was performed by the laboratory and approved by the auditor during the inspection. No further response is necessary for this Finding. Page 4 #5044 Farmville WWTP IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for Farmville WWTP (NPDES permit # NC0029572) for random months in 2016, and March and May, 2017. 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 Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation and implementation dates for each corrective action. 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