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HomeMy WebLinkAbout#5353_2017_0531_TS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5353 Laboratory Name: Town of Roseboro Inspection Type: Field Municipal Maintenance Inspector Name(s): Tonja Springer Inspection Date: May 31, 2017 Date Forwarded for Initial Review: June 6, 2017 .Initial Review by: Anna Ostendorff Date Initial Review Completed: June 8, 2017 Cover Letter to use: ❑ Insp. Initial ❑Insp. No Finding ❑Corrected ® Insp. Reg ❑Insp. CP ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: June 14, 2017 Date Forwarded to Admin.: June 15, 2017 Date Mailed: June 20, 2017 Special Mailing Instructions: Water Resources ENVIRONMENTAL QUALITY June 20, 2017 5353 Mr. Neil Carroll Town of Roseboro P.O. Box 848 Roseboro, NC 28382 ROY COOPER MICHEAL S. REGAN S. JAY ZIMMERMAN Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Carroll: Enclosed is a report for the inspection performed on May 31, 2017 by Tonja Springer. 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 2H .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, Tonja Springer, Master File# 5353 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: hq /ldeg no goviaboutidivisions/water-resources/water-resources-data/water-sciences•home-Daga(iaborat-branch LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): Town of Roseboro NC0026816 726 East Roseboro Street Roseboro, NC 28382 5353 May 31, 2017 Field Municipal Maintenance Tonja Springer LOCAL PERSON(S) CONTACTED: David Phillips and Neil Carroll 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 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. The laboratory analyst was very forthcoming and receptive to implementing the necessary changes in response to Findings and Recommendations made during the inspection. 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 Environmental Chemists Inc. (Envirochem) (Certification #94). 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: Documentation A. Finding: All original records were not on file. Page 2 #5353 Town of Roseboro Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). Comment: In -situ measurements for Dissolved Oxygen (DO) and Temperature are recorded on a scrap piece of paper in the field and then transferred to the benchsheet upon returning to the laboratory. The original paperwork is then discarded. Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) B. Finding: Units of measure are not documented on the benchsheets. Requirement: Data pertinent to each analysis must be maintained for five years. Certified data must consist of date collected, time collected, samples site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Comment: Units of measure are not documented for the meter calibration temperature (i.e., °C) and dissolved oxygen (i.e., mg/L). Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Temperature — Standard Methods, 2550 B-2000 (Aqueous) C. Finding: Sample analysis time is not clearly documented as being analyzed in situ. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Date and time of sample collection; Date and time of sample analysis. Alternatively, since EPA requires samples to be analyzed immediately one time may be documented for collection and analysis with the notation that samples are measured in situ or immediately at the sample site. When this "one time" option is used, state that the documented time is both collection and analysis time. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Date and time of sample collection; Date and time of sample analysis to verify the 15 minute holding time is met. Alternatively, one time may be documented for collection and analysis with the notation that samples are measured in situ or immediately at the sample site. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Comment: There was only one time documented on the benchsheet, with no statement that the sample was analyzed in situ or on site. D. Finding: The laboratory benchsheet is lacking pertinent data: facility name. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: facility name. Ref: The NC WW/GW LC Approved Procedure for the Analysis of Temperature and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Page 3 #5353 Town of Roseboro Temperature — Standard Methods, 2550 B-2000 (Aqueous) E. Finding: The laboratory is analyzing samples and reporting data for parameters without North Carolina Wastewater/Groundwater Laboratory Certification. Requirement: Commercial, Municipal, Industrial and Other facilities are required to obtain certification for field parameters which will be reported by the client to comply with State surface water, ground water, and pretreatment Rules. Ref: 15 A NCAC 2H .0804 (a). Please submit an amendment form requesting certification with the report reply. Comment: The facility's NPDES permit requires Temperature to be analyzed weekly on the Effluent, Upstream and Downstream sites. The laboratory is analyzing and reporting the Upstream and Downstream sample results. The Effluent Temperature is being analyzed by a contract lab. F. Finding: The temperature sensing device on the DO meter, used to obtain reported temperature values for compliance monitoring, has not been calibrated against a NIST traceable thermometer every 12 months. Requirement: All thermometers and temperature measuring devices used for compliance monitoring must be checked every 12 months against a NIST traceable temperature measuring device and the process documented. NIST traceable temperature measuring devices used for this verification must have a stated accuracy of at least ± 0.5 °C. The thermometer/meter readings must be less than or equal to 0.5 °C from the NIST traceable temperature measuring device reading. The calibration verification documentation must include the serial number of the thermometer/meter being checked and the NIST traceable temperature measuring device that was used in the comparison. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. 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 the Town of Roseboro (NPDES # NC0026816) for January, February and March 2017. The following errors were noted: Date Parameter Location Value on Benchsheet Value on eDMR 1/11/2017 DO Downstream 13.1 mg/L 3.0 mg/L 1/11/2017 Temperature Downstream 3.0 °C 13.1°C 3/15/2017 DO Downstream 10.3 mg/L 6.8 mg/L 3/15/2017 Temperature Downstream 6.8 °C 10.3 °C To avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended eDMR will be required. A copy of this report will be made available to the Regional Office. Page 4 #5353 Town of Roseboro V. CONCLUSIONS: 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 and implementation dates for each corrective action. Report prepared by: Tonja Springer Date: June 5, 2017 Report reviewed by: Anna Ostendorff Date: June 8, 2017 N w w a 0 w LL F w u N W O O M p O O 0 N d o Z 0 � � o o `o c w 3 � o N Z .o a J Q 9