HomeMy WebLinkAbout#5394_2017_0308_TS_FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5394
Laboratory Name:
Star WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tonja Springer
Inspection Date:
March 8, 2017
Date Forwarded for Initial
Review:
April 3, 2017
Initial Review by:
Beth Swanson
Date Initial Review
Completed:
April 3, 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:
April 7, 2017
Date Forwarded to Admin.:
April 20, 2017
Date Mailed:
April 25, 2017
Special Mailing Instructions:
Water Rescourc es
ENVIacsrsMF EAL QUALO Y
April 25, 2016
5394
Mr. Wesley Brown
Star WWTP
P.O. Box 97
Star, NC 27356
MICHEAL S. REGAN
i.." IP i"?`ii
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Brown:
Enclosed is a report for the inspection performed on March 8, 2017 by Tonja Springer. Since the
Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a
response is not required. The staff is commended for taking the initiative in correcting the Findings in
such a timely manner. 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 electronic mail, 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 5394
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 t FAX: 919-733-6241
Internet: hffp:lldeg.nc.gov/aboutldivisions/water-resources/water•resources-data/water-sciences-home-oaqeflaboratory-certification-branch
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Star WWTP
NCO058548
454 South Main St.
Star, NC 27356
5394
March 8, 2017
Field Municipal Maintenance
Tonja Springer
LOCAL PERSON(S) CONTACTED: Wesley Brown and Robin Hussey
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 the items
found Findings and Recommendations made during the inspection.
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.
Contracted analyses are performed by Pace Analytical Services, LLC - Asheville, NC (Certification
#40).
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
Comment: The laboratory benchsheet was lacking pertinent data: Instrument identification. The
NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC
Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the
Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine documents state: The following must be documented in indelible ink whenever
sample analysis is performed: Instrument identification. Notification of acceptable corrective action
#5394 Star WWTP
(i.e., an updated benchsheet which includes instrument identification with an implementation date
of March 29, 2017) was received by email on March 29, 2017. No further response is
necessary for this Finding.
Proficiency Testing
Comment: The laboratory was not analyzing PT samples in the same manner as compliance
samples. The laboratory was analyzing pH and Total Residual Chlorine (TRC) PT samples
multiple times and reporting an average of all results. Compliance samples are not analyzed
and reported in this manner. The Proficiency Testing Requirements, February 20, 2012,
Revision 1.2. document states: All PT samples are to be analyzed and the results reported in a
manner consistent with the routine analysis and reporting requirements of compliance samples
and any other samples analyzed according to the requirements of 15A NCAC 2H .0800.
Notification of acceptable corrective action (i.e., a statement that beginning with the 2017 PT
study, PT samples will be analyzed and documented in the same manner as regular samples)
was received by email on March 28, 2017. No further response is necessary for this Finding.
Comment: The preparation of TRC PT sample is not documented. The Proficiency Testing
Requirements, February 20, 2012, Revision 1.2. document states: PT samples received as
ampules must be diluted according to the PT provider's instructions. The preparation of PT
samples must be documented in a traceable log or other traceable format. The diluted PT
sample becomes a routine environmental sample and is added to a routine sample batch for
analysis. Notification of acceptable corrective action (i.e., a statement that beginning with the
2017 PT samples, the PT vendor's preparation instructions will be initialed and dated and kept
as a permanent record for five years) was received by email on March 30, 2017. No further
response is necessary for this Finding.
Comment: The laboratory is not documenting TRC and pH PT sample analyses in the same
manner as environmental samples. PT sample results are documented directly on the vendor
report form and not on the benchsheet. The Proficiency Testing Requirements, February 20,
2012, Revision 1.2. document states: All PT sample analyses must be recorded in the daily
analysis records as for any environmental sample. This serves as the permanent laboratory
record. Notification of acceptable corrective action (i.e., a statement that beginning with the
2017 PT study, PT samples will be analyzed and documented like the regular samples) was
received by email on March 28, 2017. No further response is necessary for this Finding.
Chlorine Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Recommendation: It was recommended at the inspection that the laboratory extend the range of
the calibration curve to bracket the daily check standard. The daily check standard was at the
same concentration (i.e., 250 pg/L) as the highest standard in the annual verification curve. The
acceptance criterion for the daily check standard is ± 10% of the true value. If the standard
recovery is running high, the standard would be outside the range of the calibration curve. The
laboratory sent a copy of an annual verification curve that had been analyzed in the range of 13 -
421 pg/L on March 30, 2017.
Comment: The auto-pipettors have not been calibrated annually as required. Pipettes are used
to make the daily check standard. The Quality Assurance Policies for Field Laboratories
document states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable
auto-pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated
at least every twelve months and documented. Each liquid -dispensing device must meet the
manufacturer's statement of accuracy. For variable volume devices used at more than one
setting, check the accuracy at the maximum, middle and minimum values. Testing at more than
#5394 Star VWVFP
three volumes is optional. When a device capable of variable settings is dedicated to dispense
a single specific volume, calibration is required at that setting only. Notification of acceptable
corrective action (i.e., a statement that in lieu of calibrating pipettors the facility has eliminated
the use of the auto-pipettor and has begun to use a Gel® standard that has been assigned a
true value, with an implementation date of March 29, 2017) was received by email on March 30,
2017. No further response is necessary for this Finding.
Comment: The units on the laboratory benchsheet were documented as mg/L instead of pg/L.
The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document
states: The following must be documented in indelible ink whenever sample analysis is
performed: Units of measure. Notification of acceptable corrective action (i.e., an updated
benchsheet with pg/L and an implementation date of March 30, 2017) was received by email on
March 29, 2017. No further response is necessary for this Finding.
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 Star WWTP (NPDES
# NC0058548) for August and December 2016. The following errors were noted:
Date
Parameter
Location
Value on
Benchsheet
*Contract Lab Data
Value on eDMR
8/29/2016
DO
Effluent
6.3 mg/L
No Value Reported
8/30/2016
DO
Effluent
6.6 mg/L
No Value Reported
12/7/2016
DO
Effluent
7.9 mg/L
No Value Reported
12/10/2016
Total Nitrogen
Effluent
*No value Reported
2.1 mg/L
12/10/2016
DO
Effluent
8.1 mg/L
No Value Reported
*A sample was not analyzed for Total Nitrogen. The contract laboratory's result for
Ammonia was mistakenly reported on the eDMR for both Ammonia and Total Nitrogen.
In order to avoid a possible monitoring frequency violation, 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.
V. CONCLUSIONS:
All Findings noted during the inspection were adequately addressed prior to the completion of this
report. The inspector would like to thank the staff for its assistance during the inspection and data
review process. No response is required.
Report prepared by: Tonja Springer Date: March 30, 2017
Report reviewed by: Beth Swanson Date: April 7, 2017
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