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HomeMy WebLinkAbout#5224_2016_0202_AO_FINALTo be attached to all inspection reports in-house only. Laboratory Cert. #: 5224 Laboratory Name: Town of Seaboard Inspection Type: Field Maintenance Inspector Name(s): Anna Ostendorff, Gary Francies, and Todd Crawford Inspection Date: February 2, 2016 Date Report Completed: March 4, 2016 Date Forwarded to Reviewer: March 7, 2016 Reviewed by: Beth Swanson Date Review Completed: March 7, 2016 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected ❑ Insp. Reg. Delay Unit Supervisor/Chemist III: Gary Francies Date Received: March 7, 2016 Date Forwarded to Linda: March 11, 2016 Date Mailed: March 14, 2016 ErZ , f art 7J Water Resources enrv,cRONMLNTAL QUAWr March 11, 2016 5224 Mr. Joey Barnes Town of Seaboard PO Box 327 Seaboard, NC 27876 PAT MCCRORY DONALD R. VAN DER VAART 1, S. JAY ZIMMERMAN Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Barnes: Enclosed is a report for the inspection performed on February 2 by Anna Ostendorff, Gary Francies and Todd Crawford. I apologize for the delay in getting this report to you. 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. Copies of the checklists completed during the inspection may be requested from this office. Thank you for your cooperation during the inspection. Ifyouwish 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. Attachment cc: Anna Ostendorff, master file Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources 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: 919-733-39081 FAX: 919-733-6241 internet: http:l ®rtal.ncdenr.orgtweb1N ab1cert WATER QUALITY PERMIT #: CERTIFICATE #: ItV1»•7;M1Z1&,1U C•7TF r •_ • NO 4 - • • 9 I. INTRODUCTION: On - Site Inspection Report Town of Seaboard WQ0003299 PO Box 327 Seaboard, NC 27876 5224 February 2, 2016 Field Maintenance Anna Ostendorff, Gary Francies, and Todd Crawford Joey Barnes 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: Contracted analyses are performed by Environment 1, Inc. (Certification #10). Current Quality Assurance Policies for Field Laboratories and Approved Procedures for the analysis of the facility's currently certified parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: The laboratory was not documenting all pertinent information: time collected, sample site, sample analysis time, proper units of measure, instrument identification. 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)• Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: The benchsheet column heading "Time" must be clarified to indicate sample collection and/or analysis time. As long as the facility continues to analyze samples in situ, the column heading may read "collection/analysis time". Please submit a copy of an updated benchsheet. Page 2 #5224 Town of Seaboard E. Finding: The laboratory needs to increase the documentation of purchased materials and reagents. Requirement: 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 must be retained for a period of five years. Consumable materials such as pH buffers are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. C. Finding: Several instances of writing over a number as a means of error correction were observed. Requirement: All documentation errors must be corrected by drawing a single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: NC WW/GW LC Policy. Proficiency Testing D. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples. Requirement: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. pH — Standard Methods, 4500 H+ E-2000 Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard Methods, 4500 H+ B-2000, (6) states in part: However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 pH unit. Acceptable corrective action (i.e., Number of digits for pH results was adjusted to 0.1 units on digital DMR template) was performed during the inspection and observed by the inspector to be adequate. No further response is necessary for this Finding. E. Finding: Manufacturer expiration dates of pH buffers are exceeded. Requirement: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, and consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specific day of the month), the last day of the month will be considered the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes may indicate potential contamination and the item should be discarded, even if the expiration date is not exceeded. Ref: Quality Assurance Policies for Field Laboratories. F. Finding: The pH meter was not being calibrated each day samples were analyzed. Requirement: Instruments are to be calibrated according to the manufacturer's calibration procedure prior to analysis of samples each day compliance monitoring is performed. Ref. NC WW/GW LC Approved Procedure for the Analysis of pH. Page 3 #5224 Town of Seaboard Comment: The meter was calibrated on some days but not each day samples were analyzed for compliance reporting. G. Finding: The laboratory was not performing calibration verification. Requirement: The meter must be calibrated with at least two buffers. In addition to the calibration buffers, the meter calibration must be verified with a third standard buffer solution. The check standard buffer must read within ±0.1 Standard Units (S.U.) to be acceptable. If the meter verification does not read within ±0.1 S.U., the meter must be recalibrated before any samples are analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. H. Finding: Calibration of the pH meter is not documented. Requirement: The following must be documented in indelible ink whenever sample analysis is performed. Meter calibration, meter calibration time(s), true value of buffers used for calibration, true value for the check standard buffer, and value obtained for the check standard buffer (verification of ± 0.1 S.U.). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to Non -Discharge Monitoring Reports (NDMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for May, October and September, 2015. The following error was noted: Date Parameter Location Value on Value on NDMR Benchsheet 9/25/15 pH Effluent No Value 5.6 S.U. Recorded In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Non -Discharge Monitoring Report will be required. A copy of this report will be made available to the Regional Office. A value reported on the NDMR without supporting documentation may appear to be falsified. V. CONCLUSIONS: Correcting the above -cited Findings will help this lab 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. Report prepared by: Anna Ostendorff Date: March 4, 2016 Report reviewed by: Beth Swanson Date: March 7, 2016