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
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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 #:
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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.
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#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.
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#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