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HomeMy WebLinkAbout#5268_2016_0816_NJ_FINALINSPECTION REPORT ROUTING SHEET Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: To be attached to all inspection reports in-house only. 5268 Town of Flookerton Field Municipal Initial Nick Jones August 16, 2016 Date Report Completed: August 30, 2016 Date Forwarded to Reviewer: August 30, 2016 Reviewed by: Jason Smith Date Review Completed: September 7, 2016 Cover Letter to use: ®Insp. Initial ❑Insp. No Finding ❑Corrected ❑Insp. Reg F�Insp. CP_ ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: September 8, 2016 Date Forwarded to Admin.: September 19, 2016 Date Mailed: September 23, 2016 Special Mailing Instructions: Water Resources ENWRONMENTAI_ QUALITY September 20, 2016 5268 Ms. Jennifer L. Bray Town of Hookerton PO Box 296 Hookerton, NC 28538 PAT MCCRORY DONALD R. VAN DER VAART S. JAY ZIMMERMAN SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Bray: Enclosed is a report for the inspection performed on August 16, 2016 by Nick Jones. 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. 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, Nick Jones, Master File #5268 Water Sciences Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Locatiom 4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone, 919-733-39061 FAX: 919-733-6241 Internet: http:fldea.nc.gov/about/divisionslwater-resources/water•resources-datalwater-sciences-home-page/laboratoEy-certification-branch LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): On -Site Inspection Report Town of Hookerton NCO025712 227 E. Main St Hookerton, NC 28538 5268 August 16, 2016 Field Municipal Initial Nick Jones LOCAL PERSON(S) CONTACTED: Jennifer Bray 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. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. Records are well organized and easy to retrieve. Staff was forthcoming and eager to adopt necessary changes. All required Proficiency Testing (PT) samples for the 2016 PT calendar year have not been analyzed. The laboratory is reminded that results must be received by this office directly from the vendor by September 30, 2016. 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 methods were provided at the time of the inspection. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Quality Assurance / Quality Control A. Finding: The auto-pipettors have not been calibrated annually as required. Requirement: 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 three volumes is optional. When a device capable of variable settings is dedicated to dispense a single Page 2 #5268 Town of Hookerton specific volume, calibration is required at that setting only. Ref: Quality Assurance Policies for Field Laboratories. Comment: The lab utilizes a mechanical pipette to measure reagents and standards for the analysis of Total Residual Chlorine. B. Finding: Error corrections are not always performed properly. 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: Quality Assurance Policies for Field Laboratories. Proficiency Testing C. Finding: The preparation of Proficiency Testing (PT) samples is not documented. Requirement: 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. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT would satisfy the documentation requirement. Documentation D. 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 as well as the vendor and/or manufacturer, lot number. and expiration date must be retained for chemicals, reaaents. 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. Ref: Quality Assurance Policies for Field Laboratories. Dissolved Oxygen — Standard Methods, 4500 O G-2001 E. Finding: The meter is not being calibrated prior to analysis of samples each day compliance monitoring is performed. 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 Dissolved Oxygen. Requirement: Meter calibration and meter calibration time must be documented on the benchsheets. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Page 3 #5268 Town of Hookerton pH — Standard Methods, 4500 H+ B-2000 (Aqueous) F. Finding: Manufacturer expiration dates could not be determined. Requirement: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, 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. If no expiration date is given, the laboratory must have a policy for assigning an expiration date. If no date received or expiration date can be determined the item should be discarded. Ref: Quality Assurance Policies for Field Laboratories. Comment: The lab had three 40-mL volatile organics vials containing aliquots of their pH buffers (i.e., 4, 7 and 10 s.u.). These portions were obtained from Envirochem when the lab was preparing for their initial certification sometime during 2015. They are being reused to calibrate the pH meter each day compliance monitoring is performed. No information regarding the Vendor, Lot # or Date of Expiration were available. Recommendation: It is recommended that a portion of the buffer solutions not be used for more than one calibration. Discard any used buffer portions. Temperature — Standard Methods, 2550 B-2000 (Aqueous) G. Finding: The temperature sensing device on the D.O. meter, used to report Temperature for compliance monitoring, was not calibrated against an NIST traceable thermometer prior to initial use. Requirement: Any temperature measuring device, used to measure temperature for compliance monitoring, must be verified against a National Institute of Standards and Technology (NIST) traceable temperature measuring device prior to initial use and re -verified at least every 12 months and any time the instrument is serviced. NIST traceable temperature measuring devices used for this verification must have a stated accuracy of at least ± 0.5 °C. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: Notification of partial acceptable corrective action (i.e., documentation of the thermometer calibration check performed on August 22, 2016) was received from Envirochem by email on August 29, 2016. The lab has not stated that it will continue to verify their temperature sensing device against an NIST traceable thermometer at least every twelve months. Chlorine, Total Residual — Hach Method, 10014 ULR (Aqueous) H. Finding: The laboratory benchsheet for Total Residual Chlorine is lacking pertinent data: analysis time and the true value of the daily check standard. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Analysis Time and True Value of the Check Standard. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Page 4 #5268 Town of Hookerton I. Finding: The laboratory is not verifying the instrument's factory set curve every 12 months. Requirement: Analyze a water blank to zero the instrument and then analyze a series of five standards. The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. This type of curve verification must be performed at least every 12 months. The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 mg/L and must not vary by more than 25% of the known value for standard concentrations less than 50 mg/L. The overall correlation coefficient of the curve must be 4.995. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Please submit a copy of the curve verification with the report reply. Comment: The annual 5-Standard calibration curve verification performed on August 22, 2016 did not pass the individual standard recovery criteria. J. Finding: The laboratory is not verifying the Gel® Standard every 12 months. Requirement: Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily standard curve verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. When this is done, these standards may be used after the manufacturer's expiration date. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Dissolved Oxygen Standard Methods, 4500 0 G-2001 Temperature — Standard Methods, 2550 B-2000 (Aqueous) K. Finding: The laboratory records for Dissolved Oxygen and Temperature which document up and down stream compliance monitoring are lacking pertinent data: sample site including facility name and location, ID, etc., Collector's/analyst's name or initials, Meter calibration and meter calibration time(s), Units and Instrument identification. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: sample site including facility name and location, ID, etc., collector's/analyst's name or initials, meter calibration and meter calibration time(s). units and instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: The up and down stream compliance results are being recorded on a calendar. The data being documented on the calendar includes: sample collection/analysis time and the sample result for Dissolved Oxygen and Temperature. Recommendation: It is recommended that the lab develop a benchsheet to document up and down stream analyses. pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Chlorine, Total Residual — Hach Method, 10014 ULR (Aqueous) L. Finding: The laboratory benchsheets for pH and Total Residual Chlorine are lacking pertinent data: meter calibration time. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Meter Calibration Time. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for the Analysis of pH. Page 5 #5268 Town of Hookerton Dissolved Oxygen — Standard Methods, 4500 O G-2001 pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Chlorine, Total Residual — Hach Method, 10014 ULR (Aqueous) M. Finding: The laboratory benchsheets for Dissolved Oxygen, pH and Total Residual Chlorine are lacking pertinent data: units of measure. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Units of Measure. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of pH. Dissolved Oxygen — Standard Methods, 4500 O G-2001 pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Temperature — Standard Methods, 2550 B-2000 (Aqueous) Chlorine, Total Residual — Hach Method, 10014 ULR (Aqueous) N. Finding: The laboratory benchsheets for Dissolved Oxygen, pH, Temperature and Total Residual Chlorine are lacking pertinent data: instrument identification. 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 Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of Temperature and 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 Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Town of Hookerton (NPDES permit # NC0025712) for March, April and June 2016. No transcription errors were detected. 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 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: Nick Jones Date: August 30, 2016 Report reviewed by: Jason Smith Date: September 7, 2016