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To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5463
Laboratory Name:
Town of Rich Square
Inspection Type:
Field Maintenance
Inspector Name(s):
Anna Ostendorff, Gary Francies & Todd Crawford
Inspection Date:
February 2, 2016
Date Report Completed:
March 21, 2016
Date Forwarded to Reviewer:
March 21, 2016
Reviewed by:
Jason Smith
Date Review Completed:
March 22, 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 22, 2016
Date Forwarded to Admin: March 31, 2016
Date Mailed: March 31, 2016
Water resources
ENVIRONMENTAL QUALITY
March 31, 2016
5463
Mr. Jeff Long.
Town of Rich Square
PO BOX 336
Rich Square, NC 27869
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Long:
Enclosed is a report for the inspection performed on February 2, 2016 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. 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 (828) 296-4677.
Attachment
cc: Anna Ostendorff, master file
Sincerely,
G�
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences Section
NC Wastewater/Groundwater Laboratory Cerfirication 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: bttp://portal.ncdenr.orq/web/wq/lab/cert
LABORATORY NAME: Town of Rich Square
NPDES PERMIT : NC0025437
WATER QUALITY PERMIT #: WQ0023203
ADDRESS: PO BOX 336
Rich Square, NC 27869
CERTIFICATE : 5463
DATE OF INSPECTION: February 2, 2016
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Anna Ostendorff, Gary Francies and Todd Crawford
LOCAL PERSON(S) CONTACTED: Jeff Long
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:
Staff were forthcoming and seemed eager to adopt necessary changes.
All required Proficiency Testing (PT) samples for the 2016 PT calendar year have not yet been
completed. The laboratory is reminded that these results must be received by this office directly
from the vendor by September 30, 2016.
Contracted analyses are performed by Environment 1, Inc. (Certification # 10).
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.
Utilization of the benchsheet supplied by the auditor on 2/16/2016 via email would fulfill the
documentation requirements in Findings D, E, F and G.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. 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 chemicals,
reagents, standards and consumables used for a period of five years. Consumable materials
such as pH buffers and Total Residual Chlorine (TRC) Reagents are included in this
requirement. Ref: Quality Assurance Policies for Field Laboratories.
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#5463 Town of Rich Square
Comment: Utilization of the traceability document supplied by the auditor on 2/16/2016 via
email would fulfil this requirement.
Proficiency Testing
B. Finding: Proficiency Testing (PT) sample analyses are not being documented 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.
Comment: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed
and the process documented in the same manner as environmental samples.
C. Finding: The preparation of 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.
Chlorine, Total Residual — Hach Method 10014 ULR
Dissolved Oxygen — Standard Methods, 4500 O G-2001
pH — Standard Methods, 4500 H+ B-2000
Temperature — Standard Methods, 2550 B-2000
D. Finding: Pertinent data is not being documented: date collected, time collected, sample
analysis time, sample site, analyst's initials, units of measure and 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 bench sheets must provide a space for the signature or
initials of the analyst and proper units of measure for all analyses. Ref: 15A NCAC 02H
.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 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 pH, NC WW/GW
LC Approved Procedure for the Analysis of Temperature.
Comment: A date was documented but was not clearly identified as sample collection
and/or analysis date.
pH — Standard Methods, 4500 H+ B-2000
Dissolved Oxygen — Standard Methods, 4500 O G-2001
E. Finding: Calibration of the pH meter and DO meter are not documented.
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#5463 Town of Rich Square
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: meter calibration, meter calibration time(s) and true value of buffers used for
calibration. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH.
Requirement: The laboratory must document each time that a calibration is performed.
Calibration documentation must include the following, where applicable to the instrument used
and the type of calibration performed: elevation, temperature, barometric pressure (in mmHg),
salinity, slope or % efficiency. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen.
Comment: DO and pH meters are being calibrated each day samples are analyzed but
calibration information is not documented.
pH — Standard Methods, 4500 H* B-2000
F. Finding: Calibration verification of the pH meter with a check buffer is not performed or
documented.
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.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: 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.
Chlorine, Total Residual — Hach Method 10014 ULR
G. Finding: The daily calibration curve verification is not properly performed or documented.
Requirement: When a five -standard annual standard curve verification is used, the
laboratory must check the calibration curve each analysis day. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Value obtained for the check standard (verification of ± 10% recovery). Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The daily calibration curve verification was being performed on program 80, but
samples are analyzed on program 86. The daily calibration curve verification must be
performed on the same program (86) on which environmental samples are analyzed and
must be documented.
H. Finding: Values less than the established reporting limit are being reported on the
Discharge Monitoring Report (DMR).
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. One of the standards must have a concentration
equal to or below the lower reporting concentration for Total Residual Chlorine. The lower
reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
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#5463 Town of Rich Square
Comment: The laboratory currently has established a lower reporting limit of 10 pg/L by
having analyzed that concentration when verifying the calibration curve on January 27, 2016.
Environmental samples with concentration values less than that must be reported as < 10
pg/L on the DMR. The lower reporting limit may change depending on the lowest standard
verified when performing the annual calibration curve verification.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water Resources.
Data were reviewed for NPDES permit # NC0025437 for January, July and December, 2015. The
following errors were noted:
Date
Parameter
Location
Value on
Value on DMR
Benchsheet
12/08/2015
Dissolved Oxygen
Effluent
No Value
5.8 pg/L
Recorded
12/15/2015
Dissolved Oxygen
Effluent
No Value
5.7 pg/L
Recorded
12/22/2015
Dissolved Oxygen
Effluent
No Value
5.5 pg/L
Recorded
12/29/2015
Dissolved Oxygen
Effluent
No Value
5.7 pg/L
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 DMR will be required. A copy of this report will be
made available to the Regional Office. Values reported on the DMR without supporting
documentation may be perceived as Falsified Data or Information.
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: Anna Ostendorff Date: March 21, 2016
Report reviewed by: Jason Smith Date: March 22, 2016