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HomeMy WebLinkAbout#5463_2016_0202_AO_FINAL► - •► MIN =1 '• hleIMa=1 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. Page 2 #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. Page 3 #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. Page 4 #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