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HomeMy WebLinkAbout#5462_1216_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed• Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor/Chemist III: Date Received: Date Forwarded to Linda: Date Mailed: 5462 Davie Co. Water- Sparks Rd WTP Field Maintenance Beth Swanson, Gary Francies December 16, 2015 January 5 2016 January 5 2016 Jason Smith January 6 2016 ❑ Insp. Initial ❑ Insp. No Finding ❑ Corrected ® Insp. Reg. ❑ Insp. CP ❑ Insp. Reg. Delay Gary Francies January 8 2016 1 /20/2016 1 /20/2016 Water Resources r NWRONMENTAL QUALITY January 20, 2016 5462 Mr. Michael Weir Davie Co. Water- Sparks Rd. WTP 728 Sparks Rd. Mocksville, NC 27028 PAT MCCRORY DONALD R. VAN DER VAART i`ti l7'fit7;1; S. JAY ZIMMERMAN ': 'rrd' y"). Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Weir: Enclosed is a report for the inspection performed on December 16, 2015 by Beth Swanson and Gary Francies. 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. Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Attachment cc: master file Beth Swanson LABORATORY NAME: Davie Co. Water- Sparks Rd. WTP NPDES PERMIT #: NC0084212 ADDRESS: 728 Sparks Rd. Mocksville, NC 27028 CERTIFICATE #: 5462 DATE OF INSPECTION: December 16, 2015 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Beth Swanson and Gary Francies LOCAL PERSON(S) CONTACTED: Michael Weir 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. The staff is well organized and take pride in their work. Contracted analyses are performed by Statesville Analytical (Certification #440). Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2015 proficiency testing calendar year. The laboratory has fulfilled its PT requirements for the 2015 calendar year. 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. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: The laboratory needs to increase the traceability of purchased materials. 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, reagents, 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. Page 2 #5462 Davie Co Water- Sparks Rd WTP Comment: No traceability information is currently retained. A traceability log was emailed to the lab following the inspection. Use of this log will fulfill traceability requirements. B. Finding: The laboratory benchsheet was 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 pH and NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Qualitv Control C. Finding: The auto-pipettor has not been calibrated annually as required. Requirement: Mechanical volumetric liquid -dispensing devices (e.g.,fixed and adiustable auto i ettors, 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 specific volume, calibration is required at that setting only. Ref: Quality Assurance Policies for Field Laboratories. Comment: The laboratory uses a TenSette® pipettor to prepare the yearly PT sample. The preparation of this standard is considered a critical measurement. Recommendation: Since the pipette is only used for critical measurements once per year, it is recommended that a 1 mL Class A volumetric pipette be obtained for PT preparation. A volumetric pipette does not require calibration. Proficiencv Testing D. Finding: The laboratory is not analyzing PT samples in the same manner as environmental samples. Requirement: All PT samples are to be analyzed and the results reported in a manner consistent with the routine analysis and reporting requirements of compliance samples and any other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: The laboratory's common practice was to analyze a known standard along with the PT sample as additional quality control. Since this is not performed with all environmental samples, it is considered additional quality control. However, known samples are recommended when analyzing remedial PT samples as part of the troubleshooting and corrective action process. E. Finding: The laboratory is not documenting 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. Comment: The analyst currently records the result on the PT preparation sheet only. Page 3 #5462 Davie Co Water- Sparks Rd WTP F. 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. pH — Standard Methods, 4500 H+B-2000 Comment: The laboratory is having the Automatic Temperature Compensation (ATC) and temperature sensor on the pH meter checked on an annual basis. The ATC check is not required for pH meters and the temperature sensor check is only required for thermometers or meters used for temperature compliance testing. G. Finding: pH buffers are not traceable to the source. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Traceability for chemicals reagents standards and consumables Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: The laboratory uses cleaned bottles from previous buffer standards to hold aliquots from a 4L buffer container for daily use. These bottles still have labels with an old lot number and expiration date. H. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. 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. Ref: Standard Methods, 4500 H+ B-2000. (6). Recommendation: It is recommended that the results continue to be documented to 0.01 pH units. However, they must be rounded to the nearest 0.1 pH unit when reported on a Discharge Monitoring Report (DMR). Comment: PT samples are reported to two decimals. Total Residual Chlorine — Hach 10014 ULR Comment: As a reminder, when the Gel@ standard used for the daily check is verified initially and every 12 months, the standard may be used beyond the manufacturer's expiration date. I. Finding: The laboratory is reporting values lower than the reporting limit 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 Page 4 #5462 Davie Co Water- Sparks Rd WTP than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The laboratory currently has established a lower reporting limit of 15 pg/L by having verified that concentration when verifying the latest calibration curve. Values with concentrations less than that must be reported as < 15 pg/L on the DMR. Comment: The analyst stated that the laboratory was reporting values appropriately until they were informed in a previous inspection that they were required to report actual obtained values even if they were below the reporting limit. We apologize that you were previously given incorrect information. IV. PAPER TRAIL INVESTIGATION: A paper trail was not performed. Mike Mickey from the Winston-Salem Regional Office had performed a full inspection including a paper trail on the previous day, December 15, 2015. V. CONCLUSIONS: Correcting the above -cited Findings and implementing the Recommendations will help this lab to produce quality data and meet Certification requirements. The inspectors would like to thank the staff for its assistance during the inspection and data review process. Please respond to all Findings and include an implementation date for each corrective action. Report prepared by: Beth Swanson Date: January 5, 2016 Report reviewed by: Jason Smith Date: January 6, 2016