The URL can be used to link to this page

Home My WebLink About#5062_11_2015_FinalINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5062 Laboratory Name: Taylorsville WWTP Inspection Type: Field Maintenance Inspector Name(s): Jason Smith and Beth Swanson Inspection Date: November 19, 2015 Date Report Completed: December 16, 2015 Date Forwarded to Reviewer: December 16, 2015 Reviewed by: Beth Swanson Date Review Completed: December 17, 2015 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: December 18, 2015 Date Forwarded to Linda: 1/11/2016 Date Mailed: 1/12/2016 Please send copy to Wes Bell MRO I)� �` If rrt a Water resources ENVIRONMENTAL QUALITY January 12, 2016 5062 Mr. Brian Eades Taylorsville WWTP 67 Main Ave Drive Taylorsville, NC 28681 PAT MCCRORY DONALD R. VAN DER VAART S. JAY ZIMMERMAN ;lire. SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Eades: Enclosed is a report for the inspection performed on November 19, 2015 by Jason Smith. Since the Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the Findings in such a timely manner. 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 us at (828) 296-4677. Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Attachment cc: Jason Smith Master File On -Site Inspection Report LABORATORY NAME: Taylorsville WWTP NPDES PERMIT #: NCO026271 ADDRESS: 67 Main Ave Drive Taylorsville, NC 28681 CERTIFICATE #: 5062 DATE OF INSPECTION: November 19, 2015 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jason Smith and Beth Swanson LOCAL PERSON(S) CONTACTED: Brian Eades I. 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. II. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2015 proficiency testing calendar year and the graded results were 100% acceptable. The laboratory is certified for Dissolved Oxygen, however, compliance samples are not analyzed and data was not reviewed during the inspection. Contracted analyses are performed by Water Tech Labs, Inc. (Certification #50). 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 Comment: The laboratory needed to increase the documentation of purchased materials and reagents. The NC WW/GW LC Quality Assurance Policies for Field Laboratories document states: 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. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., the provided reagent receipt log which includes spaces for all required information was put into use on December 11, 2015) was received by email on December 11, 2015. No further response is necessary for this Finding. Page 2 #5062 Taylorsville VVVVfP Comment: The sample site (facility name and sample location) was not documented in the log book. The NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature, and NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine documents state: The following must be documented in indelible ink whenever sample analysis is performed: Sample site including facility name and location, ID, etc. Acceptable corrective action (i.e., a note was added to the log book identifying the sample site with facility name and sample location) was performed during the inspection. No further response is necessary for this Finding. Comment: Error corrections were not dated when performed. The NC WW/GW LC Quality Assurance Policies for Field Laboratories document states: 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., error corrections are now dated by the responsible individual) was received by email on November 24, 2015. No further response is necessary for this Finding. Comment: Instrument identification was not documented. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature, and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., instrument identification is now documented in the log book) was received by email on December 17, 2015. No further response is necessary for this Finding. Quality Control Comment: The laboratory has not had the mechanical volumetric pipet that is used for Proficiency Testing (PT) sample preparation calibrated. The NC WW/GW LC Quality Assurance Policies for Field Laboratories document states: 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., the mechanical volumetric pipet will be calibrated annually beginning in January, 2016) was received by email on November 24, 2015. No further response is necessary for this Finding. Proficiency Testing Comment: PT sample preparation was not documented. This requirement is applicable to the Total Residual Chlorine PT. The NC WW/GW LC Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., the preparation instruction sheets will be signed and dated when the PT is prepared beginning with the next PT study performed) was received by email on November 24, 2015. No further response is necessary for this Finding. Page 3 #5062 Taylorsville WWTP Comment: PT sample analysis documentation included all required information; however it was not documented in the same format as sample analysis. The NC WW/GW LC Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. 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. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., PT analyses will be documented the same as samples and a note has been added to their PT information to ensure that it is performed beginning with the next PT study) was received by email on December 14, 2015. No further response is necessary for this Finding. Total Residual Chlorine — Standard Methods, 4500 Cl G-2000 Comment: The laboratory occasionally used a Hach Pocket Colorimeter II which is not approved by the Division of Water Resources for low level Total Residual Chlorine (TRC) analyses. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine states: If a facility has no effluent limit for TRC (just a monitoring requirement), then use of a hand-held meter, sometimes described as a pocket colorimeter, is acceptable. The facility has a permit limit of 28 pg/L, so the Pocket Colorimeter is not acceptable to use. Notification of acceptable corrective action (i.e., as of November 20, 2015 a pocket colorimeter will not be used for TRC sample analyses which are reported on the Discharge Monitoring Report (DMR)) was received by email on November 20, 2015. Additionally, the town ordered a new spectrophotometer to replace their current spectrophotometer. Issues with the power button on their current spectrophotometer was the reason that a pocket colorimeter was occasionally used. No further response is necessary for this Finding. Recommendation: TRC results are reported as <22 pg/L; however, the curve was verified down to 20 pg/L. It is recommended that the lowest concentration verified during the annual curve verification (i.e., 20 pg/L) be used as the reporting limit. pH — Standard Methods, 4500 H+ B-2000 Temperature — Standard Methods, 2550 B-2000 Total Residual Chlorine — Standard Methods, 4500 CI G-2000 Comment: Sample collection and analysis times were documented, but the times were not clearly labeled. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Certified Data must consist of date collected, time collected, samples site, sample collector, and sample analysis time. Acceptable corrective action (i.e., a note added to the log book that the first time recorded is the collection time and the second time recorded is the analysis time) was performed during the inspection. No further response is necessary for this Finding. 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 the Taylorsville WWTP (NPDES permit #NC0026271) for May, June, and September, 2015. The following errors were noted: Page 4 #5062 Taylorsville WWTP Date Parameter Location Value on Benchsheet *Contract Lab Data Value on DMR 9/8/15 Ammonia Effluent *3.85 mg/L 0.58 mg/L 9/9/15 Ammonia Effluent *6.55 mg/L 4.1 mg/L 9/10/15 Ammonia Effluent *5.70 mg/L <0.2 mg/L The laboratory has submitted an amended eDMR for the month of September, 2015 to correct these errors. V. CONCLUSIONS: All findings noted during the inspection were adequately addressed prior to the completion of this report. The inspector would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Jason Smith Report reviewed by: Beth Swanson Date: December 16, 2015 Date: December 17, 2015