HomeMy WebLinkAbout#567_08_2012_FINALi a a
Ir
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
567
Ms. Lisa Richardson
Gastonia WTP Laboratory
Utilities Dept. P.O. Box 1748
Gastonia, NC 28053-1748
Division of Water Quality
Charles Wakild, P. E.
Director
November 2, 2012
Dee Freeman
Secretary
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Richardson:
Enclosed is a report for the inspection performed on August 23 2012 by Chet Whiting. I
apologize for the delay in getting this report to you. 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 electronic mail, or if you have questions or need additional information please
contact me at 828-296-4677.
Sincerely,
GZ2�
Gary Francies
Certification Unit Supervisor
Laboratory Section
CC: Chet Whiting
Master File
DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: 919-733.3908 \ FAX: 919-733-6241 One
Internet: www.dwglab.org M ffl.Cal olin.a
An Equal opportunity \ Affirmative Action Employer VVatulrally
INSPECTION 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:
Date Received:
Date Forwarded to Linda:
Date Mailed:
#567
Gastonia WTP Lab
Municipal Maintenance
Chet Whiting
August 23, 2012
October 3, 2012
October 5, 2012
Jason Smith
October 11, 2012
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
x Corrected
Gary Francies
10/12/12
11 /01 /2012
�QII,
On -Site Inspection Report
LABORATORY NAME: Gastonia WTP Laboratory
NPDES PERMIT #: NCO040070 (Inactive)
ADDRESS: Utilities Dept. P.O. Box 1748
Gastonia, NC 28053-1748
CERTIFICATE M 567
DATE OF INSPECTION: August 23, 2012
TYPE OF INSPECTION: Municipal Maintenance
AUDITOR(S): Chet Whiting
LOCAL PERSON(S) CONTACTED: Lisa Richardson
1. 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 laboratory is not currently analyzing compliance monitoring samples.
The laboratory is reminded that any time changes are made to laboratory operations; the laboratory
must update the Quality Assurance (QAYStandard Operating Procedures (SOP) document(s). Any
changes made in response to the Findings, Recommendations or Comments listed in this report must
be incorporated to insure the method is being performed as stated, references to methods are
accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory
requirements. In some instances, the laboratory may need to create a SOP to document how new
functions or policy will be implemented.
On May 18, 2012, EPA promulgated changes to the list of Clean Water Act (CWA) methods at 40 CFR
Part 136.3. This action, referred to as the Methods Update Rule (MUR) approves new methods, or
changes to existing methods, that affects over 100 EPA methods, Standard Methods, ASTM methods,
and other test procedures in Part 136 of Title 40 of the Code of Federal Regulations (CFR). The rule
also contains a number of clarifications relating to approved methods, sample preservation and holding
times, and method modifications. The final rule may be found at:
http://water.epa.gov/scitech/methods/cwa/update index.cfm. The North Carolina Wastewater/
Groundwater Laboratory Certification (NC WW/GW LC) program will be asking certified laboratories to
move toward implementation of the new rule with changes fully implemented by the end of 2012. Each
laboratory will need to review the MUR and evaluate its effect on current laboratory practices. These
changes must be made in the laboratory's Standard Operating Procedures and in Quality Manuals,
as well as any other place where the method is cited, e.g., reports, benchsheets, logs, etc. During
this transition period, inspection reports will refer to the methods employed at the laboratory at the time
of the inspection, but will reference the requirements in the most recently approved version of the
method. Any difficulties encountered with meeting the requirements of these references by the date
due may be addressed in the written corrective action response.
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#567 Gastonia WTP Laboratory
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Comment: The laboratory needed to increase the documentation of purchased materials and reagents
to include date received. NC WW/GW LC Policy 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 (where specified). This information as
well as the vendor and/or manufacturer, lot number, and expiration date must be retained for primary
standards, chemicals, reagents, and materials used for a period of five years. Consumable materials
such as pH buffers, lots of pre -made standards and/or media, solids and bacteria filters, etc. are
included in this requirement. This requirement is a new policy that has been implemented by our
program since the last inspection _Demonstration of acceptable corrective action (i.e. a revised Reagent
Log Sheet including date received) was received by e-mail September 13, 2012. No further response
is necessary for this finding.
CommenV_The_preparation of Proficiency Testing �PTZ samples was not documented. Proficiency Fo�mattea: rvounderine
Testing Requirements, February 20, 2012, Revision 1.2. 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. Demonstration of
acceptable corrective action (i.e. a acknowledgement that PT preparation information would be
documented) was received by e-mail October 30, 2012 2-042. No further response is necessary for
this finding.
AGG9ptab!G GGFFGGt;V8 @GtiGR (I=aberatGFy staff stated that PT- prep would be deGUM8Hted GR th@-44
Sheets and rata'Red foF review) was P849FM8d OR 646. Ne further response is AeGessa
for. this find;Ag
Total Suspended Solids — Standard Methods, 20th Edition, 2540 D
Comment: The 103 — 105° C oven thermometer calibration had exceeded 12 months (due July 11,
2012). The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (0) states: All thermometers
must meet National Institute of Standards and Technology (NISI) specifications for accuracy or be
checked, at a minimum annually, against a NIST traceable thermometer and proper corrections made.
Demonstration of acceptable corrective action (i.e. a copy of thermometer calibration documenting that
the oven thermometer was calibrated on. 9/12) was received by e-mail September 13, 2012. No
further response is necessary for this finding.
Total Residual Chlorine — Standard Methods, 20th Edition, 4500 CI' G
Comment: The Total Residual Chlorine (TRC) meter verification was for an instrument not capable of
reading down to the permit limit. At the time of the last inspection a pocket colorimeter met permit
requirements. The current permit requires low level analysis should the facility discharge. In
accordance with the directive from this division, a hand held pocket colorimeter will be allowed to have
a minimum reporting limit of 0.1 mg/L (100 pg/I). For any facilities with a limit less than this, the
analysis must be performed with a spectrophotometer. Ref: Division of Water Quality letter dated
August 14, 2001. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (4) states: each
facility must have glassware, chemicals, supplies, equipment, and a source of distilled or deionized
water that will meet the minimum criteria of the approved methodologies. Demonstration of acceptable
corrective action (i.e. a copy of a low level TRC meter verification) was received by e-mail September
24, 2012. No further response is necessary for this finding.
IV.
V
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#567 Gastonia WTP Laboratory
Comment: The laboratory had an instrument capable of low level analysis on site. It had not been
verified. By correcting the above the laboratory now has the proper equipment to perform analysis
specified on their certification Attachment I.
PAPER TRAIL INVESTIGATION:
No paper trail was performed since no compliance data was analyzed.
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: Chet Whiting
Report reviewed by: Jason Smith
Date: October 3, 2012
Date: October 11, 2012