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Home My WebLink About#5162 - 2012 Insp - Final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5162 Laboratory Name: Carolina Water Services, Inc. – Eastern Region Inspection Type: Field commercial Maintenance Inspector Name(s): Todd Crawford Inspection Date: February 15, 2012 Date Report Completed: March 2, 2012 Date Forwarded to Reviewer: March 2, 2012 Reviewed by: Jeff Adams Date Review Completed: March 2, 2012 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor: Dana Satterwhite Date Received: March 2, 2012 Date Forwarded to Linda: March 27, 2012 Date Mailed: March 27, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Carolina Water Services, Inc. – Eastern Region NPDES PERMIT #: NC0056618, NC0032239, NC0031577, NC0033111, WQ006254, WQ0003271, WQ0007569, WQ0000910, WQ0009772, WQ0001664 ADDRESS: P.O. Box 1869 Newport, NC 28570 CERTIFICATE #: 5162 DATE OF INSPECTION: February 15, 2012 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Eddie Baldwin and Tracy Goff I. INTRODUCTION: This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: Due to the extensive geographical area over which this company’s employees operate, the inspection was conducted at the company’s eastern regional headquarters. The majority of the individual analysts were not present. The facility uses standardized benchsheets and three months’ worth of data from each analyst was reviewed. The facility has all the equipment necessary to perform the analyses, however, not all of the equipment was inspected. The system for traceability for purchased and prepared standards and reagents was effective, thorough and easy to follow. Current quality assurance policies for Field laboratories and technical assistance documents for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. The requirements associated with Finding B are new since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Process control data is not properly labeled as such and is intermingled with compliance data. 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 benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Page 2 #5162 Carolina Water Services, Inc. – Eastern Region Recommendation: It is recommended that process control data and compliance data not be documented on the same field sheet. B. Finding: Use of Wite-Out® as a means of error correction was observed. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. C. Finding: Proficiency testing (PT) samples are not documented in the same manner as environmental samples. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Requirement: When a contract lab prepares PT samples for you, it is your responsibility to retain a copy of the documentation that describes how the sample was prepared. Ref: Proficiency Testing Requirements Document, revision 1.2. Temperature D. Finding: The temperature sensing device on all hand-held meters used to obtain reported temperature readings was checked with a NIST traceable thermometer (H-B #3T9520) that was beyond its certification period (last calibrated on 1/15/04). Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a NIST certified or NIST traceable thermometer and the process documented. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST certified or NIST traceable thermometer and record the two temperatures. The thermometer/meter readings must be less than or equal to 1ºC from the NIST certified or NIST traceable thermometer reading. (NC Wastewater/Groundwater Laboratory Certification Policy). The documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was used in the comparison. Also document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. (NOTE: Other certified laboratories may provide assistance in meeting this requirement.) • NIST traceable thermometers used for temperature measurement must be recalibrated in accordance with the manufacturer’s recalibration date. If no recalibration date is given, the NIST traceable thermometer must be recalibrated annually. • NIST certified thermometers must be recalibrated, at a minimum, every five years. A new certificate must be issued and maintained for inspection upon request. Ref: Technical Assistance for Field Analysis of Temperature. Please send all documentation related to the new temperature sensor checks with your response. Total Residual Chlorine – Standard Methods, 20th Edition, 4500 Cl G Page 2 #5162 Carolina Water Services, Inc. – Eastern Region E. Finding: Pocket Colorimeter II, serial number 11070E178024, has not had its internal calibration curve verified. Requirement: Analyze a water blank to zero the instrument and then analyze a series of five standards. The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please send documentation of curve verification with your response. F. Finding: Values below the lowest calibration curve verification standard concentration 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. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Comment: If the laboratory chooses to have a lower reporting limit of 20 µg/L for residual chlorine, you must analyze at least 20 µg/L or lower standard and report lower concentrations as < 20 µg/L or < the concentration of the chosen standard. Comment: Sample results below the lowest calibration verification standard concentration (i.e. reporting limit) were being reported at the instruction of the Wilmington Regional Office. This practice has been discussed with Regional Office personnel and laboratories are no longer instructed to report values below their established reporting limits. G. Finding: Gel-type standards being used for the daily calibration check have not had their concentrations verified on the specific meters and programs being used to analyze routine environmental samples. Requirement: Purchased “Gel-type” or sealed liquid ampoule standards may be used for daily calibration verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve and/or program used for sample analysis. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Comment: It is only necessary to verify the gel or sealed liquid standard which falls within the concentration range of the curve used to measure sample concentrations. For example, if you are measuring samples against a low range curve, a 200 µg/L standard would be verified, and not the 800 µg/L standard since the 800 µg/L standard would be measured using a high range curve. Instruments are to be calibrated or a calibration check must be performed prior to analysis of samples each day compliance monitoring is performed. Recommendation: It is recommended that the true value of each gel standard, specific to each meter, be documented on the benchsheet as well as the acceptable recovery range so that it is immediately apparent whether or not the standard recovery is acceptable. H. Finding: The 5-point curve verification for the HACH Pocket Colorimeters II, serial numbers 050100089456 and 11070E178024 have not been performed in the last 12 months. Page 4 #5162 Carolina Water Services, Inc. – Eastern Region Requirement: The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. This type of curve verification must be performed at least every 12 months. The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 µg/L and must not vary by more than 25% of the known value for standard concentrations less than 50 µg/L. The overall correlation coefficient of the curve must be ≥0.995. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Please send documentation of curve verification with your response. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for October, November and December, 2011. The following errors for NPDES permit # NC0032239 (Regalwood WWTP) were noted: Sample Date Parameter Location Value on Benchsheet Value on DMR 12/05/11 Dissolved Oxygen Effluent 7.0 mg/L 8.2 mg/L 12/06/11 Dissolved Oxygen Effluent 5.9 mg/L 7 mg/L 12/07/11 Dissolved Oxygen Effluent 5.8 mg/L 5.9 mg/L The following errors for NPDES permit # NC0007569 (Brandywine Bay) were noted: Sample Date Parameter Location Value on Benchsheet Value on DMR 10/31/11 Total Residual Chlorine Effluent 1.0 mg/L 0.9 mg/L 11/12/11 Total Residual Chlorine Effluent 0.9 mg/L 0.8 mg/L 12/26/11 Total Residual Chlorine Effluent 0.9 mg/L 1.0 mg/L 04/05/11 Total Residual Chlorine Effluent 0.8 mg/L 0.9 mg/L 04/08/11 Total Residual Chlorine Effluent 2.4 mg/L 0.9 mg/L The following errors for NPDES permit # NC0033111 (Fairfield Harbor) were noted: Sample Date Parameter Location Value on Benchsheet Value on DMR 10/31/11 Temperature Effluent 19.9ºC 20.3ºC 11/12/11 Temperature Effluent 18.2ºC 17.9ºC 12/26/11 Temperature Effluent 16.7ºC 16.4ºC The following errors for NPDES permit # WQ0001970 (Olde Point) were noted: Page 4 #5162 Carolina Water Services, Inc. – Eastern Region Sample Date Parameter Location Value on Benchsheet Value on DMR 11/27/11 Residual Chlorine Effluent 1.9 mg/L 2.00 mg/L 11/28/11 Residual Chlorine Effluent 2.1 mg/L 1.90 mg/L 11/29/11 Residual Chlorine Effluent 1.81 mg/L 2.10 mg/L 11/30/11 Residual Chlorine Effluent 1.8 mg/L 2.00 mg/L 12/01/11 Total Residual Chlorine Effluent 1.8 mg/L 1.40 mg/L 12/02/11 Total Residual Chlorine Effluent 1.7 mg/L 1.30 mg/L 12/03/11 Total Residual Chlorine Effluent 1.5 mg/L 1.20 mg/L 12/05/11 Total Residual Chlorine Effluent 1.73 mg/L 1.40 mg/L 12/06/11 Total Residual Chlorine Effluent 1.64 mg/L 1.60 mg/L 12/07/11 Total Residual Chlorine Effluent 1.24 mg/L 1.60 mg/L 12/08/11 Total Residual Chlorine Effluent 1.19 mg/L 1.60 mg/L 12/09/11 Total Residual Chlorine Effluent 1.21 mg/L 1.40 mg/L 12/10/11 Total Residual Chlorine Effluent 1.30 mg/L 1.70 mg/L 12/11/11 Total Residual Chlorine Effluent 1.41 mg/L 1.70 mg/L 12/12/11 Total Residual Chlorine Effluent 1.35 mg/L 1.80 mg/L 12/13/11 Total Residual Chlorine Effluent 1.2 mg/L 1.40 mg/L 12/15/11 Total Residual Chlorine Effluent 1.4 mg/L 1.50 mg/L 12/16/11 Total Residual Chlorine Effluent 1.3 mg/L 1.50 mg/L 12/17/11 Total Residual Chlorine Effluent 1.1 mg/L 1.40 mg/L 12/18/11 Total Residual Chlorine Effluent 1.2 mg/L 1.50 mg/L 12/19/11 Total Residual Chlorine Effluent 1.2 mg/L 1.50 mg/L 12/20/11 Total Residual Chlorine Effluent 1.3 mg/L 1.60 mg/L 12/21/11 Total Residual Chlorine Effluent 1. 4 mg/L 1.60 mg/L 12/22/11 Total Residual Chlorine Effluent 1. 4 mg/L 1.60 mg/L 12/23/11 Total Residual Chlorine Effluent 1.3 mg/L 1.40 mg/L 12/24/11 Total Residual Chlorine Effluent 1.3 mg/L 1.50 mg/L 12/29/11 Total Residual Chlorine Effluent 2.2 mg/L 1.80 mg/L Page 6 #5162 Carolina Water Services, Inc. – Eastern Region All October Settleable Residue Effluent <0.5 ml/L 0.05 mg/L All November Settleable Residue Effluent <0.5 ml/L 0.05 mg/L All December Settleable Residue Effluent <0.5 ml/L 0.05 mg/L The following errors for NPDES permit # NC0001664 (Belvedere) were noted: Sample Date Parameter Location Value on Benchsheet Value on DMR 10/31/11 Total Residual Chlorine Effluent 2.2 mg/L 3 mg/L 11/12/11 Total Residual Chlorine Effluent 2.2 mg/L 3 mg/L 12/26/11 Total Residual Chlorine Effluent 2.8 mg/L 3.8 mg/L 04/05/11 Total Residual Chlorine Effluent 2.8 mg/L 3.5 mg/L 04/08/11 Total Residual Chlorine Effluent 2.8 mg/L 3.5 mg/L 04/14/11 Total Residual Chlorine Effluent 2.8 mg/L 3.5 mg/L 04/17/11 Total Residual Chlorine Effluent 2.8 mg/L 3 mg/L 04/29/11 Total Residual Chlorine Effluent 2.8 mg/L 3 mg/L 05/03/11 Total Residual Chlorine Effluent 1.8 mg/L 2.2 mg/L 05/09/11 Total Residual Chlorine Effluent 1.4 mg/L 1.8 mg/L All October Settleable Residue Effluent <0.5 ml/L 0.05 mg/L All November Settleable Residue Effluent <0.5 ml/L 0.05 mg/L All December Settleable Residue Effluent <0.5 ml/L 0.05 mg/L In order to avoid questions of legality, it is recommended that you inform your clients and contact the appropriate Regional Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of this report will be forwarded to the Regional Office. Recommendation: In order to improve the quality of the data being reported, it is recommended that the laboratory expand their data verification system to include a technical peer review process to check for accuracy and completeness of data. Steps must be taken to minimize and correct errors in calculations and may include checks for the following: transcription errors, calculation errors, correct application of dilution factors, correct application of conversion factors, etc. The large number of transcription errors noted in the tables above, underscore the importance of this type of technical peer review process. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendations will help this lab to produce quality data and meet certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all findings. Report prepared by: Todd Crawford Date: March 2, 2012 Report reviewed by: Jeff Adams Date: March 2, 2012