HomeMy WebLinkAbout#5223_06_2012_FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5223
Laboratory Name:
Franklin Water Treatment Plant
Inspection Type:
Field Maintenance
Inspector Name(s):
Chet Whiting
Inspection Date:
June 28, 2011
Date Report Completed:
July 6, 2012
Date Forwarded to Reviewer: July 6, 2012
Reviewed by:
Todd Crawford
Date Review Completed:
July 13, 2012
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
7/16/2012
Date Forwarded to Linda:
7/24/2012
Date Mailed: q L45 f 1
A
jRi
NZ -VA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
5223
Mr. Rusty Campbell
Franklin WTP
5200 Brookshire Blvd.
Charlotte, NC 28216
Charles Wakild, P. E.
Director
July 24, 2012
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Campbell:
Enclosed is a report for the inspection performed on June 28, 2012 by Chet Whiting. 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.
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 us at
828-296-4677.
Sincerely,
s
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
Cc: Master File
Chet Whiting
DENR DWO 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
Internet: www.dwglab.org
One
Norh.Carolina
Naturally
An Equal Opportunity \ Affirmative Action Employer
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Franklin WTP
NCO084549
5200 Brookshire Blvd.
Charlotte, NC 28216
5223
June 28, 2012
Field Maintenance
Chet Whiting
Rusty Campbell
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:
The facility has all the equipment necessary to perform the analyses.
The requirements associated with Findings A, B, C and D are new policies that have been implemented by
our program since the last inspection.
III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: No instances were observed, however the laboratory was not aware that any data that does not
meet all quality control requirements is required to be qualified on the Discharge Monitoring Report,
including contract laborato rrl data. The Quality Assurance Policies for Field Laboratories document states:
When quality control (QC) failures occur, the laboratory must attempt to determine the source of the
problem and must apply corrective action. Part of the corrective action is notification to the end user. If data
qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the
intended purposes. It is the responsibility of the laboratory to provide the client or end -user of the data with
sufficient information to determine the usability of the qualified data. Where applicable, a notation must be
made on the Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet
attached to the DMR form, when any required sample quality control does not meet specified criteria and
another sample cannot be obtained.
A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents,
as well as, documentation of standards prepared in the laboratory.
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. A system (e.g., traceable identifiers) must be in place that links
standard/reagent preparation information to analytical batches in which the solutions are used.
Documentation of solution preparation must include the analyst's initials, date of preparation, the
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#5223 Franklin WTP
volume or weight of standard(s) used, the solvent and final volume of the solution. 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.
Comment: Specifically document information for pH buffers, DPD reagent, and the standard
material used to prepare the Total Residual Chlorine curve verification standards.
B. Finding: The preparation of Proficiency Testing (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: For this facility, the requirement currently applies only to Total Residual Chlorine (TRC)
since pH samples require no preparation.
C. Finding: Proficiency testing (PT) samples are not 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.
Quality Control
D. Finding: Auto-pipettors are not calibrated annually (every twelve months).
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-
pipettors, bottle -top dispensers, etc.) 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: A copy of a procedure for the calibration of mechanical volumetric liquid -dispensing
devices is attached to this report.
Comment: The testing of auto-pipettors may be contracted out to a vendor or may be performed by
another laboratory. Copies of documentation must be on file and available for review for a period of
five years.
pH — Standard Methods, 18'h Edition, 4500 H+ B
Temperature - Standard Methods, 18$h Edition, 2550 B
Comment: Units of measure and sample identification were not documented. The North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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. Acceptable corrective action (i.e., a cover statement
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#5223 Franklin WTP
specifying that pH samples results are in Units and temperature results are in degrees C 1) was added to the
log book during the inspection. No further response is necessary for this finding.
Comment: Sample collection and analysis times are documented but need to be more clearly labeled.
Temperature - Standard Methods, 181h Edition, 2550 B
E. Finding: The thermometer used for temperature analysis was not checked every 12 months against
a NIST certified or MIST traceable thermometer and the process documented.
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 10C 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.) Ref: Technical
Assistance for Field Analysis of Temperature.
Comment: The temperature results are not required for permit compliance monitoring purposes.
The results are used to document a temperature drop during sample shipment as part of sample
preservation, however they are reported on the DMRs.
Recommendation: Since temperature is not on the facility permit and the results are not used to
monitor the characteristics of the effluent it is recommended that the values not be reported on the
DMR.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring
Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data for NPDES# NC0084549
was reviewed for March, April and May, 2012. No transcription errors were detected. The facility appears to
be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendation 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: Chet Whiting Date: July 6, 2012
Report reviewed by: Todd Crawford Date: July 13, 2012
Calibration of Mechanical Volumetric Liquid -Dispensing Devices Procedure
A laboratory may use the following method for the gravimetric determination of measurement error of
mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top
dispensers, etc.) used to dispense volumes greater than or equal to 100 NI.
Apparatus and Equipment
Weighing vessel (of sufficient capacity to hold all volumes dispensed for the test and a 3:1 height -to -
diameter ratio is recommended to minimize evaporation)
Reagent water (e.g., distilled or deionized water)
Analytical balance (accurate to 0.0001 g for 100 pl to 10 ml, and accurate to 1 mg for 10 ml to 200 ml
dispensed volumes)
Calibrated thermometer (graduated, at a minimum, in 0.5 °C increments)
Documentation Requirements
Date
Analyst's signature or initials
Device identification (if there is no unique identification such as serial number, assign a laboratory
identification)
Temperature of the reagent water
Nominal or test volume
Weights of dispensed volumes
Procedure
1. Allow apparatus and reagent water to equilibrate to room temperature.
2. Check the calibration of the balance.
3. Wet the liquid -dispensing device and lubricate the piston insuring smooth operation by pipetting
several volumes to waste.
4. Weigh the vessel and tare the balance.
5. Dispense a minimum of five aliquots of water into the vessel, weighing and recording the mass
for each replicate.
6. Calculate the following:
m = mean mass = total of individual weight measurements
total number of measurements
Z = Z correction factor obtained from Table 1 using the temperature of the test liquid and
current barometric pressure.
V = volume equivalent (or corrected volume) of mass measured = m x Z
RE = relative error (%) = Vm - Volx 100
Vo
where:
Vm = corrected mean volume = total of corrected volumes
total number of dispensed volumes
Vo = nominal or test volume
S = standard deviation = For each replicate, subtract the mean volume from the corrected
volume, then square the value. Sum the squared values of all replicates, and then divide the
sum by n-1 (the number of measurements minus 1). Take the square root of this value to get
the standard deviation.
CV = coefficient of variation (%) = s x 100
Vm
To simplify this process, spreadsheets for calculating and documenting the relative error and
coefficient of variation can be found on the NC Wastewater/Groundwater Laboratory Certification (NC
WW/GW LC) website at http://h2o.enr.state.nc.us/lab/download.htm.
The Relative Error (a measure of accuracy) and Coefficient of Variation (a measure of precision) must
not be greater than the manufacturer's specifications. If the results are greater than the manufacturer's
specification, repeat the procedure. If the results remain greater, follow the manufacturer's instructions
for maintenance and adjustment and repeat the procedure. If repeated calibration attempts do not yield
results within the manufacturer's specifications, the liquid -dispensing device must be repaired or
replaced.
Note: Microliter pipettors may need to be tested under more rigorously controlled conditions or sent to
a calibration service for testing. Since most analytical balances used in environmental laboratories read
to only four decimal places, it may be necessary, when checking microliter pipettors (less than 1000
pl), to include the weight of the weighing vessel in each replicate and subtract it and subsequent
aliquots out manually in order to have a measurable mass for the purpose of this verification. Contact
your auditor if you have questions.
Table 1. Z Correction Factor Table.
Temperature
Air
pressure, kPa (mbar)
°C
80 (800)
85 (850)
90 (900)
95 (950)
100 (1000)
101.3 (1013)
105 (1050)
15.0
1.0017
1.0018
1.0019
1.0019
1.0020 `
1.0020
1.0020
15.5
1.0018
1.0019
1.0019
1.0020
1.0020
1.0020
1.0021
16.0
1.0019
1.0020
1.0020
1.0021
1.0021
1.0021
1.0022
16.5
1.0020
1.0020
1.0021
1.0021
1.0022
1.0022
1.0022
17.0
1.0021
1.0021
1.0022
1.0022
1.0023
1.0023
1.0023
17.5
1.0022
1.0022
1.0023
1.0023
1.0024
1.0024
1.0024
18.0
10022
1.0023
1.0023
1.0024
1.0025
1.0025 "
1.0025
18.5
1.0023
1.0024
1.0024
1.0025
1.0025
1.0026
1.0026
19.0 '
1.0024
1.0025
1.0025
1.0026
1.0026
" 1.0027 '
1.0027
19.5
1.0025
1.0026
1.0026
1.0027
1.0027
1.0028
1.0028
20.0 '
10026
1.0027
1.0027
1.0028.-
1.0028'
1.0029
1.0029
20.5
1.0027
1.0028
1.0028
1.0029
1.0029
1.0030
1.0030
21.0
10028
1.0029
1.0029
1.0030:
1.0031
1.0031
1.0031
21.5
1.0030
1.0030
1.0031
1.0031
1.0032
1.0032
1.0032
22.0
1.0031
1.0031
1.0032
1.0032
1.0033:'
1.0033
1.0033
22.5
1.0032
1.0032
1.0033
1.0033
1.0034
1.0034
1.0034
23.0
1.0033
1.0033
1.0034
1.0034
1.0035-
1.0035
1.0036
23.5
1.0034
1.0035
1.0035
1.0036
1.0036
1.0036
1.0037
24.0
1.0035
1.0036
1.0036
1.0037
1.0037 °
1.0038
1.0038
24.5
1.0037
1.0037
1.0038
1.0038
1.0039
1.0039
1.0039
25.0
1.0038
1.0038
1.0039
1.0039
1.0040
1.0040
1.0040
25.5
1.0039
1.0040
1.0040
1.0041
1.0041
1.0041
1.0042
26.0 >
10040
1.0041
1.0041
10042
1.0042
1.0043
1.0043
26.5
1.0042
1.0042
1.0043
1.0043
1.0044
1.0044
1.0044
27.0
10043
1.0044
1.0044
1.0045
-1.0045
1.0045
1.0046
27.5
1.0045
1.0045
1.0046
1.0046
1.0047
1.0047
1.0047
28.0
1.0046
1.0046
1.0047
1.0047''
1.0048
1.0048
1.0048
28.5
1.0047
1.0048
1.0048
1.0049
1.0049
1.0050
1.0050
29.0
1.0049
1.0049
1.0050
1.0050
1.0051
1.0051
1.0051
29.5
1.0050
1.0051
1.0051
1.0052
1.0052
1.0052
1.0053
30.0
1.0052 1
1.0052
1.0053
1.0053
1.0054
1.0054 ''
1.0054
Z correction factors are for distilled water as a function of liquid test temperature and air pressure.
Z values are in microliters per milligram.
Reprinted from ISO 8655-6:2002(E).
If your laboratory does not have a mercury barometer, the true local barometric pressure for locations throughout
North Carolina may be obtained from the North Carolina State University, State Climate Office of North Carolina
website at http://www.nc-climate.ncsu.edu/.