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Home My WebLink About#5584-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5584 Laboratory Name: Town of Candor Inspection Type: Field Municipal Initial Inspector Name(s): Jeffrey R. Adams Inspection Date: August 7, 2012 Date Report Completed: August 7, 2012 Date Forwarded to Reviewer: August 14, 2012 Reviewed by: Nick Jones Date Review Completed: August 23, 2012 Cover Letter to use: X Insp. Initial ___ Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: August 27, 2012 Date Forwarded to Linda: October 19, 2012 Date Mailed: October 22, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Candor NPDES PERMIT #: WQ0000633 ADDRESS: P.O. Box 220 Candor, NC 27229 CERTIFICATE #: 5584 DATE OF INSPECTION: August 7, 2012 TYPE OF INSPECTION: Field Municipal Initial AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Brice Hollis 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: The laboratory was clean and records were well organized; however, some quality control procedures need to be implemented. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2012 calendar year. The facility is a non-discharge spray irrigation facility and has no Total Residual Chlorine permit limit. This is the first inspection of this field laboratory. The laboratory was using the example laboratory field benchsheets that were supplied by this office. The inspector would like to commend the laboratory for implementing many of the quality control requirements (such as the check standard required for monitoring total residual chlorine and the check buffers required for the analysis of pH) prior to the on-site inspection. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and approved procedures during the inspection. Contracted analyses are performed by Pace Analytical, Inc. (Certificate #12). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Traceability A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents. 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 Page 2 #5618 Town of Candor 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 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: The laboratory had implemented some of the traceability requirements for pH and Total Residual Chlorine analyses, but lacked vendor name, date received and date opened (and/or put into use). Proficiency Testing 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. C. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples (i.e., on a laboratory benchsheet or field notebook). 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: There was no supporting documentation of the PT analyses (i.e., no documentation showing PT analysis on field benchsheets as is done for environmental sample data). pH – Standard Methods, 18th Edition, 4500 H+ B D. Finding: The laboratory is using the wrong units of measure when reporting pH data on the Non-Discharge Monitoring Report (NDMR). Requirement: Report all data values to the nearest 0.1 pH unit. Ref: NC WW/GW LC Approved Procedure for Field Analysis of pH. Comment: The laboratory was recording all of its pH values in mg/L, rather than in standard units (S.U.) on the NDMR. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G E. Finding: The check standard concentration is not at the mid range of the standard curve. Page 3 #5618 Town of Candor Requirement: The check standard concentration must be at mid range and recovery must be within 10% of the known value. Ref: NC WW/GW LC Approved Procedure for Field Analysis of Total Residual Chlorine. Comment: The laboratory is using the highest concentration gel® standard of 1.60 mg/L as its daily check, yet the annual calibration verification standard concentrations are: 0.10, 0.20, 0.50, 1.00 and 2.00 mg/L. Recommendation: It is recommended that the laboratory use the 0.90 mg/L gel® standard for its mid range check standard. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Non-Discharge Monitoring Reports submitted to the North Carolina Division of Water Quality. Data were reviewed for Town of Candor (NPDES permit #WQ0000633) for April, May and June, 2012. A reporting error for pH is noted in Finding D above. In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be made available to the Regional Office. 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: Jeffrey R. Adams Date: August 14, 2012 Report reviewed by: Nick Jones Date: August 23, 2012