HomeMy WebLinkAbout#5563_07_2012_FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5563
Laboratory Name:
Town of Vanceboro
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Nick Jones and Gary Francies
Inspection Date:
7/17/2012
Date Report Completed:
8/20/2012
Date Forwarded to Reviewer: 8/20/2012
Reviewed by:
Chet Whiting
Date Review Completed:
9/5/2012
Cover Letter to use: _
Insp. Initial x Insp. Reg. _ Insp. No Finding _ Insp. CP _ Corrected
Unit Supervisor:
Gary Francies
Date Received:
9/5/2012
Date Forwarded to Linda:
9/10/2012
Date Mailed:
( �s ta
A FA
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
5563
Ms. Renee (pock
Town of Vanceboro
P. O. Box 306
Vanceboro, NC 28586
Division of Water Quality
Charles Wakild, P. E.
Director
September 11, 2012
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Ms. (pock:
Enclosed is a report for the inspection performed on July 17, 2012 by Nick Jones and myself. I
apologize for the delay in getting this report to you. 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,
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
cc: Master File
Nick Jones
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
NorthCarolina
a ni 1
An Equal Opportunity \ Affirmative Action Employer
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
1. INTRODUCTION:
On -Site Inspection Report
Town of Vanceboro
NC0080071, NCO031828
P. O. Box 306
Vanceboro, NC 28586
5563
July 17, 2012
Municipal Maintenance
Nick Jones and Gary Francies
Renee (pock
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:
This inspection was in response to a regional inspector's observation of a complete absence
of documentation for the data generated for the town of Vanceboro WTP (NPDES permit #
NC0080071).
The Vanceboro WWTP (NPDES permit # NC0031828) laboratory is neat and well organized
and has all the equipment necessary to perform the analyses. Benchsheets are well
designed, easy to follow and concise. Records are well organized and easy to retrieve. The
laboratory has been proactive in keeping up with updates and changes required by this
program, particularly in the area of consumable traceability. Proficiency testing samples have
been analyzed for all certified parameters for the 2012 proficiency testing calendar year and
the graded results were 100% acceptable.
The auditor provided the facility with the new Approved Procedures for Field Analyses of pH,
Temperature, Dissolved Oxygen and Total Residual Chlorine.
Contract analyses are performed by Environment 1, Inc. (Cert # 10).
Ill. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Vanceboro WTP (NPDES permit # NC0080071)
Documentation
A. Finding: Original analysis records are not retained.
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#5563 Town of Vanceboro
Requirement: Data pertinent to each analysis must be maintained for five years.
Certified data must consist of date collected, time collected, samples site, sample
collector, and sample analysis time. The field benchsheets must provide a space for
the signature of the analyst, and proper units of measure for all analyses. Ref: 15A
NCAC 2H .0805 (g) (1).
B. Finding: The facility does not have a documented system of traceability for all
chemicals, reagents, standards and consumables.
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
volume or weight of standard(s), 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.
C. Finding: The calibration of the meter is not documented.
Requirement: A record of instrument calibration where applicable, must be filed in
an orderly manner so as to be readily available for inspection upon request. Ref:
15A NCAC 2H .0805 (g) (2).
Comment: The following documentation is required: Time and date of sample
collection, Time of calibration, Time and date of analysis (to verify 15 minute holding
time is met), Collector's/analyst's name, Value of buffers used for calibration, Value
obtained for check buffer, Sample location/site, Post analysis checks (if
applicable)9.Report all data values to the nearest 0.1 pH unit and Traceability for
chemicals, reagents, standards and consumables. Ref: Approved Procedure for
Field Analysis of pH.
Temperature — Standard Methods, 18th Edition, 2550 B
E. Finding: The temperature sensor on the pH meter used to obtain reported
temperature values has not been checked against a National Institute of Standards
and Technology (NIST) traceable thermometer.
Requirement: All thermometers and temperature measuring devices must be
checked every 12 months against a NIST traceable thermometer and the process
documented. The documentation must include the serial number of the 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. Ref: Approved Procedure for Field Analysis of Temperature.
F. Finding: The lab is not meeting the holding time criteria for Temperature.
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#5563 Town of Vanceboro
Requirement: Immediate analysis is required. Ref: Code of Federal Regulations,
Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table II.
Comment: When collecting samples in a hazardous area (such as highway bridges,
etc.), measurement may be delayed only as long as it takes to transport and analyze
the samples at a safe location near the collection point.
Vanceboro WWTP (NPDES permit # NC0031828)
Quality Control
G. Finding: The auto-pipettors have not been calibrated annually as required.
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.
H. Finding: Error corrections are not performed properly.
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. Wte-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.
Total Residual Chlorine - Standard Methods, 18th Edition, 4500 Cl G
I. Finding: The internal curve (program 86) on the HACH DR2800 had not been
verified within twelve months.
Requirement: The internal calibration curve must be verified every 12 months by
analyzing five non -zero standards in a range that covers both the permitted limit and
the expected range of sample concentrations. The overall correlation coefficient of
the curve must be >_ 0.995. Ref: Approved Procedure for Field Analysis of Total
Residual Chlorine.
pH - Standard Methods, 18th Edition, 4500 H+ B
J. Finding: Values were reported that exceed the method specified accuracy (0.1
units) for this analysis.
Requirement: By careful use of a laboratory pH meter with good electrodes, a
precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ±
0.1 pH unit represents the limit of accuracy under normal conditions, especially for
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#5563 Town of Vanceboro
measurement of water and poorly buffered solutions. For this reason, report pH
values to the nearest 0.1 pH unit. Ref: Standard Methods, 4500 H+ B-2000, (6).
Temperature - Standard Methods, 18th Edition, 2550 B
K. Finding: The temperature sensor on the Dissolved Oxygen meter used to obtain
reported temperature values has not been checked against a NIST thermometer.
Requirement: Thermometers and temperature measuring devices, used to measure
temperature for compliance monitoring, must be checked every 12 months against a
NIST traceable thermometer. The thermometer/meter readings must be less than or
equal to 1°C from the NIST traceable thermometer reading. The documentation must
include the serial number of the NIST traceable thermometer that was used in the
comparison. Document any correction that applies on both the thermometer/meter
and on a separate sheet to be filed. Ref: Approved Procedure for Field Analysis of
Temperature.
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 were reviewed for the Town of Vanceboro WWTP (NPDES permit #
NC0031828) for February, March and April, 2012. The following errors were noted:
Date
Parameter
Location
Value on Benchsheet
'Contract Lab Data
Value on
DMR
2/20/12
pH
Final Effluent
7.72
7.72
2/6/12
Temp
Eff
13.5
13.8
3/29/12
TRC
Eff
no value
<20
4/5/12
TRC
Eff
no value
<10
3/5/12
DO
Downstream
14.32
13.9
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.
A paper trail could not be performed for the Town of Vanceboro WTP (NPDES permit #
NC0080071).
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#5563 Town of Vanceboro
V. CONCLUSIONS:
Correcting the above -cited findings 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: Nick Jones Date: August 20, 2012
Report reviewed by: Chet Whiting Date: September 4, 2012