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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. Page 2 #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. Page 3 #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 Page 4 #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). Page 5 #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