HomeMy WebLinkAbout#5598_11_2012_FINALi-WYWA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
5598
Mr. Kevin Mullineaux
Hydro Services and Consulting
P. O. Box 317
Newport, NC 28532
Charles Wakild, P. E.
Director
December 21, 2012
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Mullineaux:
Enclosed is a report for the inspection performed on November 7, 2012 by Nick Jones. 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 DWQ 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
An Equal Opportunity \ Affirmative Action Employer
One
NortbCarolina
Naturally
LABORATORY NAME:
NPDES PERMIT #:
WATER QUALITY PERMIT #:
ADDRESS:
CERTIFICATE #:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
• • ••
Hydro Services and Consulting
NC0074837
WQ0003067
P.O. Box 317
Newport, NC 28532
5598
November 7, 2012
Field Initial
Nick Jones
Kevin Mullineaux
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.
H. GENERAL COMMENTS:
The facility has all the equipment n0ecessary to perform the analyses.
Contracted analyses are performed by Environment 1, Inc. (Certification, #10).
Current quality assurance policies for Field laboratories and the approved procedures
for the analysis of the facility's currently certified parameters were provided at the time
of the inspection as well as example benchsheets and an example traceability log. The
aforementioned approved procedures have undergone revision since the inspection and
include new requirements. Current versions will be enclosed with the laboratory's 2013
certificate.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
Comment: The laboratory was unable to supply all of the documentation requested in a
legible format. The North Carolina Administrative Code, 15A NCAC 02H .0807 (a) states:
A laboratory may be decertified for any or all parameters for up to one year for any of the
following infractions: (10) Failing to supply analytical data requested by the State
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Laboratory. Notification of acceptable corrective action (i.e., submission of one out of
three requested months of data) was received by email on 11/30/12. No further
response is necessary for this finding.
Quality Control
A. Finding: The laboratory has not analyzed Proficiency Samples this year for pH
or Total Residual Chlorine.
Requirement: A laboratory may be decertified for any or all parameters for up
to one year for any of the following infractions; Failing to report analysis of
required annual performance evaluation samples submitted by EPA approved
vendor within the specified time limit. Ref: 15A NCAC 02H .0807 (a) (8). Please
submit these results with the response to this report.
Comment: The laboratory was informed that missing the September 30, 2012
deadline is considered a first miss. They were also given a remedial Proficiency
Testing sample deadline of December 31, 2012.
B. Finding: The laboratory is not documenting Proficiency Testing (PT) sample
analyses 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.
C. 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. 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.
D. Finding: The laboratory needs to increase the documentation of purchased
materials and reagents, as well as documentation of standards and reagents
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. This
information 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:
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Quality Assurance Policies for Field Laboratories. Please submit a copy of this
log with the response to this report.
Temperature — Standard Methods, 2550 B-2000
E. Finding: The temperature sensor on the Dissolved Oxygen (DO) meter used to
obtain reported temperature values has not been checked against a NIST
traceable 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 10C 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:
Technical Assistance for Field Analysis of Temperature. Please submit a copy
with the response to this report.
Comment: The date of the last NIST thermometer check was 10/30/2011.
pH — Standard Methods, 4500-H+ B-2000
Dissolved Oxygen — Standard Methods, 4500-0 G-2001
Total Residual Chlorine — Standard Methods, 4500-CI G-2000
Temperature — Standard Methods, 2550 B-2000
F. Finding: The laboratory is not documenting collection and analysis times.
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 02H .0805 (g) (1).
Comment: In some situations the collection and analysis times will be the same.
pH — Standard Methods, 4500-H+ B-2000
Dissolved Oxygen — Standard Methods, 4500-0 G-2001
Total Residual Chlorine — Standard Methods, 4500-CI G-2000
G. Finding: The laboratory is not documenting meter calibration time.
Requirement: The following criteria must be documented whenever sample
analysis is performed: Time of calibration. Ref. NC WW/GW LC Approved
Procedure for Field Analysis of pH, NC WW/GW LC Approved Procedure for
Field Analysis of Total Residual Chlorine and NC WW/GW LC Approved
Procedure for Field Analysis of Dissolved Oxygen.
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PH — Standard Methods, 4500-H+ B-2000
Total Residual Chlorine — Standard Methods, 4500-CI G-2000
Temperature — Standard Methods, 2550 B-2000
H. Finding: The laboratory is not documenting proper units of measure.
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 02H .0805 (g) (1).
pH — Standard Methods, 4500-H+ B-2000
Total Residual Chlorine — Standard Methods, 4500-CI G-2000
1. Finding: The laboratory is not analyzing a post analysis check standard when
applicable.
Requirement: When performing analyses away from the certified laboratory's
primary location, a post analysis calibration verification using the check standard
buffer must be analyzed at the end of the run. It is recommended that a mid -day
check standard buffer be analyzed when samples are analyzed over an
extended period of time. The post analysis check standard buffer(s) must read
within t0.1 S.0 or corrective actions must be taken. Ref: NC WW/GW LC
Approved Procedure for Field Analysis of pH.
Requirement When performing analyses away from the certified laboratory's
primary location, a post analysis calibration verification must be analyzed at the
end of the run. The post analysis calibration verification standard concentration
must be at mid range. It is recommended that a mid -day calibration verification
be performed when samples are analyzed over an extended period of time. The
value obtained for the post analysis calibration verification check standard must
read within 10% of the true value of the post analysis calibration verification
check standard. If the obtained value is outside of the ±10% range, corrective
action must be taken. Ref: NC WW/GW LC Approved Procedure for Field
Analysis of Total Residual Chlorine.
Dissolved Oxygen — Standard Methods, 4500-0 G-2001
J. Finding: The laboratory is not documenting the calibration of the meter.
Requirement: The following criteria must be documented whenever sample
analysis is performed: 5. Meter calibration and time of calibration. Ref. NC
WW/GW LC Approved Procedure for Field Analysis of Dissolved Oxygen.
Total Residual Chlorine — Standard Methods, 4500-CI G-2000
K. Finding: On the non -Discharge Monitoring Reports (DMRs), the laboratory is
reporting results which are less than the established reporting limit.
IV
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#5598 Hydro Services and Consulting
Requirement: One of the standards must have a concentration equal to or below
the lower reporting concentration for Total Residual Chlorine. The lower reporting
limit must be less than or equal to the permit limit. Ref: NC WW/GW LC
Approved Procedure for Field Analysis of Total Residual Chlorine.
Comment: Observed on non-DMR permit # WQ0003067 for August 21, 22, 23,
27, 28 and 29 of 2012. Established reporting limit observed during inspection was
0.2 mg/L, therefore any results which are less than this concentration must be
reported as <0.2 mg/L.
Comment: Because of these incorrectly reported values, the monthly average
and the monthly minimum are also incorrect. In order to avoid questions of
legality, it is recommended that you submit amended reports to your client. A
copy of this report will be made available to the Regional Office.
Please submit a copy of the new benchsheets addressing Findings F, G, H,
I and J with the response to this report.
PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory benchsheets, client reports and DMRs
and non-DMRs submitted to the North Carolina Division of Water Quality. Data were
reviewed for NPDES permit # NC0074837 for June, July and August 2012, and Water
Quality permit # WQ0003067 for August 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 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
Report reviewed by: Jeff Adams
Date: December 5, 2012
Date: December 5, 2012
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor:
Date Received:
Date Forwarded to Linda:
Date Mailed:
5598
Hydro Services and Consulting
Field Initial
Nick Jones
November 7,
2012
December 5,
2012
December 5,
2012
Jeff Adams
December 5.
2012
® Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected
Gary Francies
12/5/2012
12/20/2012
12/21/12 Ic