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Home My WebLink About#5626_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5626 Laboratory Name: Carteret County Water Plant Inspection Type: Field Municipal Initial Inspector Name(s): Todd Crawford Inspection Date: December 6, 2012 Date Report Completed: December 10, 2012 Date Forwarded to Reviewer: December 10, 2012 Reviewed by: Jeff Adams Date Review Completed: December 10, 2012 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor: Dana Satterwhite Date Received: December 10, 2012 Date Forwarded to Linda: December 20, 2012 Date Mailed: December 20, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Carteret County Water Plant NPDES PERMIT # : NC0086975 ADDRESS: 534 Laurel Road Beaufort, NC 28516 CERTIFICATE #: 5626 DATE OF INSPECTION: December 6, 2012 TYPE OF INSPECTION: Field Municipal Initial AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Doug Mangold and John Nevill I. INTRODUCTION: 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 is the initial NC WW/GW LC inspection of the laboratory. The facility has all equipment necessary to perform the analyses. Current quality assurance policies for Field laboratories and approved procedures for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. Contracted analyses are performed by Environment 1, Inc. (Certification #10). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. 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. Comment: Instances of writing over the incorrect entry and use of Wite-Out® were observed. B. Finding: The laboratory needs to increase the documentation of 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 Page 2 #5626 Carteret County Water Plant 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) 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. Proficiency Testing C. 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: Dating and initialing the direction sheet for Total Residual Chlorine (TRC) will satisfy this requirement. D. 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. pH – Standard Methods, 4500 H+ B-2000 E. Finding: The calibration of the meter is not verified with a standard (buffer) following calibration. Requirement: Use a pH meter accurate and reproducible to 0.1 pH unit (as demonstrated daily by acceptable performance of a check standard buffer) with a range of 0 to 14 and equipped wit h temperature-compensation adjustment. The meter must be calibrated with at least two buffers. In addition to the calibration buffers, the meter calibration must be verified with a third standard buffer solution. The calibration and check standard buffers must bracket the range of the samples being analyzed. A portion of the buffer solutions should not be used for more than one calibration. Discard any used buffer portions. Ref: NC WW/GW LC Approved Procedure for Field Analysis of pH. Requirement: The check standard buffer must read within ±0.1 S.U. to be acceptable. If the meter verification does not read within ±0.1 S.U., the meter must be recalibrated before any samples are analyzed. Ref: NC WW/GW LC Approved Procedure for Field Analysis of pH. F. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. 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 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). Page 3 #5626 Carteret County Water Plant pH – Standard Methods, 4500 H+ B-2000 Dissolved Oxygen – HACH Method 10360 (LDO) G. Finding: Sample collection times are not documented for the upstream and downstream samples. 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 2H .0805 (g) (1). Dissolved Oxygen – HACH Method 10360 (LDO) H. Finding: The theoretical DO of the moist air calibration verification is not documented. Requirement: The calculated DO value must verify the meter reading within ±0.5 mg/L. Ref: NC WW/GW LC Approved Procedure for Field Analysis of Dissolved Oxygen. Recommendation: It is recommended that the theoretical value be documented on the benchsheet to clearly show that the requirement is being met. Temperature – Standard Methods, 2550 B-2000 I. Finding: The temperature correction factor is not documented on the thermometer used to obtain reported temperatures. Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a National Institute of Standards and Technology (NIST) traceable thermometer. The process must be documented and proper corrections made to all compliance data. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST traceable thermometer and record the two temperatures. The verification must be performed in the approximate range of the sample temperatures measured. The thermometer/meter readings must be less than or equal to 1ºC from the NIST traceable thermometer reading. 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: NC WW/GW LC Approved Procedure for Field Analysis of Temperature. Total Residual Chlorine Comment: The laboratory is still in the process of obtaining certification for this parameter. The determination of which method to cite (Standard Method 4500 Cl G-2000 or HACH Method 10014) has to be made. Comment: The initial PT sample was not graded acceptable. Inaccurate dilution of the PT sample is thought to be the reason. Recommendation: It is recommended that a Class A volumetric pipette, instead of a mechanical pipette, be used to prepare the Total Residual Chlorine (TRC) PT sample. Page 4 #5626 Carteret County Water Plant 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 or September, October and November, 2012. The following errors were noted: Date Parameter Location Value on Contract Lab Report Value on DMR 9/11/12 Total Nitrogen Effluent 2.76 mg/L 1.8 mg/L 10/9/12 Total Nitrogen Effluent 1.90 mg/L 0.92 mg/L 11/6/12 Total Nitrogen Effluent 2.32 mg/L 1.29 mg/L Comment: The values reported as Total Nitrogen were actually Total Kjeldahl Nitrogen (TKN) values. Recommendation: Since TKN is not required to be reported on the DMR, it is recommended that the contract lab be asked not to include that result on the client report so as to eliminate any confusion on which result to report. 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: Todd Crawford Date: December 10, 2012 Report reviewed by: Jeff Adams Date: December 10, 2012