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HomeMy WebLinkAbout#563 - 09 - 2011 - FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 563 Laboratory Name: Town of Yadkinville WWTP Laboratory Inspection Type: Municipal Maintenance Inspector Name(s): Chet Whiting and Gary Francis Inspection Date: September 15, 2001 Date Report Completed: September 23, 2011 Date Forwarded to Reviewer: September 23, 2011 RCVICwuu by: Jason Smit1h Date Review Completed: September 26, 2011 Cover Letter to use: _ Insp. Initial _ Insp. Reg. _ Insp. No Finding X Insp. CP _Corrected Unit Supervisor: Gary Francies Date Received: 9/28/2011 Date Forwarded for mailing: 10/10/2011 Date Mailed: Is I t � A"p4i;`�wA WDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director October 10, 2011 563 Ms. Shannon Adams Town of Yadkinville WWTP Laboratory P.O. Drawer 816 Yadkinville, NC 27055-0816 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Adams: Enclosed is a report for the inspection performed on September 15, 2011 by Chet Whiting and myself. 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 me at 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section CC: Gary Francies Master File DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch One 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 NdfthCarohna Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-39081 FAX: 919-733-6241 Internet: www.dwglab.org An Equal Opportunity\ Affirmative Action Employer Customer Service:1-877-623-6748 www.ncwaterquality.org LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED I. INTRODUCTION: On -Site Inspection Report Town of Yadkinville WWTP Laboratory NCO020338 P.O. Drawer 816 Yadkinville, NC 27055-0816 563 September 15, 2011 Municipal Maintenance Chet Whiting and Gary Francies Shannon Adams and Grant Trivette This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. The inspection was performed as a technical assistance visit requested by the laboratory regarding BOD analyses .and a follow up to the inspection in February 2011. Since there are corrections to be made as a result of this report the deadline for submitting updated Standard Operating Procedures has been extended to March 15, 2012. In response to an e-mail from the laboratory (9/16/2011) requesting clarification SOPs for Dissolved Oxygen (DO), Temperature and Vector Attraction and Reduction are required. General Laboratory Comment: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.) had not been calibrated. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.) must be calibrated at least twice per year, approximately six months apart and documented. Each liquid -dispensing device must meet the manufacturer's statement of accuracy. Notification of acceptable corrective action (i.e., a statement that mechanical pipettes are no longer used) was received by email on 9/16/11. No further response is necessary for this finding. Page 2 #563 Town of Yadkinville WWTP Laboratory Suspended Solids — Standard Methods, 18th Edition, 2540 D Recommendation: The laboratory is currently filtering suspended solids samples using a Gooch crucible apparatus. The small surface area makes it difficult to filter larger volumes. The laboratory has equipment on -site that will use the larger 4.7 cm filters, and the filters as well. It is recommended the laboratory use the larger filters to allow for filtration of greater sample volumes and a lower reporting level. Fecal Coliform — Standard Methods, 18th Edition, 9222 D Comment: Comparison testing was not properly conducted before a new lot(s) of consumables are put into use. Standard Methods, 18th Edition — Method 9020 B. (3) (d) States: It is required that when a new lot of culture medium, pads, or membrane filters is to be used, a comparison of the current lot in use, (reference lot) against the new lot (test lot), be made. As a minimum, make single analyses on five positive samples. Notification of acceptable corrective action (results for consumable testing) was received by email on 10/7/11. Please submit a copy of consumables testing results (including colony counts for each dilution on both lots of materials and the the lot numbers for the material used) with the response to this report. Total Residual Chlorine — Standard Methods, 18th Edition, 4500 Cl G Comment: Results were reported that were below the lowest standard verified for the instrument's (factory installed) internal curve. 15A NCAC 2H .0805 (a) (7) (1) sates: For analytical procedures requiring analysis of a series of standards, the concentrations of these standards must bracket the concentration of the samples analyzed. One of the standards must have a concentration equal to the laboratory's lower reporting concentration for the parameter involved. Notification of acceptable corrective action (i.e., stating that Total Residual Chlorine was reported as "less than" the lowest verified curve standard [26 ,ug/L]) was received by email on 9/16/11.Cited previously on 2/16/11. In order to verify that this finding has been corrected please submit a copy of the first DMR with values reported below the lowect standard verified on the instruments curve with the response to this report. Ammonia Nitrogen — Standard Methods, 18th Edition, 4500 NH3 F Total Phosphorus — Standard Methods, 18th Edition, 4500 P E Comment: A calibration blank and calibration verification standard (mid -range) were not analyzed at the end of the sample group and/or after every tenth sample. North Carolina Wastewater/Groundwater Laboratory Certification Policy states: The calibration blank and calibration verification standard (mid- range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each sample group to check for carry over and calibration drift. If either fall outside established quality control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since the last acceptable calibration verification, repeating the initial calibration, etc.). Notification of acceptable corrective action for ammonia nitrogen (i.e., an updated benchsheet which includes documentation of end calibration standard and blank analysis.) was received by email on 9/21/11. Cited previously on 2/16/11. In order to verify that this finding has been corrected please submit a copy of the Total Phosphorus bench sheet documenting end standard and blank analysis with the response to this report. Comment: Matrix spikes were being analyzed but not documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) states: Analytical Quality Control Program. Each laboratory shall Page 3 #563 Town of Yadkinville WWTP Laboratory develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Acceptable corrective action (i.e., creation of an ammonia nitrogen benchsheet that documents matrix spike data) was carried out during the inspection. In order to verify that this finding has been corrected please submit a copy of the Total Phosphorus bench sheet documenting matrix spike anaysis with the response to this report. Comment: A second source standard was not analyzed. Carolina Wastewater/Groundwater Laboratory Certification Policy states: When a standard curve is manually prepared (as opposed to a factory -set calibration), it is required to analyze one known standard in addition to calibration standards each day samples are analyzed to document accuracy. Notification of acceptable corrective action for ammonia nitrogen (i.e., an updated benchsheet which includes documentation of a second source standard analysis.) was received by email on 9/21/11. In order to verify that this finding has been corrected please submit a copy of the Total Phosphorus bench sheet documenting analysis of a second source standard with the response to this report. Comment: This standard must be prepared from materials obtained from a source independent from the one used for preparing the calibration standards (often referred to as a second source standard or external reference standard). A second source standard may be: • a quality control standard obtained from a vendor, • a standard prepared from primary standards obtained from a second vendor, or • a standard made from primary standards from the same vendor but from a different lot number (i.e., an independent lot) as those used to make the calibration standards. Comment: Laboratory control standards are evaluated to assess whether the lab is in control of the processes involved in the preparation and analysis of specific tests. Laboratory control standards must be similar in composition to the environmental samples. They must contain known concentrations of all anaiytes of interest and undergo the same preparatory and determinative procedures as the environmental samples. Second source standards must be evaluated using one of the following: vendor supplied criteria, method -defined acceptance criteria, in-house calculated acceptance limits that are statistically -derived from historical data based on three standard deviations from the mean in the detectable range or other statistically viable evaluation criterion. If the results fall outside of acceptance limits, the analysis is out of control. The analysis must be terminated and the problem corrected prior to sample analysis. Biochemical Oxygen Demand — Standard Methods, 18th Edition, 5210 B Comment: Laboratory personnel were observed setting up BOD samples. The laboratory switched from checking for drift on the DO meter using saturated air to a full bottle of water. In follow up discussions lab personnel indicated that consistency has improved. Dissolved Oxygen — Standard Methods, 18th Edition, 4500 O G A. Finding: The calibration time of the Dissolved Oxygen (DO) meter is not documented. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7). Cited previously on 2/16/11. VA Page 4 #563 Town of Yadkinville WWTP Laboratory B. Finding: The facility is not calibrating the meter each day samples are analyzed. Requirement: Calibrate the meter using manufacturer's instructions prior to analysis of samples. Ref: Standard Methods, 18th Edition, 4500 O G. Comment: The laboratory is performing ambient air verification on some days. All steps of the method must be followed each day samples are analyzed. A bottle of water saturated air, or the calibration chamber containing a moist sponge to saturate the air, are considered standards of a known concentration. Comment: The calibration procedure discussed during the inspection is' section 6 & 7 of the YSI Model 550 A Operations Manual. Recommendation: Calibration in percent saturation is recommended. The directions for the percent saturation calibration procedure can be found in the YSI Model 550 A Operations Manual page 6. PAPER TRAIL INVESTIGATION: No paper trail performed We are concerned with the findings that were cited previously and not corrected. Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (13) and (14): A laboratory may be decertified for any or all parameters for up to one year for any or all of the following infractions: (1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control program as set forth in the application, and these Rules; or (13) Failing to respond to requests for information by the date due; or (14) Failing to comply with any other terms, conditions, or requirements of this Section or of a Laboratory certification. Correcting the above -cited findings and implementing the recommendations will help this lab to produce quality data and meet certification requirements. Please respond to all findings. Report prepared by: Chet Whiting Report reviewed by: Jason Smith Date: September 21, 2011 Date: September 26, 2011