HomeMy WebLinkAbout#5040 - 12 - 2011 - FINALINSPECTION 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:
5040
Rutherfordton WWTP
Field Maintenance
Jason Smith
December 21, 2011
December 30 2011
December 30, 2011
Tonja Springer
January 17, 2012_
Cover Letter to use: _ Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP
Unit Supervisor: Gary Francies
Date Received:
1 /17/2012
Date Forwarded to Linda: 1/27/2012
boDate Mailed: f
Note to Gary — Report should go to Karen Andrews, not Jerry
Corrected
Al AL
fAx
NCDENR
Noah Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
5040
Rutherfordton WWTP
Ms. Karen Andrews
129 N Main Street
Rutherfordton, NC 28139
Division of Water Quality
Charles Wakild, P. E.
Director
January 27, 2012
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Andrews:
Enclosed is a report for the inspection performed on December 21, 2011 by Jason Smith.
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,
l�
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
Cc Master files
Jason Smith
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
One
N&Marolina
An Equal opportunity \ Affirmative Action Employer
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
Ii "Z OYD RAM41j,
Rutherfordton WWTP
NC0025909
129 N Main Street
Rutherfordton, NC 28139
5040
December 21, 2011
Field Maintenance
Jason Smith
Jerry Alexander and Phillip Reynolds
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the
analysis of environmental samples.
II. GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. Technical assistance and quality
assurance policies were provided to the laboratory at the time of the inspection. The requirements
associated with Findings A, B, and C are new policies that have been implemented since the last
inspection.
Comment: The laboratory needed to increase the documentation of purchased materials and reagents.
The Quality Assurance Policies for Field Laboratories states: 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) 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. This requirement is a new policy that has been implemented by our program since the last
inspection. Demonstration of acceptable corrective action (i.e., a log documenting all required
information was created and put into use) was performed at the time of the audit. No further response
is necessary for this finding.
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#5040 Rutherfordton WWTP
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.
B. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. Part of the corrective
action is notification to the end user. If data qualifiers are used to qualify samples not meeting
QC requirements, the data may not be useable for the intended purposes. It is the responsibility
of the laboratory to provide the client or end -user of the data with sufficient information to
determine the usability of the qualified data. Where applicable, a notation must be made on the
Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet
attached to the DMR form, when any required sample quality control does not meet specified
criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field
Laboratories.
C. Finding: Proficiency Testing (PT) samples are not documented in the same manner as
environmental samples.
Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results. Therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Quality
Assurance Policies for Field Laboratories.
D. Finding: The time of calibration is not clearly documented.
Requirement: The time of calibration must be documented whenever sample analysis is
performed. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen.
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 February, 2010 and February and June, 2011. The following errors were noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
2/1/11
Total Residual Chlorine
Effluent
45 N /L
48,u /L
2/3/11
Total Residual Chlorine
Effluent
33 N /L
32,u /L
2/7/11
Total Residual Chlorine
Effluent
34li /L
24,u /L
6/9/11
Total Residual Chlorine
I Effluent
31 ,u /L
21 ,u /L
Page 3
#5040 Rutherfordton WWTP
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of
this report will be forwarded to the Regional Office.
Recommendation: These transcription errors appear to be the result of the way the laboratory handles
data. Field laboratory results are entered on a legal sized paper log. This log is then faxed to the person
responsible for entering the data. The faxing process reduces the size of the log to letter size paper and
adds some distortion, which makes the results hard to read. It is recommended that the laboratory
develop a way to improve this process, such as entering the data into a spreadsheet on the computer
which is emailed rather than faxed.
V. CONCLUSIONS:
Report prepared by: Jason Smith
Report reviewed by: Tonja Springer
Date: December 30, 2011
Date: January 17, 2012