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HomeMy WebLinkAbout#5120 - 05 - 2011 - FINALDee Freeman Secretary July 11, 2011 5120 Mr. Robert Heaton Town of Beech Mountain 403 Beech Mountain Parkway Beech Mountain, NC 28604 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Initial Inspection Dear Mr. Heaton: Enclosed is a report for the inspection performed on May 17, 2011 by Jason Smith. I apologize for the delay in getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30 days of receipt, please supply this office with a written item for item description of how these finding(s) were corrected. 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: Chet Whiting Gary Francies Master files 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: ws,vv,dwglab.org An Equal Opporluniry\Affirmalive Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org One North Carolina �/ atillrally INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. 4: 5120 Laboratory Name: Town of Beech Mountain Inspection Type: Field Maintenance Inspector Names): Jason Smith Inspection Date:. May 17, 2011 Date Report Completed: July 6, 2011 Date Forwarded to Reviewer: July 7, 2011 Reviewed b : Todd Crawford Date Review Completed: July 7, 2011 Cover Letter to use: _ Insp. Initial x Insp. Reg. _ Insp. No Finding Insp. CP Unit Supervisor. Date Received: Date Forwarded to Alberta: Date Mailed: Gary Francies 7/7/2011 Corrected 11 0 LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE : DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED I. INTRODUCTION: Town of Beech Mountain NCO069761 and N00022730 403 Beech Mountain Parkway Leech Mountain, NC 28604 5120 May 17, 2011 Field Maintenance Jason Smith Robert Heaton and Gary Tipton 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 laboratory has all the equipment necessary to perform the analyses. Samples are analyzed at the Beech Mountain WWTP and the Grassy Gap WWTP. Technical assistance documents for all certified parameters were provided to the laboratory at the time of the inspection. Findings A and B are new policies that have been implemented by our program since the last inspection. HIM A. Finding: The laboratory needs to increase the documentation of purchased 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 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. B. Finding: Data that does not meet all quality control requirements is not qualified on the Discharge Monitoring Report (DMR). Page 2 #5120 Town of Beech Mountain 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. Ref: Quality Assurance Policies for Field Laboratories, Comment: 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. Temperature - Standard Methods, 215t Edition, 2550 Dissolved Ox qen — Standard methods, 21st Edition, 4500 G G Comment: The time of collection and analysis was not clearly documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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 bench sheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., an updated benchsheet that indicates that the time recorded is the collection and analysis time due to in -situ analysis) was received by email on May 19, 2011. No further response is necessary for this finding. FI — Standard Methods, 21$t Edition, 4500 H' S Comment: The pH samples and calibration buffers did not have proper units of measurement (S.U.) associated with the pH values. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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 bench sheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., an updated benchsheet that documents units of measure for pH) was received by email on May 19, 2011. No further response is necessary for this finding. Dissolved Oxygen — Standard Methods, 215t Edition, 4500 O G Comment: The calibration time was not documented. The Technical Assistance for Field Analysis of Dissolved Oxygen states: The time of calibration must be documented whenever sample analysis is performed. Notification of acceptable corrective action (i.e., an updated benchsheet that documents the calibration time) was received by email on May 19, 2011. No further response is necessary for this finding. Total Residual Chlorine -- Standard Methods, 21 st Edition, 4500 Cl G Comment: The time of analysis of the gel standard was not documented. The Technical Assistance for Field Analysis of Total Residual Chlorine states: The time the calibration check was performed must be documented whenever sample analysis is performed. Notification of acceptable corrective action (i.e., an updated benchsheet that documents the calibration check time) was received by email on May 19, 2011. No further response is necessary for this finding. Comment: The annual curve verification was performed by analyzing only three acceptable standards. The laboratory performed the curve verification with 20, 200, 400, 1000, and 1500 pg/L standards. The Page 3 #5120 Town of Beech Mountain first three standards were analyzed on the low-level program and the last two standards were analyzed on the regular -level program. This does not fulfill the requirement of a five -point curve verification because the two programs are distinct and separate. All five standards must be analyzed on the program used for sample analysis. Additionally, the laboratory was analyzing the gel standard on the regular -level program. The Technical Assistance for Field Analysis of Total Residual Chlorine states: Calibration checks must be for the curve and/or program used for sample analysis. Notification of acceptable corrective action (i.e., an acceptable curve verification consisting of five points on the low level program and assigning the gel standard a true value on the low-level program) was received by fax on June 8, 2011. No further response is necessary for this finding. The paper trail consisted of comparing laboratory bench sheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Beech Mountain WWTP (NPDES permit #NC0069761) and Grassy Gap WWTP (NPDES permit #NC0022730) for August, 2010. The following error was noted: Date Parameter Location Value on 13enchsheet Value on DMR 08/09/10 pH Grassy Gap Effluent 7.1 S.U. 7.0 S.U. 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 forwarded to the Regional Office. 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: Jason Smith Date: July 6, 2011 Report reviewed by: Todd Crawford Date: July 7, 2011