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Home My WebLink About#5180_9_2014_Final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5180 Laboratory Name: Blue Ridge Parkway/Mt. Pisgah Inspection Type: Field Maintenance Inspector Name(s): Jason Smith Inspection Date: September 16, 2014 Date Report Completed: October 23, 2014 Date Forwarded to Reviewer: October 23, 2014 Reviewed by: Nick Jones Date Review Completed: October 23, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Insp. Reg. Delay Unit Supervisor/Chemist III: Gary Francies Date Received: 10/24/2014 Date Forwarded to Linda: 10/28/2014 Date Mailed: 10/28/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Blue Ridge Parkway/Mt. Pisgah NPDES PERMIT #: NC0072729 ADDRESS: 199 Hemphill Knob Road Asheville, NC 28803 CERTIFICATE #: 5180 DATE OF INSPECTION: September 16, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jason Smith LOCAL PERSON(S) CONTACTED: Wayne Arnold and Henry Keefer 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: The facility has all the equipment necessary to perform the analyses. Since the last inspection, a new wastewater treatment plant and laboratory has been constructed. The new facility is very clean and well maintained. Contracted analyses are performed by Environmental Testing Solutions, Inc. (Certification #600). 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. The requirements associated with Findings A, B, C, F and G have been implemented by our program since the last inspection. The laboratory submitted unacceptable Proficiency Testing (PT) results for Total Residual Chlorine (TRC) and Conductivity. The laboratory no longer analyzes TRC due to disinfection by ultraviolet light and Conductivity analyses are no longer permit required. The laboratory chose to drop certification for these parameters. This change was made effective October 17, 2014. The laboratory maintains certification for pH, Dissolved Oxygen (DO), and Temperature. An acceptable pH PT was submitted and all PT requirements for 2014 are completed. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Error corrections are not dated. 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 Page 2 #5180 Blue Ridge Parkway/Mt. Pisgah 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: 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. Ref: Quality Assurance Policies for Field Laboratories. Comment: An example traceability log was provided to the facility at the time of the inspection. C. Finding: Instrument identification is not documented on the benchsheets for Dissolved Oxygen, Temperature and pH. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of Temperature, and NC WW/GW LC Approved Procedure for the Analysis of pH. D. Finding: Units of measure for Temperature (°C) and DO (mg/L) were not documented on the Dissolved Oxygen calibration log. Units of measure for pH (S.U.) were not documented on the pH calibration log. Requirement: 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). Quality Assurance E. Finding: The 10 Standard Units (S.U.) buffer expired March, 2014. Requirement: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specific day of the month), the last day of the month will be considered the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes may indicate potential contamination and the item should be discarded, even if the expiration date is not exceeded. If no expiration date is given, the laboratory must have a policy for assigning an expiration date. If no date received or expiration date can be determined, the item should be discarded. Ref: Quality Assurance Policies for Field Laboratories. Proficiency Testing F. Finding: The laboratory is not documenting 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. Page 3 #5180 Blue Ridge Parkway/Mt. Pisgah Comment: This means that the PT analyses must be documented on a benchsheet in the same manner as daily samples. pH – Standard Methods, 4500 H+ B-2000 Comment: The pH meter was not being calibrated daily. The NC WW/GW LC Approved Procedure for the Analysis of pH states: Instruments are to be calibrated according to the manufacturer’s calibration procedure prior to analysis of samples each day compliance monitoring is performed. The laboratory was analyzing a check buffer daily and the meter is only calibrated if the check buffer was unacceptable. A Notice of Finding for Immediate Response (NOFIR) was issued to the laboratory during the inspection. The laboratory agreed to calibrate the meter daily when samples are analyzed beginning September 17, 2014. Please submit a copies of the September (since the implementation date) and October, 2014 pH calibration logs with the reply to this report. Temperature – Standard Methods, 2550 B-2000 Recommendation: It is recommended that Temperature results be rounded to the nearest whole number. G. Finding: Temperature corrections were not applied to the results. Requirement: Document sample temperature measurements with any applicable temperature corrections applied. Ref: NC WW/GW LC Approved Procedure for Analysis of Temperature. H. Finding: The temperature correction is not posted on the meter. Requirement: The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for 5 years). Ref: NC WW/GW LC Approved Procedure for Analysis of Temperature. Recommendation: The laboratory checks the temperature sensor daily. Since this makes posting the correction on the meter difficult due to minor changes on a day-to-day basis, it is recommended that the laboratory check the temperature sensor less frequently, e.g., monthly. Temperature verification is only required annually. pH – Standard Methods, 4500 H+ B-2000 Temperature – Standard Methods, 2550 B-2000 Dissolved Oxygen – Standard Methods, 4500 O G-2001 I. Finding: The time of analysis is not clearly documented. Requirement: Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Date and time of sample analysis. Ref: NC WW/GW LC Approved Procedure for Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for Analysis of pH, and NC WW/GW LC Approved Procedure for Analysis of Temperature. Comment: The analysis time was not recorded because the samples are analyzed in-stream. A footnote may be added to the benchsheet to indicate this. Page 4 #5180 Blue Ridge Parkway/Mt. Pisgah 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 Resources. Data were reviewed for April, May, and August, 2014. 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 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: October 23, 2014 Report reviewed by: Nick Jones Date: October 23, 2014