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Home My WebLink About#5132_03_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5132 Laboratory Name: Town of Beulaville Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: March 20, 2014 Date Report Completed: March 31, 2014 Date Forwarded to Reviewer: March 31, 2014 Reviewed by: Nick Jones Date Review Completed: April 1, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: April 1, 2014 Date Forwarded to Linda: April 4, 2014 Date Mailed: April 7, 2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Beulaville NPDES PERMIT #: NC0026018 ADDRESS: PO Box 130 Beulaville, NC 28518 CERTIFICATE #: 5132 DATE OF INSPECTION: March 20, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Angie Miller 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not yet been analyzed. The laboratory is reminded that these results must be submitted to this office directly from the vendor by September 30, 2014. 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 Vann Laboratories (Certification #22). The requirements associated with Findings B, C, D, and E been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Instrument identification for the meters used for Temperature, pH, Dissolved Oxygen and Total Residual Chlorine was not documented on the benchsheet. The NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. This Page 2 #5132 Town of Beulaville requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that the revised benchsheet developed by the inspector, which identifies all meters by model and serial number, would be used starting April, 2014) was received via email on March 27, 2014. No further response is necessary for this finding. General A. Finding: Proper rounding of numbers is not consistent. Requirement: Rounding off by dropping digits that are not significant. If the digit 6, 7, 8, or 9 is dropped, increase the preceding digit by one unit; if the digit 0, 1, 2, 3, or 4 is dropped, do not alter the preceding digit. If the digit 5 is dropped, round off the preceding digit to the nearest even number: thus 2.25 becomes 2.2 and 2.35 becomes 2.4. Ref: Standard Methods, 1050 B-2006. (2). 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. 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. Comment: This Finding refers specifically to pH buffers and the reagents used for total residual chlorine. Proficiency Testing C. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as environmental samples. Requirement: All PT samples are to be analyzed and the results reported in a manner consistent with the routine analysis and reporting requirements of compliance samples and any other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: The laboratory’s common practice was to analyze a known standard along with the PT sample as additional quality control. Environmental samples are not analyzed in this manner. D. 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. Page 3 #5132 Town of Beulaville Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT would satisfy the documentation requirement. E. 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 F. Finding: The check buffer reading was frequently outside the acceptable range of ±0.1 S.U. and the meter was not recalibrated. Requirement: In addition to the calibration standards, the meter must be verified with a third calibration standard. 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 the Analysis of pH. Comment: If the check buffer does not read within ±0.1 S.U., the lab should first try pouring a new aliquot of the check buffer and reading it again. If it still does not read within ±0.1 S.U., the meter must be recalibrated. If, after recalibration, the check buffer does not read within ±0.1 S.U., the meter and/or probe operation may be suspect and may require servicing. If the laboratory does not have a back-up meter/electrode, or another meter/electrode cannot be procured, it is recommended that the lab report the measured pH results with a qualifier that indicates the value is estimated. Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 Comment: It would be acceptable and more economical, in terms of cost and time, if the facility switched from liquid reagents to DPD powder pillows. Use of the flow-thru cell could also be discontinued. Comment: The true value of the check standard was not documented on the benchsheet. The NC WW/GW LC Approved Procedure for Analysis of Total Residual Chlorine document states: “The following must be documented in indelible ink whenever sample analysis is performed: True value of the check standard”. Notification of acceptable corrective action (i.e., a statement that the revised benchsheet developed by the inspector, which shows the true value of the check standard, would be used starting April, 2014) was received via email on March 27, 2014. No further response is necessary for this finding. pH – Standard Methods, 4500 H+ B-2000 Dissolved Oxygen – Standard Methods, 4500 O G-2001 Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 Comment: The pH meter, chlorine meter and Dissolved Oxygen meter calibration times were not being documented. The NC WW/GW LC Approved Procedure for Analysis of pH, the NC WW/GW LC Approved Procedure for Analysis of Dissolved Oxygen (DO) and the NC WW/GW LC Approved Procedure for Analysis of Total Residual Chlorine documents state: “The following must be documented in indelible ink whenever sample analysis is performed: Meter calibration and meter Page 4 #5132 Town of Beulaville calibration time(s)”. Notification of acceptable corrective action (i.e., a statement that the revised benchsheet developed by the inspector, which provides space for calibration times for all three meters, would be used starting April, 2014) was received via email on March 27, 2014. No further response is necessary for this finding. 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 NPDES permit #NC0026018 for December, 2013, January and February, 2014. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DMR 12/17/13 Temperature Effluent 15.3 °C 17 °C 1/28/14 Temperature Effluent 10.8 °C 10 °C * 2/18/14 pH Effluent 6.85 S.U. 6.9 S.U. * * See Finding A requirement. 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 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: March 31, 2014 Report reviewed by: Nick Jones Date: April 1, 2014