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HomeMy WebLinkAbout#5211_11_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5211 Laboratory Name: Town of White Lake WWTP Inspection Type: Field Maintenance Inspector Name(s): Tonja Springer Inspection Date: 11/19/2014 Date Report Completed: 12/5/2014 Date Forwarded to Reviewer: 12/5/2014 Reviewed by: Todd Crawford Date Review Completed: 12/5/2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Insp. Reg. Delay Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 12/9/2014 Date Forwarded to Linda: 12/17/2014 Date Mailed: 12/18/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of White Lake WWTP ADDRESS: P.O Box 7250 White Lake, NC 28337 NPDES PERMIT # NC0023353 CERTIFICATE #: 5211 DATE OF INSPECTION: November 19, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: Bill Stafford and Tim Frush 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. Contracted analyses are performed by Environment 1, Inc. (Certification #10). 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 requirement associated with Finding H has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Quality Control Comment: Data from the contract lab reports that does not meet all quality control requirements is not qualified on the Discharge Monitoring Report (DMR). The Quality Assurance Policies for Field Laboratories document states: 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. Notification of acceptable corrective action (i.e., a statement that qualifiers from contract lab reports will Page 2 #5211 Town of White Lake be documented on the DMR) was received by email on 12/2/2014. No further response is necessary for this finding. Documentation Comment: Error corrections are not performed properly. Corrections were not initialed or dated. The Quality Assurance Policies for Field Laboratories states: 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. Notification of acceptable corrective action (i.e., a statement that date and initials will be documented with error corrections) was received by email on 12/2/2014. No further response is necessary for this finding. Comment: The laboratory benchsheets for Temperature, Dissolved Oxygen, Total Residual Chlorine, and pH were lacking pertinent data: Instrument identification. The NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature, 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. Notification of acceptable corrective action (i.e., a statement that the benchsheet provided at the time of the inspection that includes a space for instrument identification will be implemented 12/9/2014) was received per telephone conversation on 12/8/2014 from Mr. Bill Stafford. No further response is necessary for this finding. A. Finding: The laboratory needs to increase the documentation of purchased 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: The Quality Assurance Policies for Field Laboratories. Please submit a copy of an updated completed benchsheet that includes the required traceability information with the response to this report. Comment: An updated benchsheet with traceability information was faxed to our office on December 9, 2014. All the traceability information was documented on the benchsheet with the exception of the actual date for the date received, date opened and expiration date. The dates documented must be included with the month/day/year in order to be able to trace the reagents to the benchsheet. When a manufacturer does not give a day for expiration, the laboratory may assign the last day of the month. B. Finding: The laboratory is not maintaining temperature sensor calibration documentation for 5 years. Requirement: Thermometers and temperature measuring devices, used to measure temperature for compliance monitoring, must be checked every 12 months against a NIST Page 3 #5211 Town of White Lake traceable thermometer. The thermometer/meter readings must be less than or equal to 1ºC from the NIST traceable thermometer reading. The documentation must include the serial number of the NIST traceable thermometer that was used in the comparison. Document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. The following must be documented in indelible ink whenever sample analysis is performed: 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 the Analysis of Temperature. Please submit a copy of the temperature sensor verification with the response to this report. Comment: The temperature sensor on the Dissolved Oxygen meter used to obtain reported temperature values has been checked against a National Institute of Standards and Technology (NIST) traceable thermometer and is posted on the meter but the paperwork wasn’t available at the time of the inspection. C. Finding: The laboratory is not documenting the signature or initials of all analysts. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analytes. Ref: 15A NCAC 2H .0805 (g) (1). Please send copies of two weeks of completed benchsheets with the response to this report. Do not send a blank benchsheet. Comment: There are two analysts that are involved in sample collection and analysis and only one analyst is initialing laboratory benchsheets. One analyst does the analysis and calls out the result for another analyst to document the result on the benchsheet. pH – Standard Methods, 4500 H+ B-2000 Comment: Buffers are not poured fresh each analysis day. Standard Methods, 4500 H+B-2000. (3) (a) states: Because buffer solutions may deteriorate as a result of mold growth or contamination, prepare fresh. Growth of mold was observed at the time of the inspection in the secondary bottles used for the pH buffers. Notification of acceptable corrective action (i.e., a statement that fresh buffer solutions will be used each time an analysis is performed and fresh buffers will be poured into a beaker instead of using the plastic bottles.) was received by email on 12/2/2014. No further response is necessary for this finding. Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 D. Finding: The Total Residual Chlorine meter factory set curve is not verified every twelve months. Requirement: Instruments are to be calibrated according to the manufacturer’s procedure or a standard curve verification must be performed prior to analysis of samples each day compliance monitoring is performed. Standard curve verification checks must be performed for the standard curve and/or program used for sample analysis. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Requirement: Analyze a water blank to zero the instrument and then analyze a series of five standards. The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. This type of curve verification must be performed initially and at least every 12 months. The values obtained must not vary by more than Page 4 #5211 Town of White Lake 10% of the known value for standard concentrations greater than or equal to 50 µg/L and must not vary by more than 25% of the known value for standard concentrations less than 50 µg/L. The overall correlation coefficient of the curve must be ≥0.995. When a five-standard annual verification curve is generated, the laboratory must check the calibration curve each analysis day. To do this, the laboratory must analyze a calibration blank to zero the instrument and analyze a check standard each day the samples are analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Please send a copy of the calibration curve verification upon completion. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). Recommendation: It is recommended that the laboratory verify the internal calibration using the following concentrations: 10 (or 15), 20, 50, 200 and 400 µg/L. This will verify the analytical range used to measure Proficiency Testing (PT) samples, gel standards; as well as. environmental samples. Comment: The laboratory sent the meter back to Hach Company for calibration and servicing in 2014. When it was returned, Hach Company supplied paperwork that stated the meter had been calibrated. The laboratory was under the impression this met the NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine requirement for the annual calibration curve verification since the manufacturer’s paperwork stated it had been calibrated. E. Finding: The laboratory is not validating the annual calibration curve verifications against the required criteria. Requirement: The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 µg/L and must not vary by more than 25% of the known value for standard concentrations less than 50 µg/L. The overall correlation coefficient of the curve must be ≥0.995. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine Comment: The factory set annual calibration curve verifications analyzed by the lab from 2008 through 2012 did not meet all the acceptance criteria requirements. The curves that were submitted either had several standards that were outside the acceptance criteria and/or the overall correlation coefficient did not meet the >0.995 acceptance criteria. F. Finding: The Gel® standard is not verified every 12 months. Requirement: Purchased “Gel-type” or sealed liquid ampoule standards may be used for daily standard curve verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. When this is done, these standards may be used after the manufacturer’s expiration date. It is only necessary to verify the gel or sealed liquid standard which falls within the concentration range of the curve used to measure sample concentrations. For example, if you are measuring samples against a low range curve, a 200 g/L standard would be verified. Ref: Approved Procedure for the Analysis of Total Residual Chlorine. Please send a copy of the Gel® standard verification upon completion. Comment: The Gel® standard was verified in September, 2014 but the actual date was not documented on the benchsheet. The Gel® standard will need to be verified against the verified calibration curve and reassigned a new value. Page 5 #5211 Town of White Lake G. Finding: Values are being reported as less than the permit limit on the Discharge Monitoring Report (DMR). Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to the permit limit. Example: If the laboratory chooses to have a lower reporting limit of 17 µg/L for total residual chlorine, you must analyze at least a 17 g/L or lower standard and report lower concentrations as <17 µg/L or < the concentration of the chosen standard. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: An annual verification curve has not been analyzed to determine the lower reporting limit. The laboratory is reporting “< 17 µg/L”, which is their permit limit. Proficiency Testing Comment: The preparation of Total Residual Chlorine (TRC) Proficiency Testing (PT) samples was not documented. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: 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 fo rmat. The diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for analysis. Dating and initialing the instruction sheet for the preparation of the TRC PT would satisfy the documentation requirement. This 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 preparation of the TRC PT will be documented) was received by email on 12/2//2014. No further response is necessary for this finding. Comment: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: 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. This requirement is a new policy that has been implemented by our program since the last inspection. Known standards are being analyzed with the unknown samples. These constituted an additional level of QC that is not analyzed with routine compliance samples. However, known samples are recommended when analyzing remedial PT samples as part of the troubleshooting and corrective action process. Notification of acceptable corrective action (i.e., a statement that only unknown samples will be analyzed in the future) was received by email on 12/2/2014. No further response is necessary for this finding. H. 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. Comment: PT samples are not being documented on the benchsheets. Results were only documented on the vendor reporting form and then submitted electronically. Page 6 #5211 Town of White Lake IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for January, June and September, 2014. No transcription errors were detected. It appears the facility is doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendation 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: Tonja Springer Date: December 5, 2014 Report reviewed by: Todd Crawford Date: December 5, 2014