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HomeMy WebLinkAbout#176_2010 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 176 Laboratory Name: City of Durham Water & Wastewater Laboratory Environmental Resources 101 City Hall Plaza Durham, NC 27701 Inspection Type: Technical Assistance and Municipal Maintenance Follow-up Inspector Name(s): Jeff Adams, Gary Francies and Dana Satterwhite Inspection Date: January 27, 2010 Date Report Completed: January 28, 2010 Date Forwarded to Reviewer: January 28, 2010 Reviewed by: Gary Francies Date Review Completed: January 29, 2010 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: January 29, 2010 Date Forwarded to Alberta: January 29, 2010 Date Mailed: January 29, 2010 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: City of Durham Water & Wastewater Laboratory Environmental Resources NPDES PERMIT #: NC0047597 ADDRESS: 101 City Hall Plaza Durham, NC 27701 CERTIFICATE #: 176 DATE OF INSPECTION: January 27, 2010 TYPE OF INSPECTION: Technical Assistance and Municipal Maintenance Inspection Follow-up AUDITOR(S): Jeff Adams, Gary Francies and Dana Satterwhite LOCAL PERSON(S) CONTACTED: Sheila Hopkins and Henry Plachinski I. INTRODUCTION: 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: This visit to the laboratory was to provide technical assistance and follow-up to the maintenance inspection performed on August 19, 2009. Technical assistance was provided and troubleshooting was performed for Total Kjeldahl Nitrogen (TKN) analysis. The laboratory was instructed to disregard the findings cited for TKN in the previous inspection report and submit written responses to this report under separate cover. The preparatory work that the laboratory analysts performed in advance was instrumental in effectively troubleshooting the TKN procedure. We appreciate the cooperation and diligence of the analysts in working to resolve the questions about the TKN procedure and derivation of the calculated results. It was also noted that the laboratory has implemented many of the recommendations and requirements cited in the August 19, 2009 inspection (e.g., the laboratory has developed and implemented the use of a digestion log for TKN digestion). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Recommendation: It is recommended that the laboratory rotate the position of samples, blanks and quality control samples in the block digester during TKN digestion. Random placement will help to identify when optimal performance is not achieved in an individual sample well. It is also recommended that the laboratory implement a temperature grid check of the block digester by alternating the well location of the thermometer each time samples are digested. This will document heating uniformity and consistency of all sample wells in the block. Page 2 #176 City of Durham Water and Wastewater Laboratory Recommendation: It is recommended that the laboratory analyze the digested organic nitrogen standard at a concentration in the range of the concentration of effluent samples. Establish acceptance limits based upon three standard deviations of the mean concentration of a minimum of 25 measurements. The laboratory may adopt a default acceptance criterion until sufficient data points are collected to calculate historical control limits. Recommendation: It is recommended that the laboratory contact the block digester manufacturer (i.e., Lachat Instruments) to obtain a copy of the published TKN digestion method for the BD-46 block digester. Recommendation: It is recommended that the laboratory insert the electrode into a low concentration standard solution after measurement of high concentration samples and standards to help decrease the stabilization time of the meter reading. A. Finding: An inconsistency was noted between the TKN Standard Operating Procedure (SOP) and laboratory practice as follows: Personnel were not following procedures as stated in the Laboratory’s SOP. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Ref: 15A NCAC 2H .0805 (a) (7). Comment: The SOP stated that 20 mL sample volumes are pipetted into digestion tubes. The laboratory analyst was pouring sample volumes to the 20 mL mark imprinted on the digestion tubes. Recommendation: It is recommended that sample volumes be dispensed using volumetric pipettes. As an alternative, digestion tubes may be calibrated volumetrically or gravimetrically and etched at the appropriate volume mark. In either case, the SOP must accurately describe the procedure employed during analysis. B. Finding: The laboratory is not using the catalyst cited in the referenced method. Requirement: All of the reagents listed for the determination of Nitrogen (Ammonia) (Section 4500-NH3.B.3) and Nitrogen (Organic) macro-kjeldahl (Section 4500-Norg.B.3) are required. Prepare all reagents and dilutions with ammonia-free water. Ref: Standard Methods, 19th Edition, 4500-Norg C. (3). Comment: The laboratory is citing Standard Methods, 19th Edition, 4500-Norg C. This method (which refers to 4500-Norg B for the reagents) specifies the use of copper sulfate (CuSO4) as the digestion catalyst. The lab is using mercuric sulfate (HgSO4) as the digestion catalyst. The more recently published methods have replaced the mercury catalysts with copper sulfate because of mercury’s toxicity and problems associated with legal disposal of mercury residues. In addition, the Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 72, No. 47, March 12, 2007; Table IB, footnote 5 allows the use of copper sulfate in place of mercuric sulfate where older methods specify the mercury catalyst. C. Finding: Total Kjeldahl Nitrogen results are not calculated according to the instrument manufacturer’s manual or the approved method. Requirement: Refer to the manufacturer’s instructions and proceed as in ¶s 4a and b [of Standard Methods, 19th Edition, 4500-NH3 D.]. Page 3 #176 City of Durham Water and Wastewater Laboratory Comment: The laboratory is equipped with a specific ion meter, which is capable of producing direct-read measurements in mg/L based upon the slope obtained for the specified calibration standards (undigested). Although the laboratory calibrated the instrument in a manner consistent with manufacturer’s instructions initially, raw environmental sample results were then manually calculated using a linear regression of digested standard readings versus the theoretical concentration of those digested standards. This manual regression of digested standards step must be eliminated. When the meter is properly calibrated with undigested standards and a slope in the approximate range of 54 to 60 mV/decade is obtained, a direct reading of samples, blanks and standards (in mg/L) may be used to calculate the final result. This is done using the calculation in Standard Methods, 19th Edition, 4500-NH3 D. (5). Note: Both pre- and post-digestion dilutions must be taken into account when calculating final results. In addition to calculating sample results from an improper “secondary” manual regression, the laboratory was not including a 10X dilution factor (derived from bringing the initial digestion volume (Vi) of 20 mL to a final volume (Vf) of 200 mL) in the final calculated results. Comment: It appears that, in spite of using improper means for calculating TKN results (as described above), the data was not significantly impacted. As further support of this assessment, the laboratory has been able to obtain acceptable results on blind TKN proficiency testing samples obtained by an approved A2LA-accredited vendor. D. Finding: The proper ratio of digestion solution to sample was not maintained. Requirement: Except as set forth in paragraph (b) (3) of this section, an analyst may modify an approved test procedure (analytical method) provided that the chemistry of the method or the determinative technique is not changed, and provided that the requirements of paragraph (b) (2) of this section are met. Ref: Code of Federal Regulations, Title 40, Part 136.6; Federal Register Vol. 72, No. 47, March 12, 2007. When adjusting sample volumes, the proper ratios of reagents must be maintained. Comment: When using the Lachat BD-46 hot block digestion apparatus, the laboratory would need to add 4 mL digestion solution to 20 mL sample to maintain the ratio described in the approved method. E. Finding: The laboratory is not recording the volume of 10N NaOH added. Requirement: Record volume of 10N NaOH added. Ref: Standard Methods, 19th Edition, 4500- NH3 D. (4) (e). F. Finding: The laboratory was not documenting all information necessary to calculate the final results (i.e., final volume after digestion). Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a) (7) (A). This is considered pertinent data. Comment: The volume of sample digested and dilution factor for pre-digestion dilutions was recorded on the benchsheet, however, the final volume of the digested sample must be recorded in order to reconstruct the calculated results. Recommendation: Add an additional column to the TKN bench worksheet to record the final volume after digestion. Page 4 #176 City of Durham Water and Wastewater Laboratory G. Finding: The laboratory was not compensating for any difference between the volume of sodium hydroxide solution added to samples and standards in the results calculation. Requirement: When the volume of 10N NaOH used for the samples is different than that used for the calibration standards this must be compensated for in the calculation. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon SM 19th, 20th, 21st 4500-NH3 D. (5). Comment: The following formula must be used in the calculation: mg NH3 – N/L = A x B x (100 + D) (100 + C) A= Dilution Factor B= Concentration of NH3-N/L, mg/L, from calibration curve C= Volume of 10N NaOH added to the calibration standards, mL D= Volume of 10N NaOH added to sample, mL H. Finding: The laboratory is not documenting the pH adjustment (i.e., to >11 pH units) of samples, blanks and quality control samples after 10N NaOH addition. Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to be readily available for inspection upon request. All analytical records must be available for a period of five years. Ref: 15A NCAC 2H .0805 (a) (7) (A) and (G). Comment: This pH adjustment may be performed using pH test strips, a meter or color- indicating Ionic Strength Adjuster (ISA). Recommendation: It is recommended that the laboratory consider using the color-indicating ISA. I. Finding: The volume of spike solution used in matrix spike preparation exceeds 1% (but is <10%) of the total matrix spike volume, and this volume adjustment is not factored into the calculated results. Requirement: The volume of spike solution used in matrix spike preparation must in all cases be ≤ 10% of the total matrix spike volume. It is preferable that the spike solution constitutes ≤ 1% of the total matrix spike volume so that the matrix spike can be considered a whole volume sample with no adjustment by calculation necessary. If the spike solution volume constitutes >1% of the total sample volume, the sample concentration or spike concentration must be adjusted by calculation. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Comment: The laboratory had corrected the issue of using >10% spike volume, but was not factoring the volume adjustment in the calculated results. IV. PAPER TRAIL INVESTIGATION: No paper trail performed. Page 5 #176 City of Durham Water and Wastewater Laboratory V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendations will help this lab to produce quality data and meet certification requirements. The inspectors would like to thank the staff for their assistance during the inspection and troubleshooting process. Please respond to all findings. Report prepared by: Dana Satterwhite Date: January 27, 2010 Report reviewed by: Gary Francies Date: January 29, 2010