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Home My WebLink About#113 2010-final2 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 113 Laboratory Name: Central Johnston County Regional WWTP Laboratory Inspection Type: Municipal Maintenance Inspector Name: Jeffrey R. Adams Inspection Date: April 13, 2010 Date Report Completed: April 30, 2010 Date Forwarded to Reviewer: 4/30/2010 Reviewed by: Tonja Springer Date Review Completed: 5/5/2010 Cover Letter to use: Insp. Initial Insp. Reg. X Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: May 6, 2010 Date Forwarded to Alberta: May 6, 2010 Date Mailed: May 6, 2010 _____________________________________________________________________ cc: Section Chief (Routing Sheet only) INSP-RTE.DO On-Site Inspection Report LABORATORY NAME: Central Johnston County Regional WWTP Laboratory NPDES PERMIT # NC0030716; WQ0019632 ADDRESS: P.O. Box 22263 Smithfield, NC 27577 CERTIFICATE # 113 DATE OF INSPECTION: April 13, 2010 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON (s) CONTACTED: Jennifer Doll and Chad Thompson 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: The laboratory was clean and the equipment appeared well maintained. The facility has all the equipment necessary to perform the analyses. Performance testing samples have been analyzed for all certified parameters for the 2009 proficiency testing calendar year and the graded results were 100% acceptable. Records were well maintained and organized. A field packet containing North Carolina Laboratory Certification policies and Quality Control requirements was presented to the laboratory supervisor by the inspector and was reviewed with the laboratory supervisor and staff during the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Ammonia – Standard Methods, 18th Edition, 4500 NH3 F Total Phosphorous – EPA Method 365.3 Comment: The laboratory was not performing matrix spike sample analysis. North Carolina Wastewater/Groundwater Laboratory Certification Policy requires, Unless the referenced method states a greater frequency, spike 5% of samples on a monthly basis. Laboratories analyzing less than 20 samples per month must analyze at least one matrix spike (MS) each month samples are analyzed. Prepare the MS from a reference source different from that used for calibration unless otherwise stated in the method. If MS results are out of control, the results must be qualified or the laboratory must take corrective action to rectify the effect, use another method, or employ the method of standard additions. When the method of choice specifies MS performance acceptance criteria for accuracy, and the laboratory chooses to develop statistically valid, laboratory-specific limits, the laboratory-generated limits cannot be less stringent than the criteria stated in the approved method. The laboratory has corrected this finding subsequent to the inspection. No further response is necessary for this finding. Page 2 #113 Central Johnston County Regional WWTP Laboratory BOD – Standard Methods, 18th Edition, 5210 B Comment: The laboratory was using a commercially-prepared double-strength standard consisting of 300 mg/L each of Glucose and Glutamic Acid. Rather than adjusting the dosage by using 3.0 ml of the standard to obtain a final 2% GGA solution as required by the method, the laboratory was using 2.5 mls yielding a 1.67% solution. This is a variation from the method. Standard Methods, 18th Edition, 5210 B. (4) (c) states, Determine 5-d 20°C BOD of a 2% dilution of the glucose-glutamic acid [GGA] standard check solution using the techniques outlined in ¶s 4d-j. Adjust concentrations of commercial mixtures to give 3 mg/L glucose and 3 mg/L glutamic acid in each GGA test bottle. The laboratory has corrected this procedure subsequent to the inspection. No further response is necessary for this finding. Comment: The laboratory stated historical BOD GGA standard data verified using the full 2% solution yielded very high and unacceptable numbers requiring the constant data qualifying, therefore, they opted to decrease the amount of GGA from 3 mls to 2.5 mls in order to yield GGA values within the acceptable range of 198 ± 30.5 mg/L BOD. Recommendation: It is recommended that the laboratory adjust the amount of seed in an attempt to compensate for the high GGA readings. Standard Methods, 20th and 21st editions, 5210 B. (6) allow for a Seed Correction Factor (SCF) greater than 1.0 mg/L but only if lab has data on file to show this is the only way to get acceptable results on GGA. However, the SCF in this case should not exceed 1.4 mg/L (per EPA Region IV). Comment: Extra nutrient, mineral, and buffer solutions are not added to the sample bottles containing more than 67% sample. North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th Edition, 5210 B. (4) (f) and Standard Methods, 21st Edition, 5210 B. (5) (c) (2) states, When a bottle contains more than 67% of the sample after dilution, nutrients may be limited in the diluted sample and, subsequently, reduce biological activity. In such samples, add the nutrient, mineral, and buffer solutions (3a through e) directly to individual BOD bottles at a rate of 1 mL/L (0.33 mL/300-mL bottle) or use commercially-prepared solutions designed to dose the appropriate bottle size. The laboratory has implemented this requirement subsequent to the inspection. No further response is necessary for this finding. Recommendation: It is recommended that a powder pillow for a 300-mL sample bottle be used. Dilution water would be prepared as it currently is and for the bottles containing more than 67% sample, one powder pillow would be added in addition to the dilution water containing the nutrient solutions. Total Suspended Residue – Standard Methods, 18th Edition, 2540 D Comment: A minimum dried residue weight gain of 1 mg was used to determine the practical quantitation limit (PQL). North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 21st Editions, 2540 D. (3) (b) states, Choose sample volume to yield between 2.5 and 200 mg dried residue. If volume filtered fails to meet m inimum yield, increase sample volume up to 1 L. If complete filtration takes more than 10 minutes increase filter diameter or decrease sample volume. The laboratory has implemented its reporting limit to 2.5 mg/L subsequent to the inspection. No further response is necessary for this finding. Comment: Since the publication of the Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 72, No. 47, March 12, 2007, there is no longer an approved method that allows for a 1 mg weight gain. Currently, the minimum weight gain allowed is 2.5 mg. In instances where the weight gain is less than the required 2.5 mg, the value must be reported as less than the appropriate value based upon the volume used. For example, if 500 mL of sample is analyzed and < 2.5 mg of dried Page 2 #113 Central Johnston County Regional WWTP Laboratory residue is obtained, the value reported would be < 5 mg/L. The minimum reporting value is now established at 2.5 mg/L based upon a sample volume used of 1000 mL. Turbidity – Standard Methods, 18th Edition, 2130 B Recommendation: Turbidity is no longer required to report for compliance purposes. Only performance evaluation sample data was available for review. It was recommended to the laboratory that they file an Amendment to Laboratory Certification requesting Turbidity be deleted from their certificate. The laboratory has filed an amendment with certification subsequent to the inspection and Turbidity has been removed from their certificate. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) and Non-Discharge Monitoring Reports (NDMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Central Johnston County Regional WWTP (NPDES permit #NC0030716) and (NPDES permit #WQ0019632) for December, 2009, January and February, 2010. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: The findings noted during the inspection were all corrected prior to the generation of this report. Implementing the recommendations will further improve the quality of the data. The inspector would like to thank the staff for its assistance during the inspection and data review process and quick attention to correcting the findings noted during the audit. No response is required. Report prepared by: Jeffrey R. Adams Date: April 30, 2010 Report reviewed by: Tonja Springer Date: May 5, 2010