The URL can be used to link to this page

Home My WebLink About#5138-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5138 Laboratory Name: Town of River Bend Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: July 21, 2010 Date Report Completed: August 3, 2010 Date Forwarded to Reviewer: August 3, 2010 Reviewed by: Tonja Springer Date Review Completed: August 4, 2010 Cover Letter to use: Insp. Initial x Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: August 4, 2010 Date Forwarded to Alberta: August 5, 2010 Date Mailed: August 5, 2010 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of River Bend NPDES PERMIT #: NC0030406 ADDRESS: 45 Shoreline Drive River Bend, NC 28562-8970 CERTIFICATE #: 5138 DATE OF INSPECTION: July 21, 2010 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Brandon Mills 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 lab was very clean and well organized. All equipment necessary to perform the certified parameters were present and appeared well maintained. A description of current field lab policies and technical assistance documents for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Data for pH and Dissolved Oxygen (DO) are being reported more often than required by the permit, which is fine. However, calibrations are only being documented for the days that data is actually required to be reported. Calibration information must be documented each day that sample results are reported, regardless of whether or not the reporting was required to meet frequency requirements. The North Carolina Administrative Code, 15a NCAC 2B .0506 (b) (3) (J) states: The results of all tests on the characteristics of the effluent, including but not limited to NPDES Permit Monitoring Requirements, shall be reported on monthly report forms. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, samples site, sample collector, and sample analysis time. The field bench sheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. These requirements were discussed during the audit and it was agreed that calibration information would be documented each day that analyses were performed. No further response is necessary for this finding. Comment: Benchsheets for pH and DO need to state that the analyses are being performed “in-situ”. Page 2 #5138 Town of River Bend A. Finding: Error corrections are being done in an unapproved manner. 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 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. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G Recommendation: Document the true value of the gel standard and the acceptable recovery range on the benchsheet so that it can be easily determined whether or not the calibration check standard is in control. B. Finding: The 5-point annual calibration verification curve expired on March 4, 2010. 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 at least every 12 months. The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 g/L and must not vary by more than 25% of the known value for standard concentrations less than 50 g/L. The overall correlation coefficient of the curve must be ≥0.995. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Send documentation with your response to this report. Comment: The curve currently being used did not pass all the acceptance criteria. While the overall correlation coefficient was 0.999, the 50 g/L and 100 g/L standards did not recover within 10 % of their true values. C. Finding: Results below the concentration of the lowest calibration standard are being routinely reported. Requirement: One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. Example: If the laboratory chooses to have a lower reporting limit of 100 μg/L for residual chlorine, you must analyze at least 100 µg/L or lower standard and report lower concentrations as < 100 μg/L or < the concentration of the chosen standard. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Recommendation: Document the value displayed on the meter, just as it appears, on the benchsheet. If that value is below the lowest calibration curve standard (10 μg/L), report that value on the Discharge Monitoring Report (DMR) as “< 10 μg/L”. 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 Quality. Data were reviewed for NPDES permit # NC0030406 for January, February and May, 2010. The following error was detected: Page 2 #5138 Town of River Bend Date Parameter Location Value on Benchsheet Value on DMR 05/18/10 Residual Chlorine Effluent 48 μg/L 32 μg/L In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended DMR will be required. A copy of this report will be forwarded to the Regional Office. 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 honesty and assistance during the inspection and subsequent data discovery and review process. Please respond to all findings. Report prepared by: Todd Crawford Date: August 3, 2010 Report reviewed by: Tonja Springer Date: August 3, 2010