HomeMy WebLinkAboutNC0026271_Regional Office Historical File Pre 2018 (38)Water Resources
ENVIRONMENTAL QUALITY
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
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S. JAY ZIMMERMAN
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5062 AeCr=1VED/Nt oC-NR/0WR
Mr. Brian Eades JAN 12 2016
Taylorsville WWTP
67 Main Ave Drive wQR0$3
Taylorsville, NC 28681 MOGRESVIUA RRMONAI, OFFP4
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Eades:
Enclosed is .a report for the inspection performed on November 19, 2015 by Jason Smith. Since the
Finding(s) cited during the inspection were all corrected prior to the_completion of the enclosed report, a
response is not required. The staff is commended for taking the initiative in correcting the Findings in
such a timely manner. For Certification maintenance, your laboratory must continue to carry out the
requirements set forth in 15A NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office. Thank you
for your cooperation during the inspection. If you wish to obtain an electronic -copy of this report by
email, or if you have questions or need additional information, please contact us at (828) 296-4677.
Attachment
cc: Jason Smith.
Master File
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: 919-733-39081 FAX: 919-733-6241
Internet: http:Ilportal.ncdenr.org[weblwallablcert
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. M
Laboratory Narrie:
Inspection Type:
Inspector Name(s).
Inspection Date:
Date Report .Completed:
Date Forwarded to Reviewer:
Reviewed by.
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Linda:
Date Mailed:
5062
Taylorsville WWTP
Field Maintenance
Jason Smith and Beth Swanson
November 19, 2015
December 16, 2015
December 16, 2015
Beth Swanson
December 17, 2015
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected ❑ Insp. Reg. Delay
Gary Francies
December 18, 2015
1/11/2016
Please send copy to Wes Bell MRO
1 /12/2016
W,
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Taylorsville WWTP
NCO026271
.67 Main Ave Drive
Taylorsville, NC 28681
5062
November 19, 2015
Field Maintenance
Jason Smith and Beth Swanson
LOCAL PERSON(S) CONTACTED: Brian Eades
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. Proficiency Testing (PT) samples
have been analyzed for all certified parameters for the 2015 proficiency testing calendar year and the
graded results were 100% acceptable.
The laboratory is certified for Dissolved Oxygen, however, compliance samples are not analyzed and data
was not reviewed during the inspection.
Contracted analyses are performed by Water Tech Labs, Inc. (Certification #50).
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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory needed to increase the documentation of purchased materials and reagents.
The NC WW/GW LC Quality Assurance Policies for Field Laboratories document states: 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.
Consumable materials such as pH buffers and lots of pre -made standards are included in this
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., the provided reagent receipt log which
includes spaces for all required information was put into ,use on December 11, 2015) was received by
email on December 11, 2015. No further response is necessary for this Finding.
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#5062 Taylorsville VWVTP
Comment: The sample site (facility name and sample location) was not documented in the log book.
The NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure
for the Analysis of Temperature, 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: Sample site including facility name and location, ID, etc. Acceptable corrective
action (i:e., a note was added to the log book identifying the sample site with facility name. and sample
location) was performed during the inspection. No further response is necessary for this Finding.
Comment: Error corrections were not dated when performed. The NC WW/GW LC Quality Assurance
Policies for Field Laboratories document 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. This requirement is a new policy that has
been implemented by our program since the last inspection. Notification of acceptable corrective action
(i.e., error corrections are now dated by the responsible individual) was received by email on November
24, 2015. No further response is necessary for this Finding.
Comment: Instrument identification was not documented. The NC WW/GW LC Approved Procedure for
the Analysis of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of pH,. NC
WW/GW LC Approved Procedure for the Analysis of Temperature, and NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen state: The following must be documented in indelible
ink whenever sample analysis is performed: Instrument Identification. This requirement is a new policy
that has been implemented by our program since the last inspection. Notification of acceptable corrective
action (i.e., instrument identification is now documented in the log book) was received by email on
December 17, 2015. No further response is necessary for this Finding.
Quality Control
Comment: The laboratory has not had the mechanical volumetric pipet that is used for Proficiency
Testing (PT) sample preparation calibrated. The NC WW/GW LC Quality Assurance Policies for Field
Laboratories document states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable
auto-pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at least
every twelve months and documented. This requirement is a new policy that has been implemented by
our program since the last inspection. Notification of acceptable corrective action (i.e., the mechanical
volumetric pipet will be calibrated annually beginning in January, 2016) was received by email on
November 24, 2015. No further response is necessary for this Finding.
Proficiency Testing
Comment: PT sample preparation was not documented. This requirement is applicable to the Total
Residual Chlorine PT. The NC WW/GW LC 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 format. The diluted PT sample becomes a routine environmental sample and is added to a
routine sample batch for analysis. This requirement is a new policy that has been implemented by our
program since the last inspection. Notification of acceptable corrective action (i.e., the preparation
instruction sheets will be signed and dated when the PT is prepared beginning with the next PT study
performed) was received by email on November 24, 2015. No further response is necessary for this
Finding.
N
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#5062 Taylorsville WWTP
Comment: PT sample analysis documentation included all required information; however it was not
documented in the same format as sample analysis. The NC WW/GW LC Proficiency Testing
Requirements, February 20, 2012, Revision 1.2 document states: All PT sample analyses must be
recorded in the daily analysis records as for any environmental sample. This serves as the permanent
laboratory record. The analysis of PT samples is designed to. evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and the
process documented in the same manner as environmental samples. This requirement is a new policy
that has been implemented by our program since the last inspection. Notification of acceptable
corrective action (i.e., PT analyses will be documented the same as samples and a note has been
added to their PT information to ensure that it is performed beginning with the next PT study) was
received by email on December 14, 2015. No further response is necessary for this Finding.
Total Residual Chlorine — Standard Methods, 4600 Cl G-2000.
Comment: The laboratory occasionally used a Hach Pocket Colorimeter II which is not approved by the
Division'of Water Resources for low level Total Residual Chlorine (TRC) analyses: The NC WW/GW LC
Approved Procedurefor the Analysis of Total Residual Chlorine states: If a facility has no effluent limit for
TRC (just a monitoring requirement), then use of a hand-held meter, sometimes described as a pocket
colorimeter, is acceptable. The facility has a permit, limit of 28 pg/L, so the Pocket Colorimeter is not
acceptable to use. Notification of acceptable corrective action (i.e., as of November 20, 2015 a pocket
colorimeter will not be used for TRC sample analyses which are reported on the Discharge Monitoring
Report (DMR)) was received by email on November 20, 2015. Additionally, the town ordered a new
spectrophotometer to replace their current spectrophotometer. Issues with the power button on their
current spectrophotometer was the reason that a, pocket colorimeter was occasionally used. No further
response is necessary for this Finding.
Recommendation: TRC results are reported as <22 pg/L; however, the curve was verified down to 20
pg/L. It is recommended that the lowest concentration verified during the annual curve verification (i.e., 20
lag/L) be used as the reporting limit.
pH — Standard Methods, 4500 H* B-2000
Temperature — Standard Methods, 2660 B-2000
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: Sample collection and analysis times were documented, but the times were not clearly
labeled. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Certified Data must
consist of date collected, time collected, samples site, sample collector, and sample analysis time.
Acceptable corrective action (i.e., a note added to the log - book that the first time recorded is the
collection time and the second time recorded is the analysis time) was performed during the inspection.
No further response is necessary for this Finding.
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 the Taylorsville WWTP- (NPDES permit
#NC0026271) for May, June, and'September, 2015. The following errors were noted:
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#5062 Taylorsville WWTP
Date
Parameter
Location
Value on Benchsheet
*Contract Lab Data
Value on DMR
9/8/15
Ammonia
Effluent
*3.85 mg/L
0.58 mg/L
9/9/15
Ammonia
Effluent
*6.55 mg/L
4.1 mg/L
9/10/15
Ammonia
Effluent
*5.70 mg/L
<0.2 mg/L
The laboratory has submitted an amended eDMR for the month of September, 2015 to correct these
errors.
V. CONCLUSIONS:
All findings noted during the inspection were adequately addressed prior to the completion of this
report. The inspector would like to thank the staff for its assistance during the inspection and data review
process. No response is required.
Report prepared by: Jason Smith
Report reviewed by: Beth Swanson
Date: December 16, 2015
Date: December 17, 2015