HomeMy WebLinkAboutNC0044725_Lab Inspection_20080828August 28, 2008
5085
Mr. Mickey Oxendine
Laurinburg-Maxton Airport
16701 Airport Rd.
Maxton, NC 28364-
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
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SEP 0 5 2008
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SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Laboratory Certification Maintenance Inspection
Dear Mr. Oxendine :
Enclosed is a report for theinspection performed on July 16, 2008 by Ms. Tonja
Springer and Mr. Chet Whiting. Where finding(s) are cited in this report, a response is required.
Within thirty days of receipt, please supply this .office with a written item for item description of
how these finding(s) were corrected. If the finding(s) cited in the enclosed report are not
corrected, enforcement actions may be recommended. 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 919-733-.3908.
Sincerely,
Dana Satterwhite
Certification Unit Supervisor
Laboratory Section
Enclosure
Cc: Tonja Springer
Fayetteville Regional Office
None Carolina
Naturally
North Carolina Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 Phone (919) 733-3908 Customer Service
Internet: www.dwglab.org Location: 4405 Reedy Creek Rd Raleigh, NC 27607 Fax (919) 733-6241 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
On -Site Inspection Report
Laurinburg — Maxton Airport
NC0044725, NC005479
16701 Airport Rd.
Maxton, NC 28364
#5085
July 16, 2008
Field Maintenance
Tonja Springer, Chet Whiting
Mickey Oxendine
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 has undergone some personnel changes since the last inspection. Therefore, this inspection
consisted of technical assistance as well as a laboratory inspection.
Comment: The lab had been using an example field benchsheet provided by this unit during a past inspection. This
document no longer adequately documents required pertinent- information. Please be reminded that example.
documents are provided for technical assistance. It is the laboratory's responsibility to modify and update
documentation as needed to meet program requirements.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
A. Finding: Overwriting correction(s) was observed and some data entries were in pencil.
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 andlog entries must be written in indelible ink. Pencil entries are not
acceptable. Ref: North Carolina Wastewater/Groundwater Laboratory Certification (NC VVVV/GW LC)
Policy.
DO — Standard Methods,18th Edition, 4500 0 G
A. Finding: The cathode in the probe for the DO meter appeared to need cleaning.
Requirement: Follow all precautions recommended by the manufacturer to insure acceptable results. Ref:
Standard Methods, 18th Edition, 4500 O G 3 (b) page 4-104.
Comment: For correct probe , operation, the gold cathode must be textured properly. It can become
tarnished or plated with silver after extended use. The gold cathode can be cleaned by using the YSI 5238
Probe Reconditioning Kit or 400 grit wet/dry sandpaper. Never use chemicals or abrasives not
recommended or supplied by YSI. Ref: YSI 550A manual Probe Electrode Maintenance.
B Finding: The meter is calibrated but the calibration is not documented nor is the calibration time.
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#5085 Laurinburg - Maxton Airport
Requirement: A record of instrument calibration where applicable, must be filed in an orderly manner so
as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (g) (2) and NC WW/GW
LC Technical Assistance Document for field analysis of DO dated 9/07.
DO — Standard Methods, 18th Edition, 4500 0 G
pl — Standard Methods, 18th Edition, 4500 H+ B
Total Residual Chlorine — Standard Methods, 18th Edition, 4500 CI G
C. Finding: The meters are calibrated after samples are analyzed.
Requirement: The meter must be calibrated prior to the analysis of samples. Ref: NC WW/GW LC
Technical Assistance Documents for Field Analysis of pH, DO and Total Residual Chlorine, each dated 9/07.
�H — Standard Methods, 18th Edition, 4500 H+ B
D. Finding: The Automatic Temperature Compensator (ATC) has not been verified for the pH meter.
Requirement: The ATC must be verified annually (i.e., every twelve months) by analyzing a buffer at 25°C
(the temperature that pH values are compensated to) and a temperature(s) that bracket the temperature
ranges of the samples to be analyzed. This may require the analysis of a third temperature reading that is
> 25°C. Ref: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Policy
Statement September 2007. (See Attachment for Procedures) Please send a copy to our office with
your. reply.
E. Finding: The temperature at which pH is measured is not documented.
Requirement: Document the temperature at which the pH sample(s) are analyzed. Ref: Standard Methods
18th Edition Method 4500H+ B.1 b. and NC WW/GW LC Technical Assistance Document for field analysis of
pH dated 9/07.
F. Finding: The pH 10 buffer was past the expiration date of 1/03/08.
Requirement: Each facility must have glassware, chemicals, supplies, equipment, and a source of distilled
or deionized water that will meet the minimum criteria of the approved methodologies. Ref: 15A NCAC 2H
.0805 (g) (4).
Comment: Replace expired buffers. Expired buffers are not considered proper chemicals and supplies.
G. Finding: Proper units of measure are not documented on the benchsheet.
Requirement: 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 or initials of the analyst, and proper units of
measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Ref: (NC WW/GW LC) Technical Assistance
Document for field Analysis of pH dated 9/07
Total Residual Chlorine — Standard Methods, 18th Edition, 4500 CI G
Comment: The facility is analyzing low-level Total Residual Chlorine (TRC) with a Hach DR-2000. This instrument
was not originally designed with an internal curve for this procedure. The instrument was modified to allow
measurement in the microgram range. Since the manufacturer no longer supports this instrument, repair may be
difficult. We recommend the facility purchase upgraded instrumentation.
Comment: The facility has indicated that a new meter will be ordered.. Once the new meter is received an annual
verification of the curve must be performed along with a gel standard verification prior to analyzing samples.
(Guidance on how to obtain a true value for the gel standard is at the end of the report as an Attachment.)
Please send a copy upon completion of the verification curve for the new meter and the gel verification.
Comment: The lab was reading all 3 gel standards each analysis day as a calibration verification check. The
verification check was not performed on the internal curve used for sample analysis. The regular level curve is
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#5085 Laurinburg - Maxton Airport
entirely separate and its verification does not satisfy the curve verification requirement for the low-level (program
86) curve. There is probably a greater degree of variation since the regular level curve is factory installed and the
low-level curve was generated and installed by a contract laboratory. The gel standard (verification check) and
samples must be read on program 86. The gel standard in the 200 pg/L and blank are the only gel standards that
should be read for the low level program. The other gel standards included in the set will read "over range".
H. Finding: A mid -range check standard is not analyzed each day compliance samples are tested.
Requirement: When a five -standard annual curve verification is used, the laboratory must check the
calibration curve each analysis day. To do this, the laboratory must analyze a blank to zero the instrument
and analyze a check standard each day that samples are analyzed. Ref: Technical. Assistance for Field
Analysis of Total Residual Chlorine (9/07).
Finding: A copy of the last verification curve was not available at the time of the inspection.
Requirement: A verification of the internal calibration curve must be performed annually (every 12
months). This is performed by verifying the readings of five standards. The concentrations of the five
standards must bracket the concentration of the samples analyzed. One of the standards must have a
concentration equal to or below the lower reporting concentration. It is recommended that the values
obtained not vary by more than 10% ofthe known value for standards greater than 50µg/L and 25% of
the true value for standards less than 50µg/L. If the stored program readings vary by more than the above
acceptance criteria, the stored calibration program should not be used for quantitation until troubleshooting is
carried out to determine and correct the source of error. Ref: Standard Methods, 18th Edition - Method 4500-
CI G., Method 1020B Quality Control (5) page 1-5and Method 1070D 2. Ref: NC WW/GW LC Policy -
Technical Assistance for Field Analysis of Total Residual Chlorine (9/07)
Requirement: A record of instrument calibration where applicable, must be filed in an orderly manner so
as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (g) (2)
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 was reviewed for Laurinburg- Maxton Airport
(NPDES # NC0044725) and Laurel Hill (NPDES # NC005427) for April 2008. The following error was noted.
Date
Parameter
Location
Value on Benchsheet
Value on DMR
4/8/2008
Temperature
Downstream
15 °C
16 °C
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for
guidance as to whether an amended Discharge Monitoring Report 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 assistance during the
inspection and data review process. Please respond to all findings.
Report prepared by: Tonja Springer Date: July 31, 2008
Report reviewed by: Chet Whiting Date: August 1, 2008
Temperature Sensor Check Procedure:
To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a
NIST thermometer and record the two temperatures. The thermometer/meter readings must be Tess than or equal to 1°C
from the NIST thermometer reading. (NC WW/GW LC Policy). In the documentation include the serial number and
manufacturer of the NIST thermometer or NIST traceable thermometer that was used in the comparison. Also document
any correction that applies (even if zero) on both the thermometer/meter and on a separate sheet to be filed.
Recommendation: Use a NIST calibrated thermometer that approximates the temperature range on each thermometer used
with an incubator, refrigerator, or freezer. You may borrow such a thermometer, but keep a copy of the traceable to NIST
certificate on file to show the inspector.
Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a NIST
certified or NIST traceable thermometer and the process documented. NIST certified or NIST traceable thermometers
used for temperature measurement must be recalibrated in accordance with the manufacturer's recalibration date. If no
recalibration date is given, the NIST certified or NIST traceable thermometer must be recalibrated on a periodic basis to
not exceed five years. Ref: Technical Assistance for Field Analysis for Temperature dated 9/07.
Automatic Temperature Compensator (ATC) Check Procedure for Conductivity Meter:
The following must be performed on an annual (i.e., 12 month) basis:
1. Pour an adequate amount of conductivity standard into a beaker or other container and analyze at 25°C. Document
the temperature and conductivity value.
2. Lower the temperature of the standard by placing the container in cool water or a refrigerator to less than the lowest
anticipated sample temperature and analyze. Document the temperature and conductivity value.
3. If samples greater than 25°C are to be analyzed, perform the following additional step: Place the container in warm
water or a water bath and raise the temperature above 25°C to greater than the highest anticipated sample
temperature and analyze. Document the temperature and conductivity value.
As the temperature increases or decreases, the value of the conductivity standard must be within ± 10% of the
true value of the standard.
Comment: Anticipated temperatures can be obtained from a review of the Discharge Monitoring Reports (DMRs)
from the peak summer and winter months. Historical data should provide a reasonably accurate estimation of ranges
that will bracket the expected sample temperatures.
Automatic Temperature Compensator (ATC) Check Procedure for pH meter:
The following must be performed on an annual (i.e., 12 month) basis:
1. Pour an adequate amount of buffer into a beaker or other container and analyze at 25 °C. Document the temperature
and pH value.
2. Lower the temperature of the buffer by placing the container in cool water ora refrigerator to Tess than the lowest
anticipated sample temperature and analyze. Document the temperature and pH value.
3. If samples greater than 25 °C are to be analyzed, perform the following additional step: Place the container in warm
water, or a water bath and raise the temperature above 25 °C to greater than the highest anticipated sample
temperature and analyze. Document the temperature and pH value.
As the temperature increases or decreases, the value of the buffer must be within ± 0.1 S.U. of the true value of
the buffer.
Comment: Anticipated temperatures can be obtained from a review of the Discharge Monitoring Reports (DMRs)
from the peak summer and winter months. Historical data should provide a reasonably accurate estimation of ranges
that will bracket the expected sample temperatures.
How to obtain the initial "gel" standard true value for your daily TRC check standard
Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily calibration verification only. These
standards must be verified initially and every 12 months thereafter, with the standard curve.
Note: 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 pg/L standard would be verified, and not the 800 pg/L standard since the 800 pg/L standard
would be measured using a high range curve.
Immediately following curve verification:
1. Zero the instrument with the gel blank.
2. Read and record gel standard values.
3. Assign the obtained values as the true value.
The assigned values will be used for the next twelve months, or until a new curve verification is performed. The
gels are instrument specific. The gel/liquid standard verification must be performed for each instrument on which
they are to be used. If multiple instruments and/or standard sets are used, each must have assigned values
specific for the instrument and standard set.