HomeMy WebLinkAboutNC0044725_Lab Inspection_200710175085
Mr. Charles Vandenberg
Laurinburg-Maxton Airport
16701 Airport Rd.
Maxton, NC 28364-
SUBJECT: Laboratory Certification Maintenance Inspection
October 17, 2007
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen N. Sullins, Director
Division of Water Quality
DENR—FRo
OCT 1 b ` b3/
DWQ
Dear Mr. Vandenberg :
Enclosed isa report for the inspection performed on August 9, 2007 by 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,
Gary Francies
Certification Unit Supervisor
Laboratory. Section
Enclosure
cc: Chet Whiting
Fayetteville Regional Office
orthCarolina
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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, NC005427
16701 Airport Rd. Maxton, NC 28364
5085
August 9, 2007
Field Maintenance
Chet Whiting
Charles Vandenburg
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis
of environmental samples.
I1. - GENERAL COMMENTS:
There have been some policy changes and updates that were not required at that time of this facility's last inspection,
in particular Findings B, C, and E. The facility is also responsiblefor analysis of compliance monitoring samples for
NPDES permit NC0005479 (Laurel Hill Facility). Some calibration information for this facility was recorded on Togs for
NC0044725 (Maxton Airport) however this seemed incomplete and was difficult to follow. Original or copies of
compliance documentation needs to be on file in order to facilitate the review process. The items of the most concern
were data entries without a corresponding bench sheet. These were largely pH readings where no other testing was
required. The readings taken in the field are transcribed to a bench sheet; it appears that this sometimes does not
happen, possibly as a result of workload. This data is not supported and is therefore indefensible.
A follow-up technical assistance visit will be performed. At that time a paper trail will be conducted for the Laurel Hill
facility.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
A. Finding: Temperature corrections are not posted on instruments and thermometers.
Requirement: The correction factor (even if that factor is 0°C) must be documented on both the
instrument and on a separate sheet to be filed. Ref: NC Wastewater/Groundwater Laboratory Certification
Policy (NC WW/GW LC).
- Standard Methods, 18th Edition, 4500 H+ B
B. Finding: The Automatic Temperature Compensator (ATC) has not been verified.
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: NC WW/GW LC Policy Statement February 2006. See attachment for technical assistance.
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Laurinburg Maxton Airport #5085
C. Finding: The temperature at which pH is measured is not documented.
Requirement: Always report temperature at which pH is measured. Ref: Standard Methods 18th Edition
4500-H+ B.1.b.
D. Finding: The pH meter is calibrated with three buffers; however a verification buffer is not always
checked.
Requirement: In addition to the calibration standards, a pH 7 buffer calibration check must be performed.
The pH 7 buffer must read within a range of pH 6.9 to 7.1 to be acceptable. Ref: Technical Assistance for
Field Analysis of pH
E. Finding: The temperature sensing device of the pH meter had not been checked vs. an NIST
thermometer within the last 12-months.
Requirement: The temperature sensor in the meter must be checked every 12 months against a NIST
certified, or NIST traceable thermometer and the process documented even if the instrument is not used
for reporting temperature results. The meter temperature reading must be less than 1°C from the NIST
thermometer reading. (Other certified laboratories may provide assistance in meeting this requirement.)
Ref: Technical Assistance for Field Analysis of pH
Temperature — Standard Methods, 18th Edition, 2550 B
F. Finding: The NIST . check of the dissolved oxygen , meter sensor used to analyze compliance
temperatures was not performed within 12-months.
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. The meter
temperature reading must be less than 1°C from the NIST thermometer reading. (Other certified
laboratories may provide assistance in meeting this requirement.) Ref: TECHNICAL. ASSISTANCE FOR
FIELD ANALYSIS OF TEMPERATURE
Total Residual Chlorine —'Standard Methods, 18th Edition, 4500 CI G
G. Finding: The gel standard used, as a mid -range check, was not initially verified.
Requirement: The value supplied with the gel standard is an estimated value within a range. The true value
must be determined for each instrument and program. The true (assigned) values must be verified at a
minimum of ever 12-months. Ref: Manufacturer's Instructions and TECHNICAL ASSISTANCE FOR FIELD
ANALYSIS OF TOTAL RESIDUAL CHLORINE
Comment: There is a space to document the verified value on a sticker provided by some manufacturers.
H. Finding: The gel standard assigned value verified well against the regular level (program 80) instrument
curve. The .210 mg/L standard yielded a value of .210. mg/L (program 80) and 134 micrograms per liter
when checking the curve entered by the contract laboratory. Based on our experience this amount of
variation is of concern.
Requirement: The low level program must be re -checked for accuracy. Please submit a copy of the curve
with the response to this report. Ref: TECHNICAL ASSISTANCE FOR FIELD ANALYSIS OF TOTAL
RESIDUAL CHLORINE
Recommendation: The facility is analyzing low-level 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 will
continue to become difficult. We recommend the facility purchase upgraded instrumentation.
a
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Laurinburg Maxton Airport #5085
I. Finding: Sample lines to the Pour-thru cell were discolored and buildup was observed in the pour-thru cell
itself: This could be due to a build up of colored reaction products or algae.
Requirement: Clean and maintain equipment as indicated by manufacturer's Instructions. Ref: 15 A
NCAC 2H .0805 (a) (6) (H). The Hach Water Analysis Handbook Third Edition (pg. 389) states:
Equipment required to perform the analysis means properly maintained equipment. (Instructions on
cleaning are at end of report.)
J. Finding: The instrument calibration is not checked on the curve used for analysis. The gel standard is
checked on program 80; samples are analyzed on a low level program installed by the facilities contract
laboratory.
Requirement: When a five standard curve is used, the laboratory must verify the calibration curve each
analysis day. To do this, the laboratory must analyze a blank to zero the instrument and a check standard
each day that samples are analyzed. Check standard must be at mid level and within 10% of the known
value. General absorbance standard (DR/check) supplied by some manufacturers cannot be used for the
check standard. Ref: TECHNICAL ASSISTANCE FOR FIELD ANALYSIS OF TOTAL RESIDUAL
CHLORINE
Laurel Hill Facility (K,L,M):
- Standard Methods, 18th Edition, 4500 H+ B
Total Residual Chlorine (TRC) — Standard Methods, 18th Edition, 4500 CI G
DO - Standard Methods, 18th Edition, 4500 0 G
Temperature- Standard Methods 2250 B
K. Finding: Proper Units of Measure are not documented.
Requirement: Document proper units of measure. "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". Ref: 15A NCAC 2H .0805 (g) (1).
L. Finding: The instrument calibration time was not documented. Since samples may not be analyzed prior
to calibration or calibration check standards being analyzed this is considered required supporting
documentation.
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).
Comment: Calibration for pH and TRC is referenced on the Laurinburg - Maxton Calibration log. There is
however only one time on the log. During discussion it was indicated that the meters were not calibrated at
the same time.
Recommendation: A revision of the Laurel Hill bench sheet is recommended. This sheet should be
separate from the LMAC bench sheet and include all pertinent information such as: analyst initials, units of
measure, collection and analysis times and calibration times.
M. Finding: The annual temperature check of laboratory thermometers vs. an NIST Traceable Thermometer
was not documented for the following: In -line thermometer for compliance samples.
Requirement: See requirement for Finding F above.
Recommendation: The temperature is `analyzed using an in -line meter with a digital read out (°F). The °F
reading is concerted to °C using a limited table posted on a computer monitor in the lab. We recommend that
the above correction be posted onor near the digital read out. Also we recommend that temperature
conversion be performed usinga scientific calculator to increase the accuracy of the conversion. Such
calculators are easy to obtain and are inexpensive.
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Laurinburg Maxton Airport #5085
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 Laurinburg -
Maxton Airport (NPDES permit # NC0044725) for April and May 2007.
Date
Parameter
Location
Value on Benchsheet
Value on DMR
5/16/06
pH
Effluent
No bench Sheet
7.06
5/23/07
pH
Effluent
No Bench Sheet
7.44
4/17/07
pH
Effluent
No Value
8.33
4/16/07
pH
Effluent
8.33
No Value
4/10/07
pH
Effluent
6.51
6.41
In order to avoid questions of legality, it is recommended that amended DMRs be submitted to this Division.
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 lettered findings.
Report prepared by: Chet Whiting Date: August 30, 2007
Report reviewed by: Tonja Springer Date: September 13, 2007
ATTACHMENT
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 or a refrigerator
to less 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.
Sample lines and the pour-thru cell can become discolored and clogged due to a build up of
colored reaction products.
The Hach Water Analysis Handbook, Third Edition (pg. 389) states:
Cleaning the Pour-Thru Cell
The Pour-Thru Cell may accumulate a buildup of colored reaction products, especially if the
reacted solutions are allowed to remain in the cell for long periods after measurement. Remove
the buildup by rinsing the cell with 5.25 N sulfuric acid followed by rinsing with deionized water.
If your facility does not have access to or is not comfortable using sulfuric acid cleaning
solution, a contract laboratory or vendor may perform this service. Please exercise proper
safety precautions when handling acid solutions.