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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 7Uatitrallf 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. Page 2 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 Page 3 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. Page 4 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.