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HomeMy WebLinkAboutNC0020656_Lab Inspection_20020506133 William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Gregory J. Thorpe, Ph.D. Acting Director Division of Water Quality May 6, 2002 Mr. Robert Ellis Leith Creek WWTP Lab. P.O. Box 249 Covington Street Ext. Laurinburg, NC 28353-0249 SUBJECT: Wastewater/Groundwater Laboratory Certification Dear Mr. Ellis: 2ENR FRS M iW 8 2002 We have scheduled an on -site inspection of your laboratory for approximately 9:30 a.m., June 25, 2002. The scope of the inspection will include all methods marked on Attachment I of the laboratory's current North Carolina Wastewater /Groundwater Certificate and /or marked on the application for NC Wastewater/Groundwater Laboratory Certification. A copy of the current Attachment I is enclosed for your. reference. The purpose of the inspection will be to verify the laboratory's documented quality control/quality assurance procedures and adequacy in meeting the requirements of 15A NCAC 2H .0800. Enclosed are inspection checklists for the upcoming inspection. Prior to the on -site inspection, excluding the data review sections, please have your analysts complete each checklist. Any checklists that your laboratory is unable to complete, or any specific items that you do not understand, will be completed during the inspection. Completion of these checklists prior to the on -site audit, with comments by analysts relating to specific procedural differences, will help avoid any unnecessary interruption of the analyst's schedule. Please return these completed checklists, with 5 copies of completed benchsheet data for each inorganic parameter listed on your Attachment I. The checklists and requested data are to be received by this office on or before June 11, 2002. Please have available the DMR report sheets and corresponding bench data available for the months of October and December 2001 and February 2002 for us to review. If further data or report sheets are required, we will notify you during the inspection. These data sets will be used to assess the quality of your data during the inspection. Review your last inspection report to assure that all deficiencies have been corrected. If the deficiencies cited in the inspection report have not been corrected, enforcement action will be recommended. Thank you for your time and cooperation. I can be contacted at (919) 733-3908 (extension 273), if you have questions. Sincerely, rederick L. Bone Laboratory Section Enclosures cc: James W. Meyer Fayetteville Regional Office 47-74 u NCDENR Laboratory Section N. C. Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 (919) 733-3908 FAX: 919-733-6241 Internet: www.esb.enr.state.nc.usllab Michael F. Easley, Govemor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E. Director Division of Water Quality June 26, 2002 133 Mr. Robert Ellis Leith Creek WWTP Lab. P.O. Box 249 Covington Street Ext. Laurinburg, NC.28353-0249 SUBJECT: Laboratory Certification Maintenance Inspection Dear Mr. Ellis: RECEIVED JUN 2 8 2002 DENR - FAYEf f EVILLE REGIONAL OFFICE Enclosed is a report for the inspection performed on June 25,2002 by Mr. Frederick L. Bone. Where deficiencies are cited in this report, a response is required as well as for all lettered comments and/or recommendations. Within thirty days of receipt, please supply this office with a written item for item description of how these deficiencies, comments and/or recommendations were corrected. We are seriously concerned about the CITED PREVIOUSLY deficiency(ies) found during the inspection. If the deficiencies cited in the enclosed report are not corrected, enforcement actions will 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. Please contact us at 919-733-3908 if you have questions or need additional information. Sincerely, James W. Meyer Laboratory Section Enclosure cc: Frederick L. Bone Fayetteville Regional Office [/ NCDENR Laboratory Section N. C. Division of Water Quality 1623 Mail Service Center Raleigh, NC 27699-1623 (919) 733-3908 FAX: 919-733-6241 Internet: www.esb.enr.state.nc.usllab On -Site Inspection Report LABORATORY NAME: Leith Creek VWVfP ADDRESS: P.O.; Box' 249 Covington Street Ext. - Lauinburg, NC 28353-0249 CERTIFICATE NO: 133 DATE OF INSPECTION: June 25, 2002 TYPE OF INSPECTION: Maintenance EVALUATOR: Frederick L. Bone LOCAL PERSON(S) CONTACTED: Robert Ellis and Ricky Odem 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 laboratory is spacious and well equipped. All facilities and equipment are well maintained. Records are well kept and most data .looked good. Some further quality control procedures need to be implemented. III. DEFICIENCIES, RECOMMENDATIONS, REQUIREMENTS, AND COMMENTS: General: 1. DEFICIENCY: The laboratory is not verifying the automatic temperature compensation of the pH meter on an annual basis. CITED PREVIOUSLY Note: This was commented on for both the pH and Conductivity meters in the last inspection report. In addition, new meters with automatic temperature sensing devices are now being used in the laboratory to report DO. All electronic meters that use temperature compensation devices or areused to report temperature results must be calibrated annually against an NIST thermometer. REQUIREMENT: All thermometers must meet National Institute of Standards and Technology (NIST) specifications for accuracy or be checked against a NIST traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (o). 2. DEFICIENCY: Some of the daily logs used by the laboratory do not contain all of the necessary labeling information. No units of measure are associated with some of the data values listed in the logbooks. (Turbidity) Commented on previously 0 Page 2 `-REQUIREMENT =The laboratory must review all benchsheetsand-:-logbooks -toy-::ensure that every entry is marked with the appropriate units of measure. Every number recorded on a bench sheet or logbook must have an appropriate unit assigned to it. A.COMMENT: The laboratory does not list the acceptance ranges of all quality control samples on the laboratory benchsheets. (Fecal Coliform, Turbidity, BOD) RECOMMENDATION: It is strongly recommended that the laboratory list the acceptance ranges for each quality control sample on the benchsheet. This will enable the analyst to compare the analytical result to the acceptable range in a timely fashion. If the sample is out of the acceptable range, it can then be reanalyzed immediately and within all holding times. B. COMMENT: Some benchsheets were not filled out completely. Various data was omitted from random benchsheets. RECOMMENDATION: It is strongly recommended that the laboratory institute a peer review system. By having someone else look over the benchsheet data for accuracy and completeness, the laboratory can reduce the instances of the benchsheets not being fully completed. Fecal Coliform: 3. DEFICIENCY: The laboratory is not performing sufficient quality control for it's duplicate sample analysis. The laboratory must calculate either the relative percent difference, or the absolute difference for each duplicate pair analyzed. This value is then used to .establish control charts or other appropriate acceptance criteria. This type of data is necessary to demonstrate that the data is within acceptable control limits. The %RPD--must be listed on the inorganic bench sheets so that the analyst will be able to immediately confirm whether or not the data falls within acceptable limits. CITED PREVIOUSLY Note: This was cited as a general deficiency in last ' year's report. The laboratory still is not conducting any control criteria for duplicate pairs for the fecal coliform analysis. The laboratory must establish quality control limits for this analysis. Control charts are the best means of accomplishing this requirement. REQUIREMENT: Any time quality control results indicate an analytical problem, the problem must be resolved, and any samples involved must be rerun if the holding time has not expired. Ref: 15A NCAC 2H .0805 (a) (7) (f). Total Suspended Solids: 4. DEFICIENCY: The laboratory is not analyzing a sample of sufficient size to yield 1.0 mg of residue on each filter. CITED PREVIOUSLY Page 3 Note:'The = laboratoryis'analyzing 100`ml and 250 ml sample volumes. This sample,--volume'does not allow for the method required 1 mg of solids .remaining on each filter. It is recommended the laboratory filter 500 ml sample volumes for effluents in order to meet this method requirement. REQUIREMENT: The lab must filter enough sample to achieve >1.0 mg residue on the filter. Ref: EPA 600/4 - 79 -020, Revised Method 1983 Method 160.2 pg. 2-1. C. COMMENT: In cases where the 1 mg of final residue was not achieved and the laboratory only used a sample size of 100 ml or 250 ml, the laboratory was not properly adjusting the lower reporting limit of the method. Example: A sample volume of 100 ml does not yield 1 milligram of residue. The lower reporting limit in this situation would be <10mg/L. REQUIREMENT: The laboratory must properly adjust all reporting limits to reflect the .volume of sample that was actually analyzed. BOD: D. COMMENT: Some samples in the BOD incubator contained bubbles. The lab may need to strike the sides of the bottles with the glass stoppers to remove the tiny bubbles clinging to the sides df the bottles. Note: If. during the sample analysis, bubbles should develop, a . notation must be made on the laboratory benchsheet indicating this analysis problem and data shouldbe qualified on the DMR reporting form. REQUIREMENT: Fill bottles with enough dilution water, seeded if necessary, so that insertion of stopper will displace all air, leaving no bubbles. Ref: Standard Methods, 18 Edition - Method 5210 pg. 5-5. PAPER TRAIL INVESTIGATION: This consisted of comparing data reported on DMR's submitted to this Division with the values obtained on laboratory bench worksheets. Data reviewed for the months of January, March, and April 2002 indicated no problems in proper data reporting. CONCLUSIONS: We are concerned with the deficiencies that were cited previously and not corrected. Failure to correct the deficienciescited in this report will lead to enforcement action. Ref: 15A NCAC 2H .0807 (a) (1) and (14) Page 4 Laboratory; Decertification: A laboratory may be decertified for any or all parameters for up to one year for any or all of the following infractions: (1) Failing to maintain the .facilities, or records, or personnel, or equipment, or quality control program as set forth in the application, and these Rules; or (14) Failing to comply with any other terms, conditions, or requirements of this Section or of a Laboratory certification. Correcting the above deficiencies and comments and implementing the recommendations should help this lab to produce quality data and meet certification requirements. Please Respond to all Deficiencies and lettered Comments cited in this report. Report prepared by: Frederick L. Bone Date: June 25, 2002