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HomeMy WebLinkAbout#5579_2020_0130_AO_FINALLaboratory Cert. #: 5579 Laboratory Name: West Carteret Water Corporation Inspection Type: Field Municipal Maintenance Inspector Name(s): Anna Ostendorff Inspection Date: January 30, 2020 Date Forwarded for Initial February 5, 2020 Review: Initial Review by: Michael Cumbus Date Initial Review February 7, 2020 Completed: ❑ Insp. Initial ® Insp. Reg Cover Letter to use: ❑Insp. No Finding ❑Corrected ❑Insp. CP ❑Insp. Reg. Delay (to use: rt click, properties, chock) Unit Supervisor/Chemist III: Beth Swanson Date Received: 2/7/2020 Date Forwarded to Admin.: 2/10/2020 Date Mailed: 2/10/2020 Special Mailing Instructions: ROY COOPER Governor MICHAEL S. REGAN Secretary S. HANIEL SMITH Director 5579 Ms. Lisa Guarino West Carteret Water Corporation 4102 Hwy 24 Newport, NC 28570 NORTH CAROLINA Environmental Qualify February 10, 2020 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Guarino: Enclosed is a report for the inspection performed on January 30, 2020 by Anna Ostendorff. 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. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. 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. A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. 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 me at (919) 733-3908 Ext. 259. Sincerely, 1, Beth Swanson Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Dana Satterwhite, Anna Ostendorff North Carolina Department of Lnvi onmental Quality I Division of Water Resources UE 440 r Reedy Creep (toad 1 1623 Mail Set vice Center ; Raleigh, North Carolina 27h99 1623 N011t! I C�INA oepadrncrl nrE o�m +er oonay 919131.3908 LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: West Carteret Water Corporation NCO077143 4102 Hwy 24 Newport, NC 28570 5579 January 30, 2020 Field Municipal Maintenance Anna Ostendorff Lisa Guarino 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 02H .0800 for the analysis of environmental samples. GENERAL COMMENTS: The facility is neat and well organized and has all the equipment necessary to perform the analyses. Benchsheets are well designed, easy to follow and concise. Records are well organized and easy to retrieve. The inspector would like to commend the laboratory for staying current with changes in laboratory certification program requirements by visiting the NC Wastewater/ Groundwater Laboratory Certification website and proactively implementing new requirements prior to the on - site inspection. The laboratory has drafted Standard Operating Procedures (SOPs) for all parameters in compliance with the revised 15A NCAC 02H ,0800 Rules well in advance of the July 1, 2020 implementation deadline. The laboratory was voluntarily certified for Temperature by Standard Methods, 2550 B-2010 (Aqueous) and requested it be deleted from their Certified Parameter Listing (CPL) on January 31, 2020. This change was effective January 31, 2020. All required Proficiency Testing (PT) Samples have been analyzed for the 2019 PT Calendar Year and the graded results were 100% acceptable. Contracted analyses are performed by Environment 1, Inc. (Certification # 10). Page 2 #5579 West Carteret Water Corporation Approved Procedure documents for the analysis of the facility's currently certified Field Parameters were provided at the time of the inspection. Documentation A. Finding: The laboratory benchsheets for pH and Total Residual Chlorine are lacking required documentation: the method or Standard Operating Procedure and instrument identification. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the method or Standard Operating Procedure and instrument identification. Each item shall be recorded each time samples are analyzed. Analyses shall conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (A) and (C). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Method Reference and instrument identification (serial number preferred). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH; NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric). D. Finding: The laboratory benchsheet for pH is lacking required documentation: Units of measure. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the proper units of measure. Each item shall be recorded each time samples are analyzed. Analyses shall conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (L). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Units of measure. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. C. Finding: The laboratory benchsheet for Total Residual Chlorine is lacking required documentation: Daily Check Standard analysis time. Requirement: The following must be documented in indelible ink whenever _sample analysis is performed: Daily Check Standard analysis date and time(s). Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric). Proficiency Testing D. Finding: Additional QC beyond what is routine for Compliance Samples is being analyzed with PT Samples. Requirement: Laboratories are required to analyze an appropriate PT Sample by each parameter method on the laboratory's CPL. The same PT Sample may be analyzed by one or more methods. Laboratories shall conduct the analyses in accordance with their routine testing, calibration and reporting procedures, unless otherwise specified in the instructions supplied by the Accredited PT Sample Provider. This means that they are to Page 3 #5579 West Carteret Water Corporation be logged in and analyzed using the same staff, sample tracking systems, standard operating procedures including the same equipment, reagents, calibration techniques, analytical methods, preparatory techniques (e.g., digestions, distillations and extractions) and the same quality control acceptance criteria. PT Samples shall not be analyzed with additional quality control. They are not to be replicated beyond what is routine for Compliance Sample analysis. Although, it may be routine to spike Compliance Samples, it is neither required, nor recommended, for PT Samples. PT sample results from multiple analyses (when this is the routine procedure) must be calculated in the same manner as routine Compliance Samples. Ref: Proficiency Testing Requirements, November 26, 2019, Revision 4. Comment: The laboratory is analyzing a known QC sample from the PT vendor along with the blind PT Sample. The additional known QC sample is not analyzed with routine compliance samples. The laboratory may continue to order and analyze the known QC sample as part of their quality assurance plan but the known QC sample may not be analyzed on the same day as the blind PT sample. Comment: The laboratory orders a second Total Residual Chlorine PT Sample and averages the results of both blind PT Samples for reporting to the vendor. Routine compliance samples are not duplicated. E. Finding: Data qualifiers from the contract laboratory reports are not being transferred to the Discharge Monitoring Report (DMR). Requirement: Reported data associated with quality control failures, improper sample collection, holding time exceedances, or improper preservation shall be qualified as such. Ref: 15A NCAC 02H .0805 (e) (5). Comment: This was noted for a Total Suspended Residue sample collected February 19, 2019. Sample results reported by the contract lab included a qualifier that precision between duplicates exceeded the acceptance criterion. pH — Standard Methods, 4500 H+ B-2011 (Aqueous) F. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 pH unit. Ref: Standard Methods, 4500 H+ B-2011. (6). Recommendation: The laboratory currently reports pH sample results to two decimal places. It is recommended that the laboratory continue to measure and document sample results on the benchsheet to two decimal places, and to round to the nearest 0.1 S.U. when reporting results on the DMR. Comment: Per PT Vendor instructions, the PT Sample results should be reported to two decimal places. IV. PAPER TRAIL INVESTIGATION: Page 4 #5579 West Carteret Water Corporation The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for West Carteret Water Corporation (NPDES permit # NC0077143) for May, September and December 2019. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. Correcting the above -cited Findings and implementing the Recommendation will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for their assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation, implementation dates and steps taken to prevent recurrence for each corrective action. Report prepared by: Anna Ostendorff Date: February 5, 2020 Report reviewed by: Michael Cumbus Date: February 7, 2020 \ / 2 F % / 2 / - 2 a \ .. / E E ;) ) \ M ) $ \ � a \ w/3 \ { \ § E ) § \ � j v OD } ) G / ( / CY / \ f - o \ \ \ \ \ \ \ \ / a J / § / / w ƒ 2 / e § § u o / f + § ) g g o I e ED \ ) § \ r , ƒ \ \ ) } 2 \ § \ O N O N N CD N N N Lo LO Cc n a z m p N � p c � J U U W W 0 3 O N a N f/1 N N E N N W r W O C N Q N � 7 N LLI E L ]C w � W o a U 0 a� U T N N r O O 00 O 2 N U Q U Z c < O (� 0 O p_ c U d m L v N t _ (D d U N z E T U 2 o a' 3 0)Q m _0 N N d z L p 0 O 7 7 � a a m O r J n H m N N � coE @ U uj U 2 O Z z co O O O z a p v v -0-0Z J is U a