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HomeMy WebLinkAbout#5072_2017_0817_JS_FINAL-�= To be attached to all inspection reports in-house only. Laboratory Cert. #: 5072 Laboratory Name: Hickory Water Treatment Plant Inspection Type: Field Municipal Maintenance Inspector Name(s): Jason Smith Inspection Date: August 17, 2017 Date Forwarded for Initial Review: August 28, 2017 Initial Review by: Tonja Springer Date Initial Review Completed: August 28, 2017 Cover Letter to use: ❑ Insp. Initial ❑Insp. No Finding ❑Corrected ® Insp. Reg ❑Insp. CP ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: August 29, 2017 Date Forwarded to Admin.: August 31, 2017 Date Mailed: August 31, 2017 Special Mailing Instructions: Beater Resources ENVIRONMENTAL QUALITY August 31, 2017 5072 Ms. Nicole Hairston Hickory Water Treatment Plant P.O. Box 398 Hickory, NC 28603 ROY COOPER MICHEAL S. REGAN S. JAY ZIMMERMAN Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Hairston: L-resin. Enclosed is a report for the inspection performed on August 17, 2017 by Jason Smith. 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. 251. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Dana Satterwhite, Jason Smith, Master File 5072 Hickory Water Treatment Plant NCO044121 1560 Old Lenoir Rd Hickory, NC 28601 5072 August 17, 2017 Field Municipal Maintenance Jason Smith LOCAL PERSON(S) CONTACTED: Nicole Hairston INTRODUCTION: 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 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The facility is neat and well organized and has all the equipment necessary to perform the analyses. The laboratory analyst was very forthcoming and receptive to implementing the necessary changes in response to the Findings and Recommendations made during the inspection. All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year and the graded results were 100% acceptable. Contracted analyses are performed by Pace Analytical Services, LLC — Asheville, NC (Certification #40). Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the analysis of the facility's currently certified Field Parameters were provided at the time of the inspection. Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst and proper units of measure for all analyses", are intended to be a requirement to document all pertinent information for historical reconstruction of data. It is not intended to imply that existing records are not adequately maintained unless the Finding speaks directly to that. Page 2 #5072 Hickory Water Treatment Plant III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory A. Finding: For chemicals/reagents/consumables that do not have an expiration date (e.g., Potassium Permanganate and the standard prepared from it), the laboratory has not established a policy for assigning expiration dates. Requirement: If no expiration date is given, the laboratory must have a policy for assigning an expiration date. Ref: Quality Assurance Policies for Field Laboratories. Documentation D. Finding: Error corrections are not consistently properly performed. 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 and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for Field Laboratories. Comment: Some instances of errors that were not dated and initialed were noted. C. Finding: The laboratory needs to increase the traceability documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. Requirement: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date Received, Date Opened (in use), Vendor, Lot Number, and Expiration Date. A system (e.g., traceable identifiers) must be in place that links standard/reagent preparation information to analytical batches in which the solutions are used. Documentation of solution preparation must include the analyst's initials, date of preparation, the volume or weight of standard(s) used, the solvent and final volume of the solution. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). Proficiency Testing D. Finding: The preparation of PT Samples is not documented. Requirement: PT Samples received as ampules are diluted according to the Accredited PT Sample Provider's instructions. It is important to remember to document the preparation of PT Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a routine Compliance Sample and is added to a routine sample Page 3 #5072 Hickory Water Treatment Plant batch for analysis. No documentation is needed for whole volume PT Samples which require no preparation (e.g., pH), but it is recommended that the instructions be maintained. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0. Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine (TRC) PT Sample would satisfy the documentation requirement. E. Finding: The laboratory is not analyzing PT Samples in the same manner as routine Compliance Samples. Requirement: As specified in 15 NCAC 2H .0800, in order to meet the minimum standards for Certification, laboratories must use acceptable analytical methods. The acceptable methods are those defined or referenced in the current State and federal regulations for the environmental matrix being tested. All samples, (including PT Samples) that are, or that may, be used for Certification purposes, must be analyzed using approved methods only. All PT Samples are to be analyzed and the results reported in a manner consistent with the routine analysis and reporting requirements of Compliance Samples. Laboratories must document any exceptions. All PT Sample analyses must be recorded in the daily analysis records as for any Compliance Sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0. pH — Standard Methods, 4500 H+ B-2000 (Aqueous) F. Finding: The units of measure (i.e., Standard Units or S.U.) are not documented on the benchsheets. 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 of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Requirement: The units of measure for pH analyses are Standard Units (S.U.). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous) G. Finding: The laboratory benchsheet was lacking pertinent data: meter calibration time(s). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: meter calibration time(s). Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous) Comment: Duplicate analyses are no longer required for Field parameters. H. Finding: The analyst does not initial or sign the benchsheet. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and Page 4 #5072 Hickory Water Treatment Plant sample analysis time. initials of the analyst, .0805 (g) (1). The field benchsheets must provide a space for the signature or and proper units of measure for all analyses. Ref: 15A NCAC 2H Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Collector's/analyst's name or initials. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for the Analysis of pH. I. Finding: The laboratory benchsheet was lacking pertinent data: instrument identification. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for the Analysis of pH. IV. PAPER TRAIL INVESTIGATION: No paper trail performed. V. CONCLUSIONS: Correcting the above -cited Findings 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 and implementation dates for each corrective action. 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