HomeMy WebLinkAbout#5347_2017_0707_TH_FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5347
Laboratory Name:
Perquimans County Water
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tom Halvosa, Todd Crawford, Gary Francies
Inspection Date:
6/21/2017
Date Forwarded for Initial
Review:
6/28/2017
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed:
6/28/2017
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:
6/29/2017
Date Forwarded to Admin.:
7/5/2017
Date Mailed:
7/7/2017
Special Mailing Instructions:
Water Resources
ENVIRONMENTAL QUAD_ Y
July 7, 2017
5347
Mr. Nick Lolies
Perquimans County Water
P.O. Box 45
Hertford, NC 27944
OY COOPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Lolies:
Enclosed is a report for the inspection performed on June 21, 2017 by Tom Halvosa, Gary Francies and
myself. 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: Master file
Tom Halvosa
• ' ' '• • _,
LABORATORY NAME:
NPDES PERMIT #
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED
I. INTRODUCTION:
Perquimans County Water
NC0051373, NC0068861
108 Lake Rd.
Hertford, NC 27944
5347
June 21, 2017
Field Municipal Maintenance
Tom Halvosa, Todd Crawford, Gary Francies
Nick Lolies, Roy Alons and Kelvin Roberson
This laboratory was inspected by representatives 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:
Laboratory personnel communicate well with sample collectors and coordinate sample analyses
effectively to manage workload and holding times. 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. Laboratory personnel changed since the last 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 Environment 1, Inc. (Certification # 10).
Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for
the analysis of the facility's currently certified Field Parameters were provided by e-mail on June
23, 2017.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The laboratory benchsheet was lacking instrument identification. The NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the
Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature documents
state: The following must be documented in indelible ink whenever sample analysis is performed:
Instrument Identification. Acceptable corrective action (i.e., the benchsheets were updated to
include the instrument ID, were reprinted and immediately put into use) was performed by the
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#5347 Perquimans County Water
laboratory and approved by the auditor during the inspection. No further response is necessary
for this Finding.
A. Finding: The dates opened (in use) for standards and reagents are not consistently
documented in the receipt log.
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. 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).
B. Finding: The preparation of Proficiency Testing (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 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, February 20, 2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the Total
Residual Chlorine PT would satisfy the documentation requirement.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
C. Finding: The newly purchased meter had not had the calibration curve verification
performed prior to being used to analyze samples for compliance monitoring.
Requirement: Instruments are to be calibrated according to the manufacturer's
calibration procedure or a standard curve verification must be performed prior to
analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine.
D. Finding: The laboratory is not analyzing a check standard prior to analysis of samples
each day compliance monitoring is performed.
Requirement: Instruments are to be calibrated according to the manufacturer's
calibration procedure or a standard curve verification must be performed prior to
analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory was analyzing the check standard after sample analysis.
E. Finding: Values less than the established reporting limit are being reported on the
electronic Discharge Monitoring Report (eDMR).
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#5347 Perquimans County Water
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. One of the standards must have a
concentration equal to or below the lower reporting concentration for Total Residual
Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory had last established a lower reporting limit of 10 pg/L by
having analyzed that concentration when verifying the latest calibration curve. When the
new calibration curve verification is performed, compliance samples with concentrations
less than the lowest standard of the calibration curve must be reported as less than that
value on the eDMR. For example, if the lowest standard concentration in the calibration
curve verification is 10 pg/L, results would be reported as "<10 pg/L" in the daily cell of
the eDMR.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
F. Finding: The laboratory is not analyzing a post analysis check standard buffer when
analyses are performed at multiple locations.
Requirement: When performing analyses away from the certified laboratory's primary
location, a post analysis calibration verification using the check standard buffer must be
analyzed at the end of the run. Ref: NC WW/GW LC Approved Procedure for the
Analysis of pH.
Comment: An alternative to performing the post -analysis check would be to re -calibrate
at Bethel WTP locations.
G. Finding: Values were reported in the eDMR 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-2000. (6).
Dissolved Oxygen — Hach 10360-2011 rev. 1.2 (LDO) (Aqueous)
Comment: The laboratory was certified for Standard Method 4500 O G-2001 but performing
analysis with a Luminescence Dissolved Oxygen (LDO) meter. The laboratory was unaware
that there was that there was a separate method for LDO. North Carolina Administrative Code,
15A NCAC 2H .0804 (a) states: Municipal and Industrial Laboratories are required to obtain
certification for parameters which will be reported to the State to comply with State surface
water monitoring, groundwater, and pretreatment Rules. The laboratory's Certified Parameter
Listing (CPL) was amended with an effective date of June 21, 2017 to reflect Hach 10360-2011
rev. 1.2 (LDO) (Aqueous).
H. Finding: The laboratory is not performing a post analysis calibration verification when
analyses are performed away from the certified laboratory's primary location.
Requirement: When performing analyses away from the certified laboratory's primary
location, a post analysis calibration verification must be analyzed at the end of the run. It
is recommended that a mid -day calibration verification be performed when samples are
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#5347 Perquimans County Water
analyzed over an extended period of time. The calculated DO value must verify the
meter reading within ±0.5 mg/L. If the meter verification does not read within ±0.5 mg/L
of the theoretical DO, corrective action must be taken. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen.
Comment: An alternative to performing the post -analysis check would be to perform the
initial calibration at the site of Bethel WTP analysis.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Recommendation: Unless greater precision is required by the permit or data receiving agency, it
is recommended that all temperatures reported for compliance monitoring, be reported in whole
numbers as recommended by the Precision in Discharge Monitoring Reports document found
here:
http://portal.ncdenr.org/c/document library/get file°?uuid=1407b370-e848-4550-9f4b-
21 a2f05b95e4&arouold=38364.
Finding: The thermometer/meter readings varied more than 0.5°C from the NIST
traceable thermometer reading during calibration verification.
Requirement: All thermometers and temperature measuring devices used for compliance
monitoring must be checked every 12 months against a NIST traceable temperature
measuring device and the process documented. To check a thermometer or temperature
sensor of a meter, read the temperature of the thermometer/meter against a NIST
traceable temperature measuring device and record the two temperatures. The verification
must be performed in the approximate range of the sample temperatures measured. The
thermometer/meter readings must be less than or equal to 0.5°C from the NIST
traceable temperature measuring device reading. If it is not, the thermometer/meter may
not be used for compliance monitoring. The calibration verification documentation must
include the serial number of the thermometer/meter being checked and the NIST
traceable temperature measuring device that was used in the comparison. Document the
verification data and keep on file. (NOTE: Other Certified laboratories may provide
assistance in meeting this requirement. Ref: NC WW/GW LC Approved Procedure for
the Analysis of Temperature.
J. Finding: The calibration verification documentation did not include the serial number of
the thermometer/meter being checked and the NIST traceable temperature measuring
device that was used in the comparison.
Requirement: All thermometers and temperature measuring devices used for compliance
monitoring must be checked every 12 months against a NIST traceable temperature
measuring device and the process documented. To check a thermometer or temperature
sensor of a meter, read the temperature of the thermometer/meter against a NIST
traceable temperature measuring device and record the two temperatures. The verification
must be performed in the approximate range of the sample temperatures measured. The
thermometer/meter readings must be less than or equal to 0.5°C from the NIST
traceable temperature measuring device reading. If it is not, the thermometer/meter may
not be used for compliance monitoring. The calibration verification documentation must
include the serial number of the thermometer/meter being checked and the NIST
traceable temperature measuring device that was used in the comparison. Document the
verification data and keep on file. (NOTE: Other Certified laboratories may provide
assistance in meeting this requirement). Ref: NC WW/GW LC Approved Procedure for
the Analysis of Temperature.
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#5347 Perquimans County Water
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory bench sheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Perquimans County Water (NPDES permit #'s NC0051373 &
NC0068861) for October 2016 and January to February 2017. No transcription errors were
observed. The facility appears to be doing a good job of accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited Findings and implementing the Recommendations will help this
laboratory 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 Findings and include supporting documentation and implementation dates for each
corrective action.
Report prepared by: Tom Halvosa Date: June 28, 2017
Report reviewed by: Anna Ostendorff Date: July 6, 2017
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