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HomeMy WebLinkAbout#5394_2017_0308_TS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5394 Laboratory Name: Star WWTP Inspection Type: Field Municipal Maintenance Inspector Name(s): Tonja Springer Inspection Date: March 8, 2017 Date Forwarded for Initial Review: April 3, 2017 Initial Review by: Beth Swanson Date Initial Review Completed: April 3, 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: April 7, 2017 Date Forwarded to Admin.: April 20, 2017 Date Mailed: April 25, 2017 Special Mailing Instructions: Water Rescourc es ENVIacsrsMF EAL QUALO Y April 25, 2016 5394 Mr. Wesley Brown Star WWTP P.O. Box 97 Star, NC 27356 MICHEAL S. REGAN i.." IP i"?`ii S. JAY ZIMMERMAN SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Brown: Enclosed is a report for the inspection performed on March 8, 2017 by Tonja Springer. Since the Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a response is not required. The staff is commended for taking the initiative in correcting the Findings in such a timely manner. 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 electronic mail, 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, Tonja Springer, Master File 5394 Water Sciences Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607 Phone: 919-733-3908 t FAX: 919-733-6241 Internet: hffp:lldeg.nc.gov/aboutldivisions/water-resources/water•resources-data/water-sciences-home-oaqeflaboratory-certification-branch LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): On -Site Inspection Report Star WWTP NCO058548 454 South Main St. Star, NC 27356 5394 March 8, 2017 Field Municipal Maintenance Tonja Springer LOCAL PERSON(S) CONTACTED: Wesley Brown and Robin Hussey 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 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 items found Findings and Recommendations made during the inspection. All required Proficiency Testing (PT) samples for the 2017 PT calendar year have not yet been analyzed. The laboratory is reminded that results must be received by this office directly from the vendor by September 30, 2017. 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. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation Comment: The laboratory benchsheet was lacking pertinent data: Instrument identification. The NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. Notification of acceptable corrective action #5394 Star WWTP (i.e., an updated benchsheet which includes instrument identification with an implementation date of March 29, 2017) was received by email on March 29, 2017. No further response is necessary for this Finding. Proficiency Testing Comment: The laboratory was not analyzing PT samples in the same manner as compliance samples. The laboratory was analyzing pH and Total Residual Chlorine (TRC) PT samples multiple times and reporting an average of all results. Compliance samples are not analyzed and reported in this manner. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: 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 and any other samples analyzed according to the requirements of 15A NCAC 2H .0800. Notification of acceptable corrective action (i.e., a statement that beginning with the 2017 PT study, PT samples will be analyzed and documented in the same manner as regular samples) was received by email on March 28, 2017. No further response is necessary for this Finding. Comment: The preparation of TRC PT sample is not documented. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: PT samples received as ampules must be diluted according to the PT provider's instructions. The preparation of PT samples must be documented in a traceable log or other traceable format. The diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for analysis. Notification of acceptable corrective action (i.e., a statement that beginning with the 2017 PT samples, the PT vendor's preparation instructions will be initialed and dated and kept as a permanent record for five years) was received by email on March 30, 2017. No further response is necessary for this Finding. Comment: The laboratory is not documenting TRC and pH PT sample analyses in the same manner as environmental samples. PT sample results are documented directly on the vendor report form and not on the benchsheet. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2. document states: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Notification of acceptable corrective action (i.e., a statement that beginning with the 2017 PT study, PT samples will be analyzed and documented like the regular samples) was received by email on March 28, 2017. No further response is necessary for this Finding. Chlorine Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous) Recommendation: It was recommended at the inspection that the laboratory extend the range of the calibration curve to bracket the daily check standard. The daily check standard was at the same concentration (i.e., 250 pg/L) as the highest standard in the annual verification curve. The acceptance criterion for the daily check standard is ± 10% of the true value. If the standard recovery is running high, the standard would be outside the range of the calibration curve. The laboratory sent a copy of an annual verification curve that had been analyzed in the range of 13 - 421 pg/L on March 30, 2017. Comment: The auto-pipettors have not been calibrated annually as required. Pipettes are used to make the daily check standard. The Quality Assurance Policies for Field Laboratories document states: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at least every twelve months and documented. Each liquid -dispensing device must meet the manufacturer's statement of accuracy. For variable volume devices used at more than one setting, check the accuracy at the maximum, middle and minimum values. Testing at more than #5394 Star VWVFP three volumes is optional. When a device capable of variable settings is dedicated to dispense a single specific volume, calibration is required at that setting only. Notification of acceptable corrective action (i.e., a statement that in lieu of calibrating pipettors the facility has eliminated the use of the auto-pipettor and has begun to use a Gel® standard that has been assigned a true value, with an implementation date of March 29, 2017) was received by email on March 30, 2017. No further response is necessary for this Finding. Comment: The units on the laboratory benchsheet were documented as mg/L instead of pg/L. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states: The following must be documented in indelible ink whenever sample analysis is performed: Units of measure. Notification of acceptable corrective action (i.e., an updated benchsheet with pg/L and an implementation date of March 30, 2017) was received by email on March 29, 2017. No further response is necessary for this Finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Star WWTP (NPDES # NC0058548) for August and December 2016. The following errors were noted: Date Parameter Location Value on Benchsheet *Contract Lab Data Value on eDMR 8/29/2016 DO Effluent 6.3 mg/L No Value Reported 8/30/2016 DO Effluent 6.6 mg/L No Value Reported 12/7/2016 DO Effluent 7.9 mg/L No Value Reported 12/10/2016 Total Nitrogen Effluent *No value Reported 2.1 mg/L 12/10/2016 DO Effluent 8.1 mg/L No Value Reported *A sample was not analyzed for Total Nitrogen. The contract laboratory's result for Ammonia was mistakenly reported on the eDMR for both Ammonia and Total Nitrogen. In order to avoid a possible monitoring frequency violation, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended eDMR will be required. A copy of this report will be made available to the Regional Office. V. CONCLUSIONS: All Findings noted during the inspection were adequately addressed prior to the completion of this report. The inspector would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Tonja Springer Date: March 30, 2017 Report reviewed by: Beth Swanson Date: April 7, 2017 c U) 2 k k a / � 3 / \ CD k ) \ k (n / w 0 2 i / . B 2 E ) § \ ° 00 \ ) . k § ' I / { \ j \ « ■ a j 2 \ / \ C § CD f / k 8 0 o m ) 7 / / / \ \ g o] o = e m / 7 8 \ 8 8 ± ° p p 2§> o■ > 2\ ] ) \ 2 \ § § £ ■