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HomeMy WebLinkAbout#5043_2016_1020_BS_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5043 Laboratory Name: Yadkin Valley Sewer Authority (YVSA) UW TP Inspection Type: Field Maintenance Inspector Name(s): Beth Swanson Inspection Date: October 20, 2016 Date Report Completed: November 8, 2016 Date Forwarded to Reviewer: November 8, 2016 Reviewed by: Anna Ostendorff Date Review Completed: November 9, 2016 Cover Letter to use: ❑ Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ® Corrected ❑ Insp. Reg. Delay Unit Supervisor/Chemist III: Gary Francies Date Received: November 9, 2016 Date Forwarded to Admin: 11/10/16 Date Mailed: 11/14/16 Special Mailing Instructions: n /l L/ 11„ Water~ Resources LNV f RONMFN TkL QUALITY November 14, 2016 5043 Mr. Hal Transou Yadkin Valley Sewer Authority (YVSA) WWTP 211 Marion Road Elkin, NC 28621 PAT MCCRORY DONALD R. VAN DER VAART S. JAY ZIMMERMAN SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) . Maintenance Inspection Dear Mr. Transou: )111 for Enclosed is a report for the inspection performed on October 20, 2016 by Beth Swanson. 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. 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 (828) 296-4677. Sincerely, Gary Francies, Technical Assistance/Compliance Specialist Division of Water Resources Attachment Cc: master file Beth Swanson 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: 919-733-39081 FAX; 919-733-6241 Internet: httw ldea.nc.gov/abouttdivisionslwater-resources/water-resources-data/water-sciences-home-page/laboratory-certification-branch LABORATORY NAME: Yadkin Valley Sewer Authority (YVSA) WWTP NPDES PERMIT #: NC0020567 ADDRESS: 211 Marion Rd. Elkin, NC 28621 CERTIFICATE #: 5043 DATE OF INSPECTION: October 20, 2016 TYPE OF INSPECTION: Field Municipal Maintenance AUDITOR(S): Beth Swanson LOCAL PERSON(S) CONTACTED: Hal Transou 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. GENERAL COMMENTS: The facility's files were readily available and complete. The analysts were forthcoming and proactive in addressing issues that were found during the inspection. All required Proficiency Testing (PT) samples have been analyzed and the laboratory has fulfilled its PT requirements for the 2016 PT calendar year. 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. 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 methods were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Error corrections were not properly performed. The Quality Assurance Policies for Field Laboratories document states: All documentation errors must be corrected by drawing a Page 2 #5043 Yadkin Valley Sewer Authority (YVSA) WWTP single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. Notification of acceptable corrective action (i.e., a section of the SOP detailing the proper method of error correction with documentation showing that the analysts reviewed the pertinent section on October 25, 2016 and a statement that an annual review of the SOPs will be instituted going forward) was received by email on October 28 and November 8, 2016. No further response is necessary for this Finding. Comment: The lab was not transferring all information pertaining to qualified data to the electronic Discharge Monitoring Report (eDMR). The qualifier language was entered into the comments section, but there was no indication which sample/parameter the information was referring to. The Quality Assurance Policies for Field Laboratories document states: Where applicable, a notation must be made on the Discharge Monitoring Report (DMR) form, in the comment section, when any required sample quality control does not meet specified criteria and another sample cannot be obtained. Notification of acceptable corrective action (i.e., a statement that the parameter affected will be included in the comment beginning with the October 2016 eDMR (or as soon as applicable) was received by email on October 31, 2016. No further response is necessary for this Finding. Comment: The laboratory was lacking some traceability information. The pH buffers were recorded on the benchsheet and the date opened and date received were written on the bottles, but the linkage between the two sets of information was lost once the bottles were discarded. No traceability information was available for the Total Residual Chlorine (TRC) DPD powder. The Quality Assurance Policies for Field Laboratories document states: 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. Notification of acceptable corrective action (i.e., submission of a lab receipt log containing all the required information which was filled out with the current pH buffers and DPD powder and implemented on October 31, 2016. Additionally, a statement that the required information to document traceability will be added to the facility's SOP by December 31, 2016 while instituting an annual review of said SOP.) was received by email on October 31 and November 8, 2016. No further response is necessary for this Finding. Proficiency Testin Comment: The analyst was not documenting the preparation of the TRC PT. 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 the practice of initialing and dating the instruction sheet for the TRC PT sample will be implemented in 2017 and a copy of the 2016 PT instructions initialed and dated for demonstration) was received by email on October 31, 2016. No further response is necessary for this Finding. Comment: The analyst was not documenting the analysis of the PT samples in the same manner as environmental samples. The PT results were only written on the vendor's reporting page, but samples need to be associated with properly calibrated instruments and traceable to acceptable consumables. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document Page 3 #5043 Yadkin Valley Sewer Authority (YVSA) VWVfP 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 the practice of documenting the result for the PT samples in the comments section of the laboratory benchsheet, which includes meter calibration and all other required information, will be implemented in 2017) was received by email on October 31, 2016. No further response is necessary for this Finding. Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Comment: The Dissolved Oxygen (DO) meter was not being calibrated properly. The analyst was not leaving the probe in the calibration chamber during calibration. The YSI Environmental, YSI 550A Dissolved Oxygen Instrument Operations Manual, Calibration in % Saturation, (1) states: Ensure that the sponge inside the instrument's calibration chamber is moist. Insert the probe into the calibration chamber. Notification of acceptable corrective action (i.e., documentation showing that the analysts reviewed the pertinent section of the DO SOP on October 25, 2016 which has the correct calibration procedure and a statement that the practice was implemented going forward from that date) was received by email on October 28 and November 10, 2016. No further response is necessary for this Finding. Temperature — Standard Methods, 2550 B-2000 (Aqueous) Comment: The verification of the temperature measuring device used for compliance monitoring did not agree within ±0.5 °C of the National Institute of Standards and Technology (NIST) thermometer. The DO meter was being used for Temperature results, however, its correction was -0.6 °C. The NC WW/GW LC Approved Procedure for the Analysis of Temperature document states: 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, no correction factor would be applied. If it is not, the thermometer/meter may not be used for compliance monitoring. Notification of acceptable corrective action (i.e., documentation of the pH meter temperature sensor verification conducted on October 25, 2016 showing verification within 0.1 °C of the NIST traceable thermometer and a benchsheet with that meter ID documented for the Temperature results which was implemented on October 27, 2016. Also, a statement that the verification requirements for thermometers/meters will be added to the facility's SOP by December 31, 2016 while instituting an annual review of said SOP) was received by email on October 28, 31 and November 8, 2016. No further response is necessary for this Finding. Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous) Comment: Values less than the established reporting limit were being reported on the eDMR. The lowest concentration standard analyzed during the most recent curve verification was 15 pg/L. When the result was between 10 and 15 pg/L, the laboratory was reporting the actual measured value from the instrument and for results less than 10 pg/L they were reporting <10 pg/L. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states: 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. Notification of acceptable corrective action (i.e., statements that the current reporting limit (i.e., 15 pg/L) will be used starting on the October 2016 eDMR and the lowest concentration standard used for the curve verification in subsequent years will be the reporting limit, the directions for which will be added to the facility's SOP by December 31, 2016 while instituting an annual review of said SOP) was received by email on October 31, 2016. No further response is necessary for this Finding. Page 4 #5043 Yadkin Valley Sewer Authority (YVSA) WWTP pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Comment: The benchsheet did not include all necessary units. Units for the pH calibration buffers and check buffer and for the calibration value of the DO meter were not documented on the benchsheet. North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: The field benchsheets must provide a space for the signature or initials of the analyst and proper units of measure for all analyses. Notification of acceptable corrective action (i.e., submission of an updated benchsheet that was implemented October 27, 2016 which includes a note that all pH units are S.U. and the DO meter calibration units are mg/L) was received by email on October 31, 2016. No further response is necessary for this Finding. Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Temperature — Standard Methods, 2550 B-2000 (Aqueous) pH — Standard Methods, 4500 H+ B-2000 (Aqueous) Comment: Some pertinent data was absent from the original records. The analyst started using a separate log book as the original record on October 18, 2016 for DO, Temperature and pH analysis. Previously the original records for these parameters had not been retained after transferring the data to the laboratory benchsheet. However, this log book did not label which analysis each value was associated with, did not include units for pH and Temperature, analysts initials or instrument IDs. North Carolina Code, 15A NCAC 2H .0805 (g) (1) states: 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. Notification of acceptable corrective action (i.e., submission of the updated benchsheet which was implemented on October 27, 2016 with a statement that only the printed benchsheet will be used as the original record going forward) was received by email on October 31, 2016. No further response is necessary for this Finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing 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 Yadkin Valley Sewer Authority WWTP (NPDES Permit #NC0020567) for March, May and August 2016. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. 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: Beth Swanson Date: November 8, 2016 Report reviewed by: Anna Ostendorff Date: November 8, 2016