HomeMy WebLinkAbout#5261_2016_0615_AO_FINALTo be attached to all inspection reports in-house only.
Laboratory Cert. #:
5261
Laboratory Name:
Town of Scotland Neck WWTP
Inspection Type:
Field Maintenance
Inspector Name(s):
Anna Ostendorff and Gary Francies
Inspection Date:
June 15, 2016
Date Report Completed:
July 6, 2016
Date Forwarded to Reviewer:
July 7, 2016
Reviewed by:
Nick Jones
Date Review Completed:
July 7, 2016
Cover Letter to use:
❑ Insp. Initial
❑ Insp. Reg.
❑ Insp. No Finding
❑ Insp. CP
® Corrected
❑ Insp. Reg. Delay
Unit Suaervisor/Chemist III:
Gary Francies
Date Received: July 7, 2016
Date Forwarded to Admin: 7/7/2016
Date Mailed: 7/8/2016
Special Mailing Instructions: Wes Bell - MRO
Water Resources
rNV� RONMErvrai )UAUTY
July 8, 2016
5261
Mr. Antonio M. Gorham
Town of Scotland Neck WWTP
PO Box 537
Scotland Neck, NC 27874-0537
Mr. Gorham
PAT MCCRORY
m r
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Gorham:
Enclosed is a report for the inspection performed on June 15, 2016 by Anna Ostendorff and Gary
Francies. 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: Anna Ostendorff
Master File
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 l FAX: 919-733-6241
Internet: httD:/Ideci.nc.goviabouUdivisions/water-resources/water-resources•datalwater-sciences•home-page/laboratory-certification-branch
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Town of Scotland Neck WWTP
NC0023337
PO Box 537
Scotland Neck, NC 27874-0537
5261
June 15, 2016
Field Maintenance
Gary Francies and Anna Ostendorff
Antonio Gorham and Ricky Artis
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. Benchsheets are well designed, easy to follow and concise. Records are well
organized and easy to retrieve. The laboratory has been proactive in keeping up with updates
and changes required by this Program.
All Findings noted during the inspection were adequately addressed by email on June 21, 2016.
All required Proficiency Testing (PT) samples have been analyzed and the laboratory has
fulfilled its PT requirements for the 2016 PT calendar year. The PT samples were analyzed
after the inspection and the results were received from the vendor prior to issuing the report.
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:
Proficiency Testing
Comment: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples. The Proficiency Testing Requirements 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
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#5261 Town of Scotland Neck VWVfP
corrective action (i.e., a statement that PT sample results and pertinent information will be
documented on a benchsheet in the same way as environmental samples effective with the 2016
PT sample analyses) was received by email June 21, 2016. No further response is necessary
for this Finding.
Comment: The preparation of Proficiency Testing (PT) samples is not documented. The
Proficiency Testing Requirements 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 PT sample preparation will be documented
effective with the 2016 PT sample analyses) was received by email June 21, 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)
Comment: Original records for Dissolved Oxygen and Temperature were not on file. The testing
data were initially written on a piece of paper, transported back to the laboratory, and transferred
to the benchsheet. This original paperwork was then discarded. The North Carolina Administrative
Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for
five years. Notification of acceptable corrective action (i.e., use of a small spiral bound notebook
to document the pertinent information for DO and Temperature analysis with an implementation
date of June 16, 2016) was received by email June 21, 2016. No further response is necessary
for this Finding.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: A blanket statement on the benchsheet stated that calibration was "based on
appropriate altitude adjustment" when the meter actually calibrates based on barometric pressure.
The NC WW/GW LC Approved Procedure for the Analysis of DO states: Calibration
documentation must include the following, where applicable to the instrument used and the type
of calibration performed: elevation, temperature, barometric pressure (in mmHg), salinity, slope,
or %efficiency. Acceptable corrective action (i.e., the benchsheet was updated to state the
calibration is based on barometric pressure) was performed by the laboratory and approved by
the auditor during the inspection. No further response is necessary for this Finding.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: Values were reported that exceed the method specified accuracy of 0.1 units.
Standard Methods, 4500 H+ B-2000, (6) states in part: 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. Notification of
acceptable corrective action (i.e., a statement that pH results would be reported to 0.1 units
effective with the June DMR submission) was received by email on June 21, 2016. 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 Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for the Town of Scotland Neck WWTP
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#5261 Town of Scotland Neck WVV"P
(NPDES permit # NC0023337) for December 2015, January and March 2016. The following
errors were noted:
Date
Parameter
Location
Value on Senchsheet
Value on DMR
1/8/2016
Dissolved Oxygen
Influent
3.10 mg/L
2.81 mg/L
One instance was noted where qualified data from the Contract Laboratory was reported on the
DMR without qualification. This seems to be an isolated instance as several other examples
were observed where qualified data were reported appropriately.
In order to avoid questions of legality, it is recommended that you contact the appropriate
Regional Office for guidance as to whether an amended DMR 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: Anna Ostendorff Date: July 6, 2016
Report reviewed by: Nick Jones Date: July 7, 2016