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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 Page 2 #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 Page 3 #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