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To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Admin:
Date Mailed:
Special Mailing Instructions:
5656
Town of Granite Falls WWTP
Field Initial
Jason Smith
June 21, 2016
July 8, 2016
July 8. 2016
Beth Swanson
July 11, 2016
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Todd Crawford
July 11. 2016
July 18, 2016
July 21, 2016
Water Resources
ENVIRONMENTAL QUALITY
July 21, 2016
5656
Mr. Chris Graybeal
Town of Granite Falls WWTP
Post Office Box Drawer 10
Granite Falls, NC 28630
PAT MCCRORY
DONALD R. VAN DER VAART
P
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Graybeal:
Enclosed is a report for the inspection performed on June 21, 2016 by Jason Smith. 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.
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: Dana Satterwhite, Jason Smith
:� .
ADDRESS:
CERTIFICATE :
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Town of Granite Falls WWTP
60 Meandering Way
Granite Falls, NC 28630
5656
June 21, 2016
Field Initial
Jason Smith
Chris Graybeal and Tamara Coulter
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:
Although this is considered an initial inspection for Field certification, the laboratory was previously
certified as a Non -Field laboratory. The change in certification status was made effective June 30,
2014.
The facility has all the equipment necessary to perform the analyses. The laboratory was in the
process of revising their current benchsheet to meet Certification requirements at the time of the
inspection. Implementation of the revised benchsheet will address several of the Findings listed
below.
All required Proficiency Testing (PT) samples for the 2016 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, 2016.
Contracted analyses are performed by Water Tech Labs, Inc. (Certification #50).
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
Recommendation: The laboratory currently documents the meter model on the benchsheet. It is
recommended that the serial number of the meter be documented as well. This would prevent any
confusion if the meter is replaced by the same model.
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#5656 Town of Granite Falls WWTP
A. Finding: The preparation of Total Residual Chlorine (TRC) standards is not documented
in such a way as to provide traceability from preparation to analysis.
Requirement: A system (e.g., traceable identifiers) must be in place that links
standard/reagent preparation information to analytical batches in which the solutions are
used. Documentation of solution preparation must include the analyst's initials, date of
preparation, the volume or weight of standard(s) used, the solvent and final volume of
the solution. 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. Ref: Quality Assurance Policies for Field Laboratories.
Quality Control
B. Finding: The automatic pipettor has not been calibrated.
Requirement: 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 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.
Ref: Quality Assurance Policies for Field Laboratories.
Comment: A spreadsheet was provided by email for calibration following the inspection.
The laboratory may also choose to have their contract laboratory perform the calibration.
Proficiency Testing
C. Finding: The preparation of PT samples is not documented.
Requirement: 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. Ref:
Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT
would satisfy the documentation requirement. The pH and Conductivity PT samples do
not require preparation documentation since they are analyzed as whole volume
samples.
D. Finding: The laboratory is not analyzing PT samples in the same manner as compliance
samples.
Requirement: 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, Ref:
Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory's common practice was to analyze a known standard along with
the PT sample as additional quality control. Since this is not performed with all
environmental samples, it is considered additional quality control. However, known samples
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#5656 Town of Granite Falls WWTP
are recommended when analyzing remedial PT samples as part of the troubleshooting and
corrective action process.
E. Finding: The laboratory is not documenting PT sample analyses in the same manner as
environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as
for any environmental sample. This serves as the permanent laboratory record. Ref:
Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed
and the process documented in the same manner as environmental samples (i.e., on the
daily benchsheet after acceptable calibration).
Dissolved Oxygen — Standard Methods, 4500 O G-2000
Comment: The laboratory is using a Luminescent Dissolved Oxygen (LDO) meter, but was not
aware that NC WW/GW LC grants certification for this technology based upon Hach Method 10360
or ASTM Method D 888-09 C. Standard Methods 4500 O G-2000 is specifically for analysis by
membrane electrode. An amendment to the application form was emailed to the laboratory on June
22, 2016. Please complete and submit the amendment request to update the laboratory's Certified
Parameter List (CPL).
F. Finding: The date and time of sample collection are not documented.
Requirement: Certified Data must consist of date collected, time collected, sample site,
sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: The benchsheet in use did not include this information; however, the draft
benchsheet reviewed during the inspection did.
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: The laboratory is currently preparing standards from Potassium Permanganate daily for
meter verification. As discussed during the inspection, gel standards are allowed to be used for
daily meter verification. Further information may be found in the NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine,
G. Finding: The time of sample collection is not documented.
Requirement: Certified Data must consist of date collected, time collected, sample site,
sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: The benchsheet in use did not include this information; however, the draft
benchsheet reviewed during the inspection did.
H. Finding: Curve verification has not been performed every twelve months.
Requirement: Most field photometric instruments have factory -set calibration programs,
which when selected in combination with the optimum wavelength for a particular analysis,
give a direct readout in concentration. These factory -set calibration programs are
acceptable for quantitation, but due to possible analyst error, variation in sample or
standard preparation, variation in reagents or malfunction of the instrument, the factory -set
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#5656 Town of Granite Falls WWTP
calibration must be verified at least every 12 months. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
Comment: The last curve verification was performed on January 24, 2013.
Finding: The calibration curve verification does not bracket the concentration of the
annual PT samples.
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: The most recent curve verification performed only verified the meter up to 60
pg/L.
Recommendation: It is recommended that the laboratory verify the curve at 20, 40, 50,
200, and 400 pg/L. This will verify the analytical range used to measure PT samples, gel
standards, as well as environmental samples.
pH — Standard Methods, 4500 H+ B-2000
J. Finding: The sample collection date is not documented.
Requirement: Certified Data must consist of date collected, time collected, sample site,
sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: The benchsheet in use did not include this information; however, the draft
benchsheet reviewed during the inspection did.
Conductivity —Standard Methods, 2510 B-1997
K. Finding: Verification of the Automatic Temperature Compensation (ATC) did not bracket
sample temperatures.
Requirement: The Automatic Temperature Compensator (ATC) must be verified prior to
initial use and annually (i.e., 12 months) thereafter at two temperatures by analyzing a
standard or sample at 25°C (i.e., the temperature to which conductivity values are
reported) and a temperature(s) that brackets the temperature ranges of the
environmental samples routinely analyzed. This may require the analysis of a' third
temperature reading that is > 25°C. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Specific Conductance (Conductivity).
Comment: The meter was verified at 15 and 25 °C. Sample temperatures are often
outside of this range in the winter and summer.
Comment: Anticipated temperatures can be obtained from a review of the Discharge
Monitoring Reports (DMRs) from the peak summer and winter months. Historical data
should provide a reasonably accurate estimation of ranges that will bracket the expected
sample temperatures.
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
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#5656 Town of Granite Falls WWTP
Carolina Division of Water Resources. Data were reviewed for the Town of Granite Falls WWTP
(NPDES permit # NC0021890) for July, September and November 2015. No transcription errors
were detected. 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 their 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: Jason Smith Date: July 8, 2016
Report reviewed by: Beth Swanson Date: July 11, 2016