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HomeMy WebLinkAbout#602_0701_finalNorthAS ItAIMUNNOMM 2c" 50, E N R i of Environment d Natural Resources Pat McCrory Donald R, van der Vaart Governor Secretary July 23, 2015 1602 Meritech Inc II Mr. David Merritt '4350 Sea Pines Drive Southport NC 28461 Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Merritt: Enclosed is a report for the inspection performed on July 1, 2015 by Todd Crawford, Where findings) 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 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 us at (919) 733-3908. Attachment cc: Todd Crawford Sincerely, Dana Satterwhite, Environmental Program Supervisor Division of Water Resources Water Sciences Section INC 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: www.dMlab.oM An Equal Opportunity, Affirmative Action Employer INSPECTION REPORT ROUTING SHEET 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 Linda: Date Mailed: 602 Meritech, Inc. II Commercial Maintenance Abbreviated Todd Crawford July 1, 2015 July 15, 2015 July 15, 2015 Jason Smith July 16, 2015 ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected ❑ Insp. Reg. Delay Dana Satterwhite July 17, 2015 July 21, 2015 July 21, 2015 cc: Dean Hunkele — Wilmington Regional Office On -Site Inspection Report LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: Meritech, Inc. II NCO026000 (Tabor City) 4350 Sea Pines Drive Southport, NC 28461 602 July 1, 2015 Commercial Maintenance Abbreviated Todd Crawford David Merritt and Stephanie Moore 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: This inspection was conducted at the request of the Division of Water Resources Wilmington Regional Office and US EPA Region IV. This was considered to be an abbreviated audit and focused only on Field Parameter analyses conducted by Meritech, Inc. II for the Tabor City WWTP. The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples for the 2015 proficiency testing calendar year have not yet been analyzed. The laboratory is reminded that these results must be submitted to this office directly from the vendor by September 30, 2015. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: The laboratory needed to increase the documentation of purchased materials and reagents. NC WW/GW Policy 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 (where specified). Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Demonstration of acceptable corrective action (i.e., a Lab Supply Receipt Log showing reagents currently in use) was received via fax on 7/9/15. No further response is necessary for this finding. Comment: Calibration times for the pH meter, DO meter and Total Residual Chlorine meter were not documented. The NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO), NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC Approved Procedure for Page 2 #602 Meritech, Inc. II the Analysis of Total Residual Chlorine documents state: The following must be documented in indelible ink whenever sample analysis is performed: Meter calibration and meter calibration time(s). Notification of acceptable corrective action (i.e., a statement that documentation of calibration times for all three parameters was implemented on 7/6/15) was received via email on 7/13/15. No further response is necessary for this finding. Comment: The laboratory benchsheet was either lacking instrument identifications or identified older meters no longer in use. The NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen (DO), NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature 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 (i.e., a statement that the auditor -provided benchsheet, which identifies all meters, was implemented on 7/13/15) was received via email on 7/14/15. No further response is necessary for this finding. A. Finding: The laboratory needs to increase the documentation of standards prepared in the laboratory. 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: NC WW/GW LC Policy. Please send a copy of the standard prep log showing the preparation of the total residual chlorine check standard with the response to this report. Comment: Preparation of the total residual chlorine daily check standard is not documented. Quality Control B. Finding: The auto-pipettor has not been calibrated twice annually as required. 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 twice per year, approximately six months apart. 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: NC WW/GW LC Policy. Please send documentation of the pipettor calibration with the response to this report. Comment: The only critical measurement made with the pipettor is the preparation of the total residual chlorine check standard. The calibration need only be checked at the volume used for preparing that standard. Temperature — Standard Methods, 2550 B-2000 C. Finding: The temperature correction factor was not posted on the DO meter used to measure temperature. Page 3 #602 Meritech, Inc. II Requirement: The following must be documented in indelible ink whenever sample analysis is performed: The temperature correction (even if it is zero) must be posted on the meter as well as in hard copy format (to be retained for five years). Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Dissolved Oxygen — Standard Methods, 4500 O G-2001 Comment: The calibration/storage cup was missing and the meter was being calibrated with just a damp paper towel wrapped around the probe housing. This did not create a water saturated atmosphere for the calibration. The YSI Pro 1020 User Manual, Document #605187, states: Place a small amount of clean water in the calibration/storage cup and screw it onto the bulkhead. Do not thread it on completely. Be sure that 2 or 3 threads are disengaged to ensure the cup is vented to the atmosphere. Additionally, there should only be little bit of water at the bottom of the calibration cup. There should not be water droplets or water touching the DO membrane or temperature sensor. Notification of acceptable corrective action (i.e., a statement that a Nalgene bottle, adapted to allow insertion of the probe housing through the lid and create a saturated atmosphere, was implemented on 7/2/15) was received via email on 7/14/15. This corrective action was suggested by EPA auditor, Cornell Gayle. No further response is necessary for this finding. Total Residual Chlorine — Hach Method 10014 ULR Comment: The annual 5-standard calibration curve did not pass the individual standard recovery criteria. The reason for the failing curve is most likely attributed to the fact that a Hach Chlorine Standard Solution ampule was used as the stock standard. These ampules only give a concentration range and are not accurate enough to be used to verify a calibration curve. NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states: The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 tag/L and must not vary by more than 25% of the known value for standard concentrations less than 50 pg/L. The overall correlation coefficient of the curve must be >_0.995. Demonstration of acceptable corrective action (i.e., documentation of an acceptable curve verification) was received via email on 7/15/15. No further response is necessary for this finding. Comment: The lab discontinued use of the Hach chlorine ampules on 7/14/2015. All calibration curve standards and daily check standards are now prepared from Potassium Permanganate. PH — Standard Methods, 4500 H+B-2000 Comment: The pH 4 and pH 10 buffers were expired. Calibrations still appeared acceptable and the pH buffer check was within the acceptance criterion even though the buffers were expired. There appeared to be no impact on environmental data. The North Carolina Wastewater/Groundwater Laboratory Certification Policy document states: Adherence to manufacturer expiration dates is required. Chemicals, reagents, standards, and consumables exceeding the expiration date can no longer be considered reliable. If the expiration is only listed as a month and year (with no specific day of the month), the last day of the month will be considered the actual date of expiration. Monitor materials for changes in appearance or consistency. Any changes may indicate potential contamination and the item should be discarded even if the expiration date is not exceeded. If no expiration date is given, the laboratory must have a policy for assigning an expiration date. If no date received or expiration date can be determined, the item should be discarded. Demonstration of acceptable corrective action (i.e., expired buffers were discarded and replaced with fresh buffer solution) was performed during the inspection. No further response is necessary for this finding. Page 4 #602 Meritech, Inc. II IV. PAPER TRAIL INVESTIGATION: No paper trail investigation performed. This was due to the fact that the paperwork is stored at the Meritech, Inc. Reidsville facility. A paper trail investigation may be performed at a later date. V. CONCLUSIONS: Correcting the above -cited findings will help this lab to produce quality data and meet certification requirements. The inspector would like to thank the staff for its assistance during the inspection and data review process. Please respond to all findings. Report prepared by: Todd Crawford Date: July 15, 2015 Report reviewed by: Jason Smith Date: July 16, 2015