The URL can be used to link to this page

Home My WebLink About#141_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 141 Laboratory Name: Cape Fear Public Utility Authority Inspection Type: Municipal Maintenance Inspector Name(s): Todd Crawford Inspection Date: September 27, 2012 Date Report Completed: October 26, 2012 Date Forwarded to Reviewer: October 26, 2012 Reviewed by: Jeff Adams Date Review Completed: October 29, 2012 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor: Dana Satterwhite Date Received: October 29, 2012 Date Forwarded to Linda: November 8, 2012 Date Mailed: November 8, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Cape Fear Public Utility Authority NPDES PERMIT #: NC0023965, NC0023973, NC0039527, NC0088307, NC0002879 ADDRESS: 235 Government Center Drive Wilmington, NC 28403 CERTIFICATE #: 141 DATE OF INSPECTION: September 27, 2012 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Todd Crawford and Nick Jones LOCAL PERSON(S) CONTACTED: Jill Deaney, Chris Johnson and Adam Poore I. 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. II. GENERAL COMMENTS: The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. A system for traceability of standard and reagent preparation is in place and easy to follow. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2012 proficiency testing calendar year and the graded results were 100% acceptable. Benchsheets are very well designed and include all applicable information in terms of standard and reagent traceability. The laboratory has already begun to update Quality Assurance Plans and Standard Operating Procedures in response to the recent updates to the Code of Federal Regulations. The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any changes made in response to the Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory requirements. In some instances, the laboratory may need to create a SOP to document how new functions or policy will be implemented. On May 18, 2012, EPA promulgated changes to the list of Clean Water Act (CWA) methods at 40 CFR Part 136.3. This action, referred to as the Methods Update Rule (MUR) approves new methods, or changes to existing methods, that affects over 100 EPA methods, Standard Methods, ASTM methods, and other test procedures in Part 136 of Title 40 of the Code of Federal Regulations (CFR). The rule also contains a number of clarifications relating to approved methods, sample preservation and holding Page 2 #141 Cape Fear Public Utility Authority times, and method modifications. The final rule may be found at: http://water.epa.gov/scitech/methods/cwa/update_index.cfm. The North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program will be asking certified laboratories to move toward implementation of the new rule with changes fully implemented by the end of 2012. Each laboratory will need to review the MUR and evaluate its effect on current laboratory practices. These changes must be made in the laboratory’s Standard Operating Procedures and in Quality Manuals, as well as any other place where the method is cited, e.g., reports, benchsheets, logs, etc. During this transition period, inspection reports will refer to the methods employed at the laboratory at the time of the inspection, but will reference the requirements in the most recently approved version of the method. Any difficulties encountered with meeting the requirements of these references by the date due may be addressed in the written corrective action response. Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94), Pace Analytical Services, Inc. (Certification #67) and Meritech, Inc. (Certification #165). The requirement associated with Finding A is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Quality Control Comment: All data is peer and/or supervisor reviewed. Total Residual Chlorine – Standard Methods, 4500 Cl G - 2000 Comment: In addition to the annual 5-point curve verification, each day of analysis, the lab is analyzing two liquid standards and a gel standard in the lab. The meter is then taken to the field where a gel standard is again analyzed prior to wastewater sample analyses. If the annual 5-point curve option is being performed, then only one check standard at a concentration near the mid-point of the 5-point curve is required each day of analysis. The use of gel standards by Non-Field labs is permitted when the analyses are performed in a field setting. For this application, a field setting is defined as: A location off the primary facility grounds and/or at such a distance that sample collection and analysis could not be achieved at the primary facility within the parameter holding time (i.e., 15 minutes). Comment: Duplicates are not required for in situ/on-site analyses. Fecal Coliform – Standard Methods, 9222 D – 1997 A. Finding: Culture medium used for the Fecal Coliform MF method is not being tested prior to use. Requirement: When a new lot of culture medium, pads, or membrane filters is to be used, a comparison of the current lot in use (reference lot) against the new lot (test lot), must be made. As a minimum, make single analyses on five positive samples. Ref: NC WW/GW LC Policy based on Procedure for Testing Consumable Materials for Biological Testing. Comment: Testing was being performed on filters. Page 3 #141 Cape Fear Public Utility Authority IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for NPDES Permit # NC0039527 for June, 2012. The following errors were noted: Date Parameter Location Value on Benchsheet Value on DMR 06/12/12 Fecal Coliform Effluent 1 e cfu/100 1 #/100 06/19/12 Fecal Coliform Effluent 2 e cfu/100 2 #/100 06/26/12 Fecal Coliform Effluent 1 e cfu/100 1 #/100 “e” in the above chart means “estimated”. “#” in the above chart means “colony counts”. Situations where 100 ml of sample were analyzed for Fecal Coliform and the result was 1cfu/100ml would not have required that the result be qualified as “estimated”. The lab stated in an email on 11/6/12 that future reporting of Fecal Coliform results would follow the Fecal Coliform Reporting document dated 03/25/03 (see attached). In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be made available to the Regional Office. V. CONCLUSIONS: Correcting the above-cited finding and implementing the recommendations 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: October 26, 2012 Report reviewed by: Jeff Adams Date: October 29, 2012