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HomeMy WebLinkAbout#567_08_2012_FINALi a a Ir NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor 567 Ms. Lisa Richardson Gastonia WTP Laboratory Utilities Dept. P.O. Box 1748 Gastonia, NC 28053-1748 Division of Water Quality Charles Wakild, P. E. Director November 2, 2012 Dee Freeman Secretary SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Ms. Richardson: Enclosed is a report for the inspection performed on August 23 2012 by Chet Whiting. I apologize for the delay in getting this report to you. 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 electronic mail, or if you have questions or need additional information please contact me at 828-296-4677. Sincerely, GZ2� Gary Francies Certification Unit Supervisor Laboratory Section CC: Chet Whiting Master File DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733.3908 \ FAX: 919-733-6241 One Internet: www.dwglab.org M ffl.Cal olin.a An Equal opportunity \ Affirmative Action Employer VVatulrally 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: Date Received: Date Forwarded to Linda: Date Mailed: #567 Gastonia WTP Lab Municipal Maintenance Chet Whiting August 23, 2012 October 3, 2012 October 5, 2012 Jason Smith October 11, 2012 ❑ Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP x Corrected Gary Francies 10/12/12 11 /01 /2012 �QII, On -Site Inspection Report LABORATORY NAME: Gastonia WTP Laboratory NPDES PERMIT #: NCO040070 (Inactive) ADDRESS: Utilities Dept. P.O. Box 1748 Gastonia, NC 28053-1748 CERTIFICATE M 567 DATE OF INSPECTION: August 23, 2012 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Chet Whiting LOCAL PERSON(S) CONTACTED: Lisa Richardson 1. 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 is not currently analyzing compliance monitoring samples. The laboratory is reminded that any time changes are made to laboratory operations; the laboratory must update the Quality Assurance (QAYStandard 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 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. Page 2 #567 Gastonia WTP Laboratory FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Comment: The laboratory needed to increase the documentation of purchased materials and reagents to include date received. NC WW/GW LC 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). This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for primary standards, chemicals, reagents, and materials used for a period of five years. Consumable materials such as pH buffers, lots of pre -made standards and/or media, solids and bacteria filters, etc. are included in this requirement. This requirement is a new policy that has been implemented by our program since the last inspection _Demonstration of acceptable corrective action (i.e. a revised Reagent Log Sheet including date received) was received by e-mail September 13, 2012. No further response is necessary for this finding. CommenV_The_preparation of Proficiency Testing �PTZ samples was not documented. Proficiency Fo�mattea: rvounderine Testing Requirements, February 20, 2012, Revision 1.2. 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. Demonstration of acceptable corrective action (i.e. a acknowledgement that PT preparation information would be documented) was received by e-mail October 30, 2012 2-042. No further response is necessary for this finding. AGG9ptab!G GGFFGGt;V8 @GtiGR (I=aberatGFy staff stated that PT- prep would be deGUM8Hted GR th@-44 Sheets and rata'Red foF review) was P849FM8d OR 646. Ne further response is AeGessa for. this find;Ag Total Suspended Solids — Standard Methods, 20th Edition, 2540 D Comment: The 103 — 105° C oven thermometer calibration had exceeded 12 months (due July 11, 2012). The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (0) states: All thermometers must meet National Institute of Standards and Technology (NISI) specifications for accuracy or be checked, at a minimum annually, against a NIST traceable thermometer and proper corrections made. Demonstration of acceptable corrective action (i.e. a copy of thermometer calibration documenting that the oven thermometer was calibrated on. 9/12) was received by e-mail September 13, 2012. No further response is necessary for this finding. Total Residual Chlorine — Standard Methods, 20th Edition, 4500 CI' G Comment: The Total Residual Chlorine (TRC) meter verification was for an instrument not capable of reading down to the permit limit. At the time of the last inspection a pocket colorimeter met permit requirements. The current permit requires low level analysis should the facility discharge. In accordance with the directive from this division, a hand held pocket colorimeter will be allowed to have a minimum reporting limit of 0.1 mg/L (100 pg/I). For any facilities with a limit less than this, the analysis must be performed with a spectrophotometer. Ref: Division of Water Quality letter dated August 14, 2001. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (4) states: each facility must have glassware, chemicals, supplies, equipment, and a source of distilled or deionized water that will meet the minimum criteria of the approved methodologies. Demonstration of acceptable corrective action (i.e. a copy of a low level TRC meter verification) was received by e-mail September 24, 2012. No further response is necessary for this finding. IV. V Page 3 #567 Gastonia WTP Laboratory Comment: The laboratory had an instrument capable of low level analysis on site. It had not been verified. By correcting the above the laboratory now has the proper equipment to perform analysis specified on their certification Attachment I. PAPER TRAIL INVESTIGATION: No paper trail was performed since no compliance data was analyzed. 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: Chet Whiting Report reviewed by: Jason Smith Date: October 3, 2012 Date: October 11, 2012