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Home My WebLink About#5232 12 doc - FINAL INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #5232 Laboratory Name: Montgomery County WTP Inspection Type: Field Maintenance Inspector Name(s): Tonja Springer and Chet Whiting Inspection Date: February 21, 2012 Date Report Completed: April 12, 2012 Date Forwarded to Reviewer: April 13, 2012 Reviewed by: Jeffrey R. Adams Date Review Completed: April 13, 2012 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___Corrected Unit Supervisor: Dana Satterwhite Date Received: April 18, 2012 Date Forwarded to Linda: April 24, 2012 Date Mailed: April 24, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Montgomery County WTP NPDES PERMIT #: NC0080322 ADDRESS: 724 Hydro Road Mt. Gilead, NC 27306 CERTIFICATE #: 5232 DATE OF INSPECTION: February 21, 2012 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Tonja Springer and Chet Whiting LOCAL PERSON(S) CONTACTED: Tommy Overby I. INTRODUCTION: This laboratory was inspected 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. The requirements associated with Findings A and B are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Comment: The laboratory is no longer required by permit to monitor for Temperature. An amendment form was submitted during the inspection to discontinue certification for this parameter and an updated certificate attachment was mailed on April 12, 2012. General Laboratory: Comment: The laboratory was analyzing effluent samples and reporting data for Turbidity without certification. The North Carolina Administrative Code, 15A NCAC 2H .0804 (a) states: Municipal and Industrial laboratories are required to obtain certification for parameters which will be reported to the State to comply with State surface water, groundwater, and pretreatment Rules. Notification of acceptable corrective action (i.e., The laboratory stated, that since the inspection, samples are no longer taken at the effluent discharge pipe. Samples are now being taken prior to the effluent pipe and labeled as “process control” since Turbidity is not required for permit monitoring compliance.) was received by email on 4/24/2012. No further response is necessary for this finding. A. Finding: Proficiency testing (PT) sample analyses are not documented in the same manner as environmental samples. Requirement: 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 Page 2 #5232 Montgomery County WTP the process documented in the same manner as environmental samples. Ref: The Quality Assurance Policies for Field Laboratories. Comment: The PT sample analyses are documented directly on the vendor’s reporting forms and not on laboratory benchsheets. Documentation Comment: The laboratory needs to increase the documentation of the Total Residual Chlorine (TRC) DPD and pH buffers traceability information. The Quality Assurance Policies for Field Laboratories document 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. 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. Consumable materials such as pH buffers and lots of pre-made standards are included in this requirement. Demonstration of acceptable corrective action (i.e., an updated benchsheet which includes pH buffer traceability information and DPD traceability information) was received by email on 4/24/2012. No further response is necessary for the finding. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G Comment: The analysis time of the daily check standard was not being documented. The Technical Assistance for Field Analysis of Total Residual Chlorine states: Instruments are to be calibrated or a calibration check must be performed prior to analysis of samples each day compliance monitoring is performed. Calibration checks must be for the curve and/or program used for sample analysis. The time the calibration check was performed must be documented. Demonstration of acceptable corrective action (i.e., updated benchsheet which included the analysis time of the daily check standard) was received on 4/24/2012. No further response is necessary for this finding. B. Finding: The preparation of Proficiency Testing (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. pH – Standard Methods, 18th Edition, 4500 H+ B Comment: The pH meters’ calibration time is not being documented on the benchsheet. The Technical Assistance for Field Analysis of pH document states: Meter calibration and time(s) of calibration must be documented. This is a new policy that has been implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e., an updated benchsheet which included pH meter calibration time) was received by email on 3/15/2012. No further response is necessary for this finding. Comment: The benchsheet for pH used by the laboratory did not contain all the necessary labeling information. No units of measure are documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample Page 3 #5232 Montgomery County WTP analysis time. The field benchsheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Demonstration of acceptable corrective action (i.e., an updated benchsheet which included units of measure) was received by email on 3/15/2012. No further response is necessary for this finding. Comment: Data values are reported on the Discharge Monitoring Report to 0.01 S.U., not 0.1 S.U. as required by the method. Standard Methods, 18th Edition, 4500 H+ B. (6) states: A variance of ± 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., an email stating that pH is being reported to 0.1 S.U.) was received by email on 4/24/2012. No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for June, August, and December, 2011. 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 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: Tonja Springer Date: April 13, 2012 Report reviewed by: Jeffrey R. Adams Date: April 13, 2012