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Home My WebLink About#5558_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5558 Laboratory Name: Surf City WWTF Inspection Type: Field Initial Inspector Name(s): Todd Crawford Inspection Date: June 27, 2012 Date Report Completed: July 2, 2012 Date Forwarded to Reviewer: July 2, 2012 Reviewed by: Jason Smith Date Review Completed: July 6, 2012 Cover Letter to use: X Insp. Initial Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: July 11, 2012 Date Forwarded to Linda: July 17, 2012 Date Mailed: July 18, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Surf City WWTF NPDES Permit #: WQ0000795 ADDRESS: P.O. Box 2475 Surf City, NC 28445 CERTIFICATE #: 5558 DATE OF INSPECTION: June 27, 2012 TYPE OF INSPECTION: Field Initial AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Steve Smith and Kyle Rogers 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: This is the initial inspection for this facility. The laboratory was clean and well organized. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year, however, results were submitted without the proper method reference and without the EPA lab code number or NC lab certification number. Please be reminded that acceptable PT results must be received in our office before September 30, 2012 with the proper method reference and an EPA lab code in order to satisfy the 2012 PT requirements. Contracted analyses are performed by Environmental Chemists (Certification #94). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory Comment: The laboratory was analyzing samples and reporting data for Total Residual Chlorine (TRC) without North Carolina Wastewater/Groundwater Laboratory Certification. The North Carolina Administrative Code, 15A NCAC 2H .0804 (a) states: Commercial, Municipal, Industrial and Other facilities are required to obtain certification for field parameters which will be reported by the client to comply with State surface water, groundwater, and pretreatment Rules. An amendment form requesting certification for that parameter was completed during the inspection. An acceptable PT for TRC will be required before certification is granted. Page 2 #5558 Surf City WWTF Documentation Comment: The pH Proficiency Testing (PT) sample analyzed prior to being granted certification was not documented in the same manner as routine environmental samples. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document states: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. This requirement was discussed during the inspection and both Mr. Smith and Mr. Rogers stated that all future PT sample analyses would be documented in the same manner as routine environmental samples. No further response is necessary for this finding. Comment: This facility has yet to analyze a Proficiency Testing (PT) sample that required preparation; however, they have requested certification for Total Residual Chlorine (TRC) which will require the analysis of PT sample that will require preparation. The Proficiency Testing Requirements, February 20, 2012, Revision 1.2 document 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. Mr. Rogers stated during the inspection that he would date and initial the vendor’s instruction sheet as documentation of how the sample was prepared and store it with the other related paperwork. Dissolved Oxygen – Standard Methods, 21st Edition, 4500 H+ B Temperature – Standard Methods, 21st Edition, 4500 H+ B Comment: A review of the facility’s permit revealed that certification for these parameters was not required. They were not voluntarily reporting them and had no data to review. An amendment form was submitted during the inspection to remove these parameters from their certification. pH – Standard Methods, 21st Edition, 4500 H+ B Comment: pH samples for “PPI GW1” are not analyzed within 15 minutes. Samples were being collected and brought back to the lab for analysis on the benchtop pH meter. The distance from sampling point to the lab is too far to meet the 15 minute holding time. The Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table II states: Analyze within 15 minutes. Mr. Rogers stated during the inspection that he would begin taking the portable pH meter to the discharge point and analyze the samples on site. No further response is necessary for this finding. Recommendation: Since the portable pH meter will be calibrated at the lab and then taken the discharge point for sample analysis, it is recommended that the a post-analysis buffer check be performed upon returning the lab to verify that no calibration drift has occured due to meter transport. A. Finding: Neither the analyst’s signature nor initials appear on the benchsheet. Requirement: 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 analysis time. The field benchsheets must provide a space for the signature or initials of the analyst and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). B. Finding: The units of measure (i.e., S.U.) are not documented on the benchsheets. Requirement: 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 analysis Page 3 #5558 Surf City WWTF time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). C. Finding: Data that does not meet all quality control requirements is not qualified on the Discharge Monitoring Report (DMR). Requirement: When quality control (QC) failures occur, the laboratory must attempt to determine the source of the problem and must apply corrective action. Part of the corrective action is notification to the end user. If data qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the intended purposes. It is the responsibility of the laboratory to provide the client or end-user of the data with sufficient information to determine the usability of the qualified data. Where applicable, a notation must be made on the Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet attached to the DMR form, when any required sample quality control does not meet specified criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field Laboratories. Comment: Not meeting the holding time is considered a QC failure. D. Finding: Data values are reported on the Discharge Monitoring Report to 0.01 S.U., not 0.1 S.U., as required by the method. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ± 0.02 pH unit and an accuracy of ± 0.05 pH unit can be achieved. However, ± 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. Ref: Standard Methods, 4500 H+ B -2000 (6). E. Finding: The meter calibration times are not documented. Requirement: Time of calibration must be documented whenever sample analysis is performed. Ref: Technical Assistance for Field Analysis of pH. Total Residual Chlorine – Standard Methods, 21st Edition, 4500 Cl G F. Finding: None of the calibration methods approved by the North Carolina Wastewater/ Groundwater Laboratory Certification Group are being performed. Requirement: 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 concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Send documentation of 5-point curve verification with your response. Recommendation: It is recommended that calibration option 1, as described in the “Technical Assistance for Field Analysis of Total Residual Chlorine” document (which was provided during the inspection), be employed as the means of meter calibration. Recommended curve standard concentrations are: 0.05, 0.10, 0.5, 1.0 and 2.0 mg/L. This curve verification would be performed at least every 12 months. A daily calibration check standard at an approximate concentration of 1.0 mg/L would be analyzed each day that sample analyses are performed. Page 4 #5558 Surf City WWTF G. Finding: A meter calibration check is not performed prior to sample analyses. Requirement: 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. Ref: Technical Assistance for Field Analysis of Residual Chlorine. H. Finding: The sample collection time is not documented on the benchsheet. Requirement: 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 analysis time. The field benchsheets must provide a space for the signature or initials of the analyst and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). I. Finding: The combined buffer and DPD reagent packets designed for “free” chlorine were being used instead of packets for “total” chlorine. Requirement: Simplified procedure for total chlorine: Omit Step d above to obtain monochloramine and dichloramine together as combined chlorine. To obtain total chlorine in one reading, add the full amount of KI at the start, with the specified amounts of buffer reagent and DPD indicator. Read color after 2 min. Ref: Standard Methods, 4500 Cl G – 2000 (4) (h). IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for March, April and May, 2012. No transcription errors were detected. The following errors were noted: Date Parameter Location Value on Benchsheet/ *Contract Lab Report Value on DMR 03/16/12 pH PPI 005 7.48 S.U. 6.48 S.U. 03/21/12 Total Phosphorus PPI 005 *2.76 mg/L 2.67 mg/L 03/22/12 Total Residual Chlorine PPI 005 0.15 mg/L 0.24 mg/L 03/27/12 BOD PPI 005 *6 mg/L 5 mg/L 04/11/12 Nitrate PPI 005 *1.6 mg/L 1.8 mg/L In addition to the errors noted above, a value of “0” was entered in each daily cell where no sample was collected. On days when no samples are collected, the cells should be left blank rather than entering a value of zero. Monthly averages were calculated correctly. Page 5 #5558 Surf City WWTF 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 forwarded to the Regional Office. V. CONCLUSIONS: Correcting the above-cited findings 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: July 2, 2012 Report reviewed by: Jason Smith Date: July 6, 2012