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HomeMy WebLinkAbout#5616_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5616 Laboratory Name: AAA Water Services LLC Inspection Type: Field Initial Inspector Name(s): Todd Crawford Inspection Date: June 27, 2012 Date Report Completed: June 29, 2012 Date Forwarded to Reviewer: June 29, 2012 Reviewed by: Chet Whiting Date Review Completed: July 3, 2012 Cover Letter to use: X Insp. Initial Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: July 15, 2012 Date Forwarded to Linda: July 30, 2012 Date Mailed: July 30, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: AAA Water Services, LLC WATER QUALITY PERMIT #: WQ0022052 ADDRESS: P.O. Box 415 Hampstead, NC 28443 CERTIFICATE #: 5616 DATE OF INSPECTION: June 27, 2012 TYPE OF INSPECTION: Field Initial AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: J. Marty Fritz 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 has all the equipment necessary to perform the analyses. The system for traceability of purchased materials and reagents was 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. Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94). III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Original data is kept on an electronic spreadsheet which is password protected. Please be advised: The lab must insure that the complete records, including related support data, can be maintained in a secure and accessible form on the pre-existing system or migrated to a new system without modification, as needed, throughout the required retention period (5 years per 15A NCAC .0800). See attached Electronic Data Storage, Signature and Reporting Policy for your reference. Comment: The preparation of Proficiency Testing (PT) samples is not documented. 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. This requirement is Page 2 #5616 AAA Water Services, LLC a new policy that has been implemented by our program since the last inspection. Mr. Fritz stated during the inspection that he would date and initial the vendor’s instruction sheet and store it with the other related documentation. No further response is necessary for this finding. Dissolved Oxygen – Standard Methods, Online Edition, 4500 O G Comment: No samples have been analyzed since obtaining certification. No data to review. pH – Standard Methods, Online Edition, 4500 H+ B A. 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 unit and an accuracy of ±0.05 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). pH – Standard Methods, Online Edition, 4500 H+ B Temperature – Standard Methods, Online Edition, 2550 B Total Residual Chlorine – Standard Methods, Online Edition, 4500 Cl G Dissolved Oxygen – Standard Methods, Online Edition, 4500 O G B. Finding: The units of measure are 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). Total Residual Chlorine – Standard Methods, Online Edition, 4500 Cl G C. Finding: Meter calibration check standard analysis time is not being documented. Requirement: The time the calibration check was performed must be documented whenever sample analysis is performed. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. D. Finding: Sample results that exceed the verified calibration curve are being reported on the Discharge Monitoring Report (DMR). Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Comment: The laboratory’s TRC curve was last verified for concentrations between 0.2 and 2.0 mg/L. Values below or above those concentrations must be reported on DMRs as “<0.20 mg/L” or “>2.0 mg/L” respectively. Page 3 #5616 AAA Water Services, LLC Total Residual Chlorine – Standard Methods, Online edition, 4500 Cl G Residual, Settleable – Standard Methods, Online edition, 2540 F Comment: The time of sample collection was not being documented on the benchsheet. 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 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. A column for documenting the sample collection time was added to the benchsheet during the inspection. No further response is necessary for this finding. Residual, Settleable – Standard Methods, Online edition, 2540 F Comment: The end time of sample analysis was not being documented on the benchsheet. The Technical Assistance for Field Analysis of Settleable Solids states: Analysis time (start and stop) must be documented whenever sample analysis is performed. A column for documenting the sample analysis stop time was added to the benchsheet during the inspection. No further response is necessary for this finding. Comment: The 45 minute stir time was not being documented on the benchsheet. The Technical Assistance for Field Analysis of Settleable Solids states: 45 minute stir time must be documented whenever sample analysis is performed. A column for documenting the stir time was added to the benchsheet during the inspection. 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 for the Hampstead Pines HOA (Permit # WQ0022052) were reviewed for March, April and May, 2012. The following errors were noted: Date Parameter Location Value on Benchsheet/ *Contract Lab Report Value on DMR 03/03/12 Turbidity Effluent None 1.11 NTU1 03/03/12 Residue, Settleable Effluent None < 0.01 ml/L1 03/03/12 Temperature Effluent None 17.5ºC1 04/06/12 pH Effluent None 7.58 S.U. 1 04/06/12 Total Residual Chlorine Effluent None 2.2 mg/L1 04/06/12 Turbidity Effluent None 1.11 NTU1 04/06/12 Residue, Settleable Effluent None < 0.01 ml/L1 04/06/12 Temperature Effluent None 20.8ºC1 Page 4 #5616 AAA Water Services, LLC 05/03/12 pH Effluent 1.89 S.U. 7.68 S.U.2 05/17/12 Nitrate Effluent *19.9 mg/L < 0.02 mg/L3 05/24/12 Nitrate Effluent *15.6 mg/L < 0.02 mg/L2 1 This value was mistakenly left on the electronic benchsheet from the prior month and reported. 2 The Total Residual Chlorine value was reported, in error, for pH. 3 A value for nitrite was reported, in error, for nitrate. In addition to the errors noted above, there were several instances in May where values greater than the upper limit of the verified Total Residual Chlorine curve were reported on the DMR. No instances of this were observed in March or April. Mr. Fritz was made aware that any values above 2.0 mg/L must be reported as “>2.0 mg/L” on the DMR. Also, all Settleable Residue results reviewed in March, April and May were reported as <0.01 ml/L instead of <0.1 ml/L. A review of the associated permit revealed that Settleable Residue was not required to be reported. Mr. Fritz will stop reporting this parameter for Hampstead Pines. Any future reporting of Settleable Residue will be reporting using the correct reporting limit of 0.1 ml/L. Also, the Total Residual Chlorine column heading on the DMR was “µg/L” and data were being reported as mg/L. The column heading on the DMR spreadsheet was changed to show “mg/L” during the inspection. 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 recommendation 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: June 29, 2012 Report reviewed by: Chet Whiting Date: July 3, 2012 Electronic Data Storage, Signature and Reporting Policy (04/09/2010) Electronic records must be complete and in a form that does not allow alteration without detection. The lab must insure that the complete records, including related support data, can be maintained in a secure and accessible form on the pre-existing system or migrated to a new system without modification, as needed, throughout the required retention period (5 years per 15A NCAC .0800). The system must use secure, computer-generated, time-stamped audit trails to automatically record the date and time of operator entries and actions that create, modify, or delete electronic records. Audit trails must also be maintained throughout the required record-retention period and must be readily available for review. Audit trails must track the old and new records when a change is made and these changes must not obscure previously recorded information. The system must ensure that any record bearing an electronic signature contains the name of the signatory, the date and time of the signature, and information that explains the meaning affixed to the signature (e.g., review, approval, responsibility, authorship, etc.). The electronic signature must be unique to that individual at the time the signature is created and he or she must be uniquely entitled to use it. Electronic signatures must be protected so that any signature that has been affixed to a record cannot be changed, detached, copied or otherwise compromised so as to falsify an electronic record. Electronic signatures must be included in readable format on the electronic record and subsequent printouts, where applicable. In addition, it is recommended that users sign an electronic signature agreement to properly use and protect their electronic signature attesting: They agree to protect the signature from use by anyone except themselves and to confirm system security with third parties where necessary. They assert that the contents of the documents or records are both truthful and accurate. They understand and agree they will be held legally bound, obligated or responsible by their use of their electronic signature as they would with any handwritten signature. They agree never to delegate the use of their electronic signature or make it available to anyone else. They agree to report any compromise to the security of their electronic signature within a defined reasonable period of time. When authorization to an electronic signature is revoked, the holder will be notified.