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Home My WebLink About#138 2011-final (2) INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #138 Laboratory Name: Mebane WWTP Inspection Type: Municipal Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: March 10, 2011 Date Report Completed: March 22, 2011 Date Forwarded to Reviewer: March 22, 2011 Reviewed by: Jason Smith Date Review Completed: April 1, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: April 5, 2011 Date Forwarded to Alberta: April 27, 2011 Date Mailed: April 28, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Mebane WWTP NPDES PERMIT #: NC0021474 ADDRESS: 106 E Washington Street Mebane, NC 27302 CERTIFICATE #: 138 DATE OF INSPECTION: March 8, 2011 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Amy Varinoski and Dennis Hodge 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Records were well organized; however, some quality control procedures need to be implemented. Performance testing samples have been analyzed for all certified parameters for the 2010 proficiency testing calendar year and the graded results were 100% acceptable. The inspector would like to commend the laboratory for staying current with changes in laboratory certification program requirements by visiting the NC Wastewater/Groundwater Laboratory Certification website and proactively implementing new requirements (such as reporting limit changes for Total Suspended Solids, micro-pipettor calibrations and Luminescence Dissolved Oxygen air calibrations), prior to the on-site inspection. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policy changes during the inspection. Findings B and C are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory A. Finding: The National Institute of Standards and Technology (NIST) traceable thermometer calibration is not checked annually. Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a NIST certified or NIST traceable thermometer and the process documented. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST certified or NIST traceable thermometer Page 2 #138 Mebane W W TP and record the two temperatures. The calibration must be performed at a temperature that corresponds to the temperature used by the incubator, refrigerator, freezer, etc. In the case of temperature measuring devices used to perform variable temperature readings the calibration must be performed at a temperature range that approximates the range of the samples. The thermometer/meter readings must be less than or equal to 1ºC from the NIST certified or NIST traceable thermometer reading. The documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was used in the comparison. Ref: North Carolina W astewater/Groundwater Laboratory Certification Policy. Comment: The certificate for the NIST traceable thermometer, used to verify temperature sensor checks on the temperature sensing devices, had no published calibration expiration date and had not been calibrated by the laboratory in the last year. This thermometer was purchased in October, 2009. Comment: You may have trouble getting your NIST thermometer re-certified. As part of an initiative to reduce the use of mercury in products, EPA is working with stakeholders to reduce the use of mercury-containing non-fever thermometers in industrial and commercial settings. The National Institute of Standards and Technology (NIST), which is working with EPA on this effort, announced on February 2, 2011 that it will no longer calibrate mercury-in-glass thermometers for traceability purposes beginning on March 1, 2011. Other vendors may follow this lead. Additional information on the phase-out of mercury-filled thermometers and selecting alternatives to mercury-filled thermometers can be found on the following EPA website: http://www.epa.gov/hg/thermometer.htm. Conductivity – Standard Methods, 18th Edition, 2510 B Dissolved Oxygen – Hach Method 10360 (LDO) pH – Standard Methods, 18th Edition, 4500 H+ B B. Finding: The laboratory is not posting NIST temperature sensor corrections on the Luminescence Dissolved Oxygen (LDO), pH and conductivity meters. Requirement: Document any correction that applies (even if zero) on both the thermometer/meter and on a separate sheet to be filed. (NOTE: Other certified laboratories may provide assistance in meeting this requirement.) Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Dissolved Oxygen – Hach Method 10360 (LDO) Comment: The laboratory did not notify this office of the change in methodology (i.e., Luminescence Dissolved Oxygen) for Dissolved Oxygen analyses. The North Carolina Administrative Code, 15A NCAC 2H .0805 (c) (7) requires: A certified laboratory must submit a written amendment to certification each time that changes occur in methodology, reporting limits, and major equipment. The amendment must be received within 30 days of such changes. An amendment form has been completed since the inspection and the laboratory’s certificate attachment has been updated to include the LDO methodology. No further response is necessary for this finding. Total Phosphorous – Standard Methods, 18th Edition, 4500 P E C. Finding: The laboratory is not analyzing matrix spikes. Requirement: Unless the referenced method states a greater frequency, spike 5% of samples on a monthly basis. Laboratories analyzing less than 20 samples per month must analyze at Page 3 #138 Mebane W W TP least one matrix spike (MS) each month samples are analyzed. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Fecal Coliform – Standard Methods, 18th Edition, 9222 D (MF) D. Finding: No comparison test is conducted before a new lot of media and filters are put into use. Requirement: It is required that 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), be made. As a minimum, make single analyses on five positive samples. Ref: Standard Methods, 18th Edition Method 9020 B. (3) (d). Recommendation: It is recommended that the comparison tests be performed with a culture positive sample that will yield the desired 20 to 60 colonies. The culture positive sample should be analyzed the day prior to the comparison testing to determine the appropriate dilution to yield 20 – 60 colonies. 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 Wat er Quality. Data were reviewed for the Town of Mebane WWTP (NPDES permit #NC0021474) for November and December, 2010 and January, 2011. The following errors were noted. Date Parameter Location Value on Contract Data Value on DMR 1/19/11 Chloride Effluent 107 mg/L No value reported 1/19/11 Copper Effluent <0.002 mg/L No value reported 1/19/11 Zinc Effluent 0.081 mg/L No value reported In addition, all contract data analyzed for December 15, 2010 was reported on the DMR as being analyzed for December 14, 2010. In order to avoid questions of legality or a possible monitoring frequency violation, 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: Jeffrey R. Adams Date: March 22, 2011 Report reviewed by: Jason Smith Date: April 1, 2011