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Home My WebLink About#240 2011-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #240 Laboratory Name: Graham WWTP Laboratory Inspection Type: Municipal Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: March 8, 2011 Date Report Completed: March 16, 2011 Date Forwarded to Reviewer: March 16, 2011 Reviewed by: David Livingston Date Review Completed: March 21, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: March 23, 2011 Date Forwarded to Alberta: April 6, 2011 Date Mailed: April 6, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Graham WWTP Laboratory NPDES PERMIT #: NC0021211 ADDRESS: P.O. Drawer 357 Graham, NC 27253 CERTIFICATE #: 240 DATE OF INSPECTION: March 8, 2011 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Shelby Smith, Scott Pickard and Ed Canfield 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 maintained and 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 laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policy changes during the inspection. Findings A and B are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory 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. BOD – Standard Methods, 18th Edition, 5210 B A. Finding: The Glucose - Glutamic Acid (GGA) check often exceeds the prescribed control limits. Page 2 #240 Graham W W TP Laboratory Requirement: Determine the 5-d 20°C BOD of a 2% dilution of the glucose-glutamic acid standard check solution using the techniques outlined in ¶s 4d-j. Evaluate data as described in ¶ 6, Precision and Bias. Ref: Standard Methods, 18th Edition, 5210 B. (4) (c). Requirement: For the 300-mg/L mixed primary standard, the average 5-d BOD would be 198 mg/L with a standard deviation of 30.5 mg/L. Ref: Standard Methods, 18th Edition, 5210 B. (6). Comment: Since the audit, the laboratory changed their glassware washing protocol, but this did not improve GGA performance. This office will continue to work with the laboratory in troubleshooting this issue. Seed preparation will be examined next. Settleable Residue – Standard Methods, 18th Edition, 2540 F B. Finding: The ending time (i.e., the time the result is observed) and the time the sample was agitated or spun is not being documented. Requirement: Fill an Imhoff cone to the 1-L mark with a well mixed sample. Settle for 45 min, gently agitate sample near the sides of the cone with a rod or by spinning, settle 15 min. longer, and record volume of settleable solids in the cone as milliliters per liter. Ref: Standard Methods, 18th Edition, 2540 F. (3) (a). Turbidity – Standard Methods, 18th Edition, 2130 B Recommendation: It is recommended that the laboratory cite Standard Methods, 20th Edition for turbidity analyses. The 18th edition requires the following for measurement of turbidities above 40 NTU: Dilute sample with one or more volumes of turbidity-free water until turbidity falls between 30 and 40 NTU. The 20th edition states: Avoid dilution whenever possible. Ref: Standard Methods, 20th Edition, 2130 B. (4) (a). However, care must be taken not to exceed the range of the instrument. Refer to the instrument manufacturer’s instructions for measurement of high turbidities. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for the City of Graham WWTP (NPDES permit #NC0021211) for October, November and December, 2010 and January, 2011. The following error was noted: Date Parameter Location Value from Contract Data Value on DMR 11/16/10 Total Nitrogen (NO3 +NO2 + TKN) Effluent 1.39 for TKN 1.09 for NO3 +NO2 3.48 for TN 3.48 mg/L (should have reported 2.48 mg/L) Recommendation: It appears the contract lab reported the Total Nitrogen (TN) value in error. It is recommended that the laboratory contact the contract laboratory to notify them of this system failure and obtain an amended report. It is also recommended that the laboratory implement a data calculation check system (i.e., someone checks the TN calculation before transcribing the value to the DMR) in place to prevent reporting inaccurate Total Nitrogen values in the future. Page 3 #240 Graham W W TP Laboratory 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: Jeffrey R. Adams Date: March 16, 2011 Report reviewed by: David Livingston Date: March 21, 2011