HomeMy WebLinkAbout#350 11-final
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: #350
Laboratory Name: Franklin County WWTP Laboratory
Inspection Type: Municipal Maintenance
Inspector Name(s): Jeffrey R. Adams
Inspection Date: June 29, 2011
Date Report Completed: July 7, 2011
Date Forwarded to Reviewer: July 7, 2011
Reviewed by: Chet Whiting
Date Review Completed: July 18, 2011
Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected
Unit Supervisor: Dana Satterwhite
Date Received: July 26, 2011
Date Forwarded to Linda Chavis July 27, 2011
Date Mailed: July 27, 2011
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Franklin County WWTP Laboratory
NPDES PERMIT #: NC0069311
ADDRESS: 1630 US Hwy 1
Youngsville, NC 27596
CERTIFICATE #: 350
DATE OF INSPECTION: June 29, 2011
TYPE OF INSPECTION: Municipal Maintenance
AUDITOR(S): Jeffrey R. Adams
LOCAL PERSON(S) CONTACTED: Wrenne Kapornyai and Steve Styers
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, however, some quality control procedures need to be implemented. As a reminder, the 2011
proficiency testing results must be submitted by your vendor and received in the certification laboratory no
later than October 31, 2011.
The laboratory was given a packet containing North Carolina Laboratory Certification quality control
requirements and policies during the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
A. Finding: The laboratory needs to increase the documentation of materials and reagents used
or made in the laboratory.
Requirement: 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 (where specified). 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 primary standards, chemicals, reagents, and materials
used for a period of five years. Consumable materials such as pH buffers, lots of pre-made
standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref:
North Carolina Wastewater/Groundwater Laboratory Certification Policy.
Page 2
#350 Franklin County W W TP Laboratory
Comment: The laboratory’s National Institute of Standards and Technology (NIST) certified thermometer
calibration expired on August 09, 2009. NC Wastewater/Groundwater Laboratory Certification policy
states: NIST certified thermometers must be recalibrated, at a minimum, every five years. A new
certificate must be issued and maintained for inspection upon request. Recalibrate sooner if the
thermometer has been exposed to temperature extremes. A new certificate for the NIST certified
thermometer was received on July 25, 2011, which adequately addresses the finding. No further
response is necessary for this finding.
Comment: The temperature sensing devices had not been checked with a properly calibrated NIST
thermometer. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (O) states: All
thermometers must meet National Institute of Standards and Technology (NSIT) specifications for
accuracy or be checked, at a minimum annually, against a NIST traceable thermometer and proper
corrections made. New NIST sensor checks of all temperature sensing devices in the laboratory were
received on July 25, 2011, which adequately address this finding. No further response is necessary
for this finding.
Comment: 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.
Ammonia Nitrogen – Standard Methods, 20h Edition, 4500 NH3 D
B. Finding: Calibration blanks are not analyzed.
Requirement: The calibration blank and calibration verification standard (mid-range) must be
analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each
sample group to check for carry over and calibration drift. If either fall outside established
quality control acceptance criteria, corrective action must be taken (e.g., repeating sample
determinations since the last acceptable calibration verification, repeating the initial calibration,
etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon
Standard Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2).
C. Finding: The laboratory is not analyzing a calibration verification standard immediately after
the calibration.
Requirement: The calibration blank and calibration verification standard (mid-range) must be
analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each
sample group to check for carry over and calibration drift. If either fall outside established
quality control acceptance criteria, corrective action must be taken (e.g., repeating sample
determinations since the last acceptable calibration verification, repeating the initial calibration,
etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon
Standard Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2).
D. Finding: Calibration verification standards are not analyzed at the proper frequency.
Requirement: See requirement for finding C.
Page 3
#350 Franklin County W W TP Laboratory
Comment: The laboratory was analyzing a second source standard after calibration, however,
no initial calibration verification standard was analyzed, and no blanks were analyzed.
Subsequent calibration verification standards were analyzed after every 15 samples.
Dissolved Oxygen – Standard Methods, 19th Edition, 4500 O G
Comment: There was no sponge or absorbent material in the probe storage well to retain a 100%
humidity environment for the probe. 15A NCAC 2H .0805 (a) (6) (H) states: Facilities and equipment.
Each laboratory requesting certification must contain or be equipped with the following: Glassware,
chemicals, supplies, and equipment required to perform all analytical procedures included in their
certification. The YSI Operators Manual, YSI 1/07, pg. 4 (section 3.4); pg. 7 (section 4.5) and pg. 8, states:
In order to properly maintain the equipment, keep the probe from drying out by storing the probe in the
calibration/storage chamber with the wet sponge. A yellow sponge was placed in the probe storage well
during the audit, which adequately addresses this finding. No further response is necessary for this
finding.
Recommendation: It is recommended that a light colored sponge always be used in the storage chamber
to discern cleanliness. It is recommended the laboratory consult the owner’s manual for instructions on
probe storage and cleanliness.
Comment: The instrument has a convenient calibration/storage chamber built into the instrument’s
side. This chamber provides an ideal storage area for the probe during transport and extended non-
use. If you look into the chamber, you will notice a small round sponge in the bottom. Carefully add 3
to 6 drops of clean water into the sponge. Turn the instrument over and allow any excess water to
drain out of the chamber.
Total Suspended Solids – Standard Methods, 20th Edition, 2540 D
D. Finding: Duplicate analyses are not being analyzed.
Requirement: Analyze five percent of all samples in duplicate to document precision.
Laboratories analyzing less than 20 samples per month must analyze at least one duplicate
each month samples are analyzed. Ref: 15A NCAC 2H .0805 (a) (7) (C).
Comment: For low level results, using a default Relative Percent Difference (RPD) may not
provide an adequate evaluation of precision of samples. An example is Total Suspended Solids
(TSS) results below 10 mg/L. In this example, TSS results yielding 4 mg/L for the parent
sample and 2 mg/L for the duplicate is a reasonable difference in raw sample concentrations;
however, the RPD presents a different picture. The RPD is calculated as follows:
RPD = 2[A-B] x 100 = 2[4 mg/L - 2 mg/L] x 100 = 66% (RPD)
A+B 4 m g/L + 2 mg/L
The RPD looks excessive, yet an examination of the raw results indicates good precision. In
such cases, we recommend a two-tiered evaluation system (i.e., using one acceptance criterion
for low concentration samples and another acceptance criterion for high concentration
samples). For example, the TSS duplicate acceptance criterion for sample concentrations
below 10 mg/L might be set at a maximum 3 mg/L absolute difference and the TSS duplicate
acceptance criterion for sample concentrations equal to 10 mg/L or higher might be set at a
maximum default RPD of 20%. Please contact this office if you need additional guidance in
establishing duplicate acceptance criteria.
Page 4
#350 Franklin County W W TP Laboratory
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 Franklin County WWTP (NPDES permit #NC0069311) for February, March and April,
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 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: July 7, 2011
Report reviewed by: Chet Whiting Date: July 18, 2011