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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