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HomeMy WebLinkAbout#99 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #99 Laboratory Name: South Granville Water & Sewer Authority - WWTP Inspection Type: Municipal Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: October 13, 2011 Date Report Completed: November 9, 2011 Date Forwarded to Reviewer: November 9, 2011 Reviewed by: Jason Smith Date Review Completed: November 15, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: November 15, 2011 Date Forwarded to Linda Chavis November 22, 2011 Date Mailed: November 22, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: South Granville Water & Sewer Authority - W W TP Laboratory NPDES PERMIT #: NC0026824 ADDRESS: 415 Central Ave. STE B Butner, NC 27509-1915 CERTIFICATE #: 99 DATE OF INSPECTION: October 13, 2011 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Brenda Bordeaux 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. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policies during the inspection. The requirements associated with Findings B, D, and F are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: Standard Operating Procedures (SOPs) are not being properly maintained. The last time the SOPs were reviewed and revised was in 2005. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory. Ref: 15A NCAC 2H .0805 (a) (7). Please submit copies of the revised and updated SOPs no later than June 01, 2012. A written response to this finding is required with the response to this report. Recommendation: It is recommended that the laboratory review all of its SOPs and bench sheets to insure that the proper methods are being cited and that they accurately reflect the analytical procedures. Page 2 #99 South Granville Water & Sewer Authority - WWTP Laboratory Recommendation: It is recommended that SOPs include a revision history with relevant dates and a brief description of the change(s) made. B. Finding: Auto-pipettors are not calibrated twice per year. Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable auto- pipettors, bottle-top dispensers, etc.) must be calibrated at least twice per year, approximately six months apart and documented. Each liquid-dispensing device must meet the manufacturer’s statement of accuracy. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. (Refer to the example Calibration of Mechanical Volumetric Liquid-Dispensing Devices Procedure left with the laboratory during the inspection.) 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 was completed during 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 Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G C. Finding: The laboratory’s calibration curve does not bracket the Proficiency Testing (PT) sample analyses. Requirement: For analytical Procedures requiring analysis of a series of standards, the concentrations of these standards must bracket the concentration of the samples analyzed. One of the standards must have a concentration equal to the laboratory's lower reporting concentration for the parameter involved. For metals by AA or ICP, a series of three standards must be analyzed with each group of samples. For colorimetric analyses, a series of five standards for a curve prepared annually or three standards for curves established each day or standards as set forth in the analytical procedure must be analyzed to establish a standard curve. The curve must be updated as set forth in the standard procedures, each time the slope changes by more than 10 percent at midrange, each time a new stock standard is prepared, or at least every twelve months. Each analyst performing the analytical procedure must produce a standard curve. Ref : 15A NCAC 2H .0805 (a) (7) (I). A copy of the New Annual 5-point Total Residual Chlorine verification curve documentation must be submitted with the response to this report. Comment: The laboratory is verifying the built-in calibration curve, but the range of the standards being used did not bracket the PT sample concentration. The highest verification standard concentration was 50 µg/L but the PT sample concentration was 140 µg/L. Recommendation: Since the laboratory’s permit limit is 17 µg/L, it is recommended that a calibration curve using the following concentrations: 10, 20, 50, 200 and 400 µg/L be prepared in order to bracket the expected concentrations of PT samples, as well as environmental samples. Recommendation: It is recommended that the values obtained not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 g/L and must not vary by more than 25% of the known value for standard concentrations less than 50 g/L. The overall correlation coefficient of the curve must be ≥0.995. Page 3 #99 South Granville Water & Sewer Authority - WWTP Laboratory Comment: When verifying a built-in “factory stored curve”, each analyst is not required to analyze an annual calibration curve. Only one curve is required annually to verify the instrument internal calibration. Fecal Coliform – Standard Methods, 18th Edition, 9222 D (MF) D. Finding: The laboratory is not using the required magnification microscope for accurate identification and enumeration of fecal coliform colonies. Requirement: Count colonies with a low-power (10 to 15 magnifications) binocular wide-field dissecting microscope or other optical device. Ref: Standard Methods, 18th Edition, 9222 D. (2) (e). Requirement: Each laboratory requesting certification must contain or be equipped with the glassware, chemicals, supplies and equipment required to perform all analytical procedures included in their certification. Ref: 15A NCAC 02H .0805 (a) (6) (H). Comment: The laboratory has a high powered microscope used for reading microbe type glass slides. This microscope is not the required equipment specified to discern fecal coliform colonies. E. 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, 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. (A copy of the instructions for performing the fecal coliform consumables testing was presented to the laboratory during the inspection). Total Suspended Residue – Standard Methods, 20th Edition, 2540 D F. Finding: A minimum dried residue weight gain of 1 mg is used to determine the reporting limit. Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. To obtain the required residue yield, successive aliquots of samples may be added to the same dish after evaporation or adjust reporting level based upon the weight gain and sample volume used. The minimum reporting value is established at 2.5 mg/L based upon a sample volume used of 1000 mL. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 21st Editions, 2540 C. (3) (d) and 2540 B. (3) (b) and 2540 D (3) (b). Comment: For example, if 100 mL sample is analyzed, and less than 2.5 mg of dried residue is obtained, the value reported would be <25 mg/L. Or if 500 mL of sample is analyzed and < 2.5 mg of dried residue is obtained, the value reported would be < 5 mg/L. G. Finding: A quarterly check standard is not being analyzed. Page 4 #99 South Granville Water & Sewer Authority - WWTP Laboratory Requirement: Excluding Oil and Grease, all residue parameters, leachate extractions, residual chlorine, and coliform, analyze one known standard in addition to calibration standards each day samples are analyzed to document accuracy. Analyze one suspended residue, one dissolved residue, one residual chlorine and one oil and grease standard quarterly. For residual chlorine, all calibration standards required by the approved procedure in use and by EPA must be analyzed. Ref: 15A NCAC 2H .0805 (a) (7) (B). 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 South Granville Water & Sewer Authority WWTP (NPDES permit #NC0026824) for October, November and December, 2010 and January, 2011. The following error was noted: Date Parameter Location Value from Benchsheet Value on DMR 6/23/11 Total Suspended Residue Effluent < 1.0 mg/L 6.0 mg/L 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: November 9, 2011 Report reviewed by: Jason Smith Date: November 15, 2011