HomeMy WebLinkAbout#5120 - 05 - 2011 - FINALDee Freeman
Secretary
July 11, 2011
5120
Mr. Robert Heaton
Town of Beech Mountain
403 Beech Mountain Parkway
Beech Mountain, NC 28604
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Initial Inspection
Dear Mr. Heaton:
Enclosed is a report for the inspection performed on May 17, 2011 by Jason Smith. I apologize for the delay in
getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30 days of
receipt, please supply this office with a written item for item description of how these finding(s) were corrected.
For certification maintenance, your laboratory must continue to carry out the requirements set forth in 15A
NCAC 2H .0800.
Copies of the checklists completed during the inspection may be requested from this office. Thank you for your
cooperation during the inspection. If you wish to obtain an electronic copy of this report by email or if you have
questions or need additional information please contact me at 828-296-4677.
Sincerely,
Gary Francies
Unit Supervisor
Laboratory Section
CC: Chet Whiting
Gary Francies
Master files
DENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: 919-733-3908 \ FAX: 919-733-6241
Internet: ws,vv,dwglab.org
An Equal Opporluniry\Affirmalive Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org
One
North Carolina
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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. 4:
5120
Laboratory Name:
Town of Beech Mountain
Inspection Type:
Field Maintenance
Inspector Names):
Jason Smith
Inspection Date:.
May 17, 2011
Date Report Completed:
July 6, 2011
Date Forwarded to Reviewer: July 7, 2011
Reviewed b :
Todd Crawford
Date Review Completed:
July 7, 2011
Cover Letter to use: _
Insp. Initial x Insp. Reg. _ Insp. No Finding Insp. CP
Unit Supervisor.
Date Received:
Date Forwarded to Alberta:
Date Mailed:
Gary Francies
7/7/2011
Corrected
11
0
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE :
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED
I. INTRODUCTION:
Town of Beech Mountain
NCO069761 and N00022730
403 Beech Mountain Parkway
Leech Mountain, NC 28604
5120
May 17, 2011
Field Maintenance
Jason Smith
Robert Heaton and Gary Tipton
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples. ,
The laboratory was clean and well organized. The laboratory has all the equipment necessary to perform
the analyses. Samples are analyzed at the Beech Mountain WWTP and the Grassy Gap WWTP.
Technical assistance documents for all certified parameters were provided to the laboratory at the time of
the inspection. Findings A and B are new policies that have been implemented by our program since the
last inspection.
HIM
A. Finding: The laboratory needs to increase the documentation of purchased materials and
reagents.
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. 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 chemicals, reagents, standards and consumables used for
a period of five years. Consumable materials such as pH buffers and lots of pre -made
standards are included in this requirement. Ref: Quality Assurance Policies for Field
Laboratories.
B. Finding: Data that does not meet all quality control requirements is not qualified on the Discharge
Monitoring Report (DMR).
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#5120 Town of Beech Mountain
Requirement: When quality control (QC) failures occur, the laboratory must attempt to determine
the source of the problem and must apply corrective action. Part of the corrective action is
notification to the end user. If data qualifiers are used to qualify samples not meeting QC
requirements, the data may not be useable for the intended purposes. It is the responsibility of the
laboratory to provide the client or end -user of the data with sufficient information to determine the
usability of the qualified data. Ref: Quality Assurance Policies for Field Laboratories,
Comment: Where applicable, a notation must be made on the Discharge Monitoring Report
(DMR) form, in the comment section or on a separate sheet attached to the DMR form„ when any
required sample quality control does not meet specified criteria and another sample cannot be
obtained.
Temperature - Standard Methods, 215t Edition, 2550
Dissolved Ox qen — Standard methods, 21st Edition, 4500 G G
Comment: The time of collection and analysis was not clearly documented. The North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: Data pertinent to each analysis must be
maintained for five years. Certified Data must consist of date collected, time collected, samples site,
sample collector, and sample analysis time. The field bench sheets must provide a space for the
signature of the analyst, and proper units of measure for all analyses. Notification of acceptable
corrective action (i.e., an updated benchsheet that indicates that the time recorded is the collection and
analysis time due to in -situ analysis) was received by email on May 19, 2011. No further response is
necessary for this finding.
FI — Standard Methods, 21$t Edition, 4500 H' S
Comment: The pH samples and calibration buffers did not have proper units of measurement (S.U.)
associated with the pH values. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1)
states: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of
date collected, time collected, samples site, sample collector, and sample analysis time. The field
bench sheets must provide a space for the signature of the analyst, and proper units of measure for all
analyses. Notification of acceptable corrective action (i.e., an updated benchsheet that documents units
of measure for pH) was received by email on May 19, 2011. No further response is necessary for this
finding.
Dissolved Oxygen — Standard Methods, 215t Edition, 4500 O G
Comment: The calibration time was not documented. The Technical Assistance for Field Analysis of
Dissolved Oxygen states: The time of calibration must be documented whenever sample analysis is
performed. Notification of acceptable corrective action (i.e., an updated benchsheet that documents the
calibration time) was received by email on May 19, 2011. No further response is necessary for this
finding.
Total Residual Chlorine -- Standard Methods, 21 st Edition, 4500 Cl G
Comment: The time of analysis of the gel standard was not documented. The Technical Assistance for
Field Analysis of Total Residual Chlorine states: The time the calibration check was performed must be
documented whenever sample analysis is performed. Notification of acceptable corrective action (i.e.,
an updated benchsheet that documents the calibration check time) was received by email on May 19,
2011. No further response is necessary for this finding.
Comment: The annual curve verification was performed by analyzing only three acceptable standards.
The laboratory performed the curve verification with 20, 200, 400, 1000, and 1500 pg/L standards. The
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#5120 Town of Beech Mountain
first three standards were analyzed on the low-level program and the last two standards were analyzed
on the regular -level program. This does not fulfill the requirement of a five -point curve verification
because the two programs are distinct and separate. All five standards must be analyzed on the program
used for sample analysis. Additionally, the laboratory was analyzing the gel standard on the regular -level
program. The Technical Assistance for Field Analysis of Total Residual Chlorine states: Calibration
checks must be for the curve and/or program used for sample analysis. Notification of acceptable
corrective action (i.e., an acceptable curve verification consisting of five points on the low level program
and assigning the gel standard a true value on the low-level program) was received by fax on June 8,
2011. No further response is necessary for this finding.
The paper trail consisted of comparing laboratory bench sheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for Beech Mountain WWTP (NPDES permit #NC0069761) and Grassy Gap WWTP (NPDES
permit #NC0022730) for August, 2010. The following error was noted:
Date
Parameter
Location
Value on 13enchsheet
Value on DMR
08/09/10
pH
Grassy Gap Effluent
7.1 S.U.
7.0 S.U.
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.
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: Jason Smith Date: July 6, 2011
Report reviewed by: Todd Crawford Date: July 7, 2011