HomeMy WebLinkAbout#5417 - 11 - 2011 - FINALINSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #1
5417
Laboratory Name:
Wilkes County Airport WWTP
Inspection Type:
Field Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
November 17 2011
Date Report Completed:
December 15, 2011
Date Forwarded to Reviewer: December 15 2011
Reviewed by:
Jeffrev R. Adams
Date Review Completed:
December 16 2011
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected
Unit Supervisor:
Gary Francies
Date Received:
12/16/2011
Date Forwarded to Linda:
12/28/2011
Date Mailed:,
4s�
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
December 28, 2011
5417
Mr. David Prevette
Wilkes County Airport WWTP
640 Wood Wallace Dr.
North Wilkesboro, NC 28659
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Prevette:
Enclosed is a report for the inspection performed on November 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: www.dwglab.org
An Equal Opportunity \ Affirmative Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org
North Carolina
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
II Z•lme] Kom
1 • - • 9
Wilkes County Airport WWTP
NC0075078
640 Wood Wallace Dr.
North Wilkesboro, NC 28659
5417
November 17, 2011
Field Maintenance
Jason Smith
David Prevette and Jimmy Martin
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
The facility has all the equipment necessary to perform the analyses. Proficiency Testing (PT) samples
have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the
graded results were 100% acceptable. Current technical assistance and quality assurance policy
documents were provided to the laboratory at the time of the inspection.
Documentation
Comment: Error corrections were not made properly. The Quality Assurance Policies for Field
Laboratories document states: All documentation errors must be corrected by drawing a single line
through the error so that the original entry remains legible. Entries shall not be obliterated by erasures
or markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are
not to be used. Write the correction adjacent to the error. The correction must be initialed by the
responsible individual and the date of change documented. All data and log entries must be written in
indelible ink. Pencil entries are not acceptable. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective action (i.e.,
that all staff have been advised of this policy) was received by electronic mail on November 22, 2011.
No further response is necessary for this finding.
Comment: The laboratory needed to increase the documentation of purchased materials and
reagents. The Quality Assurance Policies for Field Laboratories document states: 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
Page 2
#5417 Wilkes County Airport WWTP
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. This requirement is a new policy that has been
implemented by our program since the last inspection. Notification of acceptable corrective action (i.e.,
a log recording all required information has been put into use) was received by electronic mail on
November 22, 2011. No further response is necessary for this finding.
Comment: PT samples were not documented on laboratory benchsheets in the same manner as
environmental samples. The Quality Assurance Policies for Field Laboratories document states: The
analysis of PT samples is designed to evaluate the entire process used to routinely report
environmental analytical results. Therefore, PT samples must be analyzed and the process
documented in the same manner as environmental samples. This requirement is a new policy that has
been implemented by our program since the last inspection. Notification of acceptable corrective action
(i.e., all PT samples will be analyzed and documented in the same manner as environmental samples)
was received by electronic mail on November 22, 2011. No further response is necessary for this
finding.
Total Residual Chlorine — Standard Methods, 18t" Edition, 4500 Cl G
pH — Standard Methods, 181" Edition, 4500 H+
Comment: Proper units of measure were not documented for pH and Total Residual Chlorine (TRC).
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,
sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for
the signature or initials of the analyst, and proper units of measure for all analyses. Notification of
acceptable corrective action (i.e., benchsheets which include units of measure) was received by
electronic mail on November 22, 2011. No further response is necessary for this finding.
Total Residual Chlorine — Standard Methods, 18t" Edition, 4500 Cl G
A. Finding: The check standard (gel standard) was not at the mid -range of the curve.
Requirement: The check standard concentration must be at mid range and recovery must be
within 10% of the known value. Ref: Technical Assistance for Field Analysis of Total Residual
Chlorine. Please submit a copy of the new curve verification with the reply to this report.
Comment: The laboratory verified the curve using the following standard concentrations: 10,
25, 50, 100, and 200 pg/L. The gel standard concentration is approximately 200,ug/L.
Recommendation: It is recommended that the curve be verified using the following standard
concentrations: 25, 40, 50, 200, and 400 /jg/L.
B. Finding: The gel standard has not been assigned a true value.
Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily
calibration verification only. These standards must be verified initially and every 12 months
thereafter, with the standard curve. Immediately following curve verification:
1. Zero the instrument with the gel blank.
2. Read and record gel standard values.
3. Assign the obtained values as the true value.
Page 3
#5417 Wilkes County Airport WWTP
The assigned values will be used for the next twelve months, or until a new curve verification is
performed. The gel/liquid standard verification must be performed for each instrument on which
they are to be used. If multiple instruments and/or standard sets are used, each must have
assigned values specific for the instrument and standard set. Ref: Technical Assistance for Field
Analysis of Total Residual Chlorine. Please submit a copy of the gel standard value
assignment, which must be done following the curve verification, with the reply to this
report.
C. Finding: The time of analysis of the calibration check (gel standard) is not documented.
Requirement: The time the calibration check was performed must be documented whenever
sample analysis is performed. Ref: Technical Assistance for Field Analysis of Total Residual
Chlorine.
Comment: The sample location was not 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, sample site, sample collector, and sample analysis
time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper
units of measure for all analyses. Notification of acceptable corrective action (i.e., benchsheets which
include sample location) was received by electronic mail on November 22, 2011. No further response
is necessary for this finding.
pH — Standard Methods, 18th Edition, 4500 H+ B
D. Finding: The temperature sensor of the pH meter has not been checked against a National
Institute of Standards and Technology (NIST) certified or traceable thermometer.
Requirement: All thermometers and temperature measuring devices must be checked every 12
months against a NIST certified or NIST traceable thermometer and the process documented
even if the instrument is not used for reporting temperature results. To check a thermometer or
the temperature sensor of a meter, read the temperature of the thermometer/meter against a
NIST certified or NIST traceable thermometer and record the two temperatures. The
thermometer/meter readings must be less than or equal to 10C from the NIST certified or NIST
traceable thermometer reading. The documentation must include the serial number of the NIST
certified thermometer or NIST traceable thermometer that was used in the comparison. Also
document any correction that applies on both the thermometer/meter and on a separate sheet to
be filed. (NOTE: Other certified laboratories may provide assistance in meeting this requirement.)
Ref: Technical Assistance for Field Analysis of pH.
Comment: Data values were not reported to one decimal place. Standard Methods, 18th Edition, 4500
H+ B. (6) states: A variance of ± 0.1 pH unit represents the limit of accuracy under normal conditions,
especially for measurement of water and poorly buffered solutions. For this reason, report pH values to
the nearest 0.1 pH unit. This requirement is a new policy that has been implemented by our program
since the last inspection. Notification of acceptable corrective action (i.e., all pH results will be rounded
to 0.1) was received by electronic mail on November 22, 2011. No further response is necessary for
this finding.
Temperature — Standard Methods, 18th Edition, 2550 B
E. Finding: The temperature correction is not posted on the thermometer.
In
Page 4
#5417 Wilkes County Airport WWTP
Requirement: The temperature correction (even if it is zero) must be posted on the meter as well
as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of
Temperature.
Comment: Temperature sample collection times were not 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, sample site,
sample collector, and sample analysis time. The field benchsheets must provide a space for the signature
or initials of the analyst, and proper units of measure for all analyses. Notification of acceptable
corrective action (i.e., benchsheets which include time of collection) was received by electronic mail on
November 22, 2011. No further response is necessary for this finding.
Recommendation: Since there is no holding time
times will be the same. The benchsheet may
"collection/analysis time" if the laboratory chooses.
per sample.
PAPER TRAIL INVESTIGATION:
for temperature, the sample collection and analysis
be further edited to label the column header as
This would allow for the documentation of one time
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 April, May, June, and July, 2011. The following errors were noted:
Date
Parameter
Location
Value on Benchsheet
Value on DR
4/1/11
Total Residual Chlorine
Effluent
55,ug/L
45 pg/L
6/30/11
BOD
Effluent
2.8 mg/L*
2.1 mg/L
6/30/11
TSS
Effluent
10 mg/L*
15 mg/L
*contract lab results
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.
Comment: The laboratory indicated, by electronic mail on November 22, 2011, that amended DMRs
would be submitted.
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: Jason Smith Date: December 15, 2011
Report reviewed by: Jeffrey R. Adams Date: December 16, 2011