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Home My WebLink About#5279-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5279 Laboratory Name: Brunswick Co. Field Testing Laboratory Inspection Type: Field Municipal Maintenance Inspector Name(s): Todd Crawford Inspection Date: May 12, 2011 Date Report Completed: May 16, 2011 Date Forwarded to Reviewer: May 16, 2011 Reviewed by: Chet Whiting Date Review Completed: May 27, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP _ Corrected Unit Supervisor: Dana Satterwhite Date Received: May 27, 2011 Date Forwarded to Alberta: June 7, 2011 Date Mailed: June 8, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Brunswick Co. Field Testing Laboratory NPDES PERMIT #: WQ0023693 ADDRESS: P.O. Box 249 Bolivia, NC 28422 CERTIFICATE #: 5279 DATE OF INSPECTION: May 12, 2011 TYPE OF INSPECTION: Field Municipal Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Ron Worthington 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 lab area was clean and well organized. All equipment necessary to perform the certified parameters were present and appeared well maintained. A description of current field lab policies and technical assistance documents for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as, documentation of standards and reagents prepared 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. 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. Page 2 #5279 Brunswick Co. Field Testing Laboratory B. Finding: Proficiency testing (PT) samples are not documented in the same manner as environmental samples. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G C. Finding: The daily 3-point curve verification was being performed with sealed liquid standards. Requirement: The internal curve may be verified each day compliance samples are to be analyzed using three standards (not gel or sealed liquid standards) that bracket the range of the sample to be analyzed. Ref: Technical Assistance For Field Analysis of Total Residual Chlorine. Recommendation: It is recommended that the facility follow Option 1 as described in the Technical Assistance for Field Analysis of Total Residual Chlorine document. Comment: If the annual 5-point curve verification is chosen as a remedy for Finding C, the sealed liquid standard with a concentration near the mid-point of the verified curve range may be used for the daily check standard. pH – Standard Methods, 18th Edition, 4500 H B Comment: Data values are reported on the Discharge Monitoring Report to 0.01 S.U. not 0.1 S.U. as required by the method. Standard Methods, 18th Edition, 4500 H+ B. (6) states that 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. The analyst stated during the inspection that they would begin reporting pH results to one decimal place on the Discharge Monitoring Reports (DMRs). No further response is necessary for this finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing field testing records and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Field testing data were reviewed for Water Quality permit # WQ0023693 for January, 2011. The following error was noted: Date Parameter Location Value on Benchsheet Value on DMR 01/27/11 Residual Chlorine Effluent 1.005 mg/L 1.005 µg/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. Comment: The correct value for the error noted above is 1005 µg/L. The meter being used displays results in mg/L and results are documented on the benchsheet as mg/L. The units on the DMR are µg/L. Comment: It was also observed that Total Suspended Residue results were being reported with a minimum reporting limit of 1.0 mg/L. This data was being provided by the contract lab and reported as it was stated on the DMRs. The contract lab was contacted and informed of the 2.5 mg/L minimum Page 2 #5279 Brunswick Co. Field Testing Laboratory reporting limit. Both labs are now aware that 2.5 mg/L is the minimum reporting limit for Total Suspended Residue. 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: Todd Crawford Date: May 16, 2011 Report reviewed by: Chet Whiting Date: May 27, 2011