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HomeMy WebLinkAbout#5527 11-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: #5527 Laboratory Name: Town of Fuquay Varina Terrible Creek WWTP. Inspection Type: Field Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: May 19, 2011 Date Report Completed: May 24, 2011 Date Forwarded to Reviewer: May 24, 2011 Reviewed by: Tonja Springer Date Review Completed: June 6, 2011 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP ___ Corrected Unit Supervisor: Dana Satterwhite Date Received: June 7, 2011 Date Forwarded to Alberta: June 17, 2011 Date Mailed: June 20, 2011 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Fuquay Varina Terrible Creek WWTP NPDES PERMIT #: NC0066516 ADDRESS: 401 Old Honeycutt Road 5812 Hilltop Road Fuquay Varina, NC 27526 CERTIFICATE #: 5527 DATE OF INSPECTION: May 19, 2011 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Gabriel Gutierrez 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. Records were maintained according to the appropriate record retention schedule and well organized, however, some quality control procedures need to be implemented. As a reminder, your 2011 Proficiency Testing (PT) sample results are due 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. Finding A is a new policy that has been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation 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 Page 2 #5527 Town of Fuquay Varina Terrible Creek WWTP 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: Quality Assurance Policies for Field Laboratories. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G Recommendation: The yellow sponge in the probe storage well was dirty and needed changing. It is recommended that a light colored sponge be used in the storage chamber to discern cleanliness. It is recommended the lab consult the Dissol ved Oxygen (DO) probe owner’s manual for instructions on probe storage and cleanliness. Comment: If the membrane is coated with oxygen consuming (e.g., bacteria) or oxygen evolving organisms (e.g., algae), erroneous readings may occur. Ref: YSI Operators Manual pg. (7) (4.5) (2). YSI 1/07. B. Finding: The laboratory is not documenting the calibration time or the calibration value of the meter on the benchsheet. Requirement: The meter must be calibrated, either by the air calibration method or according to the manufacturer's calibration procedure. The air calibration value obtained and the time calibration was performed must be documented on the benchsheet. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen. Recommendation: It is recommended that the laboratory use a version of the example laboratory benchsheet provided during the audit, which includes spaces to record the air calibration value and the calibration time. Dissolved Oxygen – Standard Methods, 18th Edition, 4500 O G pH – Standard Methods, 18th Edition, 4500 H+ B C. Finding: The calibration of the NIST traceable thermometer used to perform the NIST sensor checks on 12/17/10 had expired on 12/10/10. Requirement: NIST certified thermometers used for temperature measurement must be recalibrated in accordance with the manufacturer’s recalibration date. If no recalibration date is given the NIST certified thermometer must be recalibrated on a periodic basis to not exceed five years. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. A copy of the new certificate must be submitted with the response to this report. The temperature sensors must be rechecked using the new certified thermometer and a copy of the checks be submitted with the response to this report. Page 3 #5527 Town of Fuquay Varina Terrible Creek WWTP Comment: You may have trouble getting your NIST thermometer re-certified. As part of an initiative to reduce the use of mercury in products, 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. 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. Data were reviewed for the Town of Fuquay Varina Terrible Creek WWTP (NPDES # NC0066516) for January, February and March, 2011. The following procedural error for transcription was noted. The contract laboratory was reporting its Practical Quantitation Limit (PQL) for Total Suspended Solids (TSS) as “<2.5 mg/L”, but the laboratory was transcribing all less than values for TSS reported by the contract laboratory as “2.5 mg/L” on the DMRs. The Division’s Instructions for Reporting on DMRs reads: For calculation purposes only, recorded values of less than a detectable limit (< #.##) may be considered to equal zero (0) for all parameters except Fecal Coliform, for which values of "less than" may be considered to be equal to one (1). Values of results which are less than a detectable limit should be reported in the daily cells using the "less than" symbol (<) and the detectable limit used during the testing (or the value with appropriate unit conversion). Please note there is never a case when an average would need to be recorded along with a "less than" symbol. A copy of the complete instructions is attached to this report. 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: May 24, 2011 Report reviewed by: Tonja Springer Date: June 6, 2011