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Home My WebLink About#5288_2014_Insp_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5288 Laboratory Name: Town of Lake Waccamaw Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: February 18, 2014 Date Report Completed: February 25, 2014 Date Forwarded to Reviewer: February 25, 2014 Reviewed by: Jason Smith Date Review Completed: February 26, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: February 26, 2014 Date Forwarded to Linda: March 21, 2014 Date Mailed: March 24, 2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Lake Waccamaw NPDES PERMIT #: NC0021881 Water Quality PERMIT #: WQCS00203 ADDRESS: PO Box 145 Lake Waccamaw, NC 28450 CERTIFICATE #: 5288 DATE OF INSPECTION: February 18, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Michael Prostinak I. INTRODUCTION: This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) program 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. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2013 proficiency testing calendar year and acceptable results were obtained. Current quality assurance policies for Field Laboratories and approved procedures for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. Contracted analyses are performed by Environment 1, Inc. (Certification #10). The requirements associated with Findings C, D, E and F have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: It is recommended that the method references on the benchsheet be updated to include the Standard Methods Committee approval year so as to conform to the naming convention used in the Federal Register (i.e., “SM 4500 H+B-2000” for pH). All method references can be found on the facility’s Certified Parameters Listing, which was provided during the inspection. Page 2 #5288 Town of Lake Waccamaw Recommendation: In order to improve the quality of the data being reported, it is recommended that the laboratory expand their data verification system to include a technical peer review process to check for accuracy and completeness of data on laboratory benchsheets and Discharge Monitoring Report (DMR) forms. Steps must be taken to minimize and correct errors and may include checks for the following: transcription errors, calculation errors, etc. The transcription errors noted in the Paper Trail Investigation section of this report, underscore the importance of this type of technical peer review process. A. Finding: Numbers ending with a “5” are not properly rounded. Requirement: Rounding off by dropping digits that are not significant. If the digit 6, 7, 8, or 9 is dropped, increase the preceding digit by one unit; if the digit 0, 1, 2, 3, or 4 is dropped, do not alter the preceding digit. If the digit 5 is dropped, round off the preceding digit to the nearest even number: thus 2.25 becomes 2.2 and 2.35 becomes 2.4. Ref: Standard Methods, 1050 B-2006. (2). B. Finding: All raw data is being documented in pencil. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. C. Finding: Instrument identification is not documented. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Temperature, and NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. D. 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. Comment: This Finding refers specifically to pH buffers and the reagents used for total residual chlorine. Page 3 #5288 Town of Lake Waccamaw Proficiency Testing E. Finding: The preparation of Proficiency Testing (PT) samples is not documented. Requirement: PT samples received as ampules must be diluted according to the PT provider’s instructions. The preparation of PT samples must be documented in a traceable log or other traceable format. The diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT would satisfy the documentation requirement. F. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples. Requirement: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. pH – Standard Methods, 4500 H+B-2000 G. Finding: The meter calibration is not verified with the analysis of a check buffer. Requirement: In addition to the calibration standards, the meter must be verified with a third calibration standard. The check standard buffer must read within ±0.1 S.U. to be acceptable. If the meter verification does not read within ±0.1 S.U., the meter must be recalibrated before any samples are analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. H. Finding: Environmental sample measurements are not bracketed with calibration and check standard buffers. Requirement: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers’ recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. The calibration and check standard buffers must bracket the range of the samples being analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: If the meter is calibrated with the pH 4 and 7 buffers, the pH 10 buffer must be used as the check buffer in order to bracket the range of environmental sample and PT standard measurements. Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 Comment: It would be acceptable and more economical, in terms of cost and time, if the facility switched from liquid reagents to DPD powder pillows. Page 4 #5288 Town of Lake Waccamaw 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 Resources. Data were reviewed for NPDES permit #NC0021881 for October, November, and December, 2013. The following errors were noted: Date Parameter Location Value on Benchsheet *Contract Lab Data Value on DMR 10/1/13 pH Effluent 7.19 S.U. 719 S.U. 10/2/13 Temperature Effluent 19.2 °C 19.8 °C 10/2/13 pH Effluent 7.49 S.U. 7.2 S.U. 10/9/13 pH Effluent 7.51 S.U. 7.4 S.U. 10/10/13 pH Effluent 7.10 S.U. 7.3 S.U. 10/24/13 Total Suspended Solids Effluent * 4.2 mg/L 4.4 mg/L 10/24/13 Dissolved Oxygen Effluent 8.57 mg/L 8.5 mg/L 11/26/13 Total Suspended Solids Effluent * 2.6 mg/L 2.3 mg/L 12/3/13 Temperature Effluent 10.15 °C 10.8 °C 12/17/13 Dissolved Oxygen Effluent 11.7 mg/L 11.9 mg/L In addition to the errors noted above, all observed Total Nitrogen values reported were actually Total Kjeldahl Nitrogen (TKN) values. To properly calculate Total Nitrogen, the TKN value must be added to the Nitrate + Nitrite value. 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 made available to the Regional Office. V. CONCLUSIONS: Correcting the above-cited findings 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: February 25, 2014 Report reviewed by: Jason Smith Date: February 26, 2014