HomeMy WebLinkAbout#5399_03_2014_FINAL1®0
NC ENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E, Skvarla, III
Governor Secretary
April 30, 2014
5399
Ms. Cherie Shaw
Harnett Co. Dept. of Public Utilities
PO Box 1119
Lillington, NC 27546
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Shaw:
Enclosed is a report for the inspection performed on March 4, 2014 by Nick Jones. Where
finding(s) are cited in this report, a response is required. Within thirty days of receipt, please supply
this office with a written item for item description of how these finding(s) were corrected. If the
finding(s) cited in the enclosed report are not corrected, enforcement actions may be
recommended. 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 us at (828)
296-4677.
Attachment
cc: master file
Nick Jones
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences 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
Phone: 919-733-39081 FAX: 919-733-6241
Internet: www.dwglab.org
An Equal Opportunity 1 Affirmative Action Employer
INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
5399
Harnett Co. Dept. of Public Utilities
Field Maintenance
Nick Jones
March 4. 2014
April 23, 2014
April 23, 2014
Tonja Springer
April 29, 2014
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected
Gary Francies
Date Received: April 29, 2014
Date Forwarded to Linda: April 30, 2014
Date Mailed: 51 ti I 14 L.(—
On -Site Inspection Report
LABORATORY NAME: Harnett Co. Dept. of Public Utilities
NPDES PERMIT M NC0021636, NC0088366,
NC0007684
WATER QUALITY PERMIT M WQ0028562
ADDRESS: PO Box 1119
Lillington, NC 27546
CERTIFICATE #: 5399
DATE OF INSPECTION: March 4, 2014
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Nick Jones
LOCAL PERSON(S) CONTACTED: Cherie Shaw
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. Laboratory personnel communicate well with sample collectors
and coordinate sample analyses effectively to manage workload and holding times.
Proficiency Testing (PT) samples have not been analyzed for all certified parameters for
the 2014 proficiency testing calendar year. The laboratory is reminded that these results
must be submitted to this office directly from the vendor by September 30.
Contracted analyses are performed by Environment 1, Inc. (Certification #10) & Meritech,
Inc. (Certification #165).
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.
The requirements associated with Findings E, F and G have been implemented by our
program since the last inspection.
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#5399 — Harnett Co. Dept. of Public Utilities
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Quality Control
A. Finding: Error corrections are not performed properly (overwriting).
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.
B. Finding: The laboratory is not properly rounding significant figures.
Requirement: Round off by dropping digits that are not significant. If the digit 6, 7,
8, or 9 is dropped, increase preceding digit by one unit; if the digit 0, 1, 2, 3, or 4 is
dropped, do not alter preceding digit. If the digit 5 is dropped, round off 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).
Comment: The laboratory was consistently rounding down digits of 1, 2, 3, and 4;
rounding up digits of 5, 6, 7, 8 and 9.
Comment: See the Paper Trail Investigation, Section IV below.
Temperature — Standard Methods 2550 B — 2000
C. Finding: The laboratory has been utilizing an expired NIST traceable thermometer
to check the Dissolved Oxygen (DO) meter used to measure and report
Temperature for NPDES compliance monitoring.
Requirement: Thermometers and temperature measuring devices, used to
measure temperature for compliance monitoring, must be checked every 12
months against a NIST traceable thermometer. The thermometer/meter readings
must be less than or equal to 1°C from the NIST traceable thermometer reading.
The documentation must include the serial number of the NIST traceable
thermometer that was used in the comparison. Document any correction that
applies on both the thermometer/meter and on a separate sheet to be filed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Temperature. Please
submit your new unexpired NIST documentation and subsequent
temperature sensing device verification.
Comment: The laboratory's NIST traceable thermometer expired on December
31, 2011.
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#5399 — Harnett Co. Dept. of Public Utilities
Documentation
D. Finding: The laboratory benchsheet for pH was lacking pertinent data: units of
measure.
Requirement: 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 bench sheets must provide a
space for the signature or initials of the analyst, and proper units of measure for
all analyses. Ref: 15A NCAC 02H .0805 (g) (1).
Total Residual Chlorine — Hach 10014 ULR
E. Finding: The lab is not filtering the sample.
Requirement: Since Hach Method ULR 10014 is approved.by EPA as an alternate
test procedure, all steps in the method must be followed. This means that the
sample must be filtered, liquid reagents must be used and the flow-thru cell must
be used. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
Comment: If the lab choses to change its certified method to Standard Methods
4500 CI G-2000, then it could maintain its current practice.
F. Finding: The lab is not analyzing a reagent blank along with the calibration curve.
Requirement: A reagent blank (sometimes also referred to as a method blank) is
only required when laboratory water is used to make quality control and/or
calibration standards. If you are using a sealed standard (e.g., gel) for your daily
check standard, a reagent blank would only be analyzed when preparing the
annual 5-point calibration curve or 5 annual calibration curve verification standards.
A reagent blank is made from the same laboratory water source used to make
quality control and/or calibration standards with DPD. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine. Please reanalyze
and submit a calibration curve accompanied by a reagent blank.
Recommendation: Two of the three laboratory generated calibration curves had
recoveries of 140 & 150 percent for the lowest concentration standard (i.e. 10
µg/L) when compared to the linear regression. In addition, there was no reagent
blank analyzed to assess the Y - intercept. This brings into question the validity of
the curve, especially the lower end of the range. Since your lowest concentration
permit limit is 28 µg/L and the Division's compliance limit is 50 µg/L, it is
recommended that your calibration standard concentrations be 20, 30, 50, 200, &
400 µg/L.
G. The lab has been utilizing a blank acceptance criterion of less than the
concentration of the lowest calibration curve (i.e. reporting limit).
Requirement: For analyses requiring a calibration curve, the concentration of
reagent, method and calibration blanks must not exceed 50% of the reporting
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#5399 — Harnett Co. Dept. of Public Utilities
limit or as otherwise specified by the reference method. Ref: North Carolina
Wastewater/Groundwater Laboratory Certification Policy.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records, laboratory benchsheets and
contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for HCPU North & South
Harnett Regional WWTPs (NPDES permit #s NCO021636 & NC008366, respectively) for
October, November and December, 2013; Harnett County Regional Water Treatment
Plant (NPDES permit # NC 0007684) for October, 2013; North Harnett Regional Spray
Field (NPDES # WQ0028562) for November, 2013. The following errors were noted:
Date
Parameter
Permit #
Location
Value on Benchsheet
Value on DMR
11/30/13
pH
NCO088366
Effluent
6.95 s.u.
6.9 s.u.
Comment: 6.95 S.U. properly rounds to 7.0 S.U.
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: Nick Jones Date: April 23, 2014
Report reviewed by: Tonja Springer Date: April 29, 2014