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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. Page 2 #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. Page 3 #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 Page 4 #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