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Home My WebLink About#51 10-final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 51 Laboratory Name: Raleigh Neuse River WWTP Inspection Type: Municipal Maintenance Inspector Name(s): Jeffrey R. Adams Inspection Date: July 8, 2010 Date Report Completed: July 15, 2010 Date Forwarded to Reviewer: July 15, 2010 Reviewed by: Jason Smith Date Review Completed: July 16, 2010________ Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP Unit Supervisor: Dana Satterwhite Date Received: July 19, 2010 Date Forwarded to Alberta: August 5, 2010 Date Mailed: August 5, 2010 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Raleigh Neuse WWTP NPDES PERMIT #: NC0029033+ ADDRESS: P.O. Box 590 Raleigh, NC 27602 CERTIFICATE #: 51 DATE OF INSPECTION: July 8, 2010 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Jeffrey R. Adams LOCAL PERSON(S) CONTACTED: Darrell Crews and Kim Lowery 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 neat and equipment was well maintained. Records were maintained and well organized, however, some quality control procedures need to be implemented. The laboratory was given a packet containing North Carolina Laboratory Certification quality control requirements and policy changes during the inspection. Findings A, B, D and F are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Thermometers A. Finding: The laboratory has not verified the infrared (IR) temperature sensing device quarterly. Requirement: When an infrared (IR) detection device is used to measure the temperature of samples, the device must be verified at least every quarter using a NIST-certified thermometer over the full temperature range that the IR thermometer will be used. Each day of use, perform a single check of the IR by checking the temperature of a bottle of water at the temperature of interest that contains a calibrated thermometer. Agreement between the two must be within 0.5ºC, or the device must be recalibrated. If the second calibration fails, the device must be repaired and/or replaced. Document the quarterly and daily calibration checks. The correction factor must be indicated on the thermometer and applied when recording temperature measurements. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Comment: The infrared temperature sensing device is being verified annually, but not quarterly. Page 2 #51 Raleigh Neuse WWTP B. Finding: The comparison measurement between the NIST thermometer and the infrared device exceeded 0.5°C. Requirement: When an infrared (IR) detection device is used to measure the temperature of samples, the device must be verified at least every quarter using a NIST-certified thermometer over the full temperature range that the IR thermometer will be used. Each day of use, perform a single check of the IR by checking the temperature of a bottle of water at the temperature of interest that contains a calibrated thermometer. Agreement between the two must be within 0.5ºC, or the device must be recalibrated. If the second calibration fails, the device must be repaired and/or replaced. Document the quarterly and daily calibration checks. The correction factor must be indicated on the thermometer and applied when recording temperature measurements. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. Autoclave C. Finding: The laboratory is not checking the operating temperature of the autoclave weekly using a minimum/maximum temperature holding thermometer. Requirement: Record items sterilized temperature, pressure and time for each run. Optimally use a recording thermometer. Check operating temperature weekly with a minimum/maximum thermometer. Ref: Standard Methods, 18th Edition, 9020 B (2) (i). Requirement: Each laboratory requesting certification must contain or be equipped with the glassware, chemicals, supplies and equipment required to perform all analytical procedures included in their certification. Ref: 15A NCAC 02H .0805 (a) (6) (H). Chemicals and Reagents D. 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 (where specified). 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 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: North Carolina Wastewater/Groundwater Laboratory Certification Policy. COD – Hach Method 8000 Total Kjeldahl Nitrogen – EPA Method 351.1 Metals – EPA Method 200.7 Block Digesters Recommendation: It is recommended that the laboratory rotate the position of samples, blanks and quality control samples in the block digester during TKN, COD and metals digestions. Random placement will help to identify when optimal performance is not achieved in an individual sample well. It is also recommended that the laboratory implement a temperature grid check of the block digester by Page 3 #51 Raleigh Neuse WWTP alternating the well location of the thermometer each time samples are digested. This will document heating uniformity and consistency of all sample wells in the block. De-ionized Water Supply Recommendation: It is recommended that the laboratory install a Total Organic Carbon filter on the outlet end of the de-ionized water supply, especially for water used in Biochemical Oxygen Demand (BOD) and metals analyses. Dissolved Oxygen – Hach Method 10360 Comment: The laboratory did not notify this office of the change in methodology (i.e., Luminescence Dissolved Oxygen) for Dissolved Oxygen analysis. The North Carolina Administrative Code, 15A NCAC 2H .0805 (c) (7) requires, A certified laboratory must submit a written amendment to certification each time that changes occur in methodology, reporting limits, and major equipment. The amendment must be received within 30 days of such changes. An amendment form was completed during the inspection. No further response is necessary for this finding. Conductivity – Standard Methods, 18th Edition, 2510 B Dissolved Oxygen – Hach Method 10360 pH – Standard Methods, 18th Edition, 4500 H+ B E. Finding: The laboratory is not posting NIST temperature sensor corrections on the Conductivity, DO and pH meters. Requirement: All thermometers must meet National Institute of Standards and Technology (NIST) specifications for accuracy or be checked, at a minimum annually, against a NIST traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (O). Comment: Document any correction that applies (even if zero) on both the temperature sensor and on a separate sheet to be filed to ensure accurate data is recorded and maintained according to the required record retention schedules. Total Phosphorous – Standard Methods, 18th Edition, 4500 P E F. Finding: The laboratory is not analyzing matrix spikes. Requirement: Unless the referenced method states a greater frequency, spik e 5% of samples on a monthly basis. Laboratories analyzing less than 20 samples per month must analyze at least one matrix spike each month samples are analyzed. Prepare the matrix spike from a reference source different from that used for calibration unless otherwise stated in the method. If matrix spike results are out of control, the results must be qualified or the laboratory must take corrective action to rectify the effect, use another method, or employ the method of standard additions. When the method of choice specifies matrix spike performance acceptance criteria for accuracy, and the laboratory chooses to develop statistically valid, laboratory-specific limits, the laboratory-generated limits cannot be less stringent than the criteria stated in the approved method. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. IV. PAPER TRAIL INVESTIGATION: No paper trail performed. Page 4 #51 Raleigh Neuse WWTP V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendation(s) 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: July 15, 2010 Report reviewed by: Jason Smith Date: July 16, 2010