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HomeMy WebLinkAbout#226 -08 - 2010 - FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 226 Laboratory Name: Spruce Pine WWTP Lab Inspection Type: Municipal Maintenance Inspector Name(s): Jason Smith Inspection Date: August 17, 2010 Date Report Com leted` September 29 2010 Date Forwarded to Reviewer: September 29 2010 Reviewed bv: Jeff Adams Date Review Completed: October 1 2010 Cover Letter to use: Insp. Initial X Insp. Reg. Insp, No Finding Insp. CP Unit Supervisor: Gary Francies Date Received: 10/1/10 Date Forwarded to Alberta: % �'o & WF7 Date Mailed: Beverly Eaves Perdue Governor 226 Mr. Darrell Graham Spruce Pine WWTP Lab P.O. Box 189 Spruce Pine, NC 28777 i . NCDENR �rarrorrrr North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director October 6, 2010 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Graham: Dee Freeman Secretary Enclosed is a report for the inspection performed on August 17, 2010 by Jason Smith. 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 me at 828-296-4677. Sincerely, C Gary Francies Unit Supervisor Laboratory Section CC: Jason Smith Central files DRNR D+NQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-39061 FAX: 919-733-6241 Internet: www.dwglab.org An Equal Opportunity\Affirmative Action Employer Customer Service:1-877-623-6748 www.ncwaterquality.arg NorthCarolina LABORATORY NAME: NPDES PERMIT #: :ITRr; CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: Spruce Pine WWTP Lab NCO021432 P.O. Box 189 Spruce Pine, NC 28777 226 August 17, 2010 Municipal Maintenance Jason Smith Darrell Graham, Phillip Burleson, and Bob Haller This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. 11. GENERAL COMMENTS: The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Findings C, D, E, F, G, J, K, N and O are new policies that have been implemented by our program since the last inspection. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: General Laboratory Comment: The laboratory was not clearly labeling process control data to differentiate between regulatory and non -regulatory data. Recommendation: Clearly document all process control data as such on the benchsheet. A. Finding: The laboratory's Standard Operating Procedures (SOP's) have not been updated since 2002. Requirement: Each laboratory shall develop and maintain a document outlining the analytical quality control practices used for the parameters included in their certification. Supporting records shall be maintained as evidence that these practices are being effectively carried out. The quality control document shall be available for inspection by the State Laboratory, Ref: 15A NCAC 2H .0805 (a) (7). Comment: Please submit updated SOPs for all certified parameters by April 6, 2011. Recommendation: It is recommended that SOP's be reviewed annually and that the date of review or revision be documented. Page 2 #226 Spruce Pine WWTP Lab B. Finding: Several instances of the use of correction fluid were observed. 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-OutO, 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: North Carolina Wastewater/ Groundwater Laboratory Certification Policy. C. Finding: The reagent receipt log did not include the date opened and expiration date. 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. D. Finding: The analytical balance weights have not been verified against ASTM standard weights. Requirement: ASTM Class 1 and 2 weights must be verified at least every 5 years. ASTM Class 1 weights (20 g to 25 kg) and ASTM Class 2 weights (10 g to 1 mg) are equivalent to the NBS Class S weights specified in 15A NCAC 2H .0805 (a) (7) (K). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. See attachment for additional guidance. pH — Standard Methods, 18'h Edition, 4500 H+ B Dissolved Oxygen — Standard Methods, 18'h Edition, 4500 O G E. Finding: The temperature sensor for the pH meter has not been checked against a NIST certified or NIST traceable thermometer. Requirement: All thermometers and temperature measuring devices must be checked every12 months against a NIST certified or NIST traceable thermometer and the process documented. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST certified or NIST traceable thermometer and record the two temperatures. The calibration must be performed at a temperature that corresponds to the temperature used by the incubator, refrigerator, freezer, etc. In the case of temperature measuring devices used to perform variable temperature readings the calibration must be performed at a temperature range that approximates the range of the samples. The thermometer/meter readings must be less than or equal to 10C from the NIST certified or NIST traceable thermometer reading. The documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was used in the comparison. Also document any correction that applies (even if zero) on both the thermometer/meter and on a separate sheet to be filed. (NOTE: Other certified laboratories may provide assistance in Page 3 #226 Spruce Pine WWTP Lab meeting this requirement.) Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy. F. Finding: —The temperature correction was not posted on the Dissolved Oxygen (DO) and pH meters. Requirement: See required above for Finding E. Temperature — Standard Methods, 18'h Edition, 2550 B Dissolved Oxygen — Standard Methods, 18'h Edition, 4500 O G Recommendation: It is recommended that the benchsheet clearly indicate that samples are analyzed in stream. pH — Standard Methods, 18'h Edition., 4500 H+ B G. Finding: Proper units of measure (Standard Units or S.U.) were not documented. Requirement: All laboratories must use printed laboratory bench worksheets that include a space to enter the signature or initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the measurement system, factor and final value to be reported and each item must be recorded each time samples are analyzed. The date and time BOD and coliform samples are removed from the incubator must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H). H. Finding: The calibration does not always bracket the sample pH. Requirement: Choose buffers that bracket the sample. Ref: Standard Methods, 18" Edition, 4500 H+ B. (1) (a). Comment: The laboratory calibrates the meter with 4 and 7 S.U. buffers and then checks a 6 S.U. buffer. Checking a 10 S.U. buffer, rather than the 6, would fulfill this requirement. Total Residual Chlorine —Standard Methods, 18'h Edition, 4500 Cl G I. Finding: The concentration of the Performance Testing (PT) sample was outside of the concentration range of the standards used to verify the internal program annually. Requirement: For analytical procedures requiring analysis of a series of standards, the concentrations of these standards must bracket the concentration of the samples anal. One of the standards must have a concentration equal to the laboratory's lower reporting concentration for the parameter involved. Ref: 15A NCAC 2H .0805 (a) (7) (1). Comment: The laboratory verified the meter using the following concentrations: 20, 25, 50, 75, and 100 lag/L. The PT sample concentration was 164 lag/L. Recommendation: It is recommended that the laboratory verify the curve using the following concentrations: 20, 40, 50, 100, and 400 lag/L. The CVS would be 200. pg/L. J. Finding: A calibration blank and CVS (mid -range) are not analyzed at the end of the sample group. Page 4 #226 Spruce Pine WWTP Lab Requirement: The calibration blank and calibration verification standard (mid -range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each sample group to check for carry over and calibration drift. If either fall outside established quality -control -acceptance criteria, corrective action must be taken (e.g., repeating_ sample determinations since the last acceptable calibration verification, repeating the initial calibration, etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2). Total Suspended Solids - Standard Methods, 181h Edition, 2540 D K. Finding: A minimum dried residue weight gain of 1 mg is used to determine the reporting limit. Requirement: The minimum weight gain allowed by any approved method is 2.5 mg. Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete filtration takes more than 10 minutes increase filter diameter or decrease sample volume. In instances where the weight gain is less than the required 2.5 mg, the value must be reported as less than the appropriate value based upon the volume used. Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20th and 21" Editions, 2540 D. (3) (b). Comment: For example, if 500 mL of sample is analyzed and < 2.5 mg of dried residue is obtained, the value reported would be < 5 mg/L. Biochemical Oxygen Demand - Standard methods, 18th Edition, 5210 B Comment: Although no samples have been analyzed in over a year with > 67% of sample, please be aware of the following policy: When a bottle contains more than 67% of the sample after dilution, nutrients may be limited in the diluted sample and, subsequently, reduce biological activity. In such samples, add the nutrient, mineral, and buffer solutions (3a through e) directly to individual BOD bottles at a rate of 1 mL/L (0.33 mL/300-mL bottle) or use commercially -prepared solutions designed to dose the appropriate bottle size. Recommendation: The 216t Edition of Standard Methods requires that the dilution water blank DO uptake in 5 days must not be more than 0.20 mg/L and preferably not more than 0.10 mg/L It is recommended that the laboratory read the DO measurements to two decimal points in order to clearly document this method criterion.. Fecal Coliform - Standard Methods, le Edition, 9222 D L. Finding: Samples are not properly preserved between collection and analysis. They are allowed to sit out at room temperature for one to two hours. Requirement: Except where noted in this Table II and the method for the parameter, preserve each grab sample within 15 minutes of collection. Ref: Code of Federal Regulations, Title 40, Parts 136 and 503; Federal Register Vol. 72, No. 57, March 26, 2007; Table 11, Footnote 2. M. Finding: Although not needed, a preservative to neutralize chlorine is being used. Additionally, it is an improper preservative (Sodium Sulfite). Requirement: Add a reducing agent only if an oxidant (e.g,, chlorine) is present. Reducing agents shown to be effective are sodium thiosulfate, ascorbic acid, sodium arsenite, or sodium Page 5 4226 Spruce Pine WWTP Lab borohydride. Ref: Code of Federal Regulations, Title 40, Parts 136 and 503; Federal Register Vol. 72, No. 57, March 26, 2007; Table 11, Footnote 5. Cornmen#;—T-he-analysis-of—Total-Residual-Chlorine-at the -time -of -the -fecal -sample -collection indicates if neutralization is required. If no residual chlorine is present, do not add any dechlorination chemical. Ammonia Nitrogen -- Standard Methods, 18t" Edition, 4500 NH3 F N. Finding: While a CVS is analyzed at the end of the sample run, a CVS is not analyzed at the beginning of the sample set. Requirement: The calibration blank and calibration verification standard (mid -range) must be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each sample group to check for carry over and calibration drift. If either fall outside established_ quality control acceptance criteria, corrective action must be taken (e.g., repeating sample determinations since the last acceptable calibration verification, repeating the initial calibration, etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon Standard Methods, 20"' Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2), O. Finding: The laboratory is not analyzing matrix spikes. Requirement: Unless the referenced method states a greater frequency, spike 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. 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: Jason Smith Date: September 29, 2010 Report reviewed by: Jeffrey R. Adams Date: October 1, 2010 Weight Verification (NC WW/GW LC Policy 05123/2008) ASTM Class 1 and 2 weights must be verified at least every 5 years. ASTM Class 1 weights (20 g to 25 kg) and ASTM-Class 2 weights (10 g to 1 mg) are equivalent to the NBS Class S weights specified --in 15A NCAC 2H .0805 (a) (7) (K). Verification may be accomplished by: ........ .tj -,'Y - _✓ ' w '.— .,—­..— — ..., —w '. . be calibrated by a body that can provide traceability to ASTM specifications, or 2. Checking laboratory weights against certified reference weights (i.e., weights that have been recertified as above) and found to be within ASTM Class 1 or Class 2 tolerances (see table below) - often the balance service technician may provide this service. Note: Although some manufacturers will assign a one-year calibration due date, 5 years is considered an acceptable calibration interval due to the limited use of the reference weight set. Documentation of weight verifications or recertification must be maintained for 5 years. If the condition of a weight(s) is in question at any time due to damage (e.g., corrosion, nicks, scratching, etc.), the laboratory must have that weight(s) re -verified as described above. Maximum tolerances (Ref. ASTM E 617-97, 2003) Denomination Maximum tolerance for ASTM Class 1 and 2 weights, i m 5009 1.2 300 g 0.75 200 g 0.50 100 g 0.25 50 g 0.12 30 g 0.074 209 0.074 10 g 0.074 59 0.054 3 g 0.054 2 g 0.054 1 g 0.054 500 mg 0.025 300 mg 0.025 200 mg 0.025 100 mg 0.025 50 mg 0,014 30 mg 0.014 20 m 0.014 10 mg 0.014 5 mg 0.014 3 mg 0.014 2 mg 0.014 1 mg 0.014