HomeMy WebLinkAbout#5545- 03-2009-FINALLaboratory Cert. #:
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• • • ' - R
5545
Linville Land Harbor
Field Initial
Jason Smith
March 31 2009
April 24, 2009
April 24, 2009
Todd Crawford
April 24, 2009
X Insp. Initial _ Insp. Reg. _ Insp. No Finding _ Insp. CP
Gary Francies
Beverly Eaves Perdue
Governor
5545
Mr. C.L. Lewis
Linville Land Harbor
P.O. Box 160
Linville, NC 28646
P
NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
April 30, 2009
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Initial Inspection
Dear Mr. Lewis:
Dee Freeman
Secretary
Enclosed is a report for the inspection performed on March 31, 2009 by Mr. Jason M. Smith. Where finding(s)
are cited in this report, a response is required. Within 30 days of receipt, please supply this office with a written
item for item description of how these finding(s) were corrected. 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,
Gary Frahcies
Unit Supervisor
Laboratory Section
CC: Jason M. Smith
Asheville Regional Office
OENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1�TOne
1623 Mail Service Center, Raleigh, North Carolina 27699-1623 l� orth C rolina
Location: 4405 Reedy Greek Road. Raleigh, North Carolina 27607-6445
Phone: 919.733-39081 FAX: 919-733-6241 Naturally
ally
Internet: wway.dwglab.org
An Equal Opportunity \AfiirmativeAction Employer Customer Service:1-877-623-6748 www.ncwaterquality.org
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE :
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR:
LOCAL PERSON CONTACTED:
1. INTRODUCTION:
Linville Land Harbor
NCO022756
P.O. Box 160
Linville, NC 28646
5545
March 31, 2009
Field Initial
Jason Smith
C.L. Lewis, Dallas Brown
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. Most data appeared accurate.
Documentation needs to be improved. Some further quality control procedures need to be
implemented. Technical Assistance documents for all certified parameters were provided at the time of
the inspection.
FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Documentation
pH - Standard Methods, 20th Edition, 4500 H+ B
Temperature - Standard Methods, 20th Edition, 2550 B
Total Residual Chlorine - Standard Methods, 20th 4500 Cl G
A. Finding: Both operators sign the benchsheets with no clear indication of which performed the
analyses.
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 benchsheets must provide a space for the signature or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
B. Finding: The time of analysis is not documented.
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 benchsheets must provide a space for the signature or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
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#5545 Linville Land Harbor
C. Finding: The calibration check buffer is not analyzed prior to sample analysis.
Requirement: In addition to the calibration standards, the meter must be verified with a third
calibration standard (e.g., pH 7 buffer). Ref: Technical Assistance for Field Analysis of pH, Rev.
02/2009.
Comment: The calibration check buffer is considered part of the calibration and must be analyzed
prior to sample analysis to verify the meter is properly calibrated.
Comment: A post analysis check buffer, which the facility currently analyzes, is only required
when compliance samples are analyzed throughout the day.
D. Finding: The facility does not report all of the pH analyses performed.
Requirement: The results of all tests on the characteristics of the effluent, including but not
limited to NPDES permit monitoring requirements, shall be reported on the monthly report
forms. Ref: 15A NCAC 2B .0506 (b) (3) (J).
Comment: Process control samples that are not reported must be collected prior to the final
effluent.
Temperature - Standard Methods, 20t" Edition, 2550 B
E. Finding: Temperature is not analyzed within EPA holding time.
Requirement: Analysis, either in situ or immediately on site, is required. Ref: Code of Federal
Regulations, Title 40, Part 136; Federal Register Vol. 72, No. 47, March 12, 2007; Table II.
Total Residual: Chlorine - Standard Methods, 20th 4500-Cl G
F. Finding: The Total Residual Chlorine (TRC) meter has not had the internal calibration curve
verified within the last twelve months.
Requirement: The annual factory set curve verification must be performed at least every 12
months. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine, Rev. 08/2008.
Please submit a copy of the TRC curve verification with the reply to this report.
Comment: The contract laboratory provided the facility with a photometer for TRC analysis in
June, 2008 and it was assumed the curve verification was performed at that time. The actual date
of the curve verification was January, 2008.
G. Finding: TRC results are reported below the reporting level (i.e. the lowest concentration verified).
Requirement: The concentrations of the calibration standards must bracket the concentrations of
the samples analyzed. One of the standards must have a concentration equal to or below the
lower reporting concentration for TRC. Ref: Technical Assistance for Field Analysis of Total
Residual Chlorine, Rev. 08/2008.
Comment: Since the lowest concentration verified was 10 pg/L, all results below that value must
be reported as < 10 pg/L.
IV.
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#5545 Linville Land Harbor
H. Finding: TRC Performance Testing (PT) samples are analyzed using an incorrect meter
program.
Requirement: "The DMR-QA study is designed to evaluate the entire process you use to
routinely report results in your Discharge Monitoring Reports." Ref: EPA DMR-QA Study 28
Letter, March 10, 2008.
Comment: Analyze PT samples on the same program, using the same procedure that is used
for sample analysis. NPDES samples are analyzed using the Ultra Low Level (pg/L) TRC
internal instrument standard curve; however, PT samples are analyzed using the Regular Level
(mg1L) TRC internal instrument curve.
Recommendation: Regular level PT samples may be diluted so that concentrations are within
the verified (bracketed) curve range. Since the dilution process can introduce additional error, it
is recommended that the facility analyze a low level TRC PT sample. These are currently
available from many vendors.
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 Quality. Data were
reviewed for August and September, 2008. No transcription errors were detected. The facility appears
to be doing a good job of accurately transcribing data.
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: Jason Smith
Report reviewed by: Todd Crawford
Date: April 24, 2009
Date: April 24, 2009