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HomeMy WebLinkAboutNC0024252_Compliance Schedule_20171115CITY OF C O N O V E R PUBLIC WORKS DEPARTMENT P.O. BOX 549 Phone 828-464-4808 CONOVER, NC 28613-0549 November 15, 2017 Mr. Ron Berry RECEIVCDINCDENWR NCNR/Water Quality NPDES Unit NOV 21 2017, 1617 Mail Service Center Water Quality Raleigh, NC 27699-1617 Permitting Section Dear Mr. Berry: In order to comply with the NPDES permit issued and effective on December 1, 2016 for the City of Conover Northeast Wastewater Treatment Plant NCO024252 under section A.(6)COMPLIANCE SCHEDULE FOR TOTAL COPPER, we wish to report on our present efforts to assure clean sample collection and quality lab control. I feel our past problem with higher than normal levels of copper were few and sporadic and we have not conclusively identified the cause. Since the issuance of our present permit we have been in total compliance with the issued copper limit. We are concerned with sample contamination and laboratory quality control and I have attached some sample collections practice and procedure and laboratory quality control statements with this correspondence. Our samples are collected in single use, sterile FDA approved bags which line our sampler jugs. The samples are then transferred to single use food grade bottles for transportation to the laboratory. All of our personnel collecting samples are nonsmokers. Our samplers and lines are cleaned on a routine basis to eliminate the possibility of contamination. We have our copper samples analyzed by a contact laboratory, Research and Analytical Labs. Attached is quality control information from the lab. We hope that if the past spikes in copper were caused by contaminated samples or laboratory contamination our review and oversite has eliminated future problems. In the event you have questions comments, or need further information please call me at (828) 465-2279. Sincerely, Michael Fox Wastewater Treatment and Collection Supervisor A. (6)CO143NIPLL&NCE-215A(b)] SCHEDULE FOR TOTAL COPPER [G,9, 1. No latcr than November 30, 201 1, the Pernilttee shall: a. Improve and impletnent "clean" techniques, Some steps that can be invetigated: 0 Discuss procedures, wi(h Qontraaed lab to ensure eliminabon of potential contaminationsou,rce�, a Fxamlne basic sampling handling processes (field sampling, laboratory haiid] inn and anal�rsis) 0 Examine sampling equipment clecmiiig procedures reagent quality) a Ensure that sampling persomiel are non-smokers. b, S-Libmit to the Division of Water lke�sources a report surnm2-1-lizint ,; impmvetnnts. and stating if the actions taken will enable the Permittee to achieve coi-ripliance with the Total Coj)per- Limits at Oud'all 001 withi'mit ficulher actions. CONOVER NEWWTP SAMPLING SOP 11/2017 Compliance schedule for Total Copper Sampling The effluent sampler is set up in the lab building, and is a dipper type sampler. A line runs from the effluent sampler pump to the lab and the effluent pump runs continuously. The effluent sampler is paced to take samples only when water is flowing through the effluent discharge. Once each week the operator turns the effluent pump on and off a few times to backwash the effluent sampler line to keep solids from accumulating in the line. The sampler is cleaned daily of any buildup of solids or organic matter. For metals sampling, the sampler jugs are lined with new, single use disposable food grade plastic bags. Sampling is done by lab personnel trained in SOP procedures and include using clean latex gloves. The operators are non-smokers and wear clean, disposable latex gloves during sampling. Metal samples are collected in clean, single use plastic bottles provided by the contract lab. The samples are preserved to pH <2 with Nitric acid and stored in a refrigerator. They are picked up by the contract lab in a manner to ensure all holding times are maintained. Proper documentation is maintained with Chain of Custody documents properly filled out and stored according to state guidelines. Evan Rubins City of Conover Pretreatment and sample collections specialist SAMPLING PROCEDURES AND HANDLING Sample containers are preserved in the laboratory unless a client instructs otherwise It is acceptable for samples to be preserved in the field at the time of collection Additionally, some samples may be preserved in the laboratory after collection if the samples can be kept on ice and if the preservatives are added within 4 hours of collection Written sample instructions are available to clients Instructions available for clients include by are not limited to bacteriologicals, wastewater composites and grabs, volatile and semi -volatile collection, stormwater, and groundwater monitoring. Other sampling procedures can be developed on a case by case basis Water Tech personnel are available to provide sampling assistance Some Water Tech personnel have been trained in drinking water and wastewater collection CHAIN OF CUSTODY PROCEDURES Chain of custody (COC) procedures are used to verify the client, project, sampler, date and time of collection, type of sample (composite or grab), type and number of containers, test parameters needed and preservatives used The laboratory verifies the holding times, preservatives, pH, and total chlorine residuals of any samples upon receipt in the laboratory If the COC form is correct and all sample validity requirements are met, the samples are accepted by the check-in person for check-in and identification If there are any questions about the COC, the client is notified and the check-in person makes a note of comments in the comment sections of the COC form SAMPLE CHECK-IN AND HANDLING Upon receipt in the laboratory samples are checked -in The purpose of the check-in step is to verify that the temperature reflects a downward trend in temperature, samples are properly preserved, and that holding times have not been exceeded A COC document should accompany each sample A COC document is used to provide information about the clients' name, date and time samples were collected, description of samples collected, type of containers used (i e glass or plastic), tests that are requested for analyses, and what preservatives were used The check-in person should complete the following steps to check-in samples 1) Open the cooler and examine contents for the presence or absence of ice Measure the temperature of the samples by inserting a pre -calibrated thermometer into a temperature blank Water Tech Labs bottle provided in the cooler The thermometer is allowed PO Box 1056 Granite Falls, IVC 28630 4 I adequate time for the temperature to stabilize, 1-2 minutes. Temperature is recorded on the COC Temperature must be <6°C. For grab samples taken within 30 minutes of arrival at the laboratory and received on ice, the temperature minimum is waived but noted on the COC. If the grab sample temperature was taken in the field, recorded on the COC and arrives on ice at the laboratory with a temperature >6°C, the downward trend in temperature from the field to the laboratory is noted on the COC. In lieu of temperature blank and glass thermometer, an infrared laser thermometer may be used — carefully point laser into sample and read 2 Check the pH of the samples by using pH paper. Check for correct sample preservation. See attached preservative requirements in the Appendix. Note the preservatives used by checking the appropriate preservative on the COC. Confirm that samples are received with the required holding time Reference the holding time list in the Appendix. If information is missing call the client and obtain information. If you are unable to reach the client, proceed with check-in so that the samples can be processed as quickly as possible. If samples have exceeded their holding time, do not analyze the samples without expressed verbal or written permission of the client. Exception: If receipt of samples is delayed due to inclement weather, Water Tech will accept fecal coliform samples whose holding time may have expired. Note such conditions on the chain of custody. The final report will also reflect that the samples were analyzed out of hold time due to inclement weather. 4 Examine COC to ensure sample test parameters are clearly recorded and that each parameter requested on the COC has a corresponding sample container. Match COC entries with sample bottles received. If information is missing or sample bottles are missing, the client is notified immediately. 5. Samples are distributed to the appropriate analysts for immediate analysis or to re$7gerated storage (<4°C) to be analyzed at the appropriate time within sample holding time requirements. 6 The laboratory should reject any sample taken for compliance purposes which does not meet the specifications for containers and preservatives, holding times, proper collection and/or transport, or completion of appropriate sections of report form. 7 Samples improperly collected, handled, preserved, documented or out of holding time are rejected 8. For rejected samples, a resample is requested. If re -sampling is not possible and the sample is analyzed, the sample data is clearly identified in the data packet and on the final report as being unusable for compliance purposes. SAMPLE DISPOSAL The analyst will dispose of samples after all assigned tests have been completed. If questions exist concerning proper disposal of samples, the lab supervisor will be notified so that proper disposal techniques can be identified. 5 SAMPLE PRESERVATION Once the sample has been collected, it should be analyzed as quickly as possible or preserved and stored in a container in an attempt to maintain the sample integrity. Complete preservation procedures are an attempt to modify (retard or stop) the chemical and biological changes that can occur after the sample has been collected and placed in a storage container. Approved methods of preservation are pH control, chemical addititon, refrigeration, and freezing in an attempt to (1) slow biological reactions, (2) control chemical reactions (hydrolysis, oxidation, reduction, etc.), (3) reduce volatility, and (4) reduce adsorption of the components of interest Recommendations for Preservation of Samples Vol. Recommended Req Holding Measurement ml Container (a) Preservative Time (b,c,d) Physical Properties Conductance 100 P,G Cool, 4°C 28 days(e) pH 100 P,G Determine on site 15 minutes Residue Filterable 500 P,G Cool, 4°C 7 days Non -filterable 500 P,G Cool, 4°C 7 days Total 500 P,G Cool, 4°C 7 days Volatile 100 P,G Cool, 4°C 7 days Settleable Matter 1000 P,G None required 48 hours Temperature 100 P,G Determine on site No holding Turbidity 100 P,G Cool, 4°C 48 hours Metals Dissolved 200 P,G Filter on site 6 months( f) HNO3 to pH <2 Suspended 200 Filter on site 6 months Total 100 P,G HNO3 to pH <2 6 months( f) Hardness 200 P,G Cool, 4°C 6 months( fl HNO3 to pH <2 Mercury Dissolved 100 P,G Filter on site 28 days HNO3 to pH <2 Total 100 P,G HNO3 to pH <2 28 days Inorganics, Non -Metallics Acidity 200 P,G Cool, 4°C 14 days Alkalinity 200 P,G Cool, 4°C 14 days Chloride 200 P,G None required 28 days Chlorine 200 P,G Determine on site No holding; Analyze immediately Cyanides 500 P,G Cool, 4°C 14 days NaOH to pH 12 Fluoride 300 P None required 28 days Nitrogen, Ammonia 400 P,G Cool, 4°C 28 days H2SO4 to pH <2 Kjeldahl, Total 500 P,G Cool, 4°C 28 days H2SO4 to pH <2 Nitrate plus Nitrite 200 P,G Cool, 4°C 28 days H2SO4 to pH <2 OA Organics BOD Vol. P,G Cool, 4°C Recommended COD Req. P,G H2SO4 to pH <2 Holding Measurement ml Container (a) Preservative Time (b,c,d) Nitrate 200 P,G Cool, 4°C or 48 hours Organic carbon 200 S Chloroform, 4°C 28 days Nitrite 100 P,G Cool, 4°C or 48 hours MBAS 250 P,G Chloroform, 4°C 48 hours Dissolved Oxygen Probe 300 G only Determine on site No holding; BOD bottle analyze immediately Winkler 300 G only Fix on site 4 — 8 hours, BOD bottle after acidified Phosphorus Orthophosphorus Dissolved 100 P,G Filter on site 48 hours Cool, 4°C Hydrolyzable 100 P,G Cool, 4°C 48 hours H2SO4 to pH <2 r � Total Phosphorus Total 100 P,G Cool, 4°C 24 hours H2SO4 to pH <2 Dissolved 100 P,G Filter on site 24 hours Cool, 4°C H2SO4 to pH <2 Silica 100 P only Cool, 4°C 28 days Sulfate 100 P,G Cool, 4°C 28 days Sulfite 100 P,G Determine on site No holding; analyze immediately Organics BOD 1000 P,G Cool, 4°C 48 hours COD 100 P,G H2SO4 to pH <2 28 days Oil and Grease 1000 G only Cool, 4°C 28 days MSOatopH<2 Organic carbon 200 S Cool, 4°C 28 days H2SO4 to pH <2 MBAS 250 P,G Cool, 4°C 48 hours �-qj (a) Plastic (P) or Glass (G). For most metal, polyethylene with a polypropylene cap (no liner) is preferred. (b) It should be pointed out that holding times listed are recommended for properly preserved samples based on currently available data. It is recognized that for some sample types, extension of these times may be possible while for other types, these times may be too long Where shipping regulations prevent the use of the proper preservation technique or the holding time is exceeded, such as the case of a 24-hour composite, the final reported data for these samples should indicate the specific variance. (c) Standard Methods for the Examination of Water and Wastewater, American Public Health Association, Washington DC. (d) EPA. Methods for Chemical Analysis of Water and Wastes. U.S. Environmental Protection Agency, EPA -690/4-79-020, Cincinnati, OR (e) If the sample is stabilized by cooling, it should be warmed to 25°C for reading, or temperature correction made and results reported at 25°C. (fl Where HNO3 cannot be used because of shipping restrictions, the sample may be initially preserved by icing and immediately shipped to the laboratory. Upon receipt in the laboratory, the sample must be acidified to a pH < 2 with HNO3 (normally 3 ml 1 + 1 HNO3/L is sufficient). At the time of analysis, the sample container should be thoroughly rinsed with 1 + 1 HNO3 and the washings added to the sample (volume correction may be required) HOLDING TIMES & PRESERVATIVES--NPDES PARAMETERS PARAMETER PRESERVATIVE CONTAINER HOLDING TIME Ammonia H2SO4 PL 28 days COD H2SO4 PL 28 days NC2+NO3 H2SO4 PL 28 days Phenol H2SO4 GL- Amber 28 days Phosphorus, Total H2SO4 PL 28 days TKN H2SO4 PL 28 days TOC H2SO4 GL 28 days TOX H2SO4 GL 28 days Cyanide NaOH/ AA PL 14 days Sulfide NaOH/ Zn Acetate GL 7 days Fecal Coliform Bacteria Na Thiosulfate PL- Sterile 8 hours Total Coliform Bacteria Na Thiosulfate PL- Sterile 8 hours Hardness HNO3 PL 28 days Metals (except Mercury) HNO3 PL 6 months Mercury HNO3 PL 28 days Metals for DWQ GW HNO3 PL Special 3030C Digestion within 72 hours Oil & Grease H2SO4 GL 28 days VOCs: 524.2/ 624/ 8240/ 8260/ 601/ 602/ 8010/ 8020/ BTEX HCL GL- VOA vial 14 days Alkalinity NP PL 14 days BOD & CBOD NP PL 48 hours Chloride NP PL 28 days Chlorine Residual, Total NP PL Immediate- Field Chlorophyll a NP PL- Amber Filter within 24 hours Color NP PL 48 hours Conductivity NP PL 28 days Dissolved Oxygen Immediate- Field Fluoride NP PL 28 days Herbicides: 615/ 8150/ 8151 NP GL- Amber 7 days MBAS NP PL 48 hours NO2 NP PL 48 hours pH - Field NP PL Immediate- Field pH - Lab NP PL Immediate Orthophosphate NP PL 48 hours Pesticides/PCBs- 608/ 8140/ 8141/8080/8081 NP GL- Amber 7 days Semivolatiles- 625/ 8270 NP GL- Amber 7 days Solids- Dissolved (TDS) NP PL 7 days Solids- Settable NP PL 48 hours Solids- Suspended (TSS) NP PL 7 days Solids- Total (TS) NP PL 7 days Solids- Volatile Suspended NP PL 7 days Solids- Volatile Total NP PL 7 days Sulfate NP PL 28 days Temperature Immediate- Field TPH 8015- 3550/ 5030 NP GL 7 days Turbidity NP PL 48 hours Water Level Field r_o"j "u - -1-T '�"' (, oker Tec� ��Lpjlc QC Excerpt of doe L.) lrleA-" SOP for Metals Analyses by ICP -MS Doc#MA00101.ra Date: Feb 2017 9.2 Initial Calibration Curve 9.2.1 A blank and at least three calibration standards must be prepared and analyzed daily. These standards will include the highest and lowest concentrations of the calibration curve for each analyte. The Standards Formulation Chart for all analytes can be found in Appendix I of this SOP. The correlation coefficient of the curve must be 0.995 or greater. 9.2.2 The instrument performance check (IPC) is used to determine the instrument performance and verify that the instrument is properly calibrated. The IPC is a mid-range standard analyzed immediately after calibration. The analysis of all analytes within the standard solution must be within ±10% of calibration. If not, the instrument must be recalibrated. 9.2.3 After the analysis of the IPC, a Quality Control Standard (QCS) sample is analyzed daily. The recovery of the sample must fall within +/- 10% of the true value in the check sample. If this criteria is not met, corrective action must be taken. If corrective action does not solve the problem, the calibration curve and the QCS must be reanalyzed. 9.2.4 After the analysis of the QCS, an Initial Calibration Blank (ICB) must be analyzed. The concentration of the ICB must be less than or equal to one half of the low standard. If this criteria is not met, corrective action must be taken. *When analyzing samples using SW -846 Method 6020B, the following criteria must be added: 9.2.5 After the initial calibration curve is completed the Spectral Interference Check (SIC) is analyzed. The concentration of all elements NOT included in the SIC solution must be no more than two (2) times the LLOQ value of each element. If this criteria is not met, corrective action must be taken. 9.2.6 After the initial calibration curve is completed the Lower Limit of Quantitation (LLOQ) check sample must be analyzed on a quarterly basis, at a minimum. The recovery of this sample must fall within ±35% of the true value and have a RSD of <20%. If this criteria is not met, corrective action must be taken. 9.3 Continuing Calibration Verification 9.3.1 The accuracy of the calibration curve must be verified throughout the analysis by a Continuing Calibration Verification sample once every 10 samples and at the end of a run sequence. The percent recovery of the CCV must fall within +/- 10% of the true value of the CCV. If this criteria is not met, corrective action must be taken. If corrective action does not solve the problem, the analyses must be terminated, the instrument must be recalibrated, and the preceding samples must be reanalyzed. 9.3.2 Immediately after the analysis of the CCV, a Continuing Calibration Blank (CCB) must be analyzed. The CCB must be less than or equal to one half of the low standard concentration. NOTE: All analytical sequences must end with a CCV and CCB. Samples must be bracketed by acceptable CCV and CCB values. 11.0 QUALITY CONTROL 11.1 The instrument detection limit (IDL) is used to characterize the instrument performance by the statistical analysis of multiple reagent blank samples. This shall be run when there are major changes to the method or instrumentation. 11.2 The method detection limit (MDL) determination is used to establish the lowest verifiable detection limit for each analyte for the instrument. The MDL is a statistical analysis of multiple low standard samples. This must be run annually or when there are major changes to the method or instrumentation. When using SW - 846 Method 6020B for analysis, this limit is described as the Lower Limit of Quantitation (LLOQ) and is to be established initially and then verified at least quarterly. The LLOQ verification must have a concentration recovery of ±35% and a RSD of <20%. 11.3 The initial demonstration of capability (IDOC) is used to prove the ability of the analyst to produce precise and accurate results. The IDOC is a statistical analysis of four LFB standard samples. This must be run by any analyst using the instrument before proceeding with sample analysis. 11.4 The Spectral Interference Check (SIC) is used when using SW -846 Method 6020B to demonstrate the appropriate magnitude of interferences and provide an adequate test of any corrections.. The concentration of all elements NOT included in the SIC solution must be no more than two (2) tunes the LLOQ value of each element. 11.5 Laboratory Reagent Blanks or Preparation Blanks (LRB or PB) A Laboratory Reagent Blank or Preparation Blank is reagent grade water that is digested or prepared and analyzed with each batch of 20 or fewer samples. It is treated exactly as a sample including exposure to all glassware, equipment, solvents, reagents, and internal standards that are used with other samples. The LRB/PB is used to determine if method analytes or other interferences are present in the laboratory environment, reagents, or apparatus. The concentration of the preparation blank must be less than or equal to one half of the low standard concentration. The LRB/PB may be re -analyzed once. If corrective action does not solve the problem, all corresponding samples must be redigested and reanalyzed. 11.6 Matrix Spike and Matrix Spike Duplicate Samples (MS/MSD) A sample is spiked with a known concentration of analytes prior to digestion every batch of 10 samples of a similar matrix and duplicated. The percent recovery of the spike compounds must be between 70% and 130%. If the recovery of any analyte falls outside the designated range and laboratory performance for that analyte is shown to be in control, the recovery problem is judged to be matrix related. The data user should be informed that the result for that analyte in the sample is suspect due to the nature of the sample or an uncorrected matrix effect. The relative percent difference between the MS and MSD must be ±10%. 11.7 Laboratory Fortified Blank (LFB) A LFB is a mid-range standard that is digested with each batch of samples. The percent recovery of the compounds present in the LFB must be within 85% and 115% recovery. If not corrective action must betaken. If corrective action does not solve the problem, all corresponding samples must be redigested and reanalyzed. 11.8 Internal Standard: The internal standard is added to all samples, extracts and standard solutions via peristaltic pump during analysis. It is used to measure the relative responses of analytes in a multi -analyte method that are components of the same sample or solution. The percent recovery of the internal standard must be between 60% and 125%. When EPA SW -846 Method 6020B is being used, the internal standard recovery must be no less than 70%. If not, corrective action must be taken. If corrective action does not solve the problem, then the sample must be redigested or diluted.