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HomeMy WebLinkAbout#5347_2017_0707_TH_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5347 Laboratory Name: Perquimans County Water Inspection Type: Field Municipal Maintenance Inspector Name(s): Tom Halvosa, Todd Crawford, Gary Francies Inspection Date: 6/21/2017 Date Forwarded for Initial Review: 6/28/2017 Initial Review by: Anna Ostendorff Date Initial Review Completed: 6/28/2017 Cover Letter to use: ❑ Insp. Initial ❑Insp. No Finding ❑Corrected ® Insp. Reg ❑Insp. CP ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: 6/29/2017 Date Forwarded to Admin.: 7/5/2017 Date Mailed: 7/7/2017 Special Mailing Instructions: Water Resources ENVIRONMENTAL QUAD_ Y July 7, 2017 5347 Mr. Nick Lolies Perquimans County Water P.O. Box 45 Hertford, NC 27944 OY COOPER Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Lolies: Enclosed is a report for the inspection performed on June 21, 2017 by Tom Halvosa, Gary Francies and myself. 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. Please describe the steps taken to prevent recurrence and include an implementation date for each corrective action. 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. A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list will reflect any changes made during the audit. 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 (919) 733-3908 ext. 251. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Master file Tom Halvosa • ' ' '• • _, LABORATORY NAME: NPDES PERMIT # ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED I. INTRODUCTION: Perquimans County Water NC0051373, NC0068861 108 Lake Rd. Hertford, NC 27944 5347 June 21, 2017 Field Municipal Maintenance Tom Halvosa, Todd Crawford, Gary Francies Nick Lolies, Roy Alons and Kelvin Roberson This laboratory was inspected by representatives 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: Laboratory personnel communicate well with sample collectors and coordinate sample analyses effectively to manage workload and holding times. The facility is neat and well organized and has all the equipment necessary to perform the analyses. Benchsheets are well designed, easy to follow and concise. Laboratory personnel changed since the last inspection. All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year and the graded results were 100% acceptable. Contracted analyses are performed by Environment 1, Inc. (Certification # 10). Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the analysis of the facility's currently certified Field Parameters were provided by e-mail on June 23, 2017. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: The laboratory benchsheet was lacking instrument identification. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument Identification. Acceptable corrective action (i.e., the benchsheets were updated to include the instrument ID, were reprinted and immediately put into use) was performed by the Page 2 #5347 Perquimans County Water laboratory and approved by the auditor during the inspection. No further response is necessary for this Finding. A. Finding: The dates opened (in use) for standards and reagents are not consistently documented in the receipt log. 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. This information as well as the vendor and/or manufacturer, lot number, and expiration date must be retained for chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC 2H .0805 (g) (1). B. Finding: The preparation of Proficiency Testing (PT) Samples is not documented. Requirement: PT Samples received as ampules are diluted according to the Accredited PT Sample Provider's instructions. It is important to remember to document the preparation of PT Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a routine Compliance Sample and is added to a routine sample batch for analysis. No documentation is needed for whole volume PT Samples which require no preparation (e.g., pH), but it is recommended that the instructions be maintained. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT would satisfy the documentation requirement. Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous) C. Finding: The newly purchased meter had not had the calibration curve verification performed prior to being used to analyze samples for compliance monitoring. Requirement: Instruments are to be calibrated according to the manufacturer's calibration procedure or a standard curve verification must be performed prior to analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. D. Finding: The laboratory is not analyzing a check standard prior to analysis of samples each day compliance monitoring is performed. Requirement: Instruments are to be calibrated according to the manufacturer's calibration procedure or a standard curve verification must be performed prior to analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The laboratory was analyzing the check standard after sample analysis. E. Finding: Values less than the established reporting limit are being reported on the electronic Discharge Monitoring Report (eDMR). Page 3 #5347 Perquimans County Water 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 Total Residual Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The laboratory had last established a lower reporting limit of 10 pg/L by having analyzed that concentration when verifying the latest calibration curve. When the new calibration curve verification is performed, compliance samples with concentrations less than the lowest standard of the calibration curve must be reported as less than that value on the eDMR. For example, if the lowest standard concentration in the calibration curve verification is 10 pg/L, results would be reported as "<10 pg/L" in the daily cell of the eDMR. pH — Standard Methods, 4500 H+ B-2000 (Aqueous) F. Finding: The laboratory is not analyzing a post analysis check standard buffer when analyses are performed at multiple locations. Requirement: When performing analyses away from the certified laboratory's primary location, a post analysis calibration verification using the check standard buffer must be analyzed at the end of the run. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: An alternative to performing the post -analysis check would be to re -calibrate at Bethel WTP locations. G. Finding: Values were reported in the eDMR that exceed the method specified accuracy of 0.1 units. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit represents the limit of accuracy under normal conditions, especially for measurement of water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1 PH unit. Ref: Standard Methods, 4500 H+ B-2000. (6). Dissolved Oxygen — Hach 10360-2011 rev. 1.2 (LDO) (Aqueous) Comment: The laboratory was certified for Standard Method 4500 O G-2001 but performing analysis with a Luminescence Dissolved Oxygen (LDO) meter. The laboratory was unaware that there was that there was a separate method for LDO. North Carolina Administrative Code, 15A NCAC 2H .0804 (a) states: Municipal and Industrial Laboratories are required to obtain certification for parameters which will be reported to the State to comply with State surface water monitoring, groundwater, and pretreatment Rules. The laboratory's Certified Parameter Listing (CPL) was amended with an effective date of June 21, 2017 to reflect Hach 10360-2011 rev. 1.2 (LDO) (Aqueous). H. Finding: The laboratory is not performing a post analysis calibration verification when analyses are performed away from the certified laboratory's primary location. Requirement: When performing analyses away from the certified laboratory's primary location, a post analysis calibration verification must be analyzed at the end of the run. It is recommended that a mid -day calibration verification be performed when samples are Page 4 #5347 Perquimans County Water analyzed over an extended period of time. The calculated DO value must verify the meter reading within ±0.5 mg/L. If the meter verification does not read within ±0.5 mg/L of the theoretical DO, corrective action must be taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Comment: An alternative to performing the post -analysis check would be to perform the initial calibration at the site of Bethel WTP analysis. Temperature — Standard Methods, 2550 B-2000 (Aqueous) Recommendation: Unless greater precision is required by the permit or data receiving agency, it is recommended that all temperatures reported for compliance monitoring, be reported in whole numbers as recommended by the Precision in Discharge Monitoring Reports document found here: http://portal.ncdenr.org/c/document library/get file°?uuid=1407b370-e848-4550-9f4b- 21 a2f05b95e4&arouold=38364. Finding: The thermometer/meter readings varied more than 0.5°C from the NIST traceable thermometer reading during calibration verification. Requirement: All thermometers and temperature measuring devices used for compliance monitoring must be checked every 12 months against a NIST traceable temperature measuring device and the process documented. To check a thermometer or temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST traceable temperature measuring device and record the two temperatures. The verification must be performed in the approximate range of the sample temperatures measured. The thermometer/meter readings must be less than or equal to 0.5°C from the NIST traceable temperature measuring device reading. If it is not, the thermometer/meter may not be used for compliance monitoring. The calibration verification documentation must include the serial number of the thermometer/meter being checked and the NIST traceable temperature measuring device that was used in the comparison. Document the verification data and keep on file. (NOTE: Other Certified laboratories may provide assistance in meeting this requirement. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. J. Finding: The calibration verification documentation did not include the serial number of the thermometer/meter being checked and the NIST traceable temperature measuring device that was used in the comparison. Requirement: All thermometers and temperature measuring devices used for compliance monitoring must be checked every 12 months against a NIST traceable temperature measuring device and the process documented. To check a thermometer or temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST traceable temperature measuring device and record the two temperatures. The verification must be performed in the approximate range of the sample temperatures measured. The thermometer/meter readings must be less than or equal to 0.5°C from the NIST traceable temperature measuring device reading. If it is not, the thermometer/meter may not be used for compliance monitoring. The calibration verification documentation must include the serial number of the thermometer/meter being checked and the NIST traceable temperature measuring device that was used in the comparison. Document the verification data and keep on file. (NOTE: Other Certified laboratories may provide assistance in meeting this requirement). Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Page 5 #5347 Perquimans County Water IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory bench sheets, logbooks, etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water Resources. Data were reviewed for Perquimans County Water (NPDES permit #'s NC0051373 & NC0068861) for October 2016 and January to February 2017. No transcription errors were observed. The facility appears to be doing a good job of accurately transcribing data. V. CONCLUSIONS: Correcting the above -cited Findings and implementing the Recommendations will help this laboratory 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 and include supporting documentation and implementation dates for each corrective action. Report prepared by: Tom Halvosa Date: June 28, 2017 Report reviewed by: Anna Ostendorff Date: July 6, 2017 LU w 2 0 � � § z \ \ ) \ / 0 \ w ƒ z / Go)/ LLJ\ \ \ j g o E o + z/ m 2[/ j G CD 8 o o to» w) a k/ §Wt0w ■ (@