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HomeMy WebLinkAbout#110_2016_0315_NJ_FINAL INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 110 Laboratory Name: Goldsboro WRF Inspection Type: Municipal Maintenance Inspector Name(s): Nick Jones Inspection Date: March 15 & 16, 2016 Date Report Completed: April 1, 2016 Date Forwarded to Reviewer: April 1, 2016 Reviewed by: Jason Smith Date Review Completed: April 6, 2016 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Todd Crawford Date Received: April 11, 2016 Date Forwarded Admin: April 19, 2016 Date Mailed: _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Goldsboro WRF NPDES PERMIT #: NC0023949 ADDRESS: P.O. Drawer A Goldsboro, NC 27533 CERTIFICATE #: 110 DATE OF INSPECTION: March 15 & 16, 2016 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Nick Jones LOCAL PERSON(S) CONTACTED: Kathy Hill I. INTRODUCTION: This laboratory was inspected by a representative 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: Proficiency Testing (PT) samples for the 2016 proficiency testing calendar year have not yet been analyzed. The laboratory is reminded that these results must be submitted to this office directly from the vendor by September 30, 2016. The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedures (SOP) document(s) in advance of the inspection. These documents were reviewed and editorial and substantive revision requirements and recommendations were made by this program outside of this formal report process. Although subsequent revisions were not requested to be submitted, they must be completed within 1 year. The laboratory is reminded that all changes made in response to the Findings, Recommendations or Comments listed in this report must be incorporated in the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). The laboratory must ensure the method is being performed as stated, references to methods are accurate, and the QA and/or SOP document(s) is/are in agreement with approved practice and regulatory requirements. In some instances, the laboratory may need to create a SOP to document how new functions or policies will be implemented. Contracted analyses are performed by Environment 1, Inc. (Certification #10), Pace Analytical Services, Inc. - Huntersville (Certification #12), Environmental Testing Solutions, Inc. (Certification #600) and Katahdin Analytical Services, LLC. (Certification #341). Page 2 #110 Goldsboro WRF III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Proficiency Testing Comment: The laboratory did not have a Standard Operating Procedure (SOP) for Proficiency Testing (PT) samples. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) states: 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. Acceptable corrective action (i.e., a SOP for PT samples was written between day 1 and 2 of the inspection with an implementation date of 3/16/2016) was performed on 3/16/16 and observed by the inspector to be adequate. No further response is necessary for this Finding. Chlorine, Total Residual – Hach 10014 ULR (Aqueous) Dissolved Oxygen – Hach 10360 2011, Rev. 1.2 (LDO) (Aqueous) Conductivity – Standard Methods, 2510 B-1997 (Aqueous) pH – Standard Methods, 4500 H+B-2000 (Aqueous) Temperature – Standard Methods, 2550 B-2000 (Aqueous) Comment: The benchsheets did not document the instrument identification. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, The NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen, The NC WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity), The NC WW/GW LC Approved Procedure for the Analysis of Temperature and The NC WW/GW LC Approved Procedure for the Analysis of pH documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. Acceptable corrective action (i.e., revised benchsheets including the instrument identification with an implementation date of 3/16/2016) was performed on 3/15/2016 and observed by the inspector to be adequate. No further response is necessary for this Finding. Dissolved Oxygen – Hach 10360 2011, Rev. 1.2 (LDO) (Aqueous) Conductivity – Standard Methods, 2510 B-1997 (Aqueous) pH – Standard Methods, 4500 H+B-2000 (Aqueous) Comment: The benchsheet did not document the units of measure for the calibration. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (H) states: 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. Acceptable corrective action (i.e., revised benchsheets including units of measure for the calibration with an implementation date of 3/16/2016) was performed on 3/15/2016 and observed by the inspector to be adequate. No further response is necessary for this Finding. Conductivity – Standard Methods, 2510 B-1997 (Aqueous) Comment: The lab was not rinsing the probe with three portions of 0.01M KCl solution before the fourth portion is used to calibrate the instrument. Standard Methods, 2510 B-1997. (4) (a) states: Rinse conductivity cell with at least three portions of 0.01M KCl solution. Notification of acceptable corrective action (i.e., a statement that the probe is rinsed with three portions of 0.01M KCl prior to determining the cell constant with an implementation date of 3/17/2016) was received by email on 4/1/2016. No further response is necessary for this Finding. Page 3 #110 Goldsboro WRF Comment: The lab was not rinsing the probe with at least one portion of sample before using the final portion for sample analysis. Standard Methods, 2510 B-1997. (4) (b) states: Thoroughly rinse cell with one or more portions of sample. Adjust temperature of a final portion to about 25°C. Measure sample resistance or conductivity and note temperature to ± 0.1°C. Notification of acceptable corrective action (i.e., a statement that the probe is rinsed with at least one portion of sample prior to sample analysis with an implementation date of 3/17/2016) was received by email on 4/1/2016. No further response is necessary for this Finding. Residue, Total – Standard Methods, 2540 B-1997 (Aqueous) Comment: The lab was not initially drying samples at 98°C to prevent spattering. Standard Methods, 2540 B-1997. (3) (b) states: When evaporating in a drying oven, lower temperature to approximately 2°C below boiling to prevent splattering. Notification of acceptable corrective action (i.e., a statement that samples are initially dried at 98°C to prevent spattering with an implementation date of 3/15/2016) was received by email on 4/1/2016. No further response is necessary for this Finding. Nitrogen, Ammonia – Standard Methods, 4500 NH3 D-1997 (Aqueous) Nitrogen, NO3+NO2 – Standard Methods, 4500 NO3 E-2000 (Aqueous) Nitrogen, Total Kjeldahl – Standard Methods, 4500 Norg C-1997 (Standard Methods, 4500 NH3 C-1997) (Aqueous) Comment: The lab was not adding preservative to reagent blanks and laboratory fortified blanks. Standard Methods, 1020 B-2011. (5) states: A reagent blank (method blank) consists of reagent water (see section 1080) and all reagents (including preservatives) that normally are in contact with a sample during the entire analytical procedure. The reagent blank is used to determine whether, and how much, reagents and the preparative analytical steps contribute to measurement uncertainty. Standard Methods, 1020 B-2011. (6) states: A laboratory fortified blank [laboratory control standard (LCS)] is a reagent water sample (with associated preservatives) to which a known concentration of the analyte(s) of interest has been added. An LFB is used to evaluate laboratory performance and analyte recovery in a blank matrix. Notification of acceptable corrective action (i.e., a statement that the reagent blanks and laboratory fortified blanks are being preserved) was received by email on 4/1/2016 with an implementation dates of 3/15/2016 for NO3+NO2, 3/21/2016 for Ammonia and 3/22/2016 for Total Kjeldahl Nitrogen (TKN). No further response is necessary for this Finding. Comment: The lab was not analyzing Laboratory Fortified Matrix Duplicates (LFMD). Standard Methods, 4020 B-2009, Rev. 2011, Table 4020: I and (2) (g) states: When appropriate for the analyte (Table 4020:I), include at least one LFM/LFMD daily or with each batch of 20 or fewer samples. Notification of acceptable corrective action (i.e., a statement that the lab will analyze LFMDs at the required frequency with implementation dates of 3/15/2016 for NO3+NO2, 3/21/2016 for Ammonia and 3/22/2016 for TKN) was received by email on 4/1/2016. No further response is necessary for this Finding. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Resources. Data were reviewed for Goldsboro WRF (NPDES permit # NC0023949) for August, September and October 2015. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. Page 4 #110 Goldsboro WRF V. CONCLUSIONS: All Findings noted during the inspection were adequately addressed prior to the completion of this report. The inspector would like to thank the staff for its assistance during the inspection and data review process. No response is required. Report prepared by: Nick Jones Date: April 1, 2016 Report reviewed by: Jason Smith Date: April 6, 2016