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HomeMy WebLinkAbout#5656_2016_0621_JS_FINAL• ' •Zia' • To be attached to all inspection reports in-house only. Laboratory Cert. #: Laboratory Name: Inspection Type: Inspector Name(s): Inspection Date: Date Report Completed Date Forwarded to Reviewer: Reviewed by: Date Review Completed: Cover Letter to use: Unit Supervisor/Chemist III: Date Received: Date Forwarded to Admin: Date Mailed: Special Mailing Instructions: 5656 Town of Granite Falls WWTP Field Initial Jason Smith June 21, 2016 July 8, 2016 July 8. 2016 Beth Swanson July 11, 2016 ❑ Insp. Initial ® Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected ❑ Insp. Reg. Delay Todd Crawford July 11. 2016 July 18, 2016 July 21, 2016 Water Resources ENVIRONMENTAL QUALITY July 21, 2016 5656 Mr. Chris Graybeal Town of Granite Falls WWTP Post Office Box Drawer 10 Granite Falls, NC 28630 PAT MCCRORY DONALD R. VAN DER VAART P S. JAY ZIMMERMAN Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Graybeal: Enclosed is a report for the inspection performed on June 21, 2016 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. 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. 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: Dana Satterwhite, Jason Smith :� . ADDRESS: CERTIFICATE : DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: Town of Granite Falls WWTP 60 Meandering Way Granite Falls, NC 28630 5656 June 21, 2016 Field Initial Jason Smith Chris Graybeal and Tamara Coulter 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: Although this is considered an initial inspection for Field certification, the laboratory was previously certified as a Non -Field laboratory. The change in certification status was made effective June 30, 2014. The facility has all the equipment necessary to perform the analyses. The laboratory was in the process of revising their current benchsheet to meet Certification requirements at the time of the inspection. Implementation of the revised benchsheet will address several of the Findings listed below. All required Proficiency Testing (PT) samples for the 2016 PT calendar year have not yet been analyzed. The laboratory is reminded that results must be received by this office directly from the vendor by September 30, 2016. Contracted analyses are performed by Water Tech Labs, Inc. (Certification #50). Current Quality Assurance Policies for Field Laboratories and Approved Procedure documents for the analysis of the facility's currently certified methods were provided at the time of the inspection. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: The laboratory currently documents the meter model on the benchsheet. It is recommended that the serial number of the meter be documented as well. This would prevent any confusion if the meter is replaced by the same model. Page 2 #5656 Town of Granite Falls WWTP A. Finding: The preparation of Total Residual Chlorine (TRC) standards is not documented in such a way as to provide traceability from preparation to analysis. Requirement: 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 chemicals, reagents, standards and consumables used for a period of five years. Ref: Quality Assurance Policies for Field Laboratories. Quality Control B. Finding: The automatic pipettor has not been calibrated. Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at least every twelve months and documented. Each liquid -dispensing device must meet the manufacturer's statement of accuracy. For variable volume devices used at more than one setting, check the accuracy at the maximum, middle and minimum values. Testing at more than three volumes is optional. When a device capable of variable settings is dedicated to dispense a single specific volume, calibration is required at that setting only. Ref: Quality Assurance Policies for Field Laboratories. Comment: A spreadsheet was provided by email for calibration following the inspection. The laboratory may also choose to have their contract laboratory perform the calibration. Proficiency Testing C. Finding: The preparation of PT samples is not documented. Requirement: PT samples received as ampules must be diluted according to the PT provider's instructions. The preparation of PT samples must be documented in a traceable log or other traceable format. The diluted PT sample becomes a routine environmental sample and is added to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT would satisfy the documentation requirement. The pH and Conductivity PT samples do not require preparation documentation since they are analyzed as whole volume samples. D. Finding: The laboratory is not analyzing PT samples in the same manner as compliance samples. Requirement: All PT samples are to be analyzed and the results reported in a manner consistent with the routine analysis and reporting requirements of compliance samples and any other samples analyzed according to the requirements of 15A NCAC 2H .0800, Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: The laboratory's common practice was to analyze a known standard along with the PT sample as additional quality control. Since this is not performed with all environmental samples, it is considered additional quality control. However, known samples Page 3 #5656 Town of Granite Falls WWTP are recommended when analyzing remedial PT samples as part of the troubleshooting and corrective action process. E. Finding: The laboratory is not documenting PT sample analyses in the same manner as environmental samples. Requirement: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2. Comment: The analysis of PT samples is designed to evaluate the entire process used to routinely report environmental analytical results; therefore, PT samples must be analyzed and the process documented in the same manner as environmental samples (i.e., on the daily benchsheet after acceptable calibration). Dissolved Oxygen — Standard Methods, 4500 O G-2000 Comment: The laboratory is using a Luminescent Dissolved Oxygen (LDO) meter, but was not aware that NC WW/GW LC grants certification for this technology based upon Hach Method 10360 or ASTM Method D 888-09 C. Standard Methods 4500 O G-2000 is specifically for analysis by membrane electrode. An amendment to the application form was emailed to the laboratory on June 22, 2016. Please complete and submit the amendment request to update the laboratory's Certified Parameter List (CPL). F. Finding: The date and time of sample collection are not documented. Requirement: Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1). Comment: The benchsheet in use did not include this information; however, the draft benchsheet reviewed during the inspection did. Total Residual Chlorine — Standard Methods, 4500 CI G-2000 Comment: The laboratory is currently preparing standards from Potassium Permanganate daily for meter verification. As discussed during the inspection, gel standards are allowed to be used for daily meter verification. Further information may be found in the NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, G. Finding: The time of sample collection is not documented. Requirement: Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1). Comment: The benchsheet in use did not include this information; however, the draft benchsheet reviewed during the inspection did. H. Finding: Curve verification has not been performed every twelve months. Requirement: Most field photometric instruments have factory -set calibration programs, which when selected in combination with the optimum wavelength for a particular analysis, give a direct readout in concentration. These factory -set calibration programs are acceptable for quantitation, but due to possible analyst error, variation in sample or standard preparation, variation in reagents or malfunction of the instrument, the factory -set Page 4 #5656 Town of Granite Falls WWTP calibration must be verified at least every 12 months. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The last curve verification was performed on January 24, 2013. Finding: The calibration curve verification does not bracket the concentration of the annual PT samples. Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The most recent curve verification performed only verified the meter up to 60 pg/L. Recommendation: It is recommended that the laboratory verify the curve at 20, 40, 50, 200, and 400 pg/L. This will verify the analytical range used to measure PT samples, gel standards, as well as environmental samples. pH — Standard Methods, 4500 H+ B-2000 J. Finding: The sample collection date is not documented. Requirement: Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. Ref: 15A NCAC 2H .0805 (g) (1). Comment: The benchsheet in use did not include this information; however, the draft benchsheet reviewed during the inspection did. Conductivity —Standard Methods, 2510 B-1997 K. Finding: Verification of the Automatic Temperature Compensation (ATC) did not bracket sample temperatures. Requirement: The Automatic Temperature Compensator (ATC) must be verified prior to initial use and annually (i.e., 12 months) thereafter at two temperatures by analyzing a standard or sample at 25°C (i.e., the temperature to which conductivity values are reported) and a temperature(s) that brackets the temperature ranges of the environmental samples routinely analyzed. This may require the analysis of a' third temperature reading that is > 25°C. Ref: NC WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity). Comment: The meter was verified at 15 and 25 °C. Sample temperatures are often outside of this range in the winter and summer. Comment: Anticipated temperatures can be obtained from a review of the Discharge Monitoring Reports (DMRs) from the peak summer and winter months. Historical data should provide a reasonably accurate estimation of ranges that will bracket the expected sample temperatures. 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 Page 5 #5656 Town of Granite Falls WWTP Carolina Division of Water Resources. Data were reviewed for the Town of Granite Falls WWTP (NPDES permit # NC0021890) for July, September and November 2015. 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 Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for their 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: Jason Smith Date: July 8, 2016 Report reviewed by: Beth Swanson Date: July 11, 2016