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HomeMy WebLinkAbout#5223_06_2012_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5223 Laboratory Name: Franklin Water Treatment Plant Inspection Type: Field Maintenance Inspector Name(s): Chet Whiting Inspection Date: June 28, 2011 Date Report Completed: July 6, 2012 Date Forwarded to Reviewer: July 6, 2012 Reviewed by: Todd Crawford Date Review Completed: July 13, 2012 Cover Letter to use: _ Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _Corrected Unit Supervisor: Gary Francies Date Received: 7/16/2012 Date Forwarded to Linda: 7/24/2012 Date Mailed: q L45 f 1 A jRi NZ -VA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor 5223 Mr. Rusty Campbell Franklin WTP 5200 Brookshire Blvd. Charlotte, NC 28216 Charles Wakild, P. E. Director July 24, 2012 Dee Freeman Secretary Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Campbell: Enclosed is a report for the inspection performed on June 28, 2012 by Chet Whiting. 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. 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 us at 828-296-4677. Sincerely, s Gary Francies Certification Unit Supervisor Laboratory Section Enclosure Cc: Master File Chet Whiting DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445 Phone: 919-733-3908 \ FAX: 919-733-6241 Internet: www.dwglab.org One Norh.Carolina Naturally An Equal Opportunity \ Affirmative Action Employer LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: INTRODUCTION: On -Site Inspection Report Franklin WTP NCO084549 5200 Brookshire Blvd. Charlotte, NC 28216 5223 June 28, 2012 Field Maintenance Chet Whiting Rusty Campbell This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. II. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. The requirements associated with Findings A, B, C and D are new policies that have been implemented by our program since the last inspection. III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation Comment: No instances were observed, however the laboratory was not aware that any data that does not meet all quality control requirements is required to be qualified on the Discharge Monitoring Report, including contract laborato rrl data. The Quality Assurance Policies for Field Laboratories document states: When quality control (QC) failures occur, the laboratory must attempt to determine the source of the problem and must apply corrective action. Part of the corrective action is notification to the end user. If data qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the intended purposes. It is the responsibility of the laboratory to provide the client or end -user of the data with sufficient information to determine the usability of the qualified data. Where applicable, a notation must be made on the Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet attached to the DMR form, when any required sample quality control does not meet specified criteria and another sample cannot be obtained. A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as, documentation of standards prepared in the laboratory. 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. 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 Page 2 #5223 Franklin WTP 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. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Comment: Specifically document information for pH buffers, DPD reagent, and the standard material used to prepare the Total Residual Chlorine curve verification standards. B. Finding: The preparation of Proficiency Testing (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: For this facility, the requirement currently applies only to Total Residual Chlorine (TRC) since pH samples require no preparation. C. Finding: Proficiency testing (PT) samples are not documented 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. Quality Control D. Finding: Auto-pipettors are not calibrated annually (every twelve months). Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto- pipettors, bottle -top dispensers, etc.) 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 copy of a procedure for the calibration of mechanical volumetric liquid -dispensing devices is attached to this report. Comment: The testing of auto-pipettors may be contracted out to a vendor or may be performed by another laboratory. Copies of documentation must be on file and available for review for a period of five years. pH — Standard Methods, 18'h Edition, 4500 H+ B Temperature - Standard Methods, 18$h Edition, 2550 B Comment: Units of measure and sample identification were not documented. The North Carolina Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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. Acceptable corrective action (i.e., a cover statement Page 3 #5223 Franklin WTP specifying that pH samples results are in Units and temperature results are in degrees C 1) was added to the log book during the inspection. No further response is necessary for this finding. Comment: Sample collection and analysis times are documented but need to be more clearly labeled. Temperature - Standard Methods, 181h Edition, 2550 B E. Finding: The thermometer used for temperature analysis was not checked every 12 months against a NIST certified or MIST traceable thermometer and the process documented. Requirement: All thermometers and temperature measuring devices must be checked every 12 months against a NIST certified or NIST traceable thermometer and the process documented. To check a thermometer or the temperature sensor of a meter, read the temperature of the thermometer/meter against a NIST certified or NIST traceable thermometer and record the two temperatures. The thermometer/meter readings must be less than or equal to 10C from the NIST certified or NIST traceable thermometer reading. (NC Wastewater/Groundwater Laboratory Certification Policy). The documentation must include the serial number of the NIST certified thermometer or NIST traceable thermometer that was used in the comparison. Also document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. (NOTE: Other certified laboratories may provide assistance in meeting this requirement.) Ref: Technical Assistance for Field Analysis of Temperature. Comment: The temperature results are not required for permit compliance monitoring purposes. The results are used to document a temperature drop during sample shipment as part of sample preservation, however they are reported on the DMRs. Recommendation: Since temperature is not on the facility permit and the results are not used to monitor the characteristics of the effluent it is recommended that the values not be reported on the DMR. IV. 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 for NPDES# NC0084549 was reviewed for March, April and May, 2012. 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: Chet Whiting Date: July 6, 2012 Report reviewed by: Todd Crawford Date: July 13, 2012 Calibration of Mechanical Volumetric Liquid -Dispensing Devices Procedure A laboratory may use the following method for the gravimetric determination of measurement error of mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.) used to dispense volumes greater than or equal to 100 NI. Apparatus and Equipment Weighing vessel (of sufficient capacity to hold all volumes dispensed for the test and a 3:1 height -to - diameter ratio is recommended to minimize evaporation) Reagent water (e.g., distilled or deionized water) Analytical balance (accurate to 0.0001 g for 100 pl to 10 ml, and accurate to 1 mg for 10 ml to 200 ml dispensed volumes) Calibrated thermometer (graduated, at a minimum, in 0.5 °C increments) Documentation Requirements Date Analyst's signature or initials Device identification (if there is no unique identification such as serial number, assign a laboratory identification) Temperature of the reagent water Nominal or test volume Weights of dispensed volumes Procedure 1. Allow apparatus and reagent water to equilibrate to room temperature. 2. Check the calibration of the balance. 3. Wet the liquid -dispensing device and lubricate the piston insuring smooth operation by pipetting several volumes to waste. 4. Weigh the vessel and tare the balance. 5. Dispense a minimum of five aliquots of water into the vessel, weighing and recording the mass for each replicate. 6. Calculate the following: m = mean mass = total of individual weight measurements total number of measurements Z = Z correction factor obtained from Table 1 using the temperature of the test liquid and current barometric pressure. V = volume equivalent (or corrected volume) of mass measured = m x Z RE = relative error (%) = Vm - Volx 100 Vo where: Vm = corrected mean volume = total of corrected volumes total number of dispensed volumes Vo = nominal or test volume S = standard deviation = For each replicate, subtract the mean volume from the corrected volume, then square the value. Sum the squared values of all replicates, and then divide the sum by n-1 (the number of measurements minus 1). Take the square root of this value to get the standard deviation. CV = coefficient of variation (%) = s x 100 Vm To simplify this process, spreadsheets for calculating and documenting the relative error and coefficient of variation can be found on the NC Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) website at http://h2o.enr.state.nc.us/lab/download.htm. The Relative Error (a measure of accuracy) and Coefficient of Variation (a measure of precision) must not be greater than the manufacturer's specifications. If the results are greater than the manufacturer's specification, repeat the procedure. If the results remain greater, follow the manufacturer's instructions for maintenance and adjustment and repeat the procedure. If repeated calibration attempts do not yield results within the manufacturer's specifications, the liquid -dispensing device must be repaired or replaced. Note: Microliter pipettors may need to be tested under more rigorously controlled conditions or sent to a calibration service for testing. Since most analytical balances used in environmental laboratories read to only four decimal places, it may be necessary, when checking microliter pipettors (less than 1000 pl), to include the weight of the weighing vessel in each replicate and subtract it and subsequent aliquots out manually in order to have a measurable mass for the purpose of this verification. Contact your auditor if you have questions. Table 1. Z Correction Factor Table. Temperature Air pressure, kPa (mbar) °C 80 (800) 85 (850) 90 (900) 95 (950) 100 (1000) 101.3 (1013) 105 (1050) 15.0 1.0017 1.0018 1.0019 1.0019 1.0020 ` 1.0020 1.0020 15.5 1.0018 1.0019 1.0019 1.0020 1.0020 1.0020 1.0021 16.0 1.0019 1.0020 1.0020 1.0021 1.0021 1.0021 1.0022 16.5 1.0020 1.0020 1.0021 1.0021 1.0022 1.0022 1.0022 17.0 1.0021 1.0021 1.0022 1.0022 1.0023 1.0023 1.0023 17.5 1.0022 1.0022 1.0023 1.0023 1.0024 1.0024 1.0024 18.0 10022 1.0023 1.0023 1.0024 1.0025 1.0025 " 1.0025 18.5 1.0023 1.0024 1.0024 1.0025 1.0025 1.0026 1.0026 19.0 ' 1.0024 1.0025 1.0025 1.0026 1.0026 " 1.0027 ' 1.0027 19.5 1.0025 1.0026 1.0026 1.0027 1.0027 1.0028 1.0028 20.0 ' 10026 1.0027 1.0027 1.0028.- 1.0028' 1.0029 1.0029 20.5 1.0027 1.0028 1.0028 1.0029 1.0029 1.0030 1.0030 21.0 10028 1.0029 1.0029 1.0030: 1.0031 1.0031 1.0031 21.5 1.0030 1.0030 1.0031 1.0031 1.0032 1.0032 1.0032 22.0 1.0031 1.0031 1.0032 1.0032 1.0033:' 1.0033 1.0033 22.5 1.0032 1.0032 1.0033 1.0033 1.0034 1.0034 1.0034 23.0 1.0033 1.0033 1.0034 1.0034 1.0035- 1.0035 1.0036 23.5 1.0034 1.0035 1.0035 1.0036 1.0036 1.0036 1.0037 24.0 1.0035 1.0036 1.0036 1.0037 1.0037 ° 1.0038 1.0038 24.5 1.0037 1.0037 1.0038 1.0038 1.0039 1.0039 1.0039 25.0 1.0038 1.0038 1.0039 1.0039 1.0040 1.0040 1.0040 25.5 1.0039 1.0040 1.0040 1.0041 1.0041 1.0041 1.0042 26.0 > 10040 1.0041 1.0041 10042 1.0042 1.0043 1.0043 26.5 1.0042 1.0042 1.0043 1.0043 1.0044 1.0044 1.0044 27.0 10043 1.0044 1.0044 1.0045 -1.0045 1.0045 1.0046 27.5 1.0045 1.0045 1.0046 1.0046 1.0047 1.0047 1.0047 28.0 1.0046 1.0046 1.0047 1.0047'' 1.0048 1.0048 1.0048 28.5 1.0047 1.0048 1.0048 1.0049 1.0049 1.0050 1.0050 29.0 1.0049 1.0049 1.0050 1.0050 1.0051 1.0051 1.0051 29.5 1.0050 1.0051 1.0051 1.0052 1.0052 1.0052 1.0053 30.0 1.0052 1 1.0052 1.0053 1.0053 1.0054 1.0054 '' 1.0054 Z correction factors are for distilled water as a function of liquid test temperature and air pressure. Z values are in microliters per milligram. Reprinted from ISO 8655-6:2002(E). If your laboratory does not have a mercury barometer, the true local barometric pressure for locations throughout North Carolina may be obtained from the North Carolina State University, State Climate Office of North Carolina website at http://www.nc-climate.ncsu.edu/.