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HomeMy WebLinkAbout#5403_2012 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5403 Laboratory Name: Rock Creek Environmental, Inc. Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: May 9, 2012 Date Report Completed: May 14, 2012 Date Forwarded to Reviewer: May 14, 2012 Reviewed by: Tonja Springer Date Review Completed: May 18, 2012 Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP __ Corrected Unit Supervisor: Dana Satterwhite Date Received: May 18, 2012 Date Forwarded to Linda: May 24, 2012 Date Mailed: May 24, 2012 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Rock Creek Environmental, Inc. NPDES Permit #: NC0062294 ADDRESS: 308 Country Club Blvd. Jacksonville, NC 28540 CERTIFICATE #: 5403 DATE OF INSPECTION: May 9, 2012 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Joshua Johnson I. INTRODUCTION: 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. The system for traceability of consumables and standards needs to be increased; however all other requested documentation was well organized and quickly made available. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2011 proficiency testing calendar year and the graded results were 100% acceptable. Please be reminded that acceptable PT results must be received in our office before September 30, 2012 in order to satisfy the 2012 PT requirements. It was determined during the inspection that the facility had been incorrectly classified in our database as Field Commercial. The facility has been re-classified as Field Municipal. Contracted analyses are performed by Beacham Laboratories (Certification #1). The requirements associated with Findings A, B and C are new policies that have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Recommendation: Analytical benchsheets were hard to follow. It was recommended that the benchsheet be redesigned to be more easily discerned. A. Finding: Proficiency Testing (PT) samples were not documented in the same manner as routine environmental samples. Page 2 #5403 Rock Creek Environmental, Inc. Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Comment: Copies of PT documentation (submitted evaluation forms) were available. B. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents 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 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. C. 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. D. Finding: Data that does not meet all quality control requirements is not qualified on the Discharge Monitoring Report (DMR). Requirement: 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. Ref: Quality Assurance Policies for Field Laboratories. Comment: The laboratory was not transcribing data qualifiers from the contract laboratory reports to the DMR. For example, the contract lab report noted that the Total suspended Solids sample collected on January 12, 2012 was analyzed outside its holding time due to a laboratory mistake. It was also stated that the reporting limit for that sample was elevated due to limited sample volume. None of this information was transferred to the DMR. E. Finding: Neither the analyst’s signature nor initials appear on the benchsheet. Requirement: 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 Page 3 #5403 Rock Creek Environmental, Inc. time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). pH – Standard Methods, 18th Edition, 4500 H+ B F. Finding: The units of measure are not documented on the benchsheet. Requirement: 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. Ref: 15A NCAC 2H .0805 (g) (1). G. Finding: Data values are reported on the Discharge Monitoring Report to 0.01 S.U. not 0.1 S.U. as required by the method. Requirement: A variance of ± 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, 18th Edition, 4500 H+ B. (6). H. Finding: The meter calibration is not verified with a third calibration standard prior to sample analysis. Requirement: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers’ recommendations for the calibration of the meter each analysis day. The meter must be calibrated with at least two buffers. In addition to the calibration standards, the meter must be verified with a third calibration standard. The calibration and check standard buffer must bracket the range of the samples being analyzed. Ref: Technical Assistance for Field Analysis of pH. Comment: A calibration check standard was being analyzed after sample analyses. Temperature – Standard Methods, 18th Edition, 2550 B Recommendation: It is recommended that the benchsheet indicate that the DO meter is used to obtain reported temperature values and the meter be identified with its serial number. Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G I. Finding: Values below the established reporting limit of 10µg/L are being reported on the DMR. Requirement: When performing the annual calibration curve verification, one of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. Example: If the laboratory chooses to have a lower reporting limit of 10 μg/L for residual chlorine, you must analyze at least 10 µg/L or lower standard and report lower concentrations as < 10 µg/L or < the concentration of the chosen standard. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. Comment: A value of 8 μg/L was reported on the DMR for the sample collected on 03/14/12. Page 4 #5403 Rock Creek Environmental, Inc. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for January, February and March, 2012. The following errors were noted: Date Parameter Location Value on Benchsheet or *Contract Lab Report Value on DMR 01/11/12 Fecal Coliform Effluent * < 1 col/100 ml 1 col/100 ml 01/24/12 Fecal Coliform Effluent * < 1 col/100 ml 1 col/100 ml 01/31/12 pH Effluent 7.60 S. U. No Data 02/07/12 BOD Effluent * > 22.1 mg/L 22.1 mg/L 02/15/12 pH Effluent 8.27 S. U. No Data 03/05/12 Ammonia Effluent * < 0.1 mg/L 0.1000 mg/L 03/14/12 pH Effluent 8.42 S. U. No Data 03/19/12 Fecal Coliform Effluent * < 1 col/100 ml 1 col/100 ml 03/26/12 DO Effluent 8.50 mg/L 6.44 mg/L 03/28/12 pH Effluent 8.79 S. U. No Data Instances when no pH data was recorded on the DMR were due to the fact that the required monitoring frequency had already been met for the month. The analyst was unaware of the reporting requirement set forth in 15A NCAC 2B .0506 (b) (3) (J), which states that the results of all tests on the characteristics of the effluent, including but not limited to NPDES Permit Monitoring Requirements, shall be reported on monthly report forms. DWQ’s guidance document on the treatment of a “less than” value in DMR reporting was also provided during the inspection. In order to avoid questions of legality, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of this report will be forwarded to the Regional Office. 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: Todd Crawford Date: May 14, 2012 Report reviewed by: Tonja Springer Date: May 18, 2012 Page 5 #5403 Rock Creek Environmental, Inc.