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HomeMy WebLinkAbout#5598_11_2012_FINALi-WYWA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor 5598 Mr. Kevin Mullineaux Hydro Services and Consulting P. O. Box 317 Newport, NC 28532 Charles Wakild, P. E. Director December 21, 2012 Dee Freeman Secretary Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Mullineaux: Enclosed is a report for the inspection performed on November 7, 2012 by Nick Jones. I apologize for the delay in getting this report to you. 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, Gary Francies Certification Unit Supervisor Laboratory Section Enclosure cc: Master File Nick Jones DENR DWQ 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 An Equal Opportunity \ Affirmative Action Employer One NortbCarolina Naturally LABORATORY NAME: NPDES PERMIT #: WATER QUALITY PERMIT #: ADDRESS: CERTIFICATE #: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: I. INTRODUCTION: • • •• Hydro Services and Consulting NC0074837 WQ0003067 P.O. Box 317 Newport, NC 28532 5598 November 7, 2012 Field Initial Nick Jones Kevin Mullineaux 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. H. GENERAL COMMENTS: The facility has all the equipment n0ecessary to perform the analyses. Contracted analyses are performed by Environment 1, Inc. (Certification, #10). Current quality assurance policies for Field laboratories and the approved procedures for the analysis of the facility's currently certified parameters were provided at the time of the inspection as well as example benchsheets and an example traceability log. The aforementioned approved procedures have undergone revision since the inspection and include new requirements. Current versions will be enclosed with the laboratory's 2013 certificate. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: General Laboratory Comment: The laboratory was unable to supply all of the documentation requested in a legible format. The North Carolina Administrative Code, 15A NCAC 02H .0807 (a) states: A laboratory may be decertified for any or all parameters for up to one year for any of the following infractions: (10) Failing to supply analytical data requested by the State Page 2 #5598 Hydro Services and Consulting Laboratory. Notification of acceptable corrective action (i.e., submission of one out of three requested months of data) was received by email on 11/30/12. No further response is necessary for this finding. Quality Control A. Finding: The laboratory has not analyzed Proficiency Samples this year for pH or Total Residual Chlorine. Requirement: A laboratory may be decertified for any or all parameters for up to one year for any of the following infractions; Failing to report analysis of required annual performance evaluation samples submitted by EPA approved vendor within the specified time limit. Ref: 15A NCAC 02H .0807 (a) (8). Please submit these results with the response to this report. Comment: The laboratory was informed that missing the September 30, 2012 deadline is considered a first miss. They were also given a remedial Proficiency Testing sample deadline of December 31, 2012. B. Finding: The laboratory is not documenting Proficiency Testing (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. C. Finding: Error corrections are not performed properly. Requirement: All .documentation errors must be corrected by drawing a single line through the error so that the original entry remains legible. Entries shall not be obliterated by erasures or markings. Wite-Out®, correction tape or similar products designed to obliterate documentation are not to be used. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for Field Laboratories. D. 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. This information 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: Page 3 #5598 Hydro Services and Consulting Quality Assurance Policies for Field Laboratories. Please submit a copy of this log with the response to this report. Temperature — Standard Methods, 2550 B-2000 E. Finding: The temperature sensor on the Dissolved Oxygen (DO) meter used to obtain reported temperature values has not been checked against a NIST traceable thermometer. Requirement: Thermometers and temperature measuring devices, used to measure temperature for compliance monitoring, must be checked every 12 months against a NIST traceable thermometer. The thermometer/meter readings must be less than or equal to 10C from the NIST traceable thermometer reading. The documentation must include the serial number of the NIST traceable thermometer that was used in the comparison. Document any correction that applies on both the thermometer/meter and on a separate sheet to be filed. Ref: Technical Assistance for Field Analysis of Temperature. Please submit a copy with the response to this report. Comment: The date of the last NIST thermometer check was 10/30/2011. pH — Standard Methods, 4500-H+ B-2000 Dissolved Oxygen — Standard Methods, 4500-0 G-2001 Total Residual Chlorine — Standard Methods, 4500-CI G-2000 Temperature — Standard Methods, 2550 B-2000 F. Finding: The laboratory is not documenting collection and analysis times. 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 02H .0805 (g) (1). Comment: In some situations the collection and analysis times will be the same. pH — Standard Methods, 4500-H+ B-2000 Dissolved Oxygen — Standard Methods, 4500-0 G-2001 Total Residual Chlorine — Standard Methods, 4500-CI G-2000 G. Finding: The laboratory is not documenting meter calibration time. Requirement: The following criteria must be documented whenever sample analysis is performed: Time of calibration. Ref. NC WW/GW LC Approved Procedure for Field Analysis of pH, NC WW/GW LC Approved Procedure for Field Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for Field Analysis of Dissolved Oxygen. Page 4 #5598 Hydro Services and Consulting PH — Standard Methods, 4500-H+ B-2000 Total Residual Chlorine — Standard Methods, 4500-CI G-2000 Temperature — Standard Methods, 2550 B-2000 H. Finding: The laboratory is not documenting proper units of measure. 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 02H .0805 (g) (1). pH — Standard Methods, 4500-H+ B-2000 Total Residual Chlorine — Standard Methods, 4500-CI G-2000 1. Finding: The laboratory is not analyzing a post analysis check standard when applicable. 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. It is recommended that a mid -day check standard buffer be analyzed when samples are analyzed over an extended period of time. The post analysis check standard buffer(s) must read within t0.1 S.0 or corrective actions must be taken. Ref: NC WW/GW LC Approved Procedure for Field Analysis of pH. 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. The post analysis calibration verification standard concentration must be at mid range. It is recommended that a mid -day calibration verification be performed when samples are analyzed over an extended period of time. The value obtained for the post analysis calibration verification check standard must read within 10% of the true value of the post analysis calibration verification check standard. If the obtained value is outside of the ±10% range, corrective action must be taken. Ref: NC WW/GW LC Approved Procedure for Field Analysis of Total Residual Chlorine. Dissolved Oxygen — Standard Methods, 4500-0 G-2001 J. Finding: The laboratory is not documenting the calibration of the meter. Requirement: The following criteria must be documented whenever sample analysis is performed: 5. Meter calibration and time of calibration. Ref. NC WW/GW LC Approved Procedure for Field Analysis of Dissolved Oxygen. Total Residual Chlorine — Standard Methods, 4500-CI G-2000 K. Finding: On the non -Discharge Monitoring Reports (DMRs), the laboratory is reporting results which are less than the established reporting limit. IV Page 5 #5598 Hydro Services and Consulting Requirement: 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 Field Analysis of Total Residual Chlorine. Comment: Observed on non-DMR permit # WQ0003067 for August 21, 22, 23, 27, 28 and 29 of 2012. Established reporting limit observed during inspection was 0.2 mg/L, therefore any results which are less than this concentration must be reported as <0.2 mg/L. Comment: Because of these incorrectly reported values, the monthly average and the monthly minimum are also incorrect. In order to avoid questions of legality, it is recommended that you submit amended reports to your client. A copy of this report will be made available to the Regional Office. Please submit a copy of the new benchsheets addressing Findings F, G, H, I and J with the response to this report. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing laboratory benchsheets, client reports and DMRs and non-DMRs submitted to the North Carolina Division of Water Quality. Data were reviewed for NPDES permit # NC0074837 for June, July and August 2012, and Water Quality permit # WQ0003067 for August 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 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: Nick Jones Report reviewed by: Jeff Adams Date: December 5, 2012 Date: December 5, 2012 INSPECTION REPORT ROUTING SHEET 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: Date Received: Date Forwarded to Linda: Date Mailed: 5598 Hydro Services and Consulting Field Initial Nick Jones November 7, 2012 December 5, 2012 December 5, 2012 Jeff Adams December 5. 2012 ® Insp. Initial ❑ Insp. Reg. ❑ Insp. No Finding ❑ Insp. CP ❑ Corrected Gary Francies 12/5/2012 12/20/2012 12/21/12 Ic