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HomeMy WebLinkAbout#5206 - 04- 2011 - FINALBeverly Eaves Perdue Governor 5206 Mr. Tim Church Town of Jefferson WWTP P.O. Box 67 Jefferson, NC 28640 MIA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director July 15, 2011 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Church: Dee Freeman Secretary Enclosed is a report for the inspection performed on April 28, 2011 by Jason Smith. I apologize for the delay in getting this report to you. Where finding(s) are cited in this report, a response is required. Within 30 days of receipt, please supply this office with a written item for item description of how these finding(s) were corrected. 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 828-296-4677. Sincerely, Gary Francies Unit Supervisor Laboratory Section CC: Jason Smith Gary Francies Master files 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 North Carolina Natun7liff An Equal Opportunity \ Affirmative Action Employer Customer Service:1-877-623-6748 www.ncwaterquality.org LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE #: DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR(S): LOCAL PERSON(S) CONTACTED: Town of Jefferson WWTP NCO021709 and NCO083470 P.O. Box 67 Jefferson, NC 28640 5206 April 28, 2011 Field Maintenance Jason Smith Tim Church This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. In addition to its own samples, the laboratory also analyzes samples for the Town of Jefferson WTP. Technical assistance documents for all certified parameters were provided to the laboratory at the time of the inspection. 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 A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents. 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. Page 2 #5206 Town of Jefferson WWTP B. 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. C. Finding: Proficiency Testing (PT) samples are not documented in the same manner as environmental samples. 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. Total Residual Chlorine — Standard Methods, 20th Edition, 4500 Cl G D. Finding: The gel standard used to verify the calibration curve daily has not been assigned a true value annually. Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily calibration verification only. These standards must be verified initially and every 12 months thereafter, with the standard curve. The assigned values will be used for the next twelve months, or until a new curve verification is performed. The gel standard verification must be performed for each instrument on which they are to be used. If multiple instruments and/or standard sets are used, each must have assigned values specific for the instrument and standard set. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine. pH — Standard Methods, 201h Edition, 4500 H+ B Temperature — Standard Methods, 20th Edition, 2550 B Dissolved Oxygen — Standard Methods, 20th Edition, 4500 O G E. Finding: The temperature sensing device on the pH meter and Dissolved Oxygen meter have not been calibrated against a certified thermometer annually (every 12 months). 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 even if the instrument is not used for reporting temperature results. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen and Technical Assistance for Field Analysis of pH. Comment: The verification was performed on April 26, 2011 after this inspection was scheduled. Prior to that, the last verification was performed in April, 2008. Failure to perform required annual quality control procedures may compromise the scientific validity and legal defensibility of the data. 59 Page 3 #5206 Town of Jefferson WWTP F. Finding: The temperature corrections were not posted on the pH and Dissolved Oxygen meters. Requirement: The temperature correction (even if it is zero) must be posted on the thermometer/ meter as well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field Analysis of pH, Technical Assistance for Field Analysis of Dissolved Oxygen, and Technical Assistance for Field Analysis of Temperature. pH — Standard Methods, 20th Edition, 4500 H+ B G. Finding: The temperature sensor of the pH meter was 1.5 °C off of the MIST reading. This meter is not used to analyze and report temperature. Requirement: The thermometer/meter readings must be less than or equal to 1 °C from the NISI certified or NIST traceable thermometer reading. Ref: Technical Assistance for Field Analysis of pH. H. Finding: Data values are reported to 0.01 S.U. 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, 20th Edition, 4500 H+ B. (6). Dissolved Oxygen — Standard Methods, 201h Edition, 4500 O G 1. Finding: The time of collection is not documented. 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). Comment: For analyses performed in situ (in stream or on site), a general statement reflecting this may be added to the benchsheet and/or the column header may be modified to "collection/analysis time". 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 were reviewed for Town of Jefferson WWTP (NPDES permit #NC0021709) and Town of Jefferson WTP (NPDES permit #NC0083470) for June, 2010. No transcription errors were detected. The facility appears to be doing a good job of accurately transcribing data. 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: Jason Smith Report reviewed by: Jeffrey R. Adams Date: July 5, 2011 Date: July 8, 2011 INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #1 5206 Laboratory Name: Town of Jefferson WWTP Inspection Type: Field Maintenance Inspector Name(s): Jason Smith Inspection Date: April 28, 2011 Date Report Completed: July 5, 2011 Date Forwarded to Reviewer: July 7, 2011 Reviewed by: Jeffrey R. Adams Date Review Completed: July 8, 2011 Cover Letter to use: _ Insp. Initial X Insp. Reg. Insp. No Finding _ Insp. CP _Corrected Unit Supervisor: Gary Francies Date Received: 7/8/11 Date Forwarded to Linda 7/15/2011 Date Mailed: V-" I � � i i