Loading...
HomeMy WebLinkAbout#5131_03_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5131 Laboratory Name: Town of Warsaw Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: March 20, 2014 Date Report Completed: April 7, 2014 Date Forwarded to Reviewer: April 7, 2014 Reviewed by: Jason Smith Date Review Completed: April 10, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 4/11/2014 Date Forwarded to Linda: 4/24/2014 Date Mailed: 4/24/2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Warsaw NPDES PERMIT #: NC0021903 ADDRESS: PO Box 464 Warsaw, NC 28398 CERTIFICATE #: 5131 DATE OF INSPECTION: March 20, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Greg Hughes and Angie Miller I. INTRODUCTION: 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: The laboratory was clean and well organized. The facility has all the equipment necessary to perform the analyses. Records were also well organized and quickly retrieved upon request. Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not yet been analyzed. The laboratory is reminded that these results must be submitted to this office directly from the vendor by September 30. Current quality assurance policies for Field Laboratories and approved procedures for the analysis of the facility’s currently certified parameters were provided at the time of the inspection. Contracted analyses are performed by Vann Laboratories (Certification #22). The requirements associated with Findings B, C, and D have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: Instrument identification for the meters used for Temperature, pH, Dissolved Oxygen and Total Residual Chlorine was not documented on the benchsheet. The NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine documents state: The following must be documented in indelible ink whenever sample analysis is performed: Instrument identification. This Page 2 #5131 Town of Warsaw requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (i.e., a statement that the revised benchsheet developed by the inspector, which identifies all meters by model and serial number, would be used starting April 1, 2014) was received via email on April 1, 2014. No further response is necessary for this finding. General Comment: The laboratory needed to increase the documentation of purchased materials and reagents. The Quality Assurance Policies for Field Laboratories document states: 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, Total Residual Chlorine reagents and lots of pre-made standards are included in this requirement. This requirement is a new policy that has been implemented by our program since the last inspection. Demonstration of acceptable corrective action (i.e., a traceability log sheet showing traceability information for all reagents currently in use) was received via email on April 1, 2014. No further response is necessary for this finding. A. 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. Proficiency Testing B. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as environmental 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. Environmental samples are not analyzed in this manner. 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. Page 3 #5131 Town of Warsaw Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual Chlorine PT would satisfy the documentation requirement. D. 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. Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 Comment: It would be acceptable and more economical, in terms of cost and time, if the facility switched from liquid reagents to DPD powder pillows. Use of the flow-thru cell could also be discontinued. Comment: The true value of the check standard was not documented on the benchsheet. The NC WW/GW LC Approved Procedure for Analysis of Total Residual Chlorine document states: The following must be documented in indelible ink whenever sample analysis is performed: True value of the check standard. Notification of acceptable corrective action (i.e., a statement that the revised benchsheet developed by the inspector, which shows the true value of the check standard, would be used starting April 1, 2014) was received via email on April 1, 2014. No further response is necessary for this finding. Comment: The meter calibration time was not documented. The NC WW/GW LC Approved Procedure for Analysis of Total Residual Chlorine documents state: The following must be documented in indelible ink whenever sample analysis is performed: Meter calibration and meter calibration time(s). Notification of acceptable corrective action (i.e., a statement that the revised benchsheet developed by the inspector, which provides space for calibration time, would be used starting April 1, 2014) was received via email on April 1, 2014. No further response is necessary for this finding. 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 Resources. Data were reviewed for December, 2013, January and February, 2014. The following error was noted: Date Parameter Location Value on Benchsheet Value on DMR 12/19/13 Dissolved Oxygen Effluent 11.5 mg/L 10.8 mg/L 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 made available to the Regional Office. Page 4 #5131 Town of Warsaw 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: Todd Crawford Date: April 7, 2014 Report reviewed by: Jason Smith Date: April 10, 2014