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HomeMy WebLinkAbout#5227_2014_Insp_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5227 Laboratory Name: Town of Chadbourn WWTP Inspection Type: Field Maintenance Inspector Name(s): Todd Crawford Inspection Date: February 18, 2014 Date Report Completed: February 25, 2014 Date Forwarded to Reviewer: February 25, 2014 Reviewed by: Tonja Springer Date Review Completed: February 26, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: February 26, 2014 Date Forwarded to Linda: March 13, 2014 Date Mailed: March 14, 2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Chadbourn WWTP NPDES PERMIT #: NC0021865, NC424020 Water Quality PERMIT #: WQ0001934 ADDRESS: 602 N. Brown Street Chadbourn, NC 28431 CERTIFICATE #: 5227 DATE OF INSPECTION: February 18, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Todd Crawford LOCAL PERSON(S) CONTACTED: Daniel C. Ward 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. Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2013 proficiency testing calendar year and the graded results were 100% acceptable. 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 Environment 1, Inc. (Certification #10). 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 requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (a revised bench sheet showing meter IDs and serial Page 2 #5227 Town of Chadbourn WWTP numbers) was received via email on February 25, 2014. No further response is necessary for this finding. A. Finding: Several instances of writing over a number as a means of error correction were observed. 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 Comment: The laboratory was not documenting Proficiency Testing (PT) sample analyses in the same manner as environmental samples. The NC WW/GW LC Proficiency Testing Requirements document, February 20, 2012, Revision 1.2 states: All PT sample analyses must be recorded in the daily analysis records as for any environmental sample. This serves as the permanent laboratory record. This requirement is a new policy that has been implemented by our program since the last inspection. Notification of acceptable corrective action (a revised benchsheet with space for PT analysis documentation) was received via email on February 25, 2014. No further response is necessary for this finding. pH – Standard Methods, 4500 H+B-2000 B. Finding: Values were reported that exceed the method specified accuracy of 0.1 units. Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 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, 4500 H+ B-2000, (6). 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. 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 NPDES permit #NC0021865 for October, November and December, 2013. The following errors were noted: Date Parameter Location Value on Benchsheet *Contract Lab Data Value on DMR 10/29/13 Total Suspended Solids Effluent * < 2.50 mg/L 5 mg/L Page 3 #5227 Town of Chadbourn WWTP 11/21/13 pH Effluent 7.84 S.U. 7.02 S. U 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. 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: February 25, 2014 Report reviewed by: Tonja Springer Date: February 26, 2014