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HomeMy WebLinkAbout#5275_03_2014_final INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5275 Laboratory Name: Town of Southern Pines WTP Inspection Type: Field Maintenance Inspector Name(s): Tonja Springer Inspection Date: March 11, 2014 Date Report Completed: March 24, 2014 Date Forwarded to Reviewer: March 24, 2014 Reviewed by: Todd Crawford Date Review Completed: March 24, 2014 Cover Letter to use: Insp. Initial Insp. Reg. Insp. No Finding Insp. CP Corrected Unit Supervisor/Chemist III: Dana Satterwhite Date Received: 3/24/2014 Date Forwarded to Linda: April 1, 2014 Date Mailed: April 2, 2014 _____________________________________________________________________ On-Site Inspection Report LABORATORY NAME: Town of Southern Pines WTP WATER QUALITY PERMIT # : NC0049778 ADDRESS: 261 Thunder Road Pine Bluff, NC 28373 CERTIFICATE #: 5275 DATE OF INSPECTION: March 11, 2014 TYPE OF INSPECTION: Field Maintenance AUDITOR(S): Tonja Springer LOCAL PERSON(S) CONTACTED: David McKew 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. 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) and Pace Analytical Services, Inc. (Certification #67). The requirements associated with Findings A, B, G, J and K have been implemented by our program since the last inspection. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Recommendation: The laboratory’s data defensibility would be improved with the addition of an instrument maintenance log. This can be as simple as a description in a comment box on a benchsheet. One example of instrument maintenance is replacing a bulb on the Total Residual Chlorine meter. Documentation A. Finding: The laboratory needs to increase the documentation of purchased materials and reagents such as the pH buffers and DPD reagents. Page 2 #5275 Town of Southern Pines WTP 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. Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 pH – Standard Methods, 4500 H+ B-2000 B. Finding: Instrument identification for the pH and Total Residual Chlorine meters is not documented on the benchsheet. Requirement: The following must be documented in indelible ink whenever samples analysis is performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for the Analysis of pH. C. Finding: The time of meter calibration is not documented. Requirement: A record of instrument calibration where applicable, must be filed in an orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (g) (2). D. Finding: Process control data is not documented as such. 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). Total Residual Chlorine – Standard Methods, 4500 Cl G-2000 Recommendation: A second set of gel standards has been purchased. It is recommended that the new set be verified against the annual verification curve whenever it is done for 2014 and be used as a backup. Both sets of gel standards will need to be assigned some type of identification so that the gel standard being used and it’s assigned true value can be linked to the samples. Recommendation: It is recommended that the true value obtained for the gel standards be put on the side of the gel standard box. E. Finding: The true value of the check standard is not documented. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: True value for the check standard. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. F. Finding: The meter is being zeroed each analysis day with a sample instead of calibration blank. Page 3 #5275 Town of Southern Pines WTP Requirement: The laboratory must analyze a calibration blank to zero the instrument and analyze a check standard each day that samples are analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The gel standard blank can be used as the calibration blank. Comment: The only time a sample is used to zero the instrument is if there is some type of interference. G. 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. Comment: Retaining the PT sample instruction sheet from the vendor, signed and dated by the technician, will satisfy this requirement. pH – Standard Methods, 4500 H+ B-2000 Recommendation: The slope is being documented on the benchsheet. It is recommended that the acceptance criterion also be documented on the benchsheet as a quick reference for to verify it is within the manufacturer’s acceptable criterion. Recommendation: The pH buffer check is being documented on the benchsheet. It is recommended that the acceptance criterion of the pH buffer check also be documented to verify that it is within the method’s acceptable criterion of +0.1 pH units. H. Finding: The benchsheet did not contain all pertinent information. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, samples site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Comments: Units were not being documented on the pH calibration documentation. I. 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). Proficiency Testing J. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as environmental samples. Page 4 #5275 Town of Southern Pines WTP 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. Since this is not performed with all environmental samples, it is considered additional quality control. However, known samples are recommended when analyzing remedial PT samples as part of the troubleshooting and corrective action process. K. 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. Comment: 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. Comment: The PT sample results are being documented directly on the vendor’s reporting form and not being documented on the benchsheet in the same manner as the environmental samples. 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 Resources. Data were reviewed for September, 2013, and January and February, 2014. The following error was noted: Date Parameter Location Value on Benchsheet Value on DMR 1/7/2014 Total Residual Chlorine Effluent < 20 µg/L <0.20 µg/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. V. CONCLUSIONS: Correcting the above-cited findings and implementing the recommendations 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: Tonja Springer Date: March 24, 2014 Report reviewed by: Todd Crawford Date: March 24, 2014