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HomeMy WebLinkAbout#5545- 03-2009-FINALLaboratory 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 Alberta: Date Mailed: • • • ' - R 5545 Linville Land Harbor Field Initial Jason Smith March 31 2009 April 24, 2009 April 24, 2009 Todd Crawford April 24, 2009 X Insp. Initial _ Insp. Reg. _ Insp. No Finding _ Insp. CP Gary Francies Beverly Eaves Perdue Governor 5545 Mr. C.L. Lewis Linville Land Harbor P.O. Box 160 Linville, NC 28646 P NR North Carolina Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Director April 30, 2009 SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Initial Inspection Dear Mr. Lewis: Dee Freeman Secretary Enclosed is a report for the inspection performed on March 31, 2009 by Mr. Jason M. Smith. 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 Frahcies Unit Supervisor Laboratory Section CC: Jason M. Smith Asheville Regional Office OENR DWQ Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch 1�TOne 1623 Mail Service Center, Raleigh, North Carolina 27699-1623 l� orth C rolina Location: 4405 Reedy Greek Road. Raleigh, North Carolina 27607-6445 Phone: 919.733-39081 FAX: 919-733-6241 Naturally ally Internet: wway.dwglab.org An Equal Opportunity \AfiirmativeAction Employer Customer Service:1-877-623-6748 www.ncwaterquality.org LABORATORY NAME: NPDES PERMIT #: ADDRESS: CERTIFICATE : DATE OF INSPECTION: TYPE OF INSPECTION: AUDITOR: LOCAL PERSON CONTACTED: 1. INTRODUCTION: Linville Land Harbor NCO022756 P.O. Box 160 Linville, NC 28646 5545 March 31, 2009 Field Initial Jason Smith C.L. Lewis, Dallas Brown This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis of environmental samples. GENERAL COMMENTS: The facility has all the equipment necessary to perform the analyses. Most data appeared accurate. Documentation needs to be improved. Some further quality control procedures need to be implemented. Technical Assistance documents for all certified parameters were provided at the time of the inspection. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS: Documentation pH - Standard Methods, 20th Edition, 4500 H+ B Temperature - Standard Methods, 20th Edition, 2550 B Total Residual Chlorine - Standard Methods, 20th 4500 Cl G A. Finding: Both operators sign the benchsheets with no clear indication of which performed the analyses. 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). B. Finding: The time of analysis 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). Page 2 #5545 Linville Land Harbor C. Finding: The calibration check buffer is not analyzed prior to sample analysis. Requirement: In addition to the calibration standards, the meter must be verified with a third calibration standard (e.g., pH 7 buffer). Ref: Technical Assistance for Field Analysis of pH, Rev. 02/2009. Comment: The calibration check buffer is considered part of the calibration and must be analyzed prior to sample analysis to verify the meter is properly calibrated. Comment: A post analysis check buffer, which the facility currently analyzes, is only required when compliance samples are analyzed throughout the day. D. Finding: The facility does not report all of the pH analyses performed. Requirement: The results of all tests on the characteristics of the effluent, including but not limited to NPDES permit monitoring requirements, shall be reported on the monthly report forms. Ref: 15A NCAC 2B .0506 (b) (3) (J). Comment: Process control samples that are not reported must be collected prior to the final effluent. Temperature - Standard Methods, 20t" Edition, 2550 B E. Finding: Temperature is not analyzed within EPA holding time. Requirement: Analysis, either in situ or immediately on site, is required. Ref: Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 72, No. 47, March 12, 2007; Table II. Total Residual: Chlorine - Standard Methods, 20th 4500-Cl G F. Finding: The Total Residual Chlorine (TRC) meter has not had the internal calibration curve verified within the last twelve months. Requirement: The annual factory set curve verification must be performed at least every 12 months. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine, Rev. 08/2008. Please submit a copy of the TRC curve verification with the reply to this report. Comment: The contract laboratory provided the facility with a photometer for TRC analysis in June, 2008 and it was assumed the curve verification was performed at that time. The actual date of the curve verification was January, 2008. G. Finding: TRC results are reported below the reporting level (i.e. the lowest concentration verified). Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for TRC. Ref: Technical Assistance for Field Analysis of Total Residual Chlorine, Rev. 08/2008. Comment: Since the lowest concentration verified was 10 pg/L, all results below that value must be reported as < 10 pg/L. IV. Page 3 #5545 Linville Land Harbor H. Finding: TRC Performance Testing (PT) samples are analyzed using an incorrect meter program. Requirement: "The DMR-QA study is designed to evaluate the entire process you use to routinely report results in your Discharge Monitoring Reports." Ref: EPA DMR-QA Study 28 Letter, March 10, 2008. Comment: Analyze PT samples on the same program, using the same procedure that is used for sample analysis. NPDES samples are analyzed using the Ultra Low Level (pg/L) TRC internal instrument standard curve; however, PT samples are analyzed using the Regular Level (mg1L) TRC internal instrument curve. Recommendation: Regular level PT samples may be diluted so that concentrations are within the verified (bracketed) curve range. Since the dilution process can introduce additional error, it is recommended that the facility analyze a low level TRC PT sample. These are currently available from many vendors. 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 August and September, 2008. 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 and implementing the recommendation 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: Todd Crawford Date: April 24, 2009 Date: April 24, 2009