#5142_2022_0628_TS_FINAL

NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch
4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623
919-733-3908

July 25, 2022

5142
Mr. Phillip Smith
Kenly Regional WWTP
P.O. Box 519
Kenly, NC 27542-

Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection

Dear Mr. Smith:

Enclosed is a report for the inspection performed on June 28, 2022 by Tonja Springer. Where
Finding(s) are cited in this report, a response is required. Within thirty days, please supply this
office with a written item for item description of how these Finding(s) were corrected. Please
describe the steps taken to prevent recurrence and include an implementation date for each
corrective action. If the Finding(s) cited in the enclosed report are not corrected, enforcement
actions may be recommended. For Certification maintenance, your laboratory must continue to
carry out the requirements set forth in 15A NCAC 02H .0800.

A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list will
reflect any changes made during the audit. Copies of the checklists completed during the
inspection may be requested from this office. Thank you for your cooperation during the
inspection. If you have questions or need additional information, please contact me at (919) 733-
3908 Ext. 259.

Sincerely,

Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources

Attachment
cc: Todd Crawford, Tonja Springer, #5142

On-Site Inspection Report

LABORATORY NAME: Kenly Regional WWTP
NPDES PERMIT #: NC0064891
ADDRESS: 102 Truck Stop Road
Kenly, NC 27542
CERTIFICATE #: 5142
DATE OF INSPECTION: June 28, 2022
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Tonja Springer

LOCAL PERSON(S) CONTACTED:

Phillip Smith

I. INTRODUCTION:

This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of
15A NCAC 02H .0800 for the analysis of compliance monitoring samples.

II. GENERAL COMMENTS:

Staff was forthcoming and responded well to suggestions from the auditor.

All required Proficiency Testing (PT) Samples for the 2022 PT Calendar Year have not yet been
analyzed. The laboratory is reminded that results must be received by this office directly from the vendor
by September 30, 2022.

The laboratory is reminded that any time changes are made to laboratory procedures, QA/SOP
document(s) must be updated and relevant staff retrained. Staff must acknowledge that they have read
and understand the changes as part of the documented training program. The same requirements apply
when changes are made in response to Findings, Recommendations or Comments listed in this report,
to ensure the methods are being performed as stated, references to methods are accurate, and the QA
and/or SOP document(s) is in agreement with each approved practice, test, analysis, measurement,
monitoring procedure or regulatory requirement being used in the laboratory. In some instances, the
laboratory may need to create an SOP to document how new functions or policies will be implemented.
Revisions to the SOPs, based on the Findings, Comments and Recommendations within this
report must be submitted to this office by January 31, 2023.

The laboratory is also reminded that SOPs are required to be reviewed at least every two years and
are intended to describe procedures exactly as they are to be performed. Use of the word “should” is
not appropriate when describing requirements (e.g., Quality Control (QC) frequency, acceptance
criteria, etc.). Evaluate all SOPs for the proper use of the word “should”.

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#5142 Kenly Regional WWTP

Contracted analyses are performed by Environment 1, Inc. (Certification # 10).

Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters
were provided at the time of the inspection.

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

Documentation

Recommendation: The pH, Temperature and Dissolved Oxygen (DO) samples are analyzed
immediately at the sample site. The sample collection time and sample analysis time are
documented on the benchsheet even though they are the same. It is recommended to delete
the sample collection time column and add a note that samples are analyzed immediately at the
sampling site (i.e., immediately following collection at a location as near to the collection point
as possible).

A. Finding: The laboratory benchsheet is lacking required documentation: the method
reference and the proper units of measure.

Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the method
or Standard Operating Procedure; the proper units of measure. Each item shall be
recorded each time samples are analyzed. Analyses shall conform to methodologies
found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (A) and (L).

Comment: The Temperature method reference is documented as SM 1550 B-2010 on
the Daily Plant Check Worksheet. The correct method reference is SM 2550 B-2010.

Comment: The units of measure are not documented on the Daily Plant Check
worksheet and Laboratory Daily Log for pH. The units were documented as pH units
instead of Standard Units (S.U.)

B. Finding: The laboratory benchsheet is lacking required documentation for Dissolved
Oxygen and pH: meter calibration time.

Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this
Rule. Ref:15A NCAC 02H .0805 (g) (4).

Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Meter calibration and meter calibration time(s). Ref: NC
WW/GW LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO) and NC
WW/GW LCB Approved Procedure for the Analysis of pH.

Comment: One calibration time is documented at the top of the benchsheet for pH and
DO. The same meter is used for both analyses. The calibration time documented is the
time the meter calibration is started. It does not separate out the time of the calibration
for the pH and a time of calibration for the DO probe.

C. Finding: The laboratory is not documenting the barometric pressure and salinity values
used to calibrate the DO meter.

Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this
Rule. Ref: 15A NCAC 02H .0805 (g) (4).

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#5142 Kenly Regional WWTP

Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Calibration variables (temperature, elevation or barometric
pressure [in mmHg], and salinity). Ref: NC WW/GW LCB Approved Procedure for the
Analysis of Dissolved Oxygen (DO).

Comment: Temperature is the only calibration variable documented.

Comment: The Hach HQ40D multimeter has an internal barometer and can be
programmed to display the barometric pressure. Instructions on how to program the
meter to display the barometric pressure were given to the laboratory after the
inspection. If a constant salinity value is programmed into the meter, a blanket
statement can be added to the benchsheet with that value.

pH – Standard Methods, 4500 H+ B-2011 (Aqueous)

D. 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-2011. (6).

Comment: The pH results are reported to two decimal places on the Discharge
Monitoring Report (DMR).

Comment: Per PT Vendor instructions, the PT Sample results should be reported to
two decimal places, which is an exception to the requirement for compliance samples.

E. Finding: The laboratory is not using fresh aliquots of standard buffers to calibrate the
pH meter each day.

Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this
Rule. Ref: 15A NCAC 02H .0805 (g) (4).

Requirement: A portion of the standard buffer is not to be used for more than one
calibration. Discard any used buffer portions. Do not pour unused portions back into the
original bottle. Ref: NC WW/GW LCB Approved Procedure for the Analysis of pH.

Proficiency Testing
F. Finding: The laboratory is not documenting PT Sample analysis in the daily analysis
records.

Requirement: All PT Sample analyses must be recorded in the daily analysis records
as for any Compliance Sample. This serves as the permanent laboratory record. Ref:
Proficiency Testing Requirements, February 19, 2020, Revision 5, Section 3.6.

Requirement: The laboratory shall retain all records necessary to facilitate historical
reconstruction of the analysis and reporting of analytical results for PT Samples. This
means the laboratory must have available and retain for five years [pursuant to 15A
NCAC 02H .0805 (a) (7) (E) and (g) (1)] all of the raw data, including benchsheets,
instrument printouts and calibration data, for all PT Sample analyses and the associated
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#5142 Kenly Regional WWTP

QC analyses conducted by all parameter methods. Ref: Proficiency Testing
Requirements, February 19, 2020, Revision 5, Section 4.0.

Requirement: The analysis of Proficiency Testing (PT) Samples is designed to evaluate
the entire process used to routinely analyze and report Compliance Sample results. PT
Samples must be analyzed the same as Compliance Samples. Also, documentation
must be made on the same benchsheets used for Compliance Samples. Ref: NC
WW/GW LCB Proficiency Testing Samples Analyzed and Documented Same as
Compliance Samples Policy.

Comment: PT Sample results are entered into the online reporting form and not
documented on the laboratory benchsheet.

Temperature – Standard Methods, 2550 B-2010 (Aqueous)

Recommendation: It is recommended that Temperature results be reported on the DMR
in whole numbers, as stated in the “Precision in Discharge Monitoring Reports” document
issued by the Division of Water Resources.

Reporting

G. Finding: Data qualifiers from the contract laboratory reports are not being transferred
to the DMR.

Requirement: Each certified Field Laboratory shall be in accordance with Paragraph
(e) of this Rule. Ref: 15A NCAC 02H .0805 (g) (17).

Requirement: Reported data associated with quality control failures, improper sample
collection, holding time exceedances, or improper preservation shall be qualified as
such. Ref: 15A NCAC 02H .0805 (e) (5).

Comment: The samples analyzed by Environment 1, Inc. on December 8, 2021,
December 9, 2021, December 10, 2021, December 13, 2021, December 14, 2021,
December 15, 2021, December 16, 2021, December 20, 2021, December 21, 2021,
December 22, 2021, February 2, 2022, February 8, 2022, February 9, 2022, February
16, 2022, February 17, 2022, February 18, 2022, February 21, 2022, February 22,
2022, February 23, 2022, February 24, 2022, February 25, 2022, February 28, 2022,
April 1, 2022, April 4, 2022, April 5, 2022 and April 8, 2022 were lacking the following
qualifications on the DMR: “BOD – b. GGA check standard was not 198 ± 30.5 mg/L”.

The samples analyzed by Environment 1, Inc. on February 2, 2022, February 3, 2022,
February 4, 2022, February 11, 2022 and February 16, 2022, were lacking the
following qualifications on the DMR: “BOD – b. Dilution water blank was >0.20 mg/L.
GGA check standard was not 198 ± 30.5 mg/L”.

The samples analyzed by Environment 1, Inc. on February 7, 2022, February 16,
2022, February 22, 2022, February 23, 2022, February 24, 2022, February 25, 2022,
February 28, 2022, April 1, 2022, April 4, 2022, April 5, 2022 and April 8, 2022 were
lacking the following qualifications on the DMR: “BOD – g. GGA check standard was
not 198 ± 30.5 mg/L”.

The samples analyzed by Environment 1, Inc. on December 6, 2021 were lacking the
following qualifications on the DMR: “Oil & Grease – s. Spike data is not within
established limits”.
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#5142 Kenly Regional WWTP

The samples analyzed by Environment 1, Inc. on February 2, 2022 were lacking the
following qualifications on the DMR: “TKN – s. Spike data is not within established
limits”.

The samples analyzed by Environment 1, Inc. on December 8, 2021 were lacking the
following qualifications on the DMR: “TSS – v. 2.5 mg/L reporting limit adjusted for
sample volume received and analyzed (<1 liter)”.

Recommendation: It is recommended that you contact the appropriate Regional
Office for guidance as to whether amended DMRs will be required. A copy of this
report will be made available to the Regional Office.

IV. PAPER TRAIL INVESTIGATION:

The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.)
and contract laboratory reports to DMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Kenly Regional WWTP (NPDES permit # NC0064891) for
December 2021, February 2022 and April 2022. No transcription errors were observed. The facility
appears to be doing a good job of accurately transcribing data. However, as stated in Finding G,
data qualifiers were not transferred from the contract laboratory data.

V. CONCLUSIONS:

Correcting the above-cited Findings and implementing the Recommendation(s) will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like to
thank the staff for their assistance during the inspection and data review process. Please respond
to all Findings and include supporting documentation, implementation dates and steps taken
to prevent recurrence for each corrective action.

Report prepared by: Tonja Springer Date: July 14, 2022
Report reviewed by: Jason Smith Date: July 15, 2022

Certificate Number:5142
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Kenly Regional WWTP
Address:NC SR 2165 Truck Stop Road
Kenly, NC 27542-
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:11/8/2021
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
DISSOLVED OXYGEN
Hach 10360-2011, Rev. 1.2 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
TEMPERATURE
SM 2550 B-2010 (Aqueous)
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions
as set forth in 15A NCAC 2H.0807.