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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
September 7, 2022
5708
Ms. Deborah Bradley
Tryon WWTP
301 North Trade Street
Tryon, NC 28782
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Initial Inspection
Dear Ms. Bradley:
Enclosed is a report for the inspection performed on August 8, 2022 by Jason Smith. 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
not 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. 251.
Sincerely,
Anna Ostendorff
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Todd Crawford, Jason Smith, Master File #5708
On-Site Inspection Report
LABORATORY NAME: Tryon WWTP
NPDES PERMIT #: NC0021601
ADDRESS: 1526 E. Howard St
Tryon, NC 28782
CERTIFICATE #: 5708
DATE OF INSPECTION: August 8, 2022
TYPE OF INSPECTION: Field Municipal Initial
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED:
Deborah Bradley and Michael Fife
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:
The facility is neat and well organized and has all the equipment necessary to perform the analyses. Staff
were 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
March 1, 2023.
The laboratory is also reminded that SOPs 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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Contracted analyses are performed by Environmental Testing Solutions (Certification #600).
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
A. Finding: Error corrections are not properly performed.
Requirement: All documentation errors shall 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; instead the correction shall be written adjacent to the error.
The correction shall be initialed by the responsible individual and the date of change
documented. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: Error corrections are not dated, and some overwriting was observed.
B. Finding: The laboratory benchsheet is lacking required documentation: the method or
Standard Operating Procedure reference; the laboratory identification; the instrument
identification; the date and time of sample collection; the date of sample analyses; the time of
sample analyses; 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 laboratory identification; the instrument identification; the date and
time of sample collection; the date of sample analyses; the time of sample analyses; 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), (B), (C), (F), (G), (H) and (L).
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: Facility name or permit number. Ref: NC WW/GW LCB Approved Procedure for
the Analysis of Dissolved Oxygen (DO), NC WW/GW LCB Approved Procedure for the
Analysis of pH, NC WW/GW LCB Approved Procedure for the Analysis of Specific
Conductance (Conductivity), NC WW/GW LCB Approved Procedure for the Analysis of
Temperature, and NC WW/GW LCB Approved Procedure for the Analysis of Total Residual
Chlorine (DPD Colorimetric by SM 4500 Cl G-2011).
Comment: The sample collection and analysis times are not clearly identified. The initial time
recorded, labeled “Time”, is the collection time for pH, Dissolved Oxygen (DO), Temperature
and Total Residual Chlorine (TRC). It is also the analysis time for pH, DO and Temperature.
The final time recorded, labeled “Ran Time”, is only the analysis time for TRC. A statement
may be added to the benchsheet to document which samples are analyzed in-situ or at the
time of sample collection.
Comment: The stream sampling benchsheet documents the collection time and has a note
the “stream samples are ran on site”. This statement gives no indication of the time between
sample collection and analysis; making it impossible to determine if the holding times were
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met. This needs to be clarified to indicate that the samples are analyzed immediately or in-
situ or the time documented may be changed to “collection/analysis time”.
Comment: The proper units of measure were missing for DO on the DO calibration log and
the blank on the TRC calibration log.
C. Finding: The laboratory is not documenting the 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).
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: A statement may be added to the benchsheet stating that the meter is always
calibrated at 0 ppt Salinity.
D. Finding: The laboratory does not document the pH meter calibration during sludge analysis.
Requirement: A record of instrument calibration or calibration verification shall be
documented and available for inspection upon request. Ref: 15A NCAC 02H .0805 (g) (3).
E. Finding: The laboratory is not documenting the percent recovery of Conductivity standards
on laboratory benchsheets.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall
be traceable to the associated sample analyses and shall consist of: the quality control
assessments. Each item shall be recorded each time samples are analyzed. Ref: 15A NCAC
02H .0805 (g) (2) (O).
Comment: The percent sign for the acceptance criterion of the Conductivity standard is not
visible on the benchsheet and must also be corrected.
F. Finding: The laboratory is lacking a documented training program.
Requirement: Each laboratory shall develop and implement a documented training program
that includes the following: that staff have the education, training, experience, or demonstrated
skills needed to generate quality control results within method-specified limits and that meet
the requirements of these Rules; that staff have read the laboratory quality assurance manual
or applicable Standard Operating Procedures; that staff have obtained acceptable results on
Proficiency Testing Samples pursuant to Rule .0803(1) of this Section or other demonstrations
of proficiency (e.g., side-by-side comparison with a trained analyst, acceptable results on a
single-blind performance evaluation sample, an initial demonstration of capability study
prescribed by the reference method). Ref: 15A NCAC 02H .0805 (g) (5).
G. Finding: The preparation of standards and reagents are not documented in such a way as to
provide traceability from preparation to analysis.
Requirement: 15A NCAC 02H .0805 (a)(7)(K) and (g)(7) requires laboratories to have a
documented system of traceability for the purchase, preparation, and use of all chemicals,
reagents, standards, and consumables. That system must include documentation of the
following information: Date received, Date Opened (in use), Vendor, Lot Number, and
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Expiration Date (where specified). 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 primary standards, chemicals, reagents, and materials
used for a period of five years. Consumable materials such as pH buffers, lots of pre-made
standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref:
NC WW/GW LCB Traceability Documentation Requirements for Chemicals, Reagents,
Standards and Consumables Policy.
Comment: This Finding applies to prepared pH buffers and TRC standards.
Proficiency Testing
H. Finding: The laboratory is not documenting the preparation of PT Samples.
Requirement: PT Samples received as ampules are diluted according to the Accredited PT
Sample Provider’s instructions. It is important to remember to document the preparation of PT
Samples in a traceable log or other traceable format. The diluted PT Sample then becomes a
routine Compliance Sample and is added to a routine sample batch for analysis. No
documentation is needed for whole volume PT Samples which require no preparation,
however the instructions must be maintained. Ref: Proficiency Testing Requirements,
February 19, 2020, Revision 5, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
I. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
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 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.
J. Finding: The laboratory does not have a documented plan for PT procedures.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. A
copy of each analytical method or Approved Procedure and Standard Operating Procedure
shall be available to each analyst and available for review upon request by the State
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Laboratory. Standard Operating Procedure documentation shall state the effective date of the
document and shall be reviewed every two years and updated if changes in procedures are
made. Each laboratory shall have a formal process to track and document review dates and
any revisions made in all Standard Operating Procedure documents. Supporting Records
shall be maintained as evidence that these practices are implemented. Ref: 15A NCAC 02H
.0805 (g) (4).
Requirement: Laboratories must have a documented plan [this is usually detailed in the
laboratory’s Quality Assurance Manual or may be a separate Standard Operating Procedure
(SOP)] of how they intend to cover the applicable program requirements for Proficiency
Testing per their scope of accreditation. This plan shall cover any commercially available PT
Samples and any inter-laboratory organized studies, as applicable. The laboratory must also
be able to explain when PT Sample analysis is not possible for certain methods and provide
a description of what the laboratory is doing in lieu of Proficiency Testing. This shall be detailed
in the plan. The plan must also address the laboratory’s process for submission of PT Sample
results and related Corrective Action Reports (CARs). Ref: Proficiency Testing Requirements,
February 19, 2020, Revision 5, Section 3.0.
Conductivity – Standard Methods, 2510 B-2011 (Aqueous)
K. Finding: The Automatic Temperature Compensator (ATC) was not verified prior to initial use
and every 12 months thereafter.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: The Automatic Temperature Compensator (ATC) must be verified prior to
initial use and annually (i.e., 12 months) thereafter at two temperatures by analyzing a
standard or sample at 25°C (i.e., the temperature to which conductivity values are reported)
and a temperature(s) that brackets the temperature ranges of the environmental samples
routinely analyzed. This may require the analysis of a third temperature reading that is >
25°C. As the temperature increases or decreases, the value of the conductivity standard or
sample must be within ±10% of the true value of the standard or ±10% of the value of the
sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LCB Approved
Procedure for the Analysis of Specific Conductance (Conductivity).
Conductivity – Standard Methods, 2510 B-2011 (Aqueous)
Dissolved Oxygen – Standard Methods, 4500 O G-2016 (Aqueous)
L. Finding: When analyses are performed at multiple sample sites, the laboratory is not
calibrating prior to sample analysis at each sample site or performing a Post-Analysis
Calibration Verification.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: When performing analyses at multiple sample sites, the meter must be
calibrated at each sample site prior to analysis or a post-analysis calibration verification must
be performed at the end of the run, regardless of meter type. The calculated theoretical DO
value must verify the meter reading within ±0.5 mg/L. If the meter verification does not read
within ±0.5 mg/L of the theoretical DO, corrective action must be taken. If the meter is not
calibrated at each sample site, it is recommended that a mid-day calibration be performed
when samples are extended over an extended period of time. Ref: NC WW/GW LCB
Approved Procedure for the Analysis of Dissolved Oxygen (DO).
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Requirement: When performing multiple sample analyses, a post-analysis calibration
verification must be analyzed at the end of the run. It is recommended that a mid-day or a
mid-batch calibration verification be performed when samples are analyzed over an extended
period of time. The value obtained for the post-analysis calibration verification check-standard
must read within 10% of the standard’s true value. If the obtained value is outside of the ±10%
range, corrective action must be taken. If recalibration is necessary, all samples analyzed
since the last acceptable calibration verification must be reanalyzed, if possible. If samples
cannot be reanalyzed, the data must be qualified. Ref: NC WW/GW LCB Approved Procedure
for the Analysis of Specific Conductance (Conductivity).
pH – SW-846 9040 C (Aqueous)
pH – SW-846 9045 D (Non-Aqueous)
Comment: At the time of the inspection, the laboratory was certified for pH by SW -846 9040 C and
SW -846 9045 D for sludge analyses. The laboratory was not aware that the 2019 Rule revision
allowed field labs to get certified for Vector Attraction Reduction (VAR) options for sludge analyses.
The laboratory submitted an amendment to request dropping SW -846 9040 C and 9045 D and adding
VAR Option 6 to more accurately reflect the sample analyses.
M. Finding: The pH meter calibration is not verified with a check buffer prior to sample analysis.
Requirement: The meter calibration must be verified with a third standard buffer solution (i.e.,
calibration check buffer) prior to sample analysis. The calibration and check standard buffers
must bracket the range of the samples being analyzed. All calibration check standard buffers
must read within ±0.1 S.U. of its true value to be acceptable. If the meter verification does not
read within ±0.1 S.U., corrective actions must be taken before any samples are analyzed. Ref:
NC WW/GW LCB SW-846 pH Calibration Verification Policy.
Comment: When the laboratory updates their Certified Parameter Listing (CPL) to include
VAR Option 6, the meter calibration must be verified with a third standard buffer solution (i.e.,
check buffer) prior to sample analysis as outlined in the Approved Procedure document.
Temperature – Standard Methods, 2550 B-2010 (Aqueous)
N. Finding: The thermometer calibration verification documentation does not include the stated
accuracy of the Reference Temperature-Measuring Device that was used in the comparison.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: All compliance temperature-measuring devices without an NIST traceable
certificate, or with an expired NIST traceable certificate, must be verified against a Reference
Temperature-Measuring Device and the process documented initially and every 12 months.
Verification documentation must include the serial number of the device being checked. The
serial number, stated accuracy and expiration date of the Reference Temperature-Measuring
Device used in the comparison must also be documented. Verification data must be kept on
file and be available for inspection for 5 years. (Note: International Organization for
Standardization (ISO) 17025 compliant vendors or other Certified laboratories may provide
assistance in meeting this requirement. When an ISO compliant vendor provides this
assistance, they must provide the serial number, accuracy and calibration date for the
Reference Temperature-Measuring Device used for the verification. When a Certified
laboratory provides this service, they must provide a copy of the NIST traceable certificate of
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the Reference Temperature-Measuring Device used for the verification). Ref: NC WW/GW
LCB Approved Procedure for the Analysis of Temperature.
Comment: Thermometers are verified by a contractor. The contractor has been notified of
the requirements in Findings N and O and provided with the Approved Procedure for the
Analysis of Temperature.
O. Finding: The compliance temperature-measuring device is not checked at two temperatures
that bracket the range of observed sample temperatures.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: To check a compliance temperature-measuring device, compare readings at
two temperatures that bracket the range of compliance samples routinely analyzed against a
Reference Temperature-Measuring Device and record all four readings. The readings from
both devices must agree within 0.5ºC. If they do not, the device may not be used for
temperature compliance monitoring. Ref: NC WW/GW LCB Approved Procedure for the
Analysis of Temperature.
Total Residual Chlorine – Standard Methods, 4500 Cl G-2011 (Aqueous)
P. Finding: The laboratory is not analyzing a Method Blank when using laboratory-prepared
standards.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref:
15A NCAC 02H .0805 (g) (4).
Requirement: Method Blanks would be required when using laboratory-prepared standards
[including Proficiency Testing (PT) Samples] and anytime sample dilutions are performed.
Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD
Colorimetric by SM 4500 Cl G-2011).
Requirement: The Method Blank is deionized or distilled water from the same source used
to prepare the calibration verification standards or the PT Sample, and is analyzed like a
sample (i.e., with DPD/buffer added). The concentration of the Method Blank must not exceed
50% of the reporting limit (i.e., the lowest calibration verification standard concentration) or
corrective action must be taken. Ref: NC WW/GW LCB Approved Procedure for the Analysis
of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011).
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract laboratory reports to Discharge Monitoring Reports (DMRs) submitted to the
North Carolina Division of Water Resources. Data were reviewed for the Tryon WWTP (NPDES
Permit #NC0021601) for January, March and April 2022. The following errors were noted:
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Date Parameter Location
Value on
Benchsheet
*Contract
Laboratory Data
Value on DMR
1/4/2022 Dissolved
Oxygen Effluent 6.7 mg/L 6.8 mg/L
1/4/2022 Copper Effluent *0.01 mg/L 0.01 µg/L
3/1/2022 Copper Effluent *0.013 mg/L 0.013 µg/L
3/13/2022 Temperature Effluent 13 °C 14 °C
3/22/2022 Dissolved
Oxygen Effluent 6.4 mg/L 6.3 mg/L
3/30/2022 pH Effluent 7.1 S.U. 7.2 S.U.
4/5/2022 Copper Effluent *0.006 mg/L 0.006 µg/L
Comment: The monthly Copper results have all been reported with the wrong units of measure
resulting in them being reported low by a factor of one thousand. Mikal Wilmer with the Asheville
Regional Office was notified of this issue and will follow-up with the facility regarding revised DMRs.
To avoid questions of legality, it is recommended that you contact the appropriate Regional Office
for guidance as to whether an amended DMR(s) 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 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: Jason Smith Date: August 25, 2022
Report reviewed by: Tonja Springer Date: August 26, 2022
Certificate Number:5708
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Tryon WWTP
Address:301 North Trade Street
Tryon, NC 28782
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:10/26/2021
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
CHLORINE, TOTAL RESIDUAL
SM 4500 Cl G-2011 (Aqueous)
CONDUCTIVITY
SM 2510 B-2011 (Aqueous)
DISSOLVED OXYGEN
SM 4500 O G-2016 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
SW-846 9040 C (Aqueous)
SW-846 9045 D (Non-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.