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HomeMy WebLinkAbout#5061_2021_0325_TS_FINAL April 30, 2021 5061 Mr. Robert Long Jr. Burlington Industries - Richmond Plant P.O. Box 250 Cordova, NC 28330- Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Long: Enclosed is a report for the inspection performed on March 25, 2021 by Tonja Springer. I apologize for the delay in getting this report to you. 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 the se 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 2H .0800. A copy of the laboratory’s Certified Paramete r 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: Tonja Springer, Todd Crawford, File #5061 On-Site Inspection Report LABORATORY NAME: Burlington Industries – Richmond Plant NPDES PERMIT #: NC0043320 ADDRESS: 740 Old Cheraw Hwy. Cordova, NC 28330 CERTIFICATE #: 5061 DATE OF INSPECTION: March 25, 2021 TYPE OF INSPECTION: Field Industrial Maint enance AUDITOR: Tonja Springer LOCAL PERSON(S) CONTACTED: Lysander Little and Robert Long, Jr. 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 02H .0800 for the analysis of compliance monitoring samples. II. GENERAL COMMENTS: The inspection was performed remotely due to the coronavirus pandemic. The laboratory submitted the requested documentation and pictures of their reagents and instruments electronically on February 25, 2021, March 16, 2021 and March 17, 2021. The inspection was performed via WebEx on March 25, 2021. The facility has all the equipment necessary to perform the analyses. Staff were forthcoming and seemed eager to adopt necessary changes. All required Proficiency Testing (PT) Samples for the 2021 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, 2021. Contracted analyses are performed by Microbac Laboratories, Inc . (Certification #11). Approved Procedure documents for the analysis of the facility’s currently certified Field Parameters were provided electronically prior to the inspection. The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedure (SOP) documents in advance of the inspection. These documents were reviewed and editorial and substantive revision requirements and recommendations were made by this program outside of this formal report process. Although subsequent revisions were not requested to be submitted, they must be completed by October 30, 2021. Page 2 #5061 Burlington Industries – Richmond Plant The laboratory is reminded that any time changes are mad e to laboratory procedures, the laboratory must update the QA/SOP document(s) and inform relevant staff. Any changes made in response to the pre-audit review or to Findings, Recommendations or Comments listed in this report must be incorporated to insure the method is 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 labor at ory. In some instances, the laboratory may need to create an SOP to document how new functions or policies will be implemented. 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”. III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS: Documentation Comment: The laboratory is documenting the Effluent sample results on one benchsheet and the Outfall 002 sample results in the WWTP Daily Report log. Recommendation: It is recommended that the Outfall 002 samples be documented on the benchsheet with the Effluent samples. A. Finding: The laboratory needs to increase the traceability documentation of purchased materials and reagents. Requirement: 15A NCAC 02H .0805 (a)(7)(K) and (g)(7) re qu ir es 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, Dat e Opened (in use), Vendor, Lot Number, and 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 requir ement. Ref : NC WW/GW LC Policy. Comment: The traceability log does not include the date opened or put into use. Expiration date and the reagent name is documented on the “Wastewater Inventory” log and purchase receipts stored in the computer are used for date re ceived, vendor and lot number. Recommendation: It is recommended to document the date opened (in use), date received, vendor and lot number on the “Wastewater Inventory” log to provide a better traceability link to analysis and to consolidate this informat io n. B. 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 Page 3 #5061 Burlington Industries – Richmond Plant chemicals, reagents, standards, and consumables. That system must include documentation of the following information: Date received, Date Opened (in use), Vendor, Lot Number, and 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 LC Policy. Comment: The documentation for the preparation of the Total Residual Chlorine (TRC) annual verification curve standards did not include the stock standard and working standard traceability information (e.g., solvent used, vendor, lot number). The preparation documentation does include the analyst’s initials, date of preparation, the volume of the standard used and the final volume of the solution. C. Finding: Documentation of the mechanical pipette calibration does not include all pertinent information. Requirement: All analytical records, including original observations and information necessary to facilitate historical reconstruction of the calculated results, shall be maintained for five years. Ref: 15A NCAC 02H .0805 (g) (1). Comment: The documentation did not include the calculated difference of the 3 readings and the manufacturer’s statement of accuracy. D. Finding: Laboratory documentation does not demonstrate that the temperature-measuring device verification or Automatic Temperature Compensator (ATC) verification are performed every 12 months. 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 a valid NIST certificate must be checked initially and every 12 months against an NIST traceable temperature-measuring device and the process documented. Documentation must include the serial number of the device being checked. The serial number, stated accuracy and expiration date of the NIST traceable temperature-measuring device used I the comparison on must also be documented. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Requirement: The AT C must be verified prior to initial use and annually (i.e., 12 months) thereaf ter 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 (see #3 below). The manner in which the ATC is verified may depend upon the meter’s capabilities and the manufacturer’s instructions. Ref: NC WW/GW LC Approved Procedure for the Analysis of Specif ic Conductan ce (Conductivity). Comment: The documentation of the ATC verification and temperature sensor check s did not include the date performed. Page 4 #5061 Burlington Industries – Richmond Plant E. Finding: Documentation of the ATC verification does not include all pertinent information. Requirement: All analytical records, including original observations and information necessary to facilitate historical reconstruction of the calculated results, shall be maintained for five years. Ref: 15A NCAC 02H .0805 (g) (1). Requirement: 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 LC Approved Procedure for the Analysis of Specific Conductance (Conductivity). Comment: The ATC verification documentation did not include the analyst’s initials or acceptance criteria used to compare the conductivity readings. F. Finding: Documentation of the compliance temperature-me asur ing device calibration verification does not include the stated accuracy of the National Institute of Standards and Technology (NIST) traceable 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 a valid NIST certificate must be checked initially and every 12 months against an NIST traceable temperature-meas uring device and the process documented. Documentation must include the serial number of the device being checked. The serial number, stated accuracy and expiration date of the NIST traceable temperature-measuring device used in the comparison must also be docume nted. Verification data must be kept on file and be available for inspection for 5 year s. (NOTE: Vendors or other Certified laboratories may provide assistance in meeting this requirement. When a vendor or other Certified laboratory provides this assistance, they must provide a copy of their NIST Certificate or the serial number, accuracy an d calibration expiration date.) Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Requirement: All NIST traceable temperature-measuring devices must have a stated accuracy of at least ± 0.5°C and be within their expiration date. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. G. Finding: Error corrections are not properly performed. Requirement: All documentation errors shal l 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 adjac ent 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: Corrections are not always initialed and dated. H. Finding: The Effluent laboratory benchsheets refer ence unapproved methods. 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 Standar d Operating Procedure. Each item shall be recorded each time samples are Page 5 #5061 Burlington Industries – Richmond Plant analyzed. Analyses shall conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (A). Comme nt: All the benchsheets reference the 18th Edition of Standard Methods. None of the approved methods are found in the 18th edition. The current app roved methods are no longer specified by the edition of Standard Methods and are now denoted by approval year. Comment: The methods for which the lab is certified ar e: • Conductivity – SM 2510 B-2011 • DO – SM 4500 O G-2011 • pH – SM 4500 H+B-2011 • Temperature – SM 2550 B -2010 • TRC – SM 4500 Cl G-2011 I. Finding: The WWTP Daily Report log is lacking required documentation: the method reference, the instrument identification , the signature or initials of the analyst , the time of sample analyses, the proper units of measure and meter calibration time. 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, instrume nt identification , the signatures or initials of the analyst , the time of sample analyses and the proper units of measure. Each item shall be recorded each time samples are analyzed. Anal yses shall conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (A), (C), (E), (H) and (L). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Daily Check Standard analysis date and time(s). Ref: NC WW/GW LC Approved Procedure for the Analysi s o f Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Requirement: The following must be documented in indelible ink whenever sample analysis is perf ormed: Meter calibration and meter calibration time(s). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: The laboratory documents Outfall 002 sample results for pH, Temperature and TRC on the WWTP Daily Report log which does not contain documentation of the method reference, instrument identification, s ignature or initials of the analyst, the time of sample analyses, proper units of measure, meter calibration time for pH and TRC. These sampl es are only analyzed once a month. Comment: The units of measure for TRC are documented on the WWTP Daily Repor t l og as mg/L instead of µg/L. Sampl e results must be documented and reported as µg/L to comply with the permit. J. Finding: The laboratory Effluent benchsheet is lacking required documentation: the instrume nt identification and proper units of measure. Req uirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of the instrument identification and 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) (C) and (L). Comment: This Finding applies to Conductivity and Temperature. Page 6 #5061 Burlington Industries – Richmond Plant Comment: The units of measure for Conductivity are documented on the benchsheet as µs instead of µmho/cm. Comment : Some meters may display units in µS/cm, however sample results are to be reported in units of µmhos/cm (1µmho/cm = 1µS/cm). Recommendation: The TRC instrument identification documented on the Effluent benchshee t is the instrument make and model. It is recommended that the serial number be used instead. K. Finding: The laboratory is not documenting the percent recovery of QC 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. Analyses shall conform to methodologies found in Su bparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2) (O). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Value obtained for the Daily Check Standard(s) and percent recovery. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: The Finding applies to TRC. The percent recovery obtained must be documented on the benchsheet and evaluated against the established acceptance criterion to demonstrate that the analyst was aware of any out-of -control situation. The corrective actions taken must be documented. L. Finding: Documentation of the calibration variables for the DO meter does not include all pertinent data. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) o f this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Req uirement: 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 LC Approved Procedure for the Analysis of Dissolved Oxygen (DO). Comment: The meter is calibrated using the elevation, salinity and temperature. The elevation an d salinity have been programmed into the meter. These values may be added to the benchsheet as a blanket statement. M. Finding: Data qualifiers from the contract laboratory reports are not being transferred to the Discharge Monitoring Report (DMR). 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 BOD qualifier (i.e., “G1: The dissolved oxygen (DO) depletion of the dilution water blank exceeded 0.20 mg/L”) was not transferred to the DMR from the client report for November 5, 2020, November 12, 2020, November 19, 2020 , December 3, Page 7 #5061 Burlington Industries – Richmond Plant 2020, December 10, 2020, December 17, 2020, December 22, 2020, December 29, 2020, January 7, 2021, January 14, 2021 and January 28, 2021. Comment : The BOD qualifier (i.e., “G2: The bacterial seed controls did not meet the requirement of a DO depletion of at least 2.0 mg/L and/or a DO residual of at least 1.0 mg/L”) was not transferred to the DMR from the client report for November 5, 2020, Comme nt: The BOD qualifier (i.e., “G3: No sample dilution met the requirement of a DO depletion of at least 2.0 mg/L and/or 1.0 mg/L”) was not transferred to the DMR from the client report for November 12, 2020, Comment: The BOD qualifier (i.e., “G5: The glucose/glutamic acid standard exceeded the range of 198 + 30.5 mg/L”) was not transferred to the DMR from the client report for November 5, 2020, December 3, 2020, Decemb er 17, 2020, January 14, 2021 and January 28, 2021. Comment: The BOD qualifier (i.e., “G6: The calculated seed correction exceeded the ran ge of 0.6 to 1.0 mg/L”) was not transferred to the DMR from the client report for December 22, 2020. Comment: The COD qualifier (i.e., “B: Analyte found in the blank at or above the method acceptance criteria”) was not transferred to the DMR from the client report for November 19, 2020 and November 24, 2020. Comment: The Nitrate/Nitrite qualifier (i.e., “A12: MS/MSD failed recovery but the LCS pass es criteria”) was not transferred to the DMR from the client report for January 7, 2021. Comment: The Ammonia qualifier (i.e., “J: The result is an estimated quantity. The associated numerical value is the approximate concentration of the analyte in the sample”) was not transferred to the DMR from the client report for January 28, 2021. Recommendation: 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. Conductivity – Standard Methods, 2510 B-2011 (Aqueous) N. Finding: The Automatic Temperature Compensator (ATC) check is not being properly performed. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: The 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 val ues 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 (see #3 below). The manner in which the ATC is verified may depend upon the meter’s capabilities and the manufacturer’s instructions. The following is one option: 1. Pour an adequate amount of conductivity standard or sample into a beaker or other container and analyze at 25 °C. Document the temperature and conductivity value. Page 8 #5061 Burlington Industries – Richmond Plant 2. Lower the temperature of the standard or sample (e.g., by placing the container in a refrigerator or ice chest) to less than the lowest anticipat ed sample temperature and anal yze. Document the temperature and conductivity value. 3. If samples greater than 25 °C are to be analyzed, perform the following additional step: Raise the temperature above 25 °C to greater than the highest anticipated samp le temperature (e.g., by placing the container in a hot water bath) and analyze. Document the temperature and conductivity value. 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 LC Approved Procedure f or the Analysis of Specific Conductance (Conductivity). Please submit an updated ATC verification bracketing the ra nge of compliance samples analyzed with the report reply. Comment: The ATC was verifi ed at 23 °C and 25 °C. Sample temperatures below 14 °C wer e included in the data submitted for review. O. Finding: The laboratory is not analyzing a second-source calibration verification check standard. Requirement: Laboratory procedures shall comply with Subpar agraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Analyze and document a second-source calibration verification check standard prior to compliance sample analysis. It is recommended that this standard value approximate (may be higher or lower than the calibration standard, as applicable) the expected range of sample values measured. The value obtained for the calibration verification check-stan dard must read within 10% of the true value of the calibration verification check standard . If the obtained value is outside of the ±10% range, corrective action must be taken. Ref : NC WW/GW LC Approved Procedure for the Analysis of Specific Conductance (Conductivity). Comment: Please note that Conductivity standards may not be diluted. Dissolved Oxygen – Standard Methods, 4500 O G -2011 (Aqu eous) P. Finding: The meter is not being calibrated according to the manufacturer’s instructions. Requirement: Calibration In % Satur ation: Ensure that the sponge inside the instrument's calibration chamber is moist. Insert the probe into the calibration chamber. Ref: YSI 550A Operator’s Manual. Comment: The laboratory is calibrating in a BOD bottle completely filled with water as mg/L of a known solution. However, the true value of the water is not known. The laboratory was instructed to begin calibrating in % Saturation, using the calibration c hamber . Temperature – Standard Methods, 2550 B -2010 (Aqueous) Q. Finding: The annual temperature-measuring device check procedure is not performed correctly. Req uirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Page 9 #5061 Burlington Industries – Richmond Plant Requirement: To check a compliance temperature-me as uring device, compare readings at two temperatures that bracket the range of compliance samples routinely analyzed against a National Instit ute of Standards and Technology (NIST) traceable temperature- measuring device and record all four readings. The read ings from both devices must agree within 0.5 ºC. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Please submit an updated temperature verification bracketing the range of compliance samples analyzed with the report reply. Comment: The temperature-measuring device check was performed at 22.5 ºC and 23.2 ºC. Sample temperatures below 14 ºC were included in the data submitted for review. Total Residual Chlorine – Standard Methods, 4500 Cl G-2011 (Aqueous) R. 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-prepare d standards [including Proficiency Testing (PT) Samples] and anytime sample dilutions are performed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: The prepared PT Sample and calibration curve standards are considered laboratory-prepared standards. Commen t: A method blank is not analyzed with the annual TRC calibration verification curve standards or with the PT Sample. Comment: 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. Proficiency Testing S. Finding: The labo ratory is not documenting the preparatio n 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. Commen t: The vendor instructions are retained for 5 years but are not dated and initialed. T. Finding: The laboratory is not documenting PT Sample analyses in the same manner as routine Compliance Samples. Page 10 #5061 Burlington Industries – Richmond Plant 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 f ac ilitate historical reconstruction of the analysis and reporting of analytical results f or 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. Comment: PT Samp le results are not documented on a benchsheet in the same way a compliance sample is documented to demonstrate that all calibration and QC requirements were met. The PT Sample is documented in a notebook that only has the sample results, parameter analyz ed, Agency ID, and method reference for TRC and Conductivity. The method reference for pH is partially documented. U. Finding: PT Samples are not being analyzed in the same manner as routine Compliance Samples. Requirement: Laboratories are required to analyze an appropriate PT Sample by each parameter method on the laboratory’s CPL. The same PT Sample may be analyzed by one or more methods. Laboratories shall conduct the analyses in accordance with their routine testing, calibration and reporting procedures, unless otherwise specified in the instructions supplied by the Accredited PT Sample Pro vider. This means that they are to be logged in and analyzed using the same staff, sample tracking systems, standard operating procedures including the same equipment, reagents, calibration techniques, analytical methods, preparatory techniques (e.g., digestions, distillations and extractions) and the same quality control acceptance criteria. PT Samples shall not be analyzed with additional quality control. They are not to be replicated beyond what is routine for Compliance Sample analysis. Although, it may be routine to spike Compliance Samples, it is neither required, nor recommended, f or PT Samples. PT sample results from multiple analyses (when this is the routine procedure) must be calculated in the same manner as routine Compliance Samples. Ref: Prof iciency Testing Requirements, February 19, 2020, Revision 5, Section 3.6. Comment: T he laboratory was analyzing pH PT Samples multiple times and reporting an average of all results. V. Finding: Values less than the established reporting limit are being repo rted on the DMR. Requirement: For all calibration options, the range of standard concentrations must bracket the permitted discharge limit concentration, the range of sample concentrations to be analyzed and anticipated PT Sample concentrations. One of the standards must have a concentration less than the permitted Daily Maximum Limit. The lower reporting limit concentration is equal to the lowest standard concentration. Sample concentrations that are less than the lower reporting limit must be reported as a less -than value. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: The laboratory currently has established a lower reporting limit of 2 0 µg/L by having verified that concentration when verifying the most recent calibration curve. Sample concentrations less than that must be reported as < 20 µg/L on the DMR. Page 11 #5061 Burlington Industries – Richmond Plant IV. PAPER TRAIL INVEST IGATION: The paper trail consisted of comparing original records (e.g., labo ratory 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 Burlington Industries – Richmond (NPDES permit # NC0043320) for November 2020, December 2020 and January 2021. The following errors were noted: 1. The Total Nitrogen was calculated incorrectly on the client report. The T otal K jeldahl N itroge n (TKN) value was not included in the calculation. The Total N itrogen on the cli en t report was 2.93 mg/L. The correct Total N itrogen value is (Nitrate 2.93 mg/L + Nitrite <0.200 mg/L + TKN 1.70 mg/L) = 4.63 mg/L. 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 and implementing the Recommendations will help this laboratory to produce quality data and meet Certification requirements. The inspector would like to thank the staff for their as sistance during the inspection and data review process. Please respond to all Findi ngs and include supporting documentation, implementation dates and steps taken to p re vent recurrence for each corrective action. Report prepared by: Tonja Springer Date: March 30, 2021 Report reviewed by: Jason Smith Date: March 31, 2021 Date Parameter Location Value on Benchsheet *Contract Laboratory Data Value on DMR 11/5/2020 Ammonia Effluent *<0.200 mg/L 2.93 mg/L 11/12/2020 Ammonia Effluent *<0.200 mg/L <2.0 mg/L 11/19/2020 Ammonia Effluent *<0.200 mg/L <2.0 mg/L 12/3/2020 Ammonia Effluent *<0.200 mg/L <2.0 mg/L 12/10/2020 Ammonia Effluent *<0.200 mg/L <2.0 mg/L 12/17/2020 Ammo nia Effluent *<0.200 mg/L <2.0 mg/L 12/22/2020 Ammonia Effluent *<0.200 mg/L <2.0 mg/L 11/5/2021 Total N itrogen Effluent *2.93 mg/L1 2.93 mg/L 11/6/2021 pH Outfall 01 6.8 S.U. 6.9 S.U. 11/16/2021 pH Outfall 01 6.9 S.U. 6.8 S.U. 11/25/2020 Temperature Effluent 17 °C 18 °C 1/08/2021 DO Effluent 6.0 mg/L No value reported Certificate Number:5061 Effective Date:1/1/2021 Expiration Date:12/31/2021 Lab Name:Burlington Industries - Richmond Plant Address:740 Old Cheraw Hwy. Cordova, NC 28330- North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment: 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-2011 (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.