HomeMy WebLinkAbout#5579_2020_0130_AO_FINALLaboratory Cert. #:
5579
Laboratory Name:
West Carteret Water Corporation
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Anna Ostendorff
Inspection Date:
January 30, 2020
Date Forwarded for Initial
February 5, 2020
Review:
Initial Review by:
Michael Cumbus
Date Initial Review
February 7, 2020
Completed:
❑ Insp. Initial
® Insp. Reg
Cover Letter to use:
❑Insp. No Finding
❑Corrected
❑Insp. CP
❑Insp. Reg. Delay
(to use: rt click, properties, chock)
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
2/7/2020
Date Forwarded to Admin.:
2/10/2020
Date Mailed:
2/10/2020
Special Mailing Instructions:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. HANIEL SMITH
Director
5579
Ms. Lisa Guarino
West Carteret Water Corporation
4102 Hwy 24
Newport, NC 28570
NORTH CAROLINA
Environmental Qualify
February 10, 2020
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Ms. Guarino:
Enclosed is a report for the inspection performed on January 30, 2020 by Anna Ostendorff. Where
Finding(s) are cited in this report, a response is required. Within thirty days of receipt, 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 2H .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 wish to obtain an electronic copy of this report by email or if you have questions
or need additional information, please contact me at (919) 733-3908 Ext. 259.
Sincerely,
1,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Dana Satterwhite, Anna Ostendorff
North Carolina Department of Lnvi onmental Quality I Division of Water Resources
UE 440 r Reedy Creep (toad 1 1623 Mail Set vice Center ; Raleigh, North Carolina 27h99 1623
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LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
West Carteret Water Corporation
NCO077143
4102 Hwy 24
Newport, NC 28570
5579
January 30, 2020
Field Municipal Maintenance
Anna Ostendorff
Lisa Guarino
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 environmental samples.
GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Benchsheets are well designed, easy to follow and concise. Records are well
organized and easy to retrieve.
The inspector would like to commend the laboratory for staying current with changes in
laboratory certification program requirements by visiting the NC Wastewater/ Groundwater
Laboratory Certification website and proactively implementing new requirements prior to the on -
site inspection. The laboratory has drafted Standard Operating Procedures (SOPs) for all
parameters in compliance with the revised 15A NCAC 02H ,0800 Rules well in advance of the
July 1, 2020 implementation deadline.
The laboratory was voluntarily certified for Temperature by Standard Methods, 2550 B-2010
(Aqueous) and requested it be deleted from their Certified Parameter Listing (CPL) on January
31, 2020. This change was effective January 31, 2020.
All required Proficiency Testing (PT) Samples have been analyzed for the 2019 PT Calendar Year
and the graded results were 100% acceptable.
Contracted analyses are performed by Environment 1, Inc. (Certification # 10).
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#5579 West Carteret Water Corporation
Approved Procedure documents for the analysis of the facility's currently certified Field
Parameters were provided at the time of the inspection.
Documentation
A. Finding: The laboratory benchsheets for pH and Total Residual Chlorine are lacking
required documentation: the method or Standard Operating Procedure and instrument
identification.
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 and instrument identification. 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 (C).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Method Reference and instrument identification (serial number
preferred). Ref: NC WW/GW LC Approved Procedure for the Analysis of pH; NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric).
D. Finding: The laboratory benchsheet for pH is lacking required documentation: 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 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) (L).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Units of measure. Ref: NC WW/GW LC Approved Procedure for
the Analysis of pH.
C. Finding: The laboratory benchsheet for Total Residual Chlorine is lacking required
documentation: Daily Check Standard analysis time.
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 Analysis of Total Residual Chlorine (DPD Colorimetric).
Proficiency Testing
D. Finding: Additional QC beyond what is routine for Compliance Samples is being analyzed
with PT 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 Provider. This means that they are to
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#5579 West Carteret Water Corporation
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, for 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: Proficiency Testing Requirements, November 26, 2019,
Revision 4.
Comment: The laboratory is analyzing a known QC sample from the PT vendor along
with the blind PT Sample. The additional known QC sample is not analyzed with routine
compliance samples. The laboratory may continue to order and analyze the known QC
sample as part of their quality assurance plan but the known QC sample may not be
analyzed on the same day as the blind PT sample.
Comment: The laboratory orders a second Total Residual Chlorine PT Sample and
averages the results of both blind PT Samples for reporting to the vendor. Routine
compliance samples are not duplicated.
E. 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: This was noted for a Total Suspended Residue sample collected February 19,
2019. Sample results reported by the contract lab included a qualifier that precision
between duplicates exceeded the acceptance criterion.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
F. 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).
Recommendation: The laboratory currently reports pH sample results to two decimal
places. It is recommended that the laboratory continue to measure and document sample
results on the benchsheet to two decimal places, and to round to the nearest 0.1 S.U.
when reporting results on the DMR.
Comment: Per PT Vendor instructions, the PT Sample results should be reported to two
decimal places.
IV. PAPER TRAIL INVESTIGATION:
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#5579 West Carteret Water Corporation
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to DMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for West Carteret Water Corporation (NPDES permit #
NC0077143) for May, September and December 2019. No transcription errors were observed.
The facility appears to be doing a good job of accurately transcribing data.
Correcting the above -cited Findings and implementing the Recommendation 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: Anna Ostendorff Date: February 5, 2020
Report reviewed by: Michael Cumbus Date: February 7, 2020
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