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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 215
Laboratory Name: City of Mount Holly WWTP
Inspection Type: Municipal Maintenance
Inspector Name(s): Beth Swanson and Anna Ostendorff
Inspection Date: November 30, 2017
Date Forwarded for Initial
Review: December 8, 2017
Initial Review by: Anna Ostendorff
Date Initial Review
Completed: December 15, 2017
Cover Letter to use:
Insp. Initial
Insp. No Finding
Corrected
Insp. Reg
Insp. CP
Insp. Reg. Delay
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: December 21, 2017
Date Forwarded to Admin.: January 3, 2018
Date Mailed: January 3, 2018
Special Mailing Instructions:
On-Site Inspection Report
LABORATORY NAME: City of Mount Holly WWTP
NPDES PERMIT #: NC0021156
ADDRESS: 165 Broome St.
Mount Holly, NC 28120
CERTIFICATE #: 215
DATE OF INSPECTION: November 30, 2017
TYPE OF INSPECTION: Municipal Maintenance
AUDITOR(S): Beth Swanson and Anna Ostendorff
LOCAL PERSON(S) CONTACTED: Johnathan Jordan, Doug Shoutd and Mike Moretz
I. INTRODUCTION:
This laboratory was inspected by representatives of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements of
15A NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory is clean, spacious and contains all equipment necessary to perform the analyses.
Records are organized and easily accessible. The laboratory staff were forthcoming and receptive
to recommendations.
All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year
and the graded results were 100% acceptable.
The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedures
(SOP) document(s) 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 January 15, 2019.
The laboratory is reminded that any time changes are made 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 laboratory. 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 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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Requirements that reference 15A NCAC 2H .0805 (a) (7) (A), stating “All analytical data pertinent
to each certified analysis must be filed in an orderly manner so as to be readily available for
inspection upon request”, are intended to be a requirement to document information pertinent to
reconstructing final results and demonstrating method compliance. Use of this requirement is not
intended to imply that existing records are not adequately maintained unless the Finding speaks
directly to that.
Contracted analyses are performed by Shealy Environmental Services, Inc. (Certification # 329).
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:
Quality Control
Comment: Laboratory thermometers are checked against a National Institute of Standards and
Technology (NIST) traceable thermometer every 6 months. The NIST comparison is only required
every 12 months. Temperatures of the refrigerators, residue oven and fecal water bath are
monitored and documented each shift (i.e., 3 times per day), which is more often than required.
Comment: Sample duplicates are not a required quality control element for Field Parameters (i.e.,
Dissolved Oxygen, pH, Temperature, Total Residual Chlorine [TRC] and Specific Conductance).
The laboratory is currently analyzing duplicates on TRC samples.
A. Finding: Auto-pipettors are not calibrated twice per year.
Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable
auto-pipettors, bottle-top dispensers, etc.) must be calibrated at least twice per year,
approximately six months apart. Each liquid-dispensing device must meet the
manufacturer’s statement of accuracy. For variable volume devices used at more than one
setting, check the accuracy at the maximum, middle and minimum values. Testing at more
than three volumes is optional. When a device capable of variable settings is dedicated to
dispense a single specific volume, calibration is required at that setting only. Ref: NC
WW/GW LC Policy.
Comment: The laboratory has not been calibrating the auto-pipettors used to prepare the
annual total Residual Chlorine calibration verification standards.
B. Finding: The laboratory is using a total immersion thermometer in the fecal water bath
improperly.
Requirement: Thermometers with no indicated depth are the total immersion type. When
a partial-immersion thermometer is used, the bottom of the thermometer up to the
immersion line should be exposed to the temperature being measured, with the remainder
of the thermometer exposed to ambient conditions. When a total immersion thermometer
is used, the bulb and the entire portion of the stem containing liquid, except for the last 1
cm, are exposed to the temperature being measured. If the thermometer is not used in this
manner, the thermometer immersion is incorrect. Ref: “User-Friendly Guidance on the
Replacement of Mercury Thermometers”, https://www.epa.gov/sites/production/files/2015-
10/documents/nistuserfriendlyguide.pdf.
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Comment: The laboratory’s previous thermometer could be used as total immersion
because it had a shorter length, however, the gradation marks were 0.2 °C. The total
immersion thermometer that the laboratory is using now has gradations in 0.1 °C, but it is
too long to use properly. It is also lying sideways at a slight angle inside the water bath.
C. Finding: Acceptance criteria have not been established for all QC elements.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
Comment: The following acceptance criteria have not been established:
• Fecal Coliform duplicate precision
• Suspended Residue duplicate precision
• Suspended Residue quarterly check standard recovery
• Total Residual Chlorine duplicate precision
Documentation
Comment: The “DMR Data Composition Book” used as an extra place to document Dissolved
Oxygen results can be eliminated since it is not an original record and does not contain any
additional required information.
Recommendation: It is recommended that all QC acceptance criteria be listed on the applicable
laboratory benchsheet.
Recommendation: It is recommended that “<2 pH” be removed from the chain of custody form
next to Ammonia samples. It gives the appearance that the pH of the sample is being checked
upon arrival at the laboratory, which it is not. The type of preservative needs to be indicated on the
chain of custody for the contract laboratory, but not actual pH.
D. Finding: All original records are not being maintained for five years.
Requirement: Supporting records shall be maintained as evidence that these practices are
being effectively carried out. All analytical records must be available for a period of five
years. Ref: 15A NCAC 2H .0805 (a) (7) and (a) (7) (G).
Comment: The laboratory is not maintaining original records for the upstream and
downstream analysis of Dissolved Oxygen, Temperature and Conductivity. Results are
recorded on Post-it ® notes and transported back to the laboratory for documentation on
the benchsheet. The notes are then discarded.
E. Finding: Values obtained for the daily and quarterly weight checks are not documented.
Requirement: The analytical balance must be checked with one class S, or equivalent,
standard weight each day used and at least three standard weights quarterly. The values
obtained must be recorded in a log and initialed by the analyst. 15A NCAC 2H .0805 (a) (7)
(K).
F. Finding: Units of measure are not consistently documented on the benchsheets.
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Requirement: All laboratories must use printed laboratory bench worksheets that include a
space to enter the signature or initials of the analyst, date of analyses, sample identification,
volume of sample analyzed, value from the measurement system, factor and final value to
be reported and each item must be recorded each time samples are analyzed. Ref: 15A
NCAC 2H .0805 (a) (7) (H).
Comment: Units of measure are lacking in the following instances:
• Temperature Log
• pH, DO and TRC on laboratory benchsheet
• Temperature on operator’s log
Recommendation: The preceding list may not be all-inclusive. It is recommended that all
benchsheets are periodically checked for proper units of measure.
Proficiency Testing
G. Finding: The laboratory does not have a documented plan for PT procedures.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
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 results and related Corrective Action Reports (CARs). Ref:
Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
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 (e.g., pH), but it is recommended that the instructions be maintained. Ref:
Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
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: As specified in 15 NCAC 2H .0800, in order to meet the minimum standards
for Certification, laboratories must use acceptable analytical methods. The acceptable
methods are those defined or referenced in the current State and federal regulations for the
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environmental matrix being tested. All samples, (including PT Samples) that are, or that
may, be used for Certification purposes, must be analyzed using approved methods only.
All PT Samples are to be analyzed and the results reported in a manner consistent with the
routine analysis and reporting requirements of Compliance Samples. Laboratories must
document any exceptions. 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, May 31, 2017, Revision 2.0.
Comment: The analyst documents most but not all required calibration and analysis data
on notebook paper, which is filed with the PT report form. Items not documented include
units of measure and times of calibration and analysis.
Recommendation: It is recommended that PT Sample analysis be documented on the
laboratory’s daily benchsheet.
Bacteria – Coliform Fecal – Standard Methods, 9222 D-1997 (MF) (Aqueous)
Recommendation: It is recommended that presence/absence of Total Residual Chorine (TRC) at
collection be documented on the Fecal Coliform benchsheet. The TRC sample is collected at the
same time as the Fecal Coliform sample. The laboratory has been assuming that if the TRC
sample does not have a residual, then the Fecal Coliform sample would be acceptable based on
the amount of Sodium Thiosulfate added to the bottle.
J. Finding: Sample bottle sterility is not verified.
Requirement: Minimally test for sterility one sample bottle per batch sterilized in the
laboratory, or at a set percentage such as 1 to 4%. This is performed by adding sterile
dilution/rinse water to the bottle after sterilization and then subsequently analyzing it as a
sample. Document results. Ref: NC WW/GW LC Policy.
K. Finding: The laboratory was not documenting their use of heat-indicating tape. This is
considered pertinent information.
Requirement: Use heat-indicating tape to identify supplies and materials that have been
sterilized. Ref: Standard Methods 9020 B-2005. (4) (h).
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (a) (7) (A).
L. Finding: The laboratory is not monitoring the quality of the reagent water used in Fecal
Coliform analysis.
Requirement: At a minimum, reagent water used to prepare buffered dilution/rinse water
or media must be analyzed at least every twelve months for the following parameters:
Specific Conductance, Total Organic Carbon, Cadmium, Chromium, Copper, Nickel, Lead,
and Zinc.
Maximum Acceptable Limits are:
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Total Organic Carbon < 1.0 mg/L
Specific Conductance < 2 µmhos/cm
Heavy Metals, single element < 0.05 mg/L
Heavy Metals, Total of cited elements < 0.10 mg/L
Ref: NC WW/GW LC Policy.
M. Finding: Plate comparison counts are not being performed.
Requirement: For routine performance evaluation, repeat counts on one or more positive
samples at least monthly, record results, and compare the counts with those of other
analysts testing the same samples. Replicate counts for the same analyst should agree
within 5% (within analyst repeatability of counting) and those between analysts should
agree within 10% (between analysts reproducibility of counting). If they do not agree,
initiate investigation and any necessary corrective action. Ref: Standard Methods, 9020 B-
2005. (9) (a).
N. Finding: Consumable materials used for the Fecal Coliform MF method are not properly
tested.
Requirement: Before a new lot of consumable materials are used for the Fecal Coliform
MF method, those materials must be tested and compared to those currently in use to
ensure they are reliable. Consumable materials included in this requirement are:
membrane filters and/or pads (often packaged together) and media. It is recommended that
only one consumable be tested at a time. At a minimum, make single analyses on five
positive samples that will yield 20-60 colonies for both the current lot and the new lot.
There are two options for determining acceptance of results:
Option 1: Follow the acceptance criteria described in Standard Methods 9020 B-2005. (5)
(f) (2) (a) and (b).
Option 2: Compare the average colony count of each five-sample set and evaluate against
your routine sample duplicate acceptance criterion. Ref: NC WW/GW LC Policy.
Comment: The laboratory conducts comparison tests using the effluent at the following
dilution volumes: 100,100, 50, 50, and 1 mL and often the colony counts are zero or below
20. The results are not evaluated to determine the acceptability of the new lot of
consumable being tested.
Recommendation: It is recommended that the laboratory test the influent or their culture
positive to obtain counts within 20-60 colonies.
O. Finding: Culture positive plates are not countable.
Requirement: A culture positive must be analyzed with each batch of prepared media and
once per week for purchased ready-to-use media. A sample volume that yields a countable
plate must be analyzed so that individual colonies may be verified to have proper
morphology (i.e. color, shape, size, surface appearance). Ref: NC WW/GW LC Policy.
Comment: The volume used often produces plates that are too numerous to count.
P. Finding: The sample volumes analyzed do not consistently yield a plate of at least 20
colonies.
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Requirement: Use sample volumes that will yield counts between 20 and 60 fecal coliform
colonies per membrane. Ref: Standard Methods, 9222 D-1997. (2) (a).
Comment: The laboratory’s normal practice is to analyze sample volumes of 50, 25 and 1
mL. There are often less than 20 colonies per plate.
Recommended: It is recommended that volumes of 100, 50 and 10 mL be analyzed.
Q. Finding: Sample results are not always calculated and reported correctly.
Requirement: Countable Membranes with 20-60 Blue Colonies: Calculate the fecal
coliform results from membrane filters within the ideal counting range of 20-60 blue
colonies using the general formula:
Number of colonies counted x 100 = Fecal coliform colonies per 100 ml
volume of sample filtered in ml
Ref: NC WW/GW LC Policy
Comment: All plate counts are used when one plate is between 20 and 60 colonies. The
data reviewed showed a slight high bias in the calculated results.
Residue, Suspended – Standard Methods, 2540 D-1997 (Aqueous)
Recommendation: It is recommended that the oven temperature column be removed from the
benchsheet. The oven temperatures are recorded elsewhere and this column is left blank on the
benchsheet.
R. Finding: The laboratory is not analyzing a volume of sample to yield a minimum of 2.5 mg
dried residue.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. If
volume filtered fails to meet minimum yield, increase sample volume up to 1 L. Ref:
Standard Methods, 2540 D-1997. (3) (b).
Comment: Typically, 200 mL of sample is analyzed and the minimum of 2.5 mg is not
consistently obtained.
Comment: The range of measurement for Suspended Residue is determined by the
optimum solids loading on the filter, which can be controlled by adjusting the volume of
sample filtered. The method-defined reporting limit for Suspended Residue is 2.5 mg/L
when filtering 1 L of sample. This sample volume may not be necessary to demonstrate
compliance with regulatory limits; however, it is not acceptable to routinely report less-than
results using a reporting limit greater than 2.5 mg/L. A copy of this report will be shared
with the regional office.
S. Finding: The laboratory is not basing the reporting limit on the minimum weight gain
required by the method.
Requirement: The minimum weight gain allowed by any approved method is 2.5 mg.
Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes a
minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete
filtration takes more than 10 minutes increase filter diameter or decrease sample volume. In
instances where the weight gain is less than the required 2.5 mg, the value must be
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reported as less than the appropriate value based upon the volume used. Ref: NC WW/GW
LC Policy.
Comment: For example, if 200 mL of sample is analyzed and < 2.5 mg of dried residue is
obtained, the value reported would be < 12.5 mg/L. Currently, the calculated result is
reported without “<” designation despite the value being below the method defined
reporting limit of 2.5 mg/L (e.g., one result was reported as 2 mg/L).
T. Finding: Filters are not dried to constant weight daily and the annual drying study is not
properly performed.
Requirement: Constant weights must be documented. The approved methods require the
following: “Repeat the cycle of drying, cooling, desiccating, and weighing until a constant
weight is obtained or until the weight change is less than 4% of the previous weight or 0.5
mg, whichever is less.” In lieu of this, an annual study documenting the time required to dry
representative samples to a constant weight may be performed. Verify minimum daily
drying time is greater than or equal to the time used for the initial verification study drying
cycle. Drying cycles must be a minimum 1 hour for verification. Ref: NC WW/GW LC Policy.
Comment: During the annual study, the laboratory does not dry the filter to constant weight
or document the drying time. Also, the sample is not representative of the daily drying
conditions because only 1 mL of sample is used.
U. Finding: The laboratory follows an unapproved method.
Requirement: Laboratory Procedures. Analytical methods, sample preservation, sample
containers and sample holding times shall conform to those requirements found in 40 CFR-
136.3. Ref: 15A NCAC 2H .0805 (a) (1).
Comment: The laboratory references SM 2540 D 18th Edition.
Chlorine, Total Residual – Standard Methods, 4500 Cl G-2000 (Aqueous)
V. Finding: The laboratory is not analyzing a reagent blank with prepared standards.
Requirement: Reagent Blank: A reagent blank (sometimes also referred to as a method
blank) is only required when laboratory water is used to make quality control and/or
calibration standards. If you are using a sealed standard (e.g., gel) for your daily check
standard, a reagent blank would only be analyzed when preparing the annual 5-point
calibration curve or 5 annual calibration curve verification standards. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: A reagent blank is made from the same laboratory water source used to make
QC and/or calibration standards with DPD. The concentration of reagent blanks must not
exceed 50% of the reporting limit (i.e., the lowest calibration or calibration verification
standard concentration), unless otherwise specified by the reference method, or corrective
action must be taken.
W. Finding: The laboratory is not verifying the instrument’s factory-set calibration curve every
12 months.
Requirement: Zero the instrument with chlorine-free water and then analyze a reagent
blank (i.e., reagent water plus buffer and DPD) and a series of five standards. The curve
verification must bracket the range of the samples to be analyzed. This type of curve
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verification must be performed at least every 12 months. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
Comment: The last curve verification was performed on November 16, 2016.
X. Finding: The laboratory did not verify the Gel® Standard concentration before initial use
and it has not been verified every 12 months since being put into use.
Requirement: Purchased “Gel-type” or sealed liquid ampoule standards may be used for
daily standard curve verification only. These standards must be verified initially and every
12 months thereafter, with the standard curve. When this is done, these standards may be
used after the manufacturer’s expiration date. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Total Residual Chlorine. Please submit a copy of the gel verification
with the report reply.
Comment: The laboratory is using the concentration provided by the manufacturer.
Y. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent when duplicate sample analyses are 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: The laboratory reports the first sample result.
Conductivity – Standard Methods, 2510 B-1997 (Aqueous)
Recommendation: It is recommended that the method reference be added to the benchsheet,
since this requirement is being added to the Approved Procedures as they are updated.
Z. Finding: The Automatic Temperature Compensator (ATC) was not verified prior to initial
use and every 12 months thereafter.
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 LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity).
Comment: Anticipated temperatures can be obtained from a review of the eDMRs from the
peak summer and winter months. Historical data should provide a reasonably accurate
estimation of ranges that will bracket the expected sample temperatures.
Dissolved Oxygen – Standard Methods, 4500 O G-2001 (Aqueous)
AA. Finding: The laboratory is not performing a post-analysis calibration verification when
analyses are performed away from the certified laboratory’s primary location.
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Requirement: When performing analyses away from the certified laboratory’s primary
location, a post-analysis calibration verification must be analyzed at the end of the run. It is
recommended that a mid-day calibration verification be performed when samples are
analyzed over an extended period of time. The calculated 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. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Dissolved Oxygen.
Comment: The laboratory analyzes Dissolved Oxygen (DO) at upstream and downstream
sites after calibrating in the laboratory. The laboratory may choose to calibrate at each site
rather than performing the post-analysis calibration verification.
pH – Standard Methods, 4500 H+B-2000 (Aqueous)
BB. Finding: The laboratory benchsheet is lacking pertinent data: Time of sample analysis.
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (a) (7) (A).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: time of sample analysis. Ref: NC WW/GW LC Approved Procedure
for the Analysis of pH.
Temperature – Standard Methods, 2550 B-2000 (Aqueous)
CC. Finding: The laboratory does not have an Analytical QC Document or SOP for this
parameter.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
DD. Finding: The laboratory benchsheet is lacking pertinent data: Time of sample collection
and time of sample analysis.
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (a) (7) (A).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: time of sample collection and time of sample analysis. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: Samples are brought into the laboratory to be analyzed. The collection time is
not documented and the analysis time is not specific. The result is documented in a row
corresponding with the hour (e.g., 0700, 0800, etc.) the analysis is performed.
Chlorine, Total Residual – Standard Methods, 4500 Cl G-2000 (Aqueous)
Temperature – Standard Methods, 2550 B-2000 (Aqueous)
EE. Finding: The laboratory benchsheet is lacking pertinent data: Instrument identification.
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Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (a) (7) (A).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Instrument identification. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved Procedure for
the Analysis of Temperature.
Comment: A serial number is the preferred method of identification.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to electronic Discharge Monitoring Reports (eDMRs) submitted to
the North Carolina Division of Water Resources. Data were reviewed for City of Mount Holly
WWTP (NPDES permit # NC0021156) for January, May and August 2017. No transcription
errors were observed. The facility appears to be doing a good job of accurately transcribing
data.
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 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: Beth Swanson Date: December 8, 2017
Report reviewed by: Anna Ostendorff Date: December 15, 2017