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HomeMy WebLinkAbout#5051_2017_0301_NJ_FINALINSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5051 Laboratory Name: Aqua North Carolina, Inc. Eastern NC Inspection Type: Field Commercial Maintenance Inspector Name(s): Nick Jones, Dana Satterwhite, Todd Crawford, Tonja Springer, Beth Swanson, Anna Ostendorff Inspection Date: March 1, 2017 Date Forwarded for Initial Review: April 6, 2017 Initial Review by: Beth Swanson Date Initial Review Completed: April 7, 2017 Cover Letter to use: ❑ Insp. Initial ® Insp. Reg ❑Insp. No Finding ❑Insp. CP ❑Corrected ❑Insp. Reg. Delay Unit Supervisor/Chemist III: Todd Crawford Date Received: April 10, 2017 Date Forwarded to Admin.: May 2, 2017 Date Mailed: May 2, 2017 Special Mailing Instructions: Forward copies to Stephanie Goss and Ted Cashion at RRO Water Resources ENV(RONMEN i AL. QUALITY May 2, 2017 5051 Mr. Chris Weaver Aqua North Carolina Inc. Eastern NC 202 MacKenan Ct. Cary, NC 27511 MICHEAL S. REGAN S. JAY ZIMMERMAN Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC) Maintenance Inspection Dear Mr. Weaver: Enclosed is a report for the inspection performed on March 1, 2017 by Nick Jones. 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 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. 251. Sincerely, Todd Crawford Technical Assistance & Compliance Specialist NC WW/GW Laboratory Certification Branch Attachment cc: Nick Jones, Dana Satterwhite, Master File 5051 On -Site Inspection Report LABORATORY NAME: Aqua North Carolina, Inc. Eastern NC NPDES PERMIT #: NC0038784, NC0040606, NC0049662, NC0051314, NC0055051, NC0055701, NC0056391, NC0056413, NC0058505, NC0059099, NC0060577, NC0061719, NC0062715, NC0062740, NC0063614, NC0064564, NC0065714, NC0073679, NC0082996, NC0085863, NC0086690, NC0087998, NC0088714, NCO088862 and NCO088889 WATER QUALITY PERMIT #: WQ0000088, WQ0018146, WQ0019569, WQ0021934, WQ0022870, WQ0024844 and WQ0028798 ADDRESS: 202 MacKenan Ct. Cary, NC 27511 CERTIFICATE #: 5051 DATE OF INSPECTION: March 1, 2017 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Nick Jones, Dana Satterwhite, Todd Crawford, Tonja Springer, Beth Swanson and Anna Ostendorff LOCAL PERSON(S) CONTACTED: Chris Weaver, Andy Stevens, Eric Riggins, Kathy Broadwell, Peter Rhodes, Ray Dixon, Ron Wall, Scott Thompson, Andy Stevens, Todd Marcum, Ronnie Dickens and Wesley Bishop 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. GENERAL COMMENTS: The open and forthcoming culture of the lab was reassuring and appreciated. In some instances, the lab began the corrective action process immediately. The laboratory has multiple operators, which in some cases, service many permits. The laboratory indicated that this report would be shared with the other Aqua North Carolina, Inc. divisions, so that they may determine where any similar deficiencies in compliance may be and voluntarily correct them. All required Proficiency Testing (PT) samples for the 2017 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, 2017. Contracted analyses are performed by Environmental Conservation Laboratories, Inc. (Certification # 591). #5051 Aqua North Carolina, Inc. Eastern NC Current Quality Assurance Policies for Field Laboratories and 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 Recommendation: It is recommended that the laboratory implement equipment maintenance logs. A. Finding: The auto-pipettors have not been calibrated annually as required. Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-pipettors, bottle -top dispensers, etc.), used for critical measurements, must be calibrated at least every twelve months and documented. 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: Quality Assurance Policies for Field Laboratories, B. Finding: Data that does not meet all QC requirements on contract laboratory reports (i.e., qualified data) is not qualified on the eDMR. Requirement: When Quality Control (QC) failures occur, the laboratory must attempt to determine the source of the problem and must apply corrective action. Part of the corrective action is notification to the end user. If data qualifiers are used to qualify samples not meeting QC requirements, the data may not be useable for the intended purposes. It is the responsibility of the laboratory to provide the client or end -user of the data with sufficient information to determine the usability of the qualified data. Where applicable, a notation must be made on the electronic Discharge Monitoring Report (eDMR) form, in the comment section when any required QC does not meet specified criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field Laboratories. Comment: For help accessing the comments section on the eDMR contact Tom Moore at 919-707-8945 or tom.f.moore@ncdenr.gov. Documentation C. Finding: Error corrections are not always performed properly. Requirement: All documentation errors must 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. Write the correction adjacent to the error. The correction must be initialed by the responsible individual and the date of change documented. All data and log entries must be written in indelible ink. Pencil entries are not acceptable. Ref: Quality Assurance Policies for Field Laboratories. D. Finding: The laboratory needs to increase the documentation of purchased materials and reagents, as well as documentation of standards and reagents prepared in the laboratory. #5051 Aqua North Carolina, Inc. Eastern NC Requirement: All chemicals, reagents, standards and consumables used by the laboratory must have the following information documented: Date Received, Date Opened (in use), Vendor, Lot Number, and Expiration Date. 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 chemicals, reagents, standards and consumables used for a period of five years. Consumable materials such as pH buffers and lots of pre -made standards are included in this requirement. Ref: Quality Assurance Policies for Field Laboratories. Comment: Some of the laboratory's operators could not verify the expiration date of their pH buffers. The operators would take aliquots from the main pH buffer reservoirs located at the laboratory headquarters. However, they did not write the new expiration dates or lot #s associated with the new aliquots on their buffer containers or on a separate document. The main buffer reservoirs located at headquarters were not expired, but there was no way to confirm that these were the buffers being currently utilized by every operator. E. Finding: Process control data is not documented as such. Requirement: Data pertinent to each analysis must be maintained for five years. Certified Data must consist of date collected, time collected, sample site, sample collector, and sample analysis time. The field benchsheets must provide a space for the signature or initials of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1). Comment: Several instances of data for various parameters did not have calibration data associated with it. After checking permit sampling frequency requirements, it was discovered that this data, collected without supporting calibrations or calibration checks, was for process control and not for compliance monitoring purposes. Since neither the process control nor the compliance data were identified as such, it appeared that all the data was for compliance purposes and that some of it was lacking necessary components of Quality Assurance. Temperature — Standard Methods, 2550 B-2000 (Aqueous) F. Finding: The laboratory benchsheet is lacking pertinent data: collection/analysis time, instrument identification (e.g., serial number). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: time of sample collection, time of sample analysis, instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature. Comment: The benchsheets contained spaces for collection and analysis time for Temperature. Temperature samples are measured in -situ (i.e., collection and analysis times are the same). The benchsheet needs clarification. Sometimes the benchsheet had the same time in both spaces. Other times one of the spaces would be empty. #5051 Aqua North Carolina, Inc. Eastern NC Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous) Dissolved Oxygen — Hach 10360-2011, Rev. 1.2 (LDO) (Aqueous) G. Finding: The laboratory benchsheet is lacking pertinent data: meter calibration time, units (i.e., mg/L.), instrument identification (e.g., serial number) and analyst's initials. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: meter calibration time, units (i.e., mg/L), instrument identification, collector's/analyst's name or initials. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. H. Finding: Some of the meters are not being calibrated in moist air for the air calibration. Requirement: The laboratory must use moist air for the air calibration. This is accomplished by calibrating the electrode in an environment with a high relative humidity. Using dry air for the calibration can result in errant readings. Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen. Comment: Some of the meters are being calibrated with the probe submerged in water. Recommendation: In at least one instance the probe was being calibrated by holding the tip of the probe casing to the mouth of a partially filled water bottle. However, the probe housing is vented and does not allow for an adequate seal to create water saturated air. It is recommended that probes with a vented probe housing be calibrated with the probe inside a baggie containing a small amount of water and a rubber band placed tightly around the probe shaft to create an airtight seal. I. Finding: The permit requires once per week monitoring. The facility voluntarily analyzes Dissolved Oxygen samples daily but does not report all the data as required. 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 monthly report forms. Ref: 15A NCAC 02B .0506 (b) (3) (J). pH — Standard Methods, 4500 H+113-2000 (Aqueous) Recommendation: It is recommended that the laboratory not reuse calibration buffers. A fresh aliquot should be used daily. Currently, the laboratory is using the same aliquot of buffer solution for three months. J. Finding: The laboratory benchsheet is lacking pertinent data: meter calibration, meter calibration time, true value of calibration buffers, true value of the check buffer, value obtained for the check standard buffer (verification of ± 0.1 S.U.), analysis time, instrument identification (e.g., serial number), analysts initials. Requirement: The following must be documented in indelible ink whenever sample analysis is performed: meter calibration, meter calibration time, true value of calibration buffers, true value of the check buffer and value obtained for the check standard buffer (verification of ± 0.1 S.U.), analysis time, instrument identification, collector's/analyst's name or initials. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. #5051 Aqua North Carolina, Inc. Eastern NC K. Finding: Some of the instruments are not being calibrated according to the manufacturer's calibration procedure prior to analysis of samples each day compliance monitoring is performed. Requirement: Instruments are to be calibrated according to the manufacturer's calibration procedure prior to analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: Some of the meters are only being calibrated weekly for some permits where pH is required to be reported five times per week. L. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior to sample analysis. Requirement: The meter must be calibrated with at least two buffers. In addition to the calibration standards the meter must be verified with a third calibration standard. The calibration and check standard buffer must bracket the range of the samples being analyzed. The check standard buffer must read within a range of ± 0.1 pH units to be acceptable. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Comment: The laboratory thought a 2-point calibration was being performed with a calibration check (i.e., the laboratory thought the first two buffers being analyzed were the calibration and the third was the calibration check). However, the meter was interpreting the assumed calibration check buffer as a third calibration point and no calibration check buffer was being analyzed. M. Finding: The laboratory is not analyzing a post analysis check standard buffer when analyses are performed at multiple locations. Requirement: When performing analyses away from the certified laboratory's primary location, a post analysis calibration verification using the check standard buffer must be analyzed at the end of the run. Ref: NC WW/GW LC Approved Procedure for the Analysis of pH. Recommendation: It is recommended that in addition to analyzing a post -analysis check standard buffer, a mid -day check standard buffer must also be analyzed if multiple locations are visited over an extended period of time. The post analysis check standard buffer(s) must read within ±0.1 S.0 or corrective actions must be taken. N. 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-2000. (6). Chlorine, Total Residual - Hach 10014 ULR (Aqueous) Chlorine, Total Residual - Standard Methods, 4500 Cl G-2000 (Aqueous) Recommendation: Where applicable, it is recommended to indicate on the eDMR that UV is the primary means of disinfection when no Total Residual Chlorine values are reported. #5051 Aqua North Carolina, Inc. Eastern NC Recommendation: It is recommended that the following concentration levels are chosen for the annual low-level Total Residual Chlorine calibration verification: 10 (or 20 depending on the permit limit), 30, 50, 200 and 400 µg/L. The first level (i.e., 10 or 20 µg/L) needs to be at or below your permitted reporting limit. The second level (i.e., 30 µg/L) needs to be between the reporting limit and the compliance limit (i.e., 50 µg/L). The third level (i.e., 50 µg/L) needs to be at the compliance limit. The fourth level (i.e., 200 µg/L) needs to be at the same concentration as the gel standard (i.e., 200 µg/L) used for daily calibration verification. The fifth level (i.e., 400 µg/L) needs to be high enough to hopefully bracket the annual PT sample, but still within the meter's upper range limit (i.e., 500 jig/Q. Comment: The laboratory was not verifying the instrument's factory set curve for regular level Total Residual Chlorine every 12 months. The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states: Analyze a water blank to zero the instrument and then analyze a series of five standards. The curve verification must check 5 concentrations (not counting the blank) that bracket the range of the samples to be analyzed. This type of curve verification must be performed at least every 12 months. The values obtained must not vary by more than 10% of the known value. The overall correlation coefficient of the curve must be z0.995. Notification of acceptable corrective action (i.e., completed Total Residual Chlorine calibration verification worksheets containing acceptable curve verifications for all applicable meters) was received by email on March 17, 2017. No further response is necessary for this Finding. Comment: The calibration curve verification instruction sheet does not reflect the dilution volumes being prepared. The sheet says that 100-mL is being added to a 4-mL aliquot of standard, when 4-mL of standard is actually brought up to 100-mL in a volumetric flask. The instruction sheet needs to be revised. O. Finding: The laboratory benchsheet is lacking pertinent data: meter calibration, meter calibration time, true value of the daily check standard, value obtained for the daily check standard, value obtained for the reagent blank (i.e., for operators that use a liquid standard for daily calibration), true value of the post analysis check standard, value obtained for the post analysis check standard, sample collection time, analysis time, units (i.e., mg/L or µg/L), instrument identification (e.g., serial number). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: meter calibration and meter calibration time, true value of the check standard, value obtained for the check standard, value obtained for the reagent blank, when prepared standards are used (verification of <1h the concentration of the lowest calibration standard), true value and value obtained for the post analysis check standard, time of sample collection, time of sample analysis, all data must be reported in mg/L or µg/L, instrument identification. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: On some benchsheets no units were observed, on others improper units were observed (e.g., µg/L were on benchsheets containing only results reported in mg/L). P. Finding: One of the annual 5-Standard, low-level calibration curves does not pass all individual standard recovery criteria. Requirement: The values obtained must not vary by more than 10% of the known value for standard concentrations greater than or equal to 50 µg/L and must not vary by more than 25% of the known value for standard concentrations less than 50 jig/L. The overall #5051 Aqua North Carolina, Inc. Eastern NC correlation coefficient of the curve must be >_0.995. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: The 10 µg/L standard in the curve verification for permit # NC0061719 did not meet the ±25% recovery acceptance criterion. Q. Finding: The laboratory is not verifying all Gel® Standards every 12 months. 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. It is only necessary to verify the gel or sealed liquid standard which falls within the concentration range of the curve used to measure sample concentrations. For example, if you are measuring samples against a low range curve, a 200 pg/L standard would be verified, and not the 800 pg/L standard since the 800 pg/L standard would be measured using a high range curve. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. R. Finding: Values less than the established reporting limit are being reported on the eDMR. S T. Requirement: The concentrations of the calibration standards must bracket the concentrations of the samples analyzed. One of the standards must have a concentration equal to or below the lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Comment: Any value less than the concentration of the lowest concentration standard used for the annual curve verification must be reported as less than the value of that lowest calibration standard. Finding: Some of the calibration curves are not verified each day of sample analysis. Requirement: When a five -standard annual standard curve verification is used, the laboratory must check the calibration curve each analysis day. To do this, the laboratory must analyze a calibration blank to zero the instrument and analyze a check standard each day that samples are analyzed. The value obtained for the check standard must read within 10% of the true value of the 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 Total Residual Chlorine. Finding: Some operators are not zeroing the instrument with a liquid calibration blank when using liquid daily check standards. Requirement: Zeroing the Instrument: For colorimetric analyses, a calibration blank must be analyzed each day to zero the instrument prior to analyzing any standards, samples or the reagent blank. A calibration blank is a volume of reagent water of the same matrix as the calibration standards, but without the target analyte and without DPD. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. U. Finding: Some operators are 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 #5051 Aqua North Carolina, Inc. Eastern NC 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 quality control 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. Comment: Some operators were using the reagent blank to zero the instrument. V. Finding: The laboratory is analyzing the sample immediately upon adding the Hach DPD powder pillow. Requirement: Some examples of the allowed types of changes, provided the requirements of this section are met include: (xiii) The use of prepackaged reagents. As such, the proper procedure for using the packaged reagents would then be determined by the manufacturer's instructions. Ref: Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; 136.6. (b) (4). Requirement: For successful testing, especially in treated effluents, strict adherence to the development time is necessary. Three to six minutes of development time are sufficient to resolve all chloramine forms without significant error from competing reactions. Ref: Hach Company, "Current Technology of Chlorine Analysis for Water and Wastewater", 2002. W. Finding: Results are being reported on the eDMRs for samples that are not analyzed. Requirement: Frequency and Location. Except as otherwise provided herein, all industrial establishments and units of government shall take influent, effluent and stream samples at such locations and with such frequency as shall be necessary to conduct the tests and analyses required by Rule .0508 of this Section. Ref: 15A NCAC 2B .0505 (c) (1). Comment: The lab is reporting estimated results on the eDMRs for the weekends without analyzing samples on the weekend. This could be perceived by a third party as falsified data, which is defined in NC Administrative Code 15A NCAC 02H .0803 (6) as data or information which has been made untrue by alteration, fabrication, omission, substitution, or mischaracterization. IV. PAPER TRAIL INVESTIGATION: The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks, etc.) and contract lab reports to eDMRs. Data were reviewed for Beachwood (NPDES permit # NC0060577) from February, March and April 2016; for The Preserve (Water Quality permit # WQ0018146) from August, September and October 2016; for Chapel Ridge (Water Quality permit # WQ0022870) from September 2016; for Trade Winds (NPDES permit # NC0065714) from October, November and December 2016; for Briarwood Farms (NPDES permit # NC0062740) from October, November and December 2016; for Lassiter Farms (NPDES permit # NC0088714) from January 2016; for Nottingham Forest (NPDES permit # NC0055701) from January 2016; for Rand Meadows (NPDES permit # NC0087998) from January 2016; for Hollybrook (NPDES permit # NC0082996) from January 2016; for The Governor's Club (Water Quality permit # WQ0000088) #5051 Aqua North Carolina, Inc. Eastern NC for August and December 2016; for Colvard Farms (Water Quality permit # WQ0019569) from July, September and October 2016; for Lake Ridge Arrow Park (NPDES permit # NC0059099) for February, May and August 2016; for Cole Park Plaza (NPDES permit # NC0051314) from August and December 2016; for Carolina Meadows (NPDES permit # NC0056413) from August 2016; for Crooked Creek (NPDES permit # NC0062715) for November and December 2016; for Cross Creek (NPDES permit # NC0056391) from October, November and December 2016; for Neuse Colony (NPDES permit # NC0064564) for October, November and December 2016. The following errors were noted: #5051 Aqua North Carolina, Inc Permit # Date Parameter Location Value on Benchsheet *Contract Late Data Value on eDMR WQ0018146 10/31/2016 Total Residual Chlorine Effluent 0.2 µg/L 0.1 µg/L WO0018146 10/31/2016 pH Effluent 7.29 s.u. 7.33 s.u. WQ0022870 9/12/2016 Total Residual Chlorine Effluent 0.1 µg/L 1.0 µg/L WQ0022870 11/10/2016 Temperature Effluent 16.8 *C 17.5 °C WQ0022870 12/21/2016 Temperature Effluent 12.5 *C Not Reported NC0062740 10/28/2016 Dissolved Oxygen Effluent 5.22 mg/L 7.07 mg/L NC0062740 12/23/2016 Temperature Effluent 9.5 *C 7.3 *C NC0062740 12/28/2016 BOD Effluent 2.0 mg/L * < 2.0 mg/L NC0062740 12/28/2016 NH3 - N Effluent 0.57 mg/L * <0.57 mg/L NC0062740 12/7/2016 NH3- N Effluent 0.079 mg/L * 3.2 mg/L WQ0000088 12/23/2016 Total Residual Chlorine Effluent No Value on Benchsheet # 0 mg/L WQ0000088 12/27/2016 Total Residual Chlorine Effluent No Value on Benchsheet # 0 mg/L WQ0000088 8/2016 Total Residual Chlorine Effluent All values < 0.1 mg/L were reported as zero. 0 mg/L WQ0000088 8/4/2016 NH3- N Effluent 0.094 mg/L J* J Qualifier Not Reported WQ0000088 8/18/2016 Nitrate Effluent 25 mg/L D* D Qualifier Not Reported WQ0019569 7/11/2016 NH3-N Effluent 0.046 mg/L J* J Qualifier Not Reported WQ0019569 9/30/2016 pH Effluent 7.15 s.u. Not Reported WQ0019569 9/6/2016 pH Effluent 7.56 s.u. 7.60 s.u. WQ0019569 9/29/2016 pH Effluent 7.29 s.u. 7.26 s.u. NC0059099 5/4/2016 NH3- N and TKN Effluent Qualifier* Qualifier Not Reported NC0059099 8/16/2016 Fecal Coliform Effluent >2420 cfu* 2420 cfu NC0059099 8/23/2016 pH Effluent 7.90 s.u. 7.80 s.u. NC0051314 8/4/2016 BOD Effluent >74 mg/L * 74 mg/L NC0051314 8/10/2016 Two results for each: NH3- N, BOD, Fecal Coliform Effluent <0.045 mg/L and 7.7 mg/L, <2.0 mg/L and 10 mg/L, 130 cfu and >2420 cfu, Respectively* Not Reported NC0051314 8/26/2016 MBAS Effluent 2.2 mg/L J* J Qualifier Not Reported NC0051314 8/26/2016 Fecal Coliform Effluent >24200 cfu with qualifier* 24200 cfu NC0051314 8/4/2016 Temperature Effluent 26.9 *C 26.4 °C NC0051314 8/8/2016 Temperature Effluent 28.4 *C 24.8 °C NC0056413 8/2016 Dissolved Oxygen and pH Effluent Various Not reporting all data. NC0056413 8/5/2016 and 8/11 /2016 NH3-N Effluent 0.047 mg/L J* J Qualifier Not Reported NC0056413 8/19/2017 NH3- N Effluent 0.065 mg/L J* J Qualifier Not Reported NC0062715 11/8/2016 NH3- N, Nitrate, Nitrite, Phosphorus Effluent Results with Qualifiers* Qualifiers Not Reported NC0062715 11/21/2016 Dissolved Oxygen Effluent 4.69 mg/L Reported on 11/22/2016 NC0062715 12/7/2016 Dissolved Oxygen Effluent 3.23 mg/L Reported on 12/8/2016 NC0056391 10/14/2016 Fecal Coliform Effluent 1.0 cfu* <1 cfu # The lack of data on the benchsheet suggests that no analysis was performed. The fact that values were reported on the eDMR could be interpreted as falsified data by a third party. #5051 Aqua North Carolina, Inc. Eastern NC Due to the number of errors noted in the paper trail investigation it is recommended that a system of checking the data entered on the eDMR be implemented. It would be beneficial to have a second person review the accuracy of data transcription to the eDMR. At a minimum, the person entering the data should review the transcriptions to the eDMR after some time has passed from the original data entry. In order to avoid questions of legality and/or possible monitoring frequency violations, it is recommended that you contact the appropriate Regional Office for guidance as to whether an amended eDMR 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 its assistance during the inspection and data review process. Please respond to all Findings and include supporting documentation and implementation dates for each corrective action. 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