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To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5072
Laboratory Name:
Hickory Water Treatment Plant
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
August 17, 2017
Date Forwarded for Initial
Review:
August 28, 2017
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
August 28, 2017
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
August 29, 2017
Date Forwarded to Admin.:
August 31, 2017
Date Mailed:
August 31, 2017
Special Mailing Instructions:
Beater Resources
ENVIRONMENTAL QUALITY
August 31, 2017
5072
Ms. Nicole Hairston
Hickory Water Treatment Plant
P.O. Box 398
Hickory, NC 28603
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Hairston:
L-resin.
Enclosed is a report for the inspection performed on August 17, 2017 by Jason Smith. 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: Dana Satterwhite, Jason Smith, Master File 5072
Hickory Water Treatment Plant
NCO044121
1560 Old Lenoir Rd
Hickory, NC 28601
5072
August 17, 2017
Field Municipal Maintenance
Jason Smith
LOCAL PERSON(S) CONTACTED: Nicole Hairston
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 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. The laboratory analyst was very forthcoming and receptive to implementing the
necessary changes in response to the Findings and Recommendations made during the
inspection.
All required Proficiency Testing (PT) Samples have been analyzed for the 2017 PT Calendar Year
and the graded results were 100% acceptable.
Contracted analyses are performed by Pace Analytical Services, LLC — Asheville, NC
(Certification #40).
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.
Requirements that reference 15A NCAC 2H .0805 (g) (1), stating "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", are
intended to be a requirement to document all pertinent information for historical reconstruction of
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that.
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#5072 Hickory Water Treatment Plant
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
General Laboratory
A. Finding: For chemicals/reagents/consumables that do not have an expiration date (e.g.,
Potassium Permanganate and the standard prepared from it), the laboratory has not
established a policy for assigning expiration dates.
Requirement: If no expiration date is given, the laboratory must have a policy for
assigning an expiration date. Ref: Quality Assurance Policies for Field Laboratories.
Documentation
D. Finding: Error corrections are not consistently properly performed.
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.
Comment: Some instances of errors that were not dated and initialed were noted.
C. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents, as well as documentation of standards and reagents prepared in
the laboratory.
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.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A
NCAC 2H .0805 (g) (1).
Proficiency Testing
D. Finding: The preparation of PT Samples is not documented.
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
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#5072 Hickory Water Treatment Plant
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 the preparation of the Total
Residual Chlorine (TRC) PT Sample would satisfy the documentation requirement.
E. Finding: The laboratory is not analyzing PT Samples 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 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.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
F. Finding: The units of measure (i.e., Standard Units or S.U.) are not documented on the
benchsheets.
Requirement: Data pertinent to each analysis must be maintained for five years.
Certified data must consist of date collected, time collected, samples site, sample
collector, and sample analysis time. The field bench sheets must provide a space for the
signature of the analyst, and proper units of measure for all analyses. Ref: 15A NCAC
2H .0805 (g) (1).
Requirement: The units of measure for pH analyses are Standard Units (S.U.). Ref: NC
WW/GW LC Approved Procedure for the Analysis of pH.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
G. Finding: The laboratory benchsheet was lacking pertinent data: meter calibration time(s).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: meter calibration time(s). Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Comment: Duplicate analyses are no longer required for Field parameters.
H. Finding: The analyst does not initial or sign the benchsheet.
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
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#5072 Hickory Water Treatment Plant
sample analysis time.
initials of the analyst,
.0805 (g) (1).
The field benchsheets must provide a space for the signature or
and proper units of measure for all analyses. Ref: 15A NCAC 2H
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Collector's/analyst's name or initials. 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 pH.
I. Finding: The laboratory benchsheet was lacking pertinent data: instrument identification.
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 pH.
IV. PAPER TRAIL INVESTIGATION:
No paper trail performed.
V. CONCLUSIONS:
Correcting the above -cited Findings will help this laboratory to produce quality data and meet
Certification requirements. The inspector would like to thank the staff for their assistance during
the inspection and data review process. Please respond to all Findings and include
supporting documentation and implementation dates for each corrective action.
Report prepared by: Jason Smith Date: August 28, 2017
Report reviewed by: Tonja Springer Date: August 28, 2017
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