#5414_2012

INSPECTION REPORT ROUTING SHEET

To be attached to all inspection reports in-house only.

Laboratory Cert. #: 5414

Laboratory Name: Webb Creek Water & Sewage, Inc.

Inspection Type: Field Maintenance

Inspector Name(s): Todd Crawford

Inspection Date: May 9, 2012

Date Report Completed: May 14, 2012

Date Forwarded to Reviewer: May 14, 2012

Reviewed by: Jason Smith

Date Review Completed: May 30, 2012

Cover Letter to use: Insp. Initial X Insp. Reg. Insp. No Finding Insp. CP __ Corrected

Unit Supervisor: Dana Satterwhite

Date Received: May 30, 2012

Date Forwarded to Linda: May 31, 2012

Date Mailed: June 1, 2012

_____________________________________________________________________

On-Site Inspection Report

LABORATORY NAME: Webb Creek Water & Sewage, Inc.

NPDES Permit #: NC0062642

ADDRESS: 250 Zachary Lane
Hubert, NC 28539

CERTIFICATE #: 5414

DATE OF INSPECTION: May 9, 2012

TYPE OF INSPECTION: Field Maintenance

AUDITOR(S): Todd Crawford

LOCAL PERSON(S) CONTACTED: William Moody and Greg Kinlaw

I. INTRODUCTION:

This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.

II. GENERAL COMMENTS:

The laboratory was clean and well organized. The facility has all the equipment necessary to perform
the analyses. The system for traceability of consumables needs to be increased; however all other
requested documentation was well organized and quickly made available. Proficiency testing samples
have been analyzed for all certified parameters for the 2012 proficiency testing calendar year and the
graded results were 100% acceptable.

Contracted analyses are performed by Environmental Chemists (Certification #94).

The requirements associated with Findings A, B and C are new policies that have been implemented by
our program since the last inspection

III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:

General Laboratory

Recommendation: The sponge at the bottom of the Dissolved Oxygen meter probe storage and
calibration chamber is gray. It is recommended that this sponge be replaced frequently or that a yellow or
other light color sponge be used so that it can be easily spotted when the sponge gets dirty or develops
mold growth, which can create an oxygen demand that could affect the calibration.

Documentation

Recommendation: In order to improve the quality of the data being reported, it is recommended that
the laboratory expand their data verification system to include a technical peer review process to check
for accuracy and completeness of data on laboratory benchsheets and DMR forms. Steps must be
taken to minimize and correct errors in calculations and may include checks for the following:
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transcription errors, calculation errors, correct application of dilution factors, etc. The transcription
errors noted in the Paper Trail Investigation section of this report, underscore the importance of this
type of technical peer review process.

A. Finding: Proficiency Testing (PT) sample analyses were not documented in the same manner
as routine environmental samples.

Requirement: The analysis of PT samples is designed to evaluate the entire process used to
routinely report environmental analytical results; therefore, PT samples must be analyzed and
the process documented in the same manner as environmental samples. Ref: Quality
Assurance Policies for Field Laboratories.

Comment: Copies of PT documentation (submitted evaluation forms) were available.

B. Finding: The laboratory needs to increase the documentation of purchased materials used 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.

C. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).

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
Discharge Monitoring Report (DMR) form, in the comment section or on a separate sheet
attached to the DMR form, when any required sample quality control does not meet specified
criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for Field
Laboratories.

Comment: The laboratory was not transcribing data qualifiers from the contract laboratory reports
to the DMR. For example, the contract lab report noted that the Total Suspended Solids sample
collected on January 12, 2012 was analyzed outside its holding time due to a laboratory mistake.
It was also stated that the reporting limit for that sample was elevated due to limited sample
volume. None of this information was transferred to the DMR.

D. Finding: Error corrections are not 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
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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: Use of Wite-Out® was observed on benchsheets dated February 15, March 13, and
March 27, 2012.

pH – Standard Methods, 18th Edition, 4500 H+ B

E. Finding: Data values are reported on the Discharge Monitoring Report to 0.01 S.U., not 0.1 S.U.
as required by the method.

Requirement: A variance of ± 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, 18th Edition, 4500 H+ B. (6).

Temperature – Standard Methods, 18th Edition, 2550 B

F. Finding: The thermometer used to measure reported temperature values is not labeled with its
temperature correction factor.

Requirement: All thermometers and temperature measuring devices must be checked every
12 months against a NIST certified or NIST traceable thermometer and the process
documented. The thermometer/meter readings must be less than or equal to 1ºC from the NIST
certified or NIST traceable thermometer reading. The documentation must include the serial
number of the NIST certified thermometer or NIST traceable thermometer that was used in the
comparison. Also document any correction that applies on both the thermometer/meter and on
a separate sheet to be filed. Ref: Technical Assistance for Field Analysis of Temperature.

IV. PAPER TRAIL INVESTIGATION:

The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality (DWQ). Data
were reviewed for January, February and March, 2012. The following errors were noted:
Date Parameter Location Value on Contract Lab Report Value on DMR
01/09/12 TSS Effluent 3.9 mg/L 5.9 mg/l
01/12/12 TSS Effluent < 15.6 mg/L 15.6 mg/L
01/12/12 Ammonia Effluent 3.3 mg/L 3.4 mg/L
01/24/12 Ammonia Effluent 5.4 mg/L 6.7 mg/L
01/24/12 TSS Effluent 2.9 mg/L 3.7 mg/L
02/07/12 BOD Effluent < 7 mg/L 0 mg/L
03/06/12 Total Phosphorus Effluent 0.37 mg/L 0.57 mg/L
03/07/12 BOD Effluent < 2 mg/L 0 mg/L

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In addition to those stated above, all other TSS and ammonia values that were reported as a “less than”
values on the contract lab reports were reported as “zero” on the DMRs. The analyst had assumed that
since “less than” values could be treated as “zero” when calculating the arithmetic mean, that zeroes
should be reported as the daily values. The analyst was instructed to report the actual value with the
“less than” sign in the space for the daily value and then treat those values as zero when doing the
monthly average calculation. DWQ’s guidance document on the treatment of “less than” values in DMR
reporting was provided during the inspection.

In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be forwarded to the Regional Office.

V. CONCLUSIONS:

Correcting the above-cited findings and implementing the recommendation will help this lab 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.

Report prepared by: Todd Crawford Date: May 14, 2012
Report reviewed by: Jason Smith Date: May 30, 2012