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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5352
Laboratory Name: Wallace Regional Wastewater Treatment Plant
Inspection Type: Field Maintenance
Inspector Name(s): Todd Crawford
Inspection Date: May 8, 2014
Date Report Completed: May 12, 2014
Date Forwarded to Reviewer: May 12, 2014
Reviewed by: Tonja Springer
Date Review Completed: May 23, 2014
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: 5/23/2014
Date Forwarded to Linda: 5/29/2014
Date Mailed: 5/30/2014
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: Wallace Regional Wastewater Treatment Plant
NPDES PERMIT #: NC0003450
ADDRESS: 311 E. Murphy St.
Wallace, NC 28466
CERTIFICATE #: 5352
DATE OF INSPECTION: May 8, 2014
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Brent Dean
I. 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 laboratory was clean and well organized. The facility has all the equipment necessary to perform the
analyses. Records were also well organized and quickly retrieved upon request.
Proficiency Testing (PT) samples for the 2014 proficiency testing calendar year have not yet been
analyzed. The laboratory is reminded that these results must be submitted to this office directly from the
vendor by September 30, 2014.
Current quality assurance policies for Field Laboratories and approved procedures for the analysis of
the facility’s currently certified parameters were provided at the time of the inspection.
Contracted analyses are performed by Environmental Chemists, Inc. (Certification #94).
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: Instrument identification for the meters used for Temperature, pH and Dissolved Oxygen was
not documented on the field logs. The NC WW/GW LC Approved Procedure for the Analysis of
Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC
Approved Procedure for the Analysis of Dissolved Oxygen documents state: The following must be
documented in indelible ink whenever sample analysis is performed: Instrument identification. This
requirement is a new policy that has been implemented by our program since the last inspection. All
meter identifications were added to the field logs during the inspection. No further response is
necessary for this finding.
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Comment: The laboratory needed to increase the documentation of purchased materials and reagents.
The Quality Assurance Policies for Field Laboratories document states: 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, Total Residual Chlorine reagents and lots of pre-made
standards are included in this requirement. This requirement is a new policy that has been implemented
by our program since the last inspection. Demonstration of acceptable corrective action (i.e.,a traceability
log sheet showing traceability information for all pH buffers currently in-house) was received via email on
May 12, 2014. No further response is necessary for this finding.
Dissolved Oxygen – Standard Methods, 4500 O G-2001
Comment: The sponge in the bottom of the probe well appeared to be too thick. The perimeter of the
sponge was mashed down so as to create a raised center circle that was able to slide inside of the
probe’s protective guard and push up against the membrane. This would mean that water from the
sponge was being analyzed during the air calibration. The sponge must be damp but not in contact
with the probe during the calibration. The YSI 550A manual states: Put 3 to 6 drops of clean water into
the sponge. Turn the instrument over and allow any excess water to drain out of the chamber. The wet
sponge creates a 100% water saturated air environment for the probe. This environment is ideal for
dissolved oxygen calibration and for storage of the probe during transport and non-use. Notification of
acceptable corrective action (i.e., a written statement that the sponge had been replaced with a thinner
sponge and that there was no longer any contact with the probe tip) was received via email on May 22,
2014. No further response is necessary for this finding.
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 Resources. Data were
reviewed for January, February and March, 2014. No transcription errors were detected; however, the
monthly averages for Fecal Coliform were not being calculated correctly. Prior to this inspection, all
“less than” Fecal Coliform values were being treated as “zero” when calculating the monthly average.
Fecal Coliform data is averaged using the geometric mean. When calculating a geometric mean, you
may consider a "less than" value as equal to “one”. Therefore, if all monthly values are “less than”
values, the monthly geometric average would be “one”. The difference between the arithmetic and
geometric means was discussed during the inspection and the NC DWQ NPDES Permitting Guidance
for DMR Calculations and Directions for Completing Monthly Discharge Monitoring Reports documents
were provided at the time for additional guidance.
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 made available to the Regional Office.
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#5352 Wallace Regional Wastewater Treatment Plant
V. CONCLUSIONS:
All findings noted during the inspection were adequately addressed prior to the completion of this
report. The inspector would like to thank the staff for its assistance during the inspection and data
review process. No response is required.
Report prepared by: Todd Crawford Date: May 12, 2014
Report reviewed by: Tonja Springer Date: May 23, 2014