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NC Department of Environmental Quality | Division of Water Resources | Laboratory Certification Branch
4405 Reedy Creek Road | 1623 Mail Service Center | Raleigh, North Carolina 27699-1623
919-733-3908
June 23, 2023
5480
Mr. Kevin C. White
Whitewater Environmental
417 C.C. Lovelace Rd.
Rutherfordton, NC 28139-8345
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. White:
Enclosed is a report for the inspection performed on June 7, 2023 by Jason Smith. Where
Finding(s) are cited in this report, a response is required. Within thirty days, 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 02H .0800.
A copy of the laboratory’s Certified Parameter List at the time of the audit is attached. This list will
not 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 have questions or need additional information, please contact me at (919) 733-
3908 Ext. 251.
Sincerely,
Anna Ostendorff
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Todd Crawford, Jason Smith, Master File #5480
On-Site Inspection Report
LABORATORY NAME: Whitewater Environmental
NPDES PERMIT #: NC0076082, NC0033430 and NC0024431
ADDRESS: 417 C.C. Lovelace Rd.
Rutherfordton, NC 28139-8345
CERTIFICATE #: 5480
DATE OF INSPECTION: June 7, 2023
TYPE OF INSPECTION: Field Commercial Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED:
Kevin White
I. INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater Laboratory
Certification Branch (NC WW/GW LCB) to verify its compliance with the requirements of 15A NCAC 02H
.0800 for the analysis of compliance monitoring samples.
II. GENERAL COMMENTS:
The analyst was forthcoming and responded well to suggestions from the auditor. The laboratory has all
the equipment necessary to perform the analyses.
All required Proficiency Testing (PT) Samples for the 2023 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, 2023.
Any time changes are made to laboratory procedures, Quality Assurance (QA) and/or Standard Operating
Procedure (SOP) document(s) must be updated and relevant staff retrained. Staff must acknowledge that
they have read and understand the changes as part of the documented training program. The same
requirements apply when changes are made in response to Findings, Recommendations or Comments
listed in this report, to ensure the methods are 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. Revisions to the SOPs, based on the Findings, Comments and Recommendations
within this report must be submitted to this office by December 31, 2023.
The laboratory is 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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#5480 Whitewater Environmental
Contracted analyses are performed by Environmental Testing Solutions Inc. (Certification #600).
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:
Documentation
A. Finding: The laboratory benchsheets are lacking required documentation: the method or
Standard Operating Procedure reference, the laboratory identification, the instrument
identification, the proper units of measure and the quality control assessments.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall
be traceable to the associated sample analyses and shall consist of: the method or Standard
Operating Procedure, the laboratory identification, the instrument identification, the proper
units of measure and the quality control assessments. Each item shall be recorded each time
samples are analyzed. Ref: 15A NCAC 02H .0805 (g) (2) (A), (B), (C), (L) and (O).
Comment: The instrument identification is documented for pH and Total Residual Chlorine
(TRC), but not for Temperature.
Comment: The pH units of measure are not documented on the pH calibration log.
B. Finding: The laboratory is not documenting all traceability information for purchased
materials, reagents and standards.
Requirement: 15A NCAC 02H .0805 (a) (7) (K) and (g) (7) requires laboratories to have a
documented system of traceability for the purchase, preparation, and use of all chemicals,
reagents, standards, and consumables. That system must include documentation of the
following information: Date received, Date Opened (in use), Vendor, Lot Number, and
Expiration Date (where specified). 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. Consumable materials such as pH buffers, lots of pre-made standards and/or media,
solids and bacteria filters, etc. are included in this requirement. Ref: NC WW/GW LCB
Traceability Documentation Requirements for Chemicals, Reagents, Standards and
Consumables Policy.
Comment: The vendor, lot number and expiration date are documented on the benchsheet,
but the date received is not. The date received is written on the pH buffer containers. While
this is required (see Finding C) and can provide a traceability link to analyses while the
chemicals are still in use, that link is lost once the bottles are discarded.
Comment: The date in use is not clear because the lot number is on the monthly benchsheet
with no indication of the day the new lot was put into use.
C. Finding: Chemical containers are not consistently dated when received and when opened.
Requirement: Chemical containers shall be dated when received and when opened. Ref:
15A NCAC 02H .0805 (g) (7).
Comment: The date received is written on pH buffer containers, but not the date opened.
Neither are written on the TRC reagent containers.
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#5480 Whitewater Environmental
Proficiency Testing
D. 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,
however the instructions must be maintained. Ref: Proficiency Testing Requirements, January
1, 2023, Revision 6, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
Quality Assurance/Quality Control (QA/AC)
E. Finding: SOPs are not reviewed every two years.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. A
copy of each analytical method or Approved Procedure and Standard Operating Procedure
shall be available to each analyst and available for review upon request by the State
Laboratory. Standard Operating Procedure documentation shall state the effective date of the
document and shall be reviewed every two years and updated if changes in procedures are
made. Each laboratory shall have a formal process to track and document review dates and
any revisions made in all Standard Operating Procedure documents. Supporting Records
shall be maintained as evidence that these practices are implemented. Ref: 15A NCAC 02H
.0805 (g) (4).
Comment: The SOPs have not been reviewed since they were created in 2020.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract laboratory reports to DMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Bear Wallow Valley MHP WWTP (NPDES permit
#NC0076082) and Kanuga Conferences WWTP (NPDES permit #NC0024431) for March 2023
and Camp Judea WWTP (NPDES permit #NC0033430) for July 2022. 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 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: Jason Smith Date: June 20, 2023
Report reviewed by: Michael Cumbus Date: June 20, 2023
Certificate Number:5480
Effective Date:1/1/2023
Expiration Date:12/31/2023
Lab Name:Whitewater Environmental
Address:417 C.C. Lovelace Rd.
Rutherfordton, NC 28139-8345
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:6/25/2021
The above named laboratory, having duly met the requirements of 15A NCAC 2H.0800, is hereby certified for the measurement of the parameters listed below.
CERTIFIED PARAMETERS
INORGANIC
CHLORINE, TOTAL RESIDUAL
SM 4500 Cl G-2011 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
TEMPERATURE
SM 2550 B-2010 (Aqueous)
This certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are subject to civil penalties and/or decertification for infractions
as set forth in 15A NCAC 2H.0807.