HomeMy WebLinkAbout#161_2023_1005_JP_FINAL
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
December 18, 2023
161
Mr. Newlyn McCullen
Whiteville WWTP Lab
P.O. Box 607
Whiteville, NC 28472
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. McCullen:
Enclosed is a report for the inspection performed on October 5, 2023, by Jill Puff. 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, 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, Jill Puff, Master File #161
On-Site Inspection Report
LABORATORY NAME: Whiteville WWTP Lab
NPDES PERMIT #: NC0021920
ADDRESS: 1000 Nolan Avenue
Whiteville, NC 28472
CERTIFICATE #: 161
DATE OF INSPECTION: October 5, 2023
TYPE OF INSPECTION: Municipal Maintenance
AUDITOR(S): Jill Puff
LOCAL PERSON(S) CONTACTED: Newlyn McCullen, Nathan Guyton, and Brandon Rich
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 facility is neat and well organized and has all the equipment necessary to perform the analyses. Staff
were forthcoming and responded well to suggestions from the auditor.
All required Proficiency Testing (PT) Samples have been analyzed for the 2023 PT Calendar Year and the
graded results were 100% acceptable.
The laboratory did not have Quality Assurance (QA) and/or Standard Operating Procedure (SOP)
document(s) in place for all currently certified parameters. These documents must be submitted for review
as specified in Finding A.
Any time changes are made to laboratory procedures, QA and/or 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 no
later than December 31, 2024.
The laboratory is reminded that SOPs are required to be reviewed at least every two years and 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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Laboratory Fortified Matrix (LFM) and Laboratory Fortified Matrix Duplicate (LFMD) are also known as
Matrix Spike (MS) and Matrix Spike Duplicate (MSD) and may be used interchangeably in this report.
Contracted analyses are performed by Waypoint Analytical - Greenville (Certification # 10).
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: SOPs have not been developed for all of the methods included on the laboratory’s
Certified Parameters Listing (CPL).
Requirement: Each laboratory shall have a documented analytical quality assurance and
quality control program. Each laboratory shall have a copy of each approved test, analysis,
measurement, or monitoring procedure being used in the laboratory. Each laboratory shall
develop documentation outlining the analytical quality control practices used for the
Parameter Methods included in its Certification, including Standard Operating Procedures
for each certified Parameter Method. Quality assurance, quality control, and Standard
Operating Procedure documentation shall indicate the effective date of the document and
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 quality assurance, quality control, and Standard Operating Procedure
documents. Supporting Records shall be maintained as evidence that these practices are
implemented. The quality assurance, quality control, and Standard Operating Procedure
documents shall be available for inspection by the State Laboratory. Ref: 15A NCAC 02H
.0805 (a) (7).
Comment: This Finding applies to Temperature. The SOP for this parameter is required
to be submitted with the report response.
B. Finding: The laboratory does not document SOP revisions.
Requirement: Each laboratory shall have a formal process to track and document review
dates and any revisions made in all quality assurance, quality control, and Standard
Operating Procedure documents. Supporting Records shall be maintained as evidence that
these practices are implemented. Ref: 15A NCAC 02H .0805 (a) (7).
C. Finding: The laboratory is lacking documentation of the training program.
Requirement: Each laboratory shall develop and implement a documented training
program that includes the following: that staff have the education, training, experience, or
demonstrated skills needed to generate quality control results within method-specified limits
and that meet the requirements of these Rules; that staff have read the laboratory quality
assurance manual or applicable Standard Operating Procedures; that staff have obtained
acceptable results on Proficiency Testing Samples pursuant to Rule .0803(1) of this Section
or other demonstrations of proficiency (e.g., side-by-side comparison with a trained analyst,
acceptable results on a single-blind performance evaluation sample, an initial demonstration
of capability study prescribed by the reference method). Ref: 15A NCAC 02H .0805 (a) (7)
(P).
Comment: The laboratory’s training program is outlined in the laboratory QA manual but
no documentation of completed training was available for review.
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D. Finding: Error corrections are not properly performed. Cited previously on March 9, 2011.
Requirement: All documentation errors shall 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 shall not to be used; instead, the correction shall be written adjacent to the
error. The correction shall be initialed by the responsible individual and the date of change
documented. Ref: 15A NCAC 02H .0805 (a) (7) (E).
Comment: There were multiple instances of overwritten entries.
E. Finding: The laboratory benchsheet is lacking required documentation: the method or
Standard Operating Procedure reference.
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. Each item shall be recorded each time samples are
analyzed. Ref: 15A NCAC 02H .0805 (a) (7) (F) (i).
Comment: This Finding applies to Temperature and Dissolved Oxygen (DO) on the Stream
Grab Samples benchsheet.
F. Finding: The laboratory benchsheet sometimes does not reference the currently approved
methods.
Requirement: Analytical methods, sample preservation, sample containers, and sample
holding times shall conform to the requirements found in: 40 CFR Part 136 and 40 CFR
Part 503. Ref: 15A NCAC 02H .0805 (a) (1) (A).
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. Each item shall be recorded each time samples are
analyzed. Ref: 15A NCAC 02H .0805 (a) (7) (F) (i).
Comment: Benchsheets for the parameters listed below do not reference the approved
method as listed on the laboratory's Certified Parameters Listing (CPL):
• Nitrogen, Ammonia – Standard Methods, 4500 NH3 D-2011 (Aqueous)
• Bacteria, Fecal Coliform – Standard Methods, 9222 D-2015 (Aqueous)
• BOD – Standard Methods, 5210 B-2016 (Aqueous)
• Residue, Suspended – Standard Methods, 2540 D-2015 (Aqueous)
G. Finding: The laboratory benchsheet is lacking required documentation: the instrument
identification.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the instrument
identification. Each item shall be recorded each time samples are analyzed. Analyses shall
conform to methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H
.0805 (a) (7) (iii).
Comment: This Finding applies to all laboratory benchsheets.
H. Finding: The laboratory benchsheets are lacking required documentation: meter calibration
time. Cited previously on March 9, 2011.
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Requirement: The State Laboratory may develop Approved Procedures for Field
Parameters based upon the methods in any of the sources referenced in Parts (a) (1) (A)
through (F) of this Rule. Ref: 15A NCAC 02H .0805 (a) (1) (F).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Meter calibration and meter calibration time(s). Ref: NC WW/GW
LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO) and NC WW/GW LCB
Approved Procedure for the Analysis of pH.
Comment: This Finding applies to the DO and pH benchsheets.
I. Finding: The units of measure are not consistently documented.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the proper units
of measure. Each item shall be recorded each time samples are analyzed. Ref: 15A NCAC
02H .0805 (a) (7) (F) (xii).
Comment: This Finding applies to the BOD, Fecal Coliform and Stream Grab Samples
benchsheets.
Comment: This Finding applies to the pH calibration log.
Comment: This Finding applies to the Temperature verification log.
J. Finding: The DO and BOD laboratory benchsheets are lacking required documentation: the
salinity value used for meter calibration.
Requirement: The State Laboratory may develop Approved Procedures for Field
Parameters based upon the methods in any of the sources referenced in Parts (a) (1) (A)
through (F) of this Rule. Ref: 15A NCAC 02H .0805 (a) (1) (F).
Requirement: All analytical records, including original observations and information
necessary to facilitate historical reconstruction of the calculated results, shall be maintained
for five years. Ref: 15A NCAC 02H .0805 (a) (7) (E).
Requirement: Determination of Initial DO: Use the Azide modification of the iodometric
method (Section 4500-O.C), membrane-electrode method (Section 4500-O.G), or optical-
probe method (Section 4500-O.H) to determine initial DO on all sample dilutions, dilution
water blanks, and, where appropriate, seed controls. Ref: Standard Methods, 5210 B-2016.
(5) (g).
Requirement: Follow manufacturer's calibration procedure exactly to obtain guaranteed
precision and accuracy. Ref: Standard Methods, 4500 O G-2016. (3) (a).
Requirement: The following must be documented in indelible ink whenever sample analysis
is performed: Calibration variables (temperature, elevation or barometric pressure [in
mmHg], and salinity). Ref: NC WW/GW LCB Approved Procedure for the Analysis of
Dissolved Oxygen (DO).
Requirement: Per NC WW/GW LC Branch policy, facilities may use the Salinity default
value of zero when calibrating the DO meter unless it is known or suspected that the Salinity
value of the samples being analyzed is > 9 ppt. In those situations, actual Salinity values
must be used. Regardless of which value is used, it must be documented. Ref: NC WW/GW
LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO).
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K. Finding: The laboratory benchsheet is lacking required documentation: Date of most recent
Total Residual Chlorine (TRC) calibration curve verification.
Requirement: The State Laboratory may develop Approved Procedures for Field
Parameters based upon the methods in any of the sources referenced in Parts(a)(1)(A)
through (F) of this Rule. Ref: 15A NCAC 02H .0805 (a) (1) (F).
Requirement: The following must be documented in indelible ink whenever sample analysis
is performed: Date of most recent calibration curve generation or calibration curve
verification. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual
Chlorine (DPD Colorimetric by Hach 10014 ULR).
L. Finding: The laboratory does not document all QC assessments.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: all quality control
assessments. Each item shall be recorded each time that samples are analyzed. Ref: 15A
NCAC 02H .0805 (a) (7) (F) (xv).
Comment: The true value of QC standards and percent recovery obtained must be
documented on the benchsheet and evaluated against established acceptance criteria to
demonstrate that the analyst was aware of any out-of-control situation. The corrective
actions taken must be documented. Any samples not meeting the acceptance criteria must
be reanalyzed, if possible. If this is not possible, the data must be flagged on the laboratory
reports as all QC requirements were not met.
Comment: This Finding applies to the laboratory benchsheets for pH, TRC and Fecal
Coliform Colony Verification.
M. Finding: The laboratory is not documenting all variables used in calibrating the mechanical
volumetric liquid-dispensing devices used for critical measurements.
Requirement: The following shall be documented with each calibration of a mechanical
liquid-dispensing device: date performed, analyst performing the test, unique identifier (e.g.,
serial number, etc.), manufacturer’s specification of accuracy, balance test-weight reading,
volumes tested, volume weights observed, reagent water used is at ambient temperature
and all calculations used to assess accuracy Ref: NC WW/GW LCB Mechanical Volumetric
Liquid-Dispensing Devices Calibration Policy (07/06/2021).
Comment: The calibration log for the auto-pipettors does not include the manufacturer’s
specification of accuracy, the volumes tested, the units of measure for the volume weights
observed, the temperature of the reagent water used, and calculations used to assess
accuracy.
N. Finding: The laboratory is not documenting the temperature each time samples are placed
into and removed from the drying oven.
Requirement: The date, time and temperature must be documented each time samples
are placed into and removed from a drying oven. Ref: NC WW/GW LCB Residue Oven
Temperature Documentation Policy (07/30/2021).
O. Finding: The autoclave temperature, pressure and cycle time are not being documented.
Requirement: During each use of an autoclave, the temperature, pressure, cycle time, and
items autoclaved shall be checked, recorded, dated, and initialed. Ref: 15A NCAC 02H
.0805 (a) (7) (I).
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Requirement: After each run cycle, record the items sterilized, sterilization temperature,
total run time (heat exposure), programmed/preset sterilization period, actual pressure
readings, and analyst initials. Ref: Standard Methods 9020 B-2015. (4) (h).
Proficiency Testing
P. Finding: PT Samples are not distributed among all analysts from year to year.
Requirement: Laboratories shall also ensure that, from year to year, PT Samples are
equally distributed among personnel trained and qualified for the relevant tests and
instrumentation (when more than one instrument is used for routine Compliance Sample
analyses), that represents the routine operation of the work group at the time the PT Sample
analysis is conducted. Ref: Proficiency Testing Requirements, January 1, 2023, Revision
6, Section 3.6.
Quality Assurance/Quality Control
Q. Finding: The laboratory did not have a copy of each approved analytical procedure available.
Requirement: Each laboratory shall have a copy of each approved test, analysis,
measurement, or monitoring procedure being used in the laboratory. Ref. 15A NCAC 02H
.0805 (a) (7).
Comment: The 21st Edition of Standard Methods was the most recent one available. Not
all of the laboratory’s certified parameter methods are referenced in this edition.
R. Finding: Thermometers in the BOD incubator and the water bath are not consistently
verified against a Reference Temperature-Measuring Device at least every three months.
Requirement: Digital temperature-measuring devices and temperature-measuring devices
used in incubators shall be verified at the temperature of use every three months against a
Reference Temperature-Measuring Device and their accuracy shall be corrected. Ref: 15A
NCAC 02H .0805 (a) (7) (N) (iii).
Comment: The thermometers were verified on February 15, April 5, and September 21 of
this year.
S. Finding: Laboratory temperature-measuring devices are not labeled with their respective
correction factors.
Requirement: Document any correction that applies (e.g., add 0.2 °C, subtract 0.3 °C, or
if no correction needed; 0.0 °C) on both the temperature-measuring device and in a format
that can be retained for a minimum of five years. Routine temperature measurements must
be documented with any applicable correction factor applied. Ref: NC WW/GW LCB
Temperature Measuring-Devices used for Laboratory Operations Policy (08/30/2021).
T. Finding: The laboratory is not consistently calibrating the mechanical volumetric liquid-
dispensing devices used for critical measurements at least once every six months.
Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable
auto-pipettors and bottle-top dispensers) used for critical volume measurements shall be
calibrated once every six months. Ref: 15A NCAC 02H .0805 (a) (7) (O).
Comment: The most recent calibration of the auto-pipettors was February 15, 2023.
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U. Finding: The desiccant in the desiccator is exhausted.
Requirement: Each laboratory requesting Certification shall be maintained so as to ensure
the security and integrity of samples. Samples shall be analyzed in such a manner that
contamination or error will not be introduced. Ref: 15A NCAC 02H .0805 (a) (6).
Requirement: Interferences: See 2540A.2 and B.1b. Ref: Standard Methods, 2540 D-
2015. (1) (b).
Requirement: Pay close attention to all samples during post-drying desiccation. Open
desiccator as few times as possible to minimize the entry of moist air. If samples are
stronger desiccants than the desiccants used in the desiccator, they may take on water. In
general, weigh samples as soon as possible after removal from desiccator to minimize
water absorption from the atmosphere. Ref: Standard Methods, 2540 A-2015. (2).
V. Finding: The laboratory has not established acceptance criteria for the weights used during
daily balance calibration.
Requirement: Unless specified by the method or this Rule, each laboratory shall establish
performance acceptance criteria for all quality control analyses. Each laboratory shall
calculate and document the precision and accuracy of all quality control analyses with each
sample set. When the method of choice specifies performance acceptance criteria for
precision and accuracy, and the laboratory chooses to develop laboratory-specific limits,
the laboratory-specific limits shall not be less stringent than the criteria stated in the
approved method. Ref: 15A NCAC 02H .0805 (a) (7) (A).
W. Finding: The laboratory has not established a policy for assigning expiration dates for
chemical/reagents/consumables that do not have an expiration date.
Requirement: When commercially prepared chemicals, reagents, standards and
consumables have expiration dates listed as a month and year (with no specific day of the
month), the last day of the month will be considered the actual date of expiration. If no
expiration date is given by the manufacturer, the laboratory must use their policy for
assigning one. If the laboratory is unable to determine an expiration date for a chemical,
reagent or standard a one-year time period from the date of receipt shall be the expiration
date unless degradation is observed prior to this date. If neither a date received nor an
expiration date can be determined, the item must not be used. If the method does not
specify an expiration date, chemicals, reagents and standards prepared in the laboratory
for use with that method must be assigned an expiration date according to the laboratory’s
policy for doing so. Monitor materials for changes in appearance or consistency. Any
changes may indicate potential contamination or degradation, and therefore, the item must
not be used, even if the manufacturer’s or laboratory’s expiration date has not been
exceeded. Laboratory-assigned expiration dates may be re-evaluated based on
performance and recovery data and new expiration dates assigned at that time.
Manufacturer-assigned expiration dates may not be extended. Ref: NC WW/GW LCB
Chemical, Reagent, Standard and Consumables Expiration Date Policy (04/21/2022).
Comment: This Finding applies to:
• Concentrated Sulfuric Acid
• Hach Buffered Dilution Water Pillows used for Fecal Coliform testing
X. Finding: Data that does not meet all QC requirements is not qualified on the Discharge
Monitoring Report (DMR).
Requirement: Reported data associated with quality control failures, improper sample
collection, holding time exceedances, or improper preservation shall be qualified as such.
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Ref: 15A NCAC 02H .0805 (e) (5).
Comment: The relative percent difference (RPD) for the Fecal Coliform duplicate on June
1, 2023 was greater than 30%. This is outside the QC acceptance limits but it was not
qualified on the DMR as required.
Chlorine, Total Residual – Hach 10014 (ULR) (Aqueous)
Y. Finding: Samples are being filtered without documentation.
Requirement: The State Laboratory may develop Approved Procedures for Field
Parameters based upon the methods in any of the sources referenced in Parts(a)(1)(A)
through (F) of this Rule. Ref: 15A NCAC 02H .0805 (a) (1) (F).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Statement that samples were filtered. Ref: NC WW/GW LCB
Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by Hach
10014 (ULR).
Bacteria, Fecal Coliform – Standard Methods, 9222 D-2015 (MF) (Aqueous)
Z. Finding: The laboratory is not monitoring the quality of the reagent water.
Requirement: At a minimum, reagent water used to make dilutions, prepare buffered
dilution/rinse water or prepare media must be analyzed at least every twelve months for the
following parameters: Specific Conductance, Total Organic Carbon, Cadmium, Chromium,
Copper, Nickel, Lead, and Zinc.
Maximum Acceptable Limits are:
Total Organic Carbon < 1.0 mg/L
Specific Conductance < 2 µmhos/cm
Heavy Metals, single element < 0.05 mg/L
Heavy Metals, Total of specified elements < 0.10 mg/L
If the facility is using vendor purchased reagent water or dilution/rinse water, this testing is
not required as long as the Certificate of Analysis from the manufacturer meets these
requirements and is kept on file. Ref: NC WW/GW LCB Bacteriological Reagent Water
Testing Policy (02/15/2018).
AA. Finding: The Fecal Coliform incubator bath temperature is not being monitored and
recorded twice daily.
Requirement: When incubator is in use (i.e., samples are being incubated), monitor and
record corrected temperature twice daily separated by 4 h. Ref: Standard Methods, 9020
B-2015. (4) (n).
Comment: The laboratory records the temperature once each day of use.
BB. Finding: The laboratory is not using an approved technique to sterilize the filtration
apparatus.
Requirement: Filtration units: See 9222B.1f. Ref: Standard Methods, 9222 D-2015. (1) (f).
Requirement: Wrap the assembly (as a whole or separate parts) in heavy wrapping paper
or aluminum foil, or place in commercial autoclave bags; sterilize via autoclaving; and store
until use. Ref: Standard Methods 9222 B-2015. (1) (f).
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Comment: The laboratory is utilizing an ultraviolet (UV) apparatus for sterilization.
Germicidal shortwave UV lights are commonly used to sanitize, not sterilize, such items as
membrane filtration units between filtrations.
CC. Finding: The UV lamp bulbs are not tested quarterly.
Requirement: Test lamps quarterly with an appropriate (short-wave) UV light meter, and
replace bulbs when output drops to <70% of initial output. Alternatively, expose spread
plates containing 200 to 300 CFU/mL of a selected bacterial suspension for 2 min. Incubate
plates at 35°C for 48 h and then count colonies. Replace bulb if colony count is not reduced
99%. It also is advisable to ask the manufacturer for the bulb’s expected life span and then
track hourly usage. Ref: Standard Methods, 9020 B-2015. (4) (l) (1).
DD. Finding: The UV lamp bulbs are not cleaned monthly.
Requirement: When in use, disconnect lamps monthly and clean bulbs with a soft cloth
moistened with ethanol (70% ethanol/30% reagent-grade water) or with spectroscopic
grade 2-propanol in areas where baked-on material is collecting. Ref: Standard Methods,
9020 B-2015. (4) (l).
BOD – Standard Methods, 5210 B-2016 (Aqueous)
EE. Finding: The laboratory is not analyzing at least two dilution water blanks.
Requirement: With each batch of dilution water, incubate two or more bottles of dilution
water containing nutrient, mineral, and buffer solutions but no seed or nitrification inhibitor.
Dilution water checks must be analyzed with each batch of samples; the dilution-water blank
serves as a check on the quality of unseeded dilution water and cleanliness of incubation
bottles. Determine initial and final DO for each bottle (5210B.5e and i), and average results.
Ref: Standard Methods, 5210 B-2016. (6) (c).
FF. Finding: Extra nutrient, mineral, and buffer solutions are not added to the incubation bottles
containing more than 67% (i.e., > 201 mL) sample.
Requirement: When a bottle contains >67% of the sample after dilution, nutrients may be
limited in the diluted sample and subsequently reduce biological activity. In such samples,
add the nutrient, mineral, and buffer solutions (5210B.3a-d) directly to diluted sample at a
rate of 1 mL/L (0.30 mL/300-mL bottle), or use commercially-prepared solutions designed
to dose the appropriate bottle size. Ref: Standard Methods, 5210 B-2016. (5) (c) (2).
Conductivity – Standard Methods, 2510 B-2011 (Aqueous)
GG. Finding: The Automatic Temperature Compensator (ATC) was not verified prior to initial
use and every 12 months thereafter.
Requirement: The State Laboratory may develop Approved Procedures for Field
Parameters based upon the methods in any of the sources referenced in Parts(a)(1)(A)
through (F) of this Rule. Ref: 15A NCAC 02H .0805 (a) (1) (F).
Requirement: The Automatic Temperature Compensator (ATC) must be verified prior to
initial use and annually (i.e., 12 months) thereafter at two temperatures by analyzing a
standard or sample at 25°C (i.e., the temperature to which conductivity values are reported)
and a temperature(s) that brackets the temperature ranges of the environmental samples
routinely analyzed. This may require the analysis of a third temperature reading that is >
25°C. As the temperature increases or decreases, the value of the conductivity standard
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or sample must be within ±10% of the true value of the standard or ±10% of the value of
the sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LCB Approved
Procedure for the Analysis of Specific Conductance (Conductivity).
Nitrogen, Ammonia – Standard Methods, 4500 NH3 D-2011 (Aqueous)
HH. Finding: The laboratory is adding 10N NaOH before immersing the electrode.
Requirement: Do not add NaOH solution before immersing electrode, because ammonia
may be lost from a basic solution. Ref: Standard Methods 4500 NH3 D-2011 (4) (b).
Residue, Suspended – Standard Methods, 2540 D-2015 (Aqueous)
Comment: The laboratory evaluates sample duplicates against a 30% acceptance criterion. This
criterion was not implemented based on control charts or other performance-based metrics and
may be ineffectively broad. Typically, the relative percent difference (RPD) of duplicates should not
exceed 10%, but RPDs may vary considerably due to sample matrix and concentration. The
laboratory may plot duplicate determinations on a control chart for evaluation. If the laboratory is
using %RPD as the acceptance criterion, check low concentration samples for compliance. A
separate low-level acceptance criterion may be appropriate based upon calculated recoveries or a
± mg/L criterion.
Recommendation: It is recommended that the laboratory document on the Suspended Residue
benchsheet that the analytical balance level indicator bubble is inside the circle of accepted range
during each use.
II. Finding: The drying cycle is not repeated until a weight change of <0.5 mg is achieved.
Requirement: Repeat the cycle (drying, cooling, desiccating, and weighing) until the weight
change is <0.5 mg. Ref: Standard Methods, 2540 D-2015. (3) (c).
Comment: The laboratory was drying and weighing routine compliance samples only once
but was conducting an annual drying study. Approval by NC WW/GW LCB for laboratories
to conduct an annual drying study in lieu of obtaining constant weight was repealed with the
2021 Methods Update Rule published in 40 CFR 136.
JJ. Finding: The laboratory is not analyzing a Method Blank.
Requirement: Analyze one method (MB) per batch of 20 samples for each method except
settleable solids (2540F). Blank analysis includes all container- and filter-preparation steps
and procedures except sample addition. Ref: Standard Methods, 2540 A-2015. (5).
Requirement: Using the same containers and glassware normally in contact with samples,
put 30 mL of DI water through the sample filter and proceed through the entire analytical
process. Acceptance criterion is ≤0.5 mg weight gain. Ref: NC WW/GW LCB Method Blank
Analysis Requirement for Suspended, Dissolved and Total Residue Policy (07/19/2021).
Comment: The laboratory was analyzing a dry filter blank. Analyzing a dry filter blank was
previously permitted in lieu of drying all prepared filters to constant weight before use. This
requirement is not in the updated method and the dry blank does not take the place of a
method blank.
KK. Finding: A Laboratory-Fortified Blank (LFB) is not being analyzed with each batch.
Requirement: Include one laboratory-fortified blank (LFB) per batch of 20 samples for all
tests except settleable solids (2540F) and total, fixed, and volatile solids in solid and
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semisolid samples (2540G). Plot the percent recoveries on a control chart for laboratory
evaluation. Laboratories may purchase known standards or prepare in-house working
controls for use. Ref: Standard Methods, 2540 A-2015. (5).
LL. Finding: The laboratory is not always analyzing a volume of sample to yield a minimum of
2.5 mg dried residue.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. If
volume filtered fails to meet minimum yield, increase sample volume up to 1 L. If filtration
takes >10 min to complete, increase filter size or decrease sample volume. Ref: Standard
Methods, 2540 D-2015 (3) (b).
Comment: The laboratory’s practice is to filter 50 mL of the influent sample. On June 7,
2023, this yielded less than 2.5 mg dried residue.
Temperature – Standard Methods, 2550 B-2010 (Aqueous)
MM. Finding: The compliance temperature-measuring devices are not checked at two
temperatures that bracket the range of observed sample temperatures.
Requirement: The State Laboratory may develop Approved Procedures for Field
Parameters based upon the methods in any of the sources referenced in Parts(a)(1)(A)
through (F) of this Rule. Ref: 15A NCAC 02H .0805 (a) (1) (F).
Requirement: To check a compliance temperature-measuring device, compare readings
at two temperatures that bracket the range of compliance samples routinely analyzed
against a Reference Temperature-Measuring Device and record all four readings. The
readings from both devices must agree within 0.5ºC. If they do not, the device may not be
used for temperature compliance monitoring. Ref: NC WW/GW LCB Approved Procedure
for the Analysis of Temperature.
Comment: The compliance temperature-measuring devices were checked at 5.4° C and
21.5° C on September 20, 2023. On June 27, 2023, the effluent temperature reported on
the DMR was 24.8° C.
Reporting
NN. Finding: The laboratory is not correctly transcribing analytical results from the contract
laboratory to the DMR.
Requirement: Daily analyses must be performed using EPA-approved methods that are
capable of producing results less than or equal to the corresponding permit limits, where
such methods exist. In the case of ‘non-detect’ values, permittees (or their laboratories) are
expected to report daily values to the Practical Quantitation Level (PQL) for each parameter
(or “<[PQL] for values less than the PQL). Ref: Precision in Discharge Monitoring Reports,
Section 3.1.
Comment: The laboratory reported the Ammonia Nitrogen results as less than the in-house
reporting limit of 1 mg/L (i.e.; < 1 mg/L) rather than the values reported by the contract
laboratory, which were below 1 mg/L. The contract laboratory has a reporting limit of 0.01
mg/L.
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IV. CONCLUSIONS:
We are concerned with the Findings that were cited previously and not corrected.
Laboratory Decertification Ref: 15A NCAC 02H .0807 (a) (1), (13), (14) and (20):
A laboratory may be decertified for any or all parameters for up to one year for any or all of the
following infractions:
(1) Failing to maintain the facilities, or records, personnel, equipment, or quality control
program as set forth in these Rules; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this Section
or of Laboratory certification; or
(20) Failing to correct findings in an inspection report.
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
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: Jill Puff Date: October 17, 2023
Report reviewed by: Tom Halvosa Date: October 24, 2023
Certificate Number:161
Effective Date:1/1/2023
Expiration Date:12/31/2023
Lab Name:Whiteville WWTP Lab
Address:1000 Nolan Avenue
Whiteville, NC 28472
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:7/19/2021
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
BACTERIA - COLIFORM FECAL
SM 9222 D-2015 (MF) (Aqueous)
BOD
SM 5210 B-2016 (Aqueous)
CHLORINE, TOTAL RESIDUAL
Hach 10014 ULR (Aqueous)
CONDUCTIVITY
SM 2510 B-2011 (Aqueous)
DISSOLVED OXYGEN
Hach 10360-2011, Rev. 1.2 (Aqueous)
SM 4500 O G-2016 (Aqueous)
NITROGEN, AMMONIA
SM 4500 NH3 D-2011 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
RESIDUE, SUSPENDED
SM 2540 D-2015 (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.