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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
April 11, 2022
5141
Mr. Roland Coburn
Town of Plymouth WWTP
124 E Water Street
Plymouth, NC 27962
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. Coburn:
Enclosed is a report for the inspection performed on March 29, 2022 by Thomas Halvosa. 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
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. 259.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Todd Crawford, Thomas Halvosa, #5141
On-Site Inspection Report
LABORATORY NAME: Town of Plymouth WWTP
NPDES PERMIT #: NC0020028
ADDRESS: 640 Gage Lane
Plymouth, NC 27962
CERTIFICATE #: 5141
DATE OF INSPECTION: March 29, 2022
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR: Tom Halvosa
LOCAL PERSON CONTACTED:
Roland Coburn
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
was forthcoming and responded well to suggestions from the auditor.
All required Proficiency Testing (PT) Samples for the 2022 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, 2022.
The laboratory is reminded that any time changes are made to laboratory procedures, QA/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 November 1, 2022.
The laboratory is also 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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#5141 Town of Plymouth WWTP
Contracted analyses are performed by Environment 1, Inc. (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: The laboratory is not documenting traceability information for purchased materials,
reagents and standards. Cited previously on March 8, 2010.
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). This information as well as the vendor and/or manufacturer,
lot number, and expiration date must be retained for primary standards, chemicals, reagents,
and materials used for a period of five years. 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 laboratory was keeping certificates of analysis in lieu of a receipt log. An
example receipt log was provided to the laboratory at the time of the inspection.
B. Finding: Error corrections are not properly performed.
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 are 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 (g) (1).
Comment: There were several instances of write-overs without dates and initials as well as
the use of correction fluid.
C. Finding: The laboratory benchsheets for pH and Temperature are lacking required
documentation: the method or Standard Operating Procedure reference 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 and the quality control assessments. 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 (g) (2) (A) and (O).
Comment: The pH benchsheet has the incorrect revision year (2000) instead of 2011 as part
of the method description. Also, the pH benchsheet lacks the acceptance criterion (±0.1 S.U.)
for the Check Standard buffer. The Temperature benchsheet does not have the method
description listed.
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#5141 Town of Plymouth WWTP
Proficiency Testing
D. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: 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, February 19, 2020, Revision 5, Section 3.6.
Requirement: The analysis of Proficiency Testing (PT) Samples is designed to evaluate the
entire process used to routinely analyze and report Compliance Sample results. PT Samples
must be analyzed the same as Compliance Samples. Also, documentation must be made on
the same benchsheets used for Compliance Samples. Ref: NC WW/GW LCB Proficiency
Testing Samples Analyzed and Documented Same as Compliance Samples Policy.
Quality Control
Comment: The laboratory’s SOPs lack sufficient detail and information. Example SOP templates
were provided to the laboratory after the inspection.
E. Finding: The laboratory is lacking a documented 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 (g) (5).
Comment: The laboratory can include training in the pH and Temperature SOPs if it includes
a section that documents that training.
Reporting
Comment: The laboratory reports Compliance Temperature results on their Discharge Monitoring
Report (DMR) to one decimal place.
Recommendation: Unless greater precision is required by the permit or data receiving agency, it is
recommended that all temperatures reported for compliance monitoring, be reported in whole
numbers as recommended by the Precision in Discharge Monitoring Reports document.
F. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent.
Requirement: The results of all tests on the characteristics of the effluent, including but not
limited to NPDES permit monitoring requirements, shall be reported on the monthly report
forms. Ref: 15A NCAC 2B .0506 (b) (3) (J).
Comment: The laboratory was certified for Dissolved Oxygen (DO) prior to the inspection but
does not have an NPDES permit requirement for that parameter. However, since the
laboratory was analyzing the effluent, the results of the analyses must have been included on
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#5141 Town of Plymouth WWTP
the DMR. The laboratory requested to drop the DO parameter method on the day of the
inspection and will no longer analyze the DO of their effluent. The laboratory is reminded that
all results of effluent analyses must be reported on the DMR regardless of certification status
or permit monitoring requirements.
pH – Standard Methods, 4500 H+ B-2011 (Aqueous)
G. Finding: Values were reported that exceed the method specified accuracy of 0.1 Standard
Units.
Requirement: By careful use of a laboratory pH meter with good electrodes, a precision of
±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 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, 4500 H+ B-2011. (6).
Comment: Per PT Vendor instructions, the PT Sample results should be reported to two
decimal places, which is an exception to the requirement for Compliance Samples.
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 Town of Plymouth WWTP (NPDES permit # NC0020028) for March, July and December
2021. 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 and implementing the Recommendation 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: Tom Halvosa Date: April 6, 2022
Report reviewed by: Jason Smith Date: April 6, 2022
Certificate Number:5141
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Town of Plymouth WWTP
Address:640 Gage Lane
Plymouth, NC 27962
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:3/30/2022
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
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.