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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
October 21, 2022
5668
Mr. Michael Schlesinger
Martin County Regional WASA Water Treatment Plant
1001 Park Street
Williamston, NC 27892
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. Schlesinger:
Enclosed is a report for the inspection performed on September 14, 2022 by Thomas Halvosa. 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. 259.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Thomas Halvosa, Todd Crawford
On-Site Inspection Report
LABORATORY NAME: Martin County Regional WASA Water Treatment Plant
NPDES PERMIT #: NC0089435
ADDRESS: 1001 Park Street
Williamston, NC 27892
CERTIFICATE #: 5668
DATE OF INSPECTION: September 14, 2022
TYPE OF INSPECTION: Field Municipal Initial
AUDITOR: Tom Halvosa
LOCAL PERSON CONTACTED: Michael Schlesinger
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. The
analyst was forthcoming and responded well to suggestions from the auditor. This facility has not had to
analyze any compliance samples since July 2021.
All required Proficiency Testing (PT) Samples have been analyzed for the 2022 PT Calendar Year and the
graded results were 100% acceptable.
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 May 1, 2023.
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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# 5668 Martin County Regional WASA Water Treatment Plant
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: Error corrections are not always 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 on the benchsheet.
B. Finding: The five-standard Total Residual Chlorine curve verification and traceability
documentation are not being maintained for five years.
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 (g) (1).
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. 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 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.
C. 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. 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
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# 5668 Martin County Regional WASA Water Treatment Plant
solution. 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 does not include the date opened on their receipt log.
D. Finding: The preparation of standards and reagents are not documented in such a way as to
provide traceability from preparation to analysis.
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. 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 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 is not documenting the preparation of the standard used for the 20
µg/L daily check standard.
E. Finding: Chemical containers are not dated when received and when opened.
Requirement: Chemical containers shall be dated when received and when opened. Ref:
15A NCAC 02H .0805 (g) (7).
Proficiency Testing
F. 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,
February 19, 2020, Revision 5, Section 3.6.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.
Quality Control
G. Finding: The laboratory is not calibrating the mechanical volumetric liquid-dispensing device
used for critical measurements at least once every twelve months.
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# 5668 Martin County Regional WASA Water Treatment Plant
Requirement: Mechanical volumetric liquid-dispensing devices (e.g., fixed and adjustable
auto-pipettors and bottle-top dispensers) shall be calibrated at least once every twelve
months. Ref: 15A NCAC 02H .0805 (g) (10).
Comment: The analyst uses a fixed pipettor to prepare the annual TRC PT Sample.
Alternatively, the laboratory could use a 1 mL Class A volumetric pipette and forgo the use of
the mechanical pipettor when preparing the annual TRC PT.
Reporting
Comment: The previous analyst (employed until June 2021) reported TRC results below the verified
concentration of the meter and pH results out to two decimal points. The current analyst has only
analyzed and reported compliance samples for one month (July 2021), but the results were correctly
reported on that Discharge Monitoring Report (DMR).
Chlorine, Total Residual – Standard Methods, 4500 Cl G-2011 (Aqueous)
Comment: The laboratory is analyzing a reagent blank using Hach Blanking Reagent and subtracting
that result from the compliance sample result. This is not required for SM 4500 Cl G-2011.
Temperature – Standard Methods, 2550 B-2010 (Aqueous)
H. Finding: The compliance temperature-measuring device is not checked at two temperatures
that bracket the range of observed sample temperatures.
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule.
Ref: 15A NCAC 02H .0805 (g) (4).
Requirement: To check a compliance temperature-measuring device, compare readings at
two temperatures that bracket the range of compliance samples routinely analyzed against a
National Institute of Standards and Technology (NIST) traceable temperature-measuring
device and record all four readings. The readings from both devices must agree within 0.5 ºC.
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 laboratory is only checking the compliance temperature-measuring device at
one temperature (ambient).
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 Martin County Regional WASA Water Treatment Plant (NPDES permit # NC0089435)
for April, May, June 2021. The following errors were noted:
Date Parameter Location Contract
Laboratory Data Value on DMR
6/2/2021 Ammonia Effluent <0.04 mg/L 0.04 mg/L
To avoid questions of legality, it is recommended that you contact the appropriate Regional Office for
guidance as to whether an amended DMR(s) will be required. A copy of this report will be made available to
the Regional Office.
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# 5668 Martin County Regional WASA Water Treatment Plant
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: Tom Halvosa Date: September 23, 2022
Report reviewed by: Jason Smith Date: September 26, 2022
Certificate Number:5668
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:Martin County Regional WASA Water Treatment Plant
Address:1001 Park Street
Williamston, NC 27892
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:5/10/2022
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
CHLORINE, TOTAL RESIDUAL
SM 4500 Cl G-2011 (Aqueous)
pH
SM 4500 H+B-2011 (Aqueous)
TEMPERATURE
SM 2550 B-2010 (Aqueous)
TURBIDITY
SM 2130 B-2011 (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.