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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5365
Laboratory Name: Town of Kenansville WWTP
Inspection Type: Field Maintenance
Inspector Name(s): Todd Crawford
Inspection Date: March 19, 2014
Date Report Completed: April 1, 2014
Date Forwarded to Reviewer: April 1, 2014
Reviewed by: Tonja Springer
Date Review Completed: April 2, 2014
Cover Letter to use: Insp. Initial Insp. Reg.
Insp. No Finding Insp. CP
Corrected
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: 4/4/2014
Date Forwarded to Linda: 4/24/2014
Date Mailed: 4/24/2014
_____________________________________________________________________
Todd - Send a copy of this report to Dean Hunkele in WiRO.
On-Site Inspection Report
LABORATORY NAME: Town of Kenansville WWTP
NPDES PERMIT #: NC0036668
ADDRESS: PO Box 370
Kenansville, NC 28349
CERTIFICATE #: 5365
DATE OF INSPECTION: March 19, 2014
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Todd Crawford
LOCAL PERSON(S) CONTACTED: Garry Benson
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.
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.
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 Vann Laboratories (Certification #22) and Environmental
Chemists, Inc. (Certification # 94).
The requirements associated with Findings B, C and D have been implemented by our program since the
last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: Instrument identification for the meters used for Temperature, pH, Dissolved Oxygen and
Total Residual Chlorine was not documented on the benchsheet. The NC WW/GW LC Approved
Procedure for the Analysis of Temperature, NC WW/GW LC Approved Procedure for the Analysis of pH,
NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine documents state: The following must be
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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.
Notification of acceptable corrective action (i.e., a statement that the revised benchsheets developed by
the inspector, which identifies all meters by model and serial number, would be used starting March 31,
2014) was received via email on March 27, 2014. No further response is necessary for this finding.
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 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 reagents currently in use) was received via email on April 1, 2014. No
further response is necessary for this finding.
Comment: This Finding refers specifically to pH buffers and the reagents used for total residual chlorine.
Sample Collection
A. Finding: Composited samples for Biological Oxygen Demand (BOD), Total Suspended Solids
(TSS), Total Nitrogen, Ammonia and Total Phosphorus are not collected from the effluent.
Requirement: Permit #NC0036668 requires composite samples be collected from the effluent.
The North Carolina Administrative Code, 15A NCAC 02B .0503 (12) defines the "Effluent" as
wastewater discharged following all treatment processes from a water pollution control facility or
other point source whether treated or untreated.
Comment: The composite sampler is located prior to the last treatment process (dechlorination).
Requirement: Corrective action for this Finding must be coordinated with the Wilmington
Regional Office prior to moving the composite sampler.
Proficiency Testing
B. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner
as environmental samples.
Requirement: All PT samples are to be analyzed and the results reported in a manner
consistent with the routine analysis and reporting requirements of compliance samples and any
other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory’s common practice was to analyze a known standard along with the
PT sample as additional quality control. Environmental samples are not analyzed in this
manner.
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C. Finding: The preparation of Proficiency Testing (PT) samples is not documented.
Requirement: PT samples received as ampules must be diluted according to the PT provider’s
instructions. The preparation of PT samples must be documented in a traceable log or other
traceable format. The diluted PT sample becomes a routine environmental sample and is added
to a routine sample batch for analysis. Ref: Proficiency Testing Requirements, February 20,
2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the Total Residual
Chlorine PT would satisfy the documentation requirement.
D. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for any
environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
pH – Standard Methods, 4500 H+ B-2000
Comment: The laboratory benchsheet did not include the units of measure. The North Carolina
Administrative Code, 15A NCAC 02H .0805 (g) (1) states: Data pertinent to each analysis must be
maintained for five years. Certified Data must consist of date collected, time collected, sample site,
sample collector, and sample analysis time. The field bench sheets must provide a space for the
signature or initials of the analyst, and proper units of measure for all analyses. Notification of
acceptable corrective action (i.e., a statement that the revised pH benchsheet developed by the inspector,
which documents the units of measure, would be used starting March 31, 2014) was received via email
on March 27, 2014. No further response is necessary for this finding.
E. Finding: Values were reported that exceed the method specified accuracy of 0.1 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-2000, (6).
Total Residual Chlorine – Standard Methods, 4500 Cl G-2000
Comment: It would be acceptable and more economical, in terms of cost and time, if the facility
switched from liquid reagents to DPD powder pillows. The use of the flow-thru cell could also be
discontinued.
Comment: The 10 µg/L calibration verification standard used in the annual 5-point calibration curve
verification did not recover within the required ± 25 % acceptance limit. The facility was told by the
contract lab that performed the verification that even though that particular standard recovery failed,
that the overall curve passed due the fact that the overall correlation coefficient of the curve was
≥0.995. This is not true and the contract lab has been contacted and made aware of all the acceptance
criteria for curve verifications. The NC WW/GW LC Approved Procedure for Analysis of Total Residual
document states: The values obtained must not vary by more than 10% of the known value for
standard concentrations greater than or equal to 50 g/L and must not vary by more than 25% of the
known value for standard concentrations less than 50 g/L. The overall correlation coefficient of the
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curve must be ≥0.995. Notification of acceptable corrective action (i.e., documentation of an acceptable
5-point curve verification with gel check standard value assignment) was received via email on April 9,
2014. No further response is necessary for this finding.
Comment: A check standard was not being analyzed whenever sample analyses are performed. The
NC WW/GW LC Approved Procedure for Analysis of Total Residual Chlorine document states: When
a five-standard annual standard curve verification is used, the laboratory must check the calibration
curve each analysis day. To do this, the laboratory must analyze a calibration blank to zero the
instrument and analyze a check standard each day that samples are analyzed. The value obtained for
the check standard must read within 10% of the true value of the check standard. If the obtained value
is outside of the ±10% range, corrective action must be taken. Notification of acceptable corrective
action (i.e., a statement that the a check standard (gel) was purchased, assigned a meter specific value
on program 86 and put into use on April 10, 2014) was received via email on April 10, 2014. No further
response is necessary for this finding.
Comment: The flow-thru cell had green algae growing in it. The North Carolina Administrative Code,
15A NCAC 2H .0805 (g) (4) states: Each facility must have glassware, chemicals, supplies, equipment,
and a source of distilled or deionized water that will meet the minimum criteria of the approved
methodologies. “Meeting the minimum criteria” means the equipment must also be properly
maintained. Clean and maintain equipment as indicated by the manufacturer’s instructions. Sample
lines and the pour-thru cell can become discolored and clogged due to a buildup of colored reaction
products. Notification of acceptable corrective action (i.e., a statement that the pour-thru cell was cleaned
on March 31, 2014, prior to sending the meter out to have the 5-point curve verification repeated) was
received via email on April 10, 2014. No further response is necessary for this finding.
F. Finding: Values less than the established minimum reporting level of 10 µg/L are reported.
Requirement: The concentrations of the calibration standards must bracket the concentrations
of the samples analyzed. One of the standards must have a concentration equal to or below the
lower reporting concentration for Total Residual Chlorine. The lower reporting limit must be less
than or equal to the permit limit. Ref: NC WW/GW LC Approved Procedure for Analysis of Total
Residual.
Comment: If the laboratory chooses to have a lower reporting limit of 10 µg/L for residual
chlorine, you must analyze at least a 10 g/L or lower standard and report lower concentrations
as <10 µg/L or < the concentration of the chosen standard.
Temperature – Standard Methods, 2550 B-2000
G. Finding: The temperature correction factor is not documented on the meter used to obtain
reported temperature values.
Requirement: Thermometers and temperature measuring devices, used to measure
temperature for compliance monitoring, must be checked every 12 months against a NIST
traceable thermometer. The thermometer/meter readings must be less than or equal to 1ºC
from the NIST traceable thermometer reading. The documentation must include the serial
number of the NIST traceable thermometer that was used in the comparison. Document any
correction that applies on both the thermometer/meter and on a separate sheet to be filed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Temperature.
H. Finding: The temperature correction factor is not being applied to reported temperature values.
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Requirement: Document sample temperature measurements with any applicable temperature
corrections applied. Ref: NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: The temperature correction factor on the meter used to read the temperature was
0.7 °C. The temperature reading that is documented must have this value added to it. If t he
meter displayed a value of 12.2 °C, then 12.9 °C would be written down. This would be reported
as 13 °C on the Discharge Monitoring Report (DMR).
I. Finding: The reported temperature values are not consistently read at the effluent.
Requirement: Temperature readings are to be taken at the effluent, which defined as
wastewater discharged following all treatment processes from a water pollution control facility or
other point source whether treated or untreated. Ref: 15A NCAC 02B .0503 (12).
Comment: Temperature readings, which are required 5 days a week, are only taken at the
effluent on days when pH, DO (both required weekly) and/or TRC (required twice per week) are
analyzed. At other times, temperature readings are taken at a point preceding the last process
control device.
Comment: Due to the effluent’s susceptibility to temperature change, the temperature readings
should always be read at a point as close to the discharge point as is safely possible.
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 December, 2013 and January and February, 2014. No transcription errors were observed
A copy of this report will be made available to the Regional Office.
V. CONCLUSIONS:
Correcting the above-cited findings will help this lab to produce quality data and meet certification
requirements. The inspector would like to thank the staff for its assistance during the inspection and
data review process. Please respond to all findings.
Report prepared by: Todd Crawford Date: April 1, 2014
Report reviewed by: Tonja Springer Date: April 2, 2014