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INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #: 5569
Laboratory Name: NC Parks and Recreation – Jordan Lake
Inspection Type: Field Maintenance
Inspector Name(s): Jeffrey R. Adams
Inspection Date: March 31, 2010
Date Report Completed: April 8, 2010
Date Forwarded to Reviewer: April 8, 2010
Reviewed by: Jason Smith
Date Review Completed: April 12, 2010_____________
Cover Letter to use: X Insp. Initial Insp. Reg. Insp. No Finding Insp. CP
Unit Supervisor: Dana Satterwhite
Date Received: April 28, 2010
Date Forwarded to Alberta: April 29, 2010
Date Mailed: April 29, 2010
_____________________________________________________________________
On-Site Inspection Report
LABORATORY NAME: NC Parks and Recreation – Jordan Lake
NPDES PERMIT #: WQ0004122, WQ0004988, WQ0000488
ADDRESS: 280 State Park Road
Apex, NC 27523
CERTIFICATE #: 5569
DATE OF INSPECTION: March 31, 2010
TYPE OF INSPECTION: Initial Field
AUDITOR(S): Jeffrey R. Adams
LOCAL PERSON(S) CONTACTED: Craig Autry and Rudy Scarborough
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the
analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory was neat and equipment appeared well maintained. Laboratory documentation, however, was
incomplete, inaccurate and additional quality control procedures need to be implemented. The inspector is
concerned about the number of transcription errors and record omissions detected during the data review
process. Many of the data points recorded on the benchsheet did not compare to the values reported on the
Non-Discharge Monitoring Reports (NDMRs). These observations are documented in the Paper Trail
Investigation section of this report.
The laboratory was given copies of the Technical Assistance Documents for all field parameters during the
inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Recommendation: In order to improve the quality of the data being reported, it is recommended that
the laboratory expand their data verification system to include a technical peer review process to check
for accuracy and completeness of data. Steps must be taken to minimize and correct transcription
errors. The transcription errors and data omissions noted during the paper trail investigation
underscore the importance of this type of technical peer review process.
Total Residual Chlorine – Standard Methods, 18th Edition, 4500 Cl G
A. Finding: The laboratory is not verifying the calibration curve each analysis day and documenting
the process.
Requirement: When a five standard curve is used, the laboratory must verify the calibration
curve each analysis day. To do this, the laboratory must analyze a blank to zero the instrument
and a check standard each day that samples are analyzed. Ref: Technical Assistance for Field
Analysis of Total Residual Chlorine.
Requirement: If compliance samples are analyzed throughout the day, a post calibration check
(mid-range) must be analyzed mid-day and at the end of the run (i.e., roughly every 4 hours based
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#5569 NC Parks and Recreation – Jordan Lake
on an eight hour day). The check standard concentration must be at mid range and recovery must
be within 10% of the known value. Ref: Technical Assistance for Field Analysis of Total Residual
Chlorine.
Requirement: Data pertinent to each analysis must be maintained for five years. A record of
instrument calibration where applicable, must be filed in an orderly manner so as to be readily
available for inspection upon request. Ref: 15A NCAC 02H .0805 (g) (2).
Recommendation: It is recommended that the laboratory purchase low-range secondary gel
standards (these are usually marketed in three dilutions) to be used for the daily calibration check.
pH – Standard Methods, 18th Edition, 4500 H+ B
Temperature – Standard Methods, 18th Edition, 2550 B
C. Finding: The laboratory is performing the NIST temperature sensor check annually, but is not
posting corrections on the meter.
Requirement: The temperature correction (even if it is zero) must be posted on the meter as
well as in hard copy format (to be retained for 5 years). Ref: Technical Assistance for Field
Analysis of pH and Technical Assistance for Field Analysis of Temperature.
pH – Standard Methods, 18th Edition, 4500 H+ B
Comment: The laboratory was not analyzing a calibration check following instrument calibration and after
sample analysis mid-day and/or at the end of the day. The Technical Assistance for Field Analysis of pH
states, if compliance samples are analyzed throughout the day, a post calibration check (e.g., 7 buffer)
must be analyzed mid-day and at the end of the run (i.e., roughly every 4 hours based on an eight hour
day). The laboratory is now performing and documenting the pH checks after initial calibration. No
further response is required for this finding.
D. Finding: The proper units of measure (S.U. for pH) are not documented on the benchsheet.
Requirement: 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. Ref: 15A NCAC 02H .0805 (g) (1).
E. Finding: Data values are reported on the Discharge Monitoring Report to 0.01 S.U. not 0.1 S.U.
as required by the method.
Requirement: A variance of ± 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, 18th Edition, 4500 H+ B. (6).
Comment: Although Standard Methods requires reporting to one decimal place for pH,
laboratories must follow vendor instructions when analyzing performance testing samples.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing benchsheets and contract lab reports to Non-Discharge Monitoring
Reports (NDMRs) submitted to the North Carolina Division of Water Quality. Data were reviewed for Poplar
Point (NPDES permit #WQ0004122), Seaforth (permit #WQ0004988), and Vista Point (NPDES permit
#WQ0000488), for December, 2009 and January and February, 2010. The following errors were noted:
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#5569 NC Parks and Recreation – Jordan Lake
Date Parameter Location -
Poplar Point
Value on Benchsheet
Value on NDMR
12/10/09 Total Residual
Chlorine
Effluent No Data 0.5 mg/L
12/10/09 pH Effluent No Data 6.34 s. u.
12/11/09 Total Residual
Chlorine
Effluent No Data 0.3 mg/L
12/11/09 pH Effluent No Data 6.45 s. u.
12/22/09 pH Effluent 5.83 s. u. 6.53 s. u.
02/08/10 pH Effluent 5.91 s. u. 5.98 s. u.
02/09/10 pH Effluent No Data 6.44 s. u.
02/09/10 Total Residual
Chlorine
Effluent 0.35 mg/L 0.32 mg/L
02/10/10 pH Effluent 6.19 s. u. 6.17 s. u.
02/11/10 pH Effluent No Data 6.21 s. u.
02/11/10 Total Residual
Chlorine
Effluent No Data 0.43 mg/L
02/18/10 pH Effluent 6.03 s. u. 6.2 s. u.
02/21/10 pH Effluent No Data 6.43 s. u.
02/21/10 Total Residual
Chlorine
Effluent No Data 0.27 mg/L
02/22/10 pH Effluent 6.43 s. u. 6.0 s. u.
02/22/10 Total Residual
Chlorine
Effluent 0.27 mg/L 0.3 mg/L
Date Parameter Location -
Seaforth
Value on Benchsheet
Value on NDMR
12/03/09 pH Effluent 6.1 s. u. No Data
12/03/09 Total Residual
Chlorine
Effluent 0.4 mg/L No Data
12/04/09 pH Effluent No Data 6.1 s. u.
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#5569 NC Parks and Recreation – Jordan Lake
Date Parameter Location -
Seaforth
(Cont’d)
Value on Benchsheet
Value on NDMR
12/04/09 Total Residual
Chlorine
Effluent No Data 0.4 mg/L
01/26/10 pH Effluent 6.80 s. u. 6.11 s. u.
02/07/10 pH Effluent 6.05 s. u. 6.49 s. u.
02/08/10 pH Effluent 6.05 s. u. 6.55 s. u.
02/08/10 Total Residual
Chlorine
Effluent 0.31 mg/L 0.4 mg/L
Date Parameter Location -
Vista Point
Value on Benchsheet
Value on NDMR
12/01/09 pH Effluent 6.29 s. u. 6.75 s. u.
12/01/09 Total Residual
Chlorine
Effluent 0.12 mg/L 0.33 mg/L
12/04/09 pH Effluent 6.27 s. u. 6.71 s. u.
12/04/09 Total Residual
Chlorine
Effluent 0.73 mg/L 0.50 mg/L
12/18/09 pH Effluent 6.20 s. u. 6.31 s. u.
12/18/09 Total Residual
Chlorine
Effluent 0.09 mg/L 0.30 mg/L
In order to avoid questions of legality or possible monitoring frequency violations, it is recommended
that you contact the appropriate Regional Office for guidance as to whether an amended Non-
Discharge Monitoring Report will be required. A copy of this report will be forwarded to the Regional
Office.
V. CONCLUSIONS:
Correcting the above-cited findings and implementing the recommendations will help this lab to produce
quality data and meet certification requirements. The inspector would like to thank the staff for its assistance
in the inspection and data review process. Please respond to all findings.
Report prepared by: Jeffrey R. Adams Date: April 8, 2010
Report reviewed by: Jason Smith Date: April 12, 2010