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HomeMy WebLinkAbout#194_2023_0228_JMS_FINALNC 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 March 14, 2023 194 Mr. Mark Jones Town of Waynesville WWTP 566 Walnut Trail Rd Waynesville, NC 28785 Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) Maintenance Inspection Dear Mr. Jones: Enclosed is a report for the inspection performed on February 28, 2023 by Jason Smith. 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 x 251. Sincerely, Anna Ostendorff Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Todd Crawford, Jason Smith, Master File #194 On-Site Inspection Report LABORATORY NAME: Town of Waynesville WWTP NPDES PERMIT #: NC0025321 WATER QUALITY PERMIT #: WQ0013116 ADDRESS: 566 Walnut Trail Rd Waynesville, NC 28785 CERTIFICATE #: 194 DATE OF INSPECTION: February 28, 2023 TYPE OF INSPECTION: Municipal Maintenance AUDITOR(S): Jason Smith LOCAL PERSON(S) CONTACTED: Mark Jones and Joey Ashe 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. 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 December 31, 2023. The laboratory is reminded that SOPs 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”. Page 2 #194 Town of Waynesville WWTP Contracted analyses are performed by Environmental Testing Solutions Inc. (Certification #600). 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 benchsheets are lacking required documentation: the proper units of measure. 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 that samples are analyzed. Ref: 15A NCAC 02H .0805 (a) (7) (F) (xii). Comment: The units of measure were not documented in the following locations: • pH units of measure on the Ammonia Nitrogen benchsheet • Dissolved Oxygen (DO) units of measure on the BOD calibration log • pH units of measure in the sample pH section of the BOD benchsheet B. Finding: The laboratory is not documenting the barometric pressure and salinity values used to calibrate the DO meter. 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: 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). C. 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 SM 4500 Cl G-2011). D. Finding: TRC samples are sometimes being filtered without documentation. Page 3 #194 Town of Waynesville WWTP 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, when applicable. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). E. Finding: Documentation does not demonstrate that the initial DO for BOD analysis is measured within 30 minutes of sample preparation. This is considered pertinent data. Requirement: All analytical records, including original observations and information necessary to facilitate historical reconstruction of the calculated results, shall be maintained for five years. All analytical data and records pertinent to each certified analysis shall be available for inspection upon request. Ref: 15A NCAC 02H .0805 (a) (7) (E). Requirement: After preparing dilution, measure initial DO within 30 min. Ref: Standard Methods, 5210 B-2016. (5) (g). BOD – Standard Methods, 5210 B-2016 (Aqueous) F. Finding: Calculated results of sample dilutions are not being evaluated to ensure < 30% difference between high and low values. Requirement: Identify results in the test reports when any of the following QC conditions occur: test replicates show >30% difference between highest and lowest values. Ref: Standard Methods, 5210 B-2016. (7) (b). Vector Attraction Reduction Option 6 – Addition of Alkali Comment: The laboratory has not analyzed this parameter since 2019 when the facility began sending the sludge to the landfill. The laboratory would like to remain certified for this parameter in case this changes in the future. Reporting Comment: Temperature is being reported to 0.1°C on the Discharge Monitoring Report (DMR). 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 Division of Water Resource’s Precision in Discharge Monitoring Reports document. G. 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 monthly report forms. Ref: 15A NCAC 02B .0506 (b) (3) (J). Comment: The laboratory analyzes Temperature immediately using the DO meter and reports this result. A sample is also collected and analyzed in the laboratory for pH. The Temperature of the pH sample is recorded, but not reported. Page 4 #194 Town of Waynesville WWTP 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 the Town of Waynesville WWTP (NPDES permit # NC0025321) for February, June and August 2022. 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 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: Jason Smith Date: March 7, 2023 Report reviewed by: Jill Puff Date: March 7, 2023 Certificate Number:194 Effective Date:1/1/2023 Expiration Date:12/31/2023 Lab Name:Town of Waynesville WWTP Address:566 Walnut Trail Waynesville, NC 28785 North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment:7/30/2021 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 IDEXX Colilert ®18 (MPN) (Aqueous) BOD SM 5210 B-2016 (Aqueous) CHLORINE, TOTAL RESIDUAL SM 4500 Cl G-2011 (Aqueous) DISSOLVED OXYGEN Hach 10360-2011, Rev. 1.2 (Aqueous) NITROGEN, AMMONIA EPA 350.1, Rev. 2.0, 1993 (TNT) (Aqueous) pH SM 4500 H+B-2011 (Aqueous) RESIDUE, SUSPENDED SM 2540 D-2015 (Aqueous) TEMPERATURE SM 2550 B-2010 (Aqueous) VECTOR ATTRACTION REDUCTION: OPTION 6 Addition of Alkali 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.