Loading...
HomeMy WebLinkAbout#5212_2023_0221_JP_FINAL INSPECTION REPORT ROUTING SHEET To be attached to all inspection reports in-house only. Laboratory Cert. #: 5212 Laboratory Name: Envirolink Inc. Date Mailed: Special Mailing Instructions: Email copy to WaRO, Anna Gurney and Michael Myers (Envirolink Owner) 4/19/23 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 18, 2023 5212 Mr. Anthony Branch Envirolink Inc. 4700 Homewood Court, Suite 108 Raleigh, NC 27609 Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC WW/GW LCB) Maintenance Inspection Dear Mr. Branch: Enclosed is a report for the inspection performed on February 21 and 22, 2023 by Beth Swanson, Anna Ostendorff, Jill Puff, Thomas Halvosa, Tonja Springer and Michael Cumbus. 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. 251. Sincerely, Anna Ostendorff Technical Assistance & Compliance Specialist Division of Water Resources Attachment cc: Todd Crawford, Jill Puff, Anna Gurney, Master File #5212 On-Site Inspection Report LABORATORY NAME: Envirolink Inc. NPDES PERMIT #: NC0001376, NC0026000, NC0026042, NC0042251, NC0056731, NC0060526, NC0085481, NC0088731, NC0089176, NC0087840 WATER QUALITY PERMIT #: WQ0023934, WQ0002560, WQ0003405, WQ0012901, WQ0013200, WQ0018708, WQ0002838, WQ0004696, WQ0014306, WQ0015052, WQ0031030, WQ0035706 ADDRESS: 4700 Homewood Court, Suite 108 Raleigh, NC 27609 CERTIFICATE #: 5212 DATE OF INSPECTION: February 21-22, 2023 TYPE OF INSPECTION: Field Commercial Maintenance AUDITOR(S): Jill Puff, Anna Ostendorff, Beth Swanson, Tonja Springer, Tom Halvosa and Michael Cumbus LOCAL PERSON(S) CONTACTED: Charles Donnell, Dave McDaniel, Tracy Miller, Josh Powers, Anthony Branch, Lynn Pope, William Lamm and Ron Wall I. INTRODUCTION: This laboratory was inspected by representatives 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 laboratory has several branches located throughout North Carolina. This was an abbreviated audit limited in scope to the analysts based in the Raleigh branch office and affiliated permits. Other locations will be scheduled for audit at a later date. The laboratory has multiple analysts that operate wastewater plants, collect samples and perform field analyses throughout the region. The analysts operate independently from one another and there is a lack of consistency in procedural and documentation practices. The laboratory would benefit greatly by hiring a dedicated Quality Assurance Officer to ensure benchsheets are completed correctly, review instrument calibrations and other quality control measures for each analyst, and to ensure all annual verifications are completed as scheduled. The facility has equipment to perform the analyses, but does not have backups for the analysts to use when their meters are sent for repairs or to have annual verifications completed. The analysts and members of management were forthcoming and responded well to suggestions from the auditors. All required Proficiency Testing (PT) Samples for the 2023 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, 2023. The laboratory did not have Quality Assurance (QA) and/or Standard Operating Procedure (SOP) document(s) in place for all currently certified parameters. These documents must be submitted for review as specified in Finding A. Page 2 #5212 Envirolink Inc. 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”. Contracted analyses are performed by Albemarle Environmental (Uncertified, see Finding GG) Environmental Chemists, Inc. (Certification # 94), Meritech Inc. (Certification #165), and Statesville Analytical Holdings (Certification #440). 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: Comment: The Comments for the Findings are not intended to be all-inclusive, but a representative selection of the conditions discussed with the laboratory during the audit. If individual permits are not listed, the Finding applies laboratory-wide. Documentation A. Finding: SOPs have not been developed for the methods included on the laboratory’s Certified Parameters Listing (CPL). Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. A copy of each analytical method or Approved Procedure and Standard Operating Procedure shall be available to each analyst and available for review upon request by the State Laboratory. Standard Operating Procedure documentation shall state the effective date of the document and shall be reviewed every two years and updated if changes in procedures are made. Each laboratory shall have a formal process to track and document review dates and any revisions made in all Standard Operating Procedure documents. Supporting Records shall be maintained as evidence that these practices are implemented. Ref: 15A NCAC 02H .0805 (g) (4). Comment: The laboratory must have an updated QC/SOP document for the parameters included on their CPL by October 31, 2023. This must be submitted for review upon completion. SOP templates have been developed and are available for download on the NC WW/GW LCB website. 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 multiple instances and methods of improper error corrections, including overwriting, obliteration of data, and Wite-Out. Comment: The pre-printed rows or columns on the laboratory benchsheet are sometimes relabeled without proper correction of the original headings. This Finding applies to the following permits: Page 3 #5212 Envirolink Inc. • WQ0018707 – Baytree Lakes WWTP • NC0020061 – Spring Hope WWTP C. Finding: The handwriting on the laboratory benchsheet is sometimes difficult to decipher. Requirement: All analytical records shall be legible to all parties and safeguarded against unauthorized amendment, obliteration, erasures, overwriting and corruption. Ref: 15A NCAC 02H .0805 (g) (1). Comment: Benchsheet entries, including units of measure and decimal points, are not always legible. This Finding applies to the below permits: • NC0060526 – Pope Industrial Park WWTP • WQ0023934 –Town of Pikeville WWTP • WQ0002560 – Town of Bailey WWTF • NC0020061 – Spring Hope WWTP D. Finding: The laboratory benchsheet is sometimes lacking required documentation: the method or Standard Operating Procedure reference. 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. 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). Comment: There are several versions of the laboratory benchsheet in use by the analysts, one of which includes the method reference for Dissolved Oxygen (DO). No other method references are included on any benchsheets. E. Finding: The laboratory benchsheet is lacking required documentation: the instrument identification. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the instrument identification. 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) (C). Comment: This Finding applies to compliance Temperature monitoring for all permits. Comment: This Finding applies to the below listed permits for Total Residual Chlorine (TRC), pH or DO compliance monitoring: • WQ0002560 – Town of Bailey WWTF • WQ0003405 – Elm City WWTP • NC0056731 – Grande Oaks WWTP • WQ0023934 – Pikeville WWTP • WQ0018707 – Baytree Lakes WWTP • NC0088731 – Certainteed WWTP • NC0085481 – Penderlea Elementary School WWTP • NC0020061 – Spring Hope WWTP Page 4 #5212 Envirolink Inc. Recommendation: It is recommended the laboratory document both the instrument model and a unique identifier, such as the serial number, on all benchsheets. F. Finding: The laboratory benchsheet is lacking required documentation: the sample collector. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the sample collector. 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) (D). Comment: The laboratory benchsheet does not clearly identify that the sample collector and analyst are the same. G. Finding: The laboratory benchsheet is sometimes lacking required documentation: the date and time of sample collection. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the date and time of sample collection. 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) (F). Comment: This Finding applies to the below listed permits: • WQ0018707 – Baytree Lakes WWTP • NC0085481 – Penderlea Elementary School WWTP H. Finding: Only one time for sample collection and analysis is documented without noting samples are analyzed in situ. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Date and time of sample collection; Date and time of sample analysis - Alternatively, one time may be documented for collection and analysis with the notation that samples are measured in situ or immediately at the sampling site (i.e., immediately following collection at a location as near to the collection point as possible). When this 'one time' option is used, state that the documented time is both collection and analysis time. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Temperature. Requirement: Date and time of sample analysis must be documented to verify the 15-minute holding time is being met. Alternatively, one time may be documented for collection and analysis with the notation that samples are measured in situ or immediately at the sampling site. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved Oxygen, NC WW/GW LCB Approved Procedure for the Analysis of pH, and NC WW/LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G- 2011). Comment: This Finding applies to the below listed permits: • NC0020061 – Spring Hope WWTP • NC0060526 – Pope Industrial Park WWTP • WQ0002838 - Deerhurst MHP WWTP Page 5 #5212 Envirolink Inc. I. Finding: The units of measure are not consistently documented on the benchsheets. 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 samples are analyzed. Ref: 15A NCAC 02H .0805 (g) (2) (L). Comment: This Finding applies to all certified parameters for the below listed permits: • WQ0002560 – Town of Bailey WWTF • WQ0003405 – Elm City WWTP • NC0056731 – Grande Oaks WWTP • WQ0018707 – Baytree Lakes WWTP • NC0085481 – Penderlea Elementary School WWTP Comment: The benchsheet pre-printed row heading documents the units of measure for TRC in µg/L, but the data is analyzed, documented and reported on the Discharge Monitoring Report (DMR) in mg/L. This applies to the below listed permits: • WQ0003405 – Elm City WWTP • WQ0002838 – Deerhurst MHP WWTP • WQ0002560 – Town of Bailey WWTF • NC0056731 – Grande Oaks WWTP Comment: This Finding applies to the logbook used for pH and TRC calibration for the below listed permits: • WQ0002560 - Town of Bailey WWTF • WQ0023934 - Town of Pikeville WWTP J. Finding: The laboratory is not consistently documenting all traceability information for purchased materials, reagents and standards. Cited previously on September 21, 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). 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 pH buffer lot numbers and TRC gel-standard lot number are sometimes documented, but not consistently done. K. 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). L. Finding: The Dissolved Oxygen (DO) meter calibration is not consistently being documented each day that Compliance Samples are analyzed. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Page 6 #5212 Envirolink Inc. Requirement: The laboratory must document each time that a calibration is performed. Calibration documentation must include the instrument identification as well as the temperature, the elevation or barometric pressure (in mmHg), and the salinity* of the sample to be analyzed. After calibration, record the final DO reading in mg/L or % saturation. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO). Comment: This Finding applies to the below listed permit: • NC0060526 – Pope Industrial Park WWTP M. Finding: The laboratory is not documenting the barometric pressure and salinity values used to calibrate the DO meter. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). 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). N. Finding: The acceptable range of the Daily Check Standard for TRC is not documented on the laboratory benchsheet. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: The following must be documented in indelible ink whenever sample analysis is performed: Quality control assessments (percent recovery or acknowledgement that observed concentration is within the acceptance range). Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G- 2011). Comment: This Finding applies to the below listed permits: • WQ0002560 – Town of Bailey WWTF • WQ0023934 – Town of Pikeville WWTP • WQ0003405 – Elm City WWTP • NC0060526 – Pope Industrial Park WWTP • WQ0002838 – Deerhurst MHP WWTP • NC0026042 – Town of Robersonville WWTP • NC0020061 – Spring Hope WWTP Proficiency Testing O. Finding: The laboratory is not documenting PT Sample analyses. Requirement: All PT Sample analyses must be recorded in the same daily analysis records (e.g., benchsheets) as for any Compliance Sample. This serves as the permanent laboratory record. Ref: Proficiency Testing Requirements, January 1, 2023, Revision 6, Section 3.6. Requirement: The laboratory shall retain all records necessary to facilitate historical reconstruction of the analysis and reporting of analytical results for PT Samples. This means the laboratory must have available and retain for five years [pursuant to 15A NCAC 02H .0805 Page 7 #5212 Envirolink Inc. (a) (7) (E) and (g) (1)] all of the raw data, including benchsheets, instrument printouts and calibration data, for all PT Sample analyses and the associated QC analyses conducted by all Parameter Methods. Ref: Proficiency Testing Requirements, January 1, 2023, Revision 6, Section 4.0. P. 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, January 1, 2023, Revision 6, Section 3.6. Comment: This Finding applies to Settleable Residue and TRC. Comment: Dating and initialing the instruction sheet for each prepared PT Sample would satisfy the documentation requirement. Q. Finding: PT Samples are not distributed among all analysts and instruments from year to year. Requirement: Laboratories shall also ensure that, from year to year, PT Samples are equally distributed among personnel trained and qualified for the relevant tests and instrumentation (when more than one instrument is used for routine Compliance Sample analyses), that represents the routine operation of the work group at the time the PT Sample analysis is conducted. Ref: Proficiency Testing Requirements, January 1, 2023, Revision 6, Section 3.6. Comment: The same analyst has performed PT Sample testing every year. Quality Control R. 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: Implementation of a documented training program would improve consistency between the analysts with regards to procedural actions, documentation of calibration and compliance monitoring results. S. Finding: The laboratory's current structure does not include a position that provides personal and direct supervision of the technical personnel. Page 8 #5212 Envirolink Inc. Requirement: Supervisors shall provide personal and direct supervision of the technical personnel and shall be responsible for adherence to all requirements in this Rule. Ref: 15A NCAC 02H .0805 (g) (11). Comment: The data and QC produced by the analysts are not reviewed for accuracy. Comment: The number and type of Findings cited in this report shows the need for a position that can carry out the proper oversight for conforming to certification requirements. T. Finding: The laboratory is not calibrating the mechanical volumetric liquid-dispensing devices used for critical measurements at least once every twelve months. Cited previously on September 21, 2010. 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: Preparation of the annual PT Samples is considered a critical measurement. Comment: A volumetric pipet can be used to prepare dilutions and alleviate the need to have the auto-pipettors calibrated. pH - Standard Methods, 4500 H+ B-2011 (Aqueous) U. Finding: The pH meter is not calibrated prior to analysis of samples each day compliance monitoring is performed. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Instruments are to be calibrated according to the manufacturer’s calibration procedure prior to analysis of samples each day compliance monitoring is performed. Calibration must include at least two buffers. The meter calibration must be verified with a third standard buffer solution (i.e., check buffer) prior to sample analysis. The calibration and check standard buffers must bracket the range of the samples being analyzed. Ref: NC WW/GW LCB Approved Procedure for the Analysis of pH. Comment: This Finding applies to the below listed permits: • WQ0002560 – Town of Bailey WWTF • WQ0023934 – Town of Pikeville WWTP • WQ0003405 – Elm City WWTP • NC0088731 – Certainteed WWTP after 9/2021 • NC0020061 – Spring Hope WWTP V. 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-2011. (6). Page 9 #5212 Envirolink Inc. 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. Comment: This Finding applies to the below listed permits: • WQ0002560 – Town of Bailey WWTF • WQ0003405 – Elm City WWTP • NC0056731 – Grande Oaks WWTP • NC0060526 – Pope Industrial Park WWTP W. Finding: The acceptance criterion for the check standard buffer is not being assessed. Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data shall be traceable to the associated sample analyses and shall consist of: the quality control assessments. Ref: 15A NCAC 02H .0805 (g) (2) (O). Comment: This Finding applies to the below listed permits: • WQ0002560 – Town of Bailey WWTF • WQ0023934 – Town of Pikeville WWTP • WQ0003405 – Elm City WWTP • NC0060526 – Pope Industrial Park WWTP • NC0088731 – Certainteed WWTP • NC0020061 – Spring Hope WWTP Comment: There were no instances observed where the pH calibration check standard did not read within ±0.1 S.U. of the true value. X. Finding: The laboratory is not analyzing a post-analysis check standard buffer when analyses are performed at multiple sample sites in a single day. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: When performing analyses at multiple sample sites, a post-analysis calibration verification using the check standard buffer must be analyzed at the end of the run. It is recommended that a mid-day check standard buffer be analyzed when samples are analyzed over an extended period of time. The post-analysis check standard buffer(s) must read within ±0.1 S.U. or corrective actions must be taken. If recalibration is necessary, all samples analyzed since the last acceptable calibration verification must be reanalyzed, if possible. If samples cannot be reanalyzed, the data must be qualified. Ref: NC WW/GW LCB Approved Procedure for the Analysis of pH. Comment: Effluent, upstream and downstream sample locations at a single facility are considered separate sites. Dissolved Oxygen – Standard Methods, 4500 O G-2016 (Aqueous) Y. Finding: The instruments are not being calibrated prior to analysis of samples each day compliance monitoring is performed. Requirement: Instruments are to be calibrated according to the manufacturer’s calibration procedure prior to analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO). Page 10 #5212 Envirolink Inc. Comment: This Finding applies to the below listed permits: • WQ0023934 – Town of Pikeville WWTP • WQ0002560 – Town of Bailey WWTF • NC0088731 – Certainteed WWTP – after 9/2021 Z. Finding: When analyses are performed at multiple sample sites, the laboratory is not calibrating prior to sample analysis at each sample site or performing a Post-Analysis Calibration Verification. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: When performing analyses at multiple sample sites, the meter must be calibrated at each sample site prior to analysis or a post-analysis calibration verification must be performed at the end of the run, regardless of meter type. The calculated theoretical DO value must verify the meter reading within ±0.5 mg/L. If the meter verification does not read within ±0.5 mg/L of the theoretical DO, corrective action must be taken. If the meter is not calibrated at each sample site, it is recommended that a mid-day calibration be performed when samples are extended over an extended period of time. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved Oxygen (DO). Comment: This Finding applies to the below listed permits: • NC0060526 – Pope Industrial Park WWTP • NC0056731– Grande Oaks WWTP Chlorine, Total Residual – Standard Methods, 4500 Cl G-2011 (Aqueous) AA. Finding for Immediate Response: The laboratory is not verifying the factory-set calibration every 12 months. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Annual Factory-set Calibration Curve Verification: This type of calibration curve verification must be performed initially, at least every 12 months and any time the instrument optics are serviced. Zero the instrument with a Calibration Blank and then analyze a Method Blank and a series of five standards (do not use gel or sealed liquid standards for this purpose). The calibration standard values obtained must not vary by more than ±10% from the known value for standard concentrations greater than or equal to 50 μg/L and must not vary by more than ±25% from the known value for standard concentrations less than 50 μg/L. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: This Finding applies to the spectrophotometers and colorimeters used to measure compliance samples for TRC by analysts based out of the Raleigh office of Envirolink Inc. Envirolink Inc. agrees to submit proof of acceptable verifications of the factory-set curves for all chlorine meters used for compliance monitoring by March 8, 2023. The original deadline was extended to minimize the impact on daily operations. Proof of acceptable verifications of the factory-set curves was submitted on March 28, 2023. BB. Finding: The laboratory benchsheet is lacking required documentation: Date of most recent TRC calibration curve verification. Page 11 #5212 Envirolink Inc. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). 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). Comment: This Finding applies to the below listed permits: • NC0060526 – Pope Industrial Park WWTP • NC0020061 – Spring Hope WWTP CC. Finding: The laboratory did not assign a true value to the gel-type standard prior to initial use. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Purchased “gel-type” or sealed liquid standards may be used only for daily calibration curve verifications. These standards must have a true value assigned initially and every 12 months thereafter. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: This Finding applies to the below listed permits: • WQ0002838 – Deerhurst MHP WWTP • NC0088731 – Certainteed WWTP • NC0020061 – Spring Hope WWTP • NC0060526 – Pope Industrial Park WWTP DD. Finding: The laboratory is not assigning the gel-type standard concentration a true value every twelve months. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: Purchased “gel-type” or sealed liquid standards may be used only for daily calibration curve verifications. These standards must have a true value assigned initially and every 12 months thereafter. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: This Finding applies to the below listed permits: • NC0060526 – Pope Industrial Park WWTP • NC0088731 – Certainteed WWTP • NC0020061 – Spring Hope WWTP • WQ0002838 – Deerhurst MHP WWTP • NC0056731– Grande Oaks WWTP • WQ0023934 – Town of Pikeville WWTP EE. Finding: The Factory-set Calibration Curve is not checked with a Daily Check Standard each day that samples are analyzed. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Page 12 #5212 Envirolink Inc. Requirement: When an annual five-standard Factory-set Calibration Curve verification is used, the laboratory must check the calibration curve each analysis day. To do this, the laboratory must zero the instrument with a Calibration Blank and analyze a Daily Check Standard (gel-type standards are most widely used for these purposes). The value obtained for the Daily Check Standard must read within ±10% of the true value of the Daily Check Standard for standards ≥50 μg/L and within ±25% of its true value for standards <50 μg/L. If the obtained value is outside of the acceptance limits, corrective action must be taken. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G-2011). Comment: This Finding applies to the below listed permits: • WQ0002560 – Town of Bailey WWTF • WQ0023934 – Town of Pikeville WWTP • WQ0003405 – Elm City WWTP • NC0060526 – Pope Industrial Park WWTP • NC0088731 – Certainteed WWTP • NC0020061 – Spring Hope WWTP Temperature – Standard Methods, 2550 B-2010 (Aqueous) Recommendation: It is recommended that temperatures for compliance monitoring be reported in whole numbers on the DMR. FF. Finding for Immediate Response: The annual temperature-measuring device verification procedure has not been performed. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H 0805(g) (4). Requirement: All compliance temperature-measuring devices without a valid NIST traceable certificate , or with an expired NIST traceable certificate, must be verified against a Reference Temperature-Measuring Device and the process documented initially and every 12 months. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Temperature. Requirement: Verification documentation must include the serial number of the device being checked. The serial number, stated accuracy and expiration date of the Reference Temperature- Measuring Device used in the comparison must also be documented. Verification data must be kept on file and be available for inspection for 5 years. (Note: International Organization for Standardization (ISO) 17025 compliant vendors or other Certified laboratories may provide assistance in meeting this requirement. When an ISO compliant vendor provides this assistance, they must provide the serial number, accuracy and calibration date for the Reference Temperature- Measuring Device used for the verification. When a Certified laboratory provides this service, they must provide a copy of the NIST traceable certificate of the Reference Temperature-Measuring Device used for the verification. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Temperature. Requirement: A Reference Temperature-Measuring Device is an NIST traceable temperature- measuring device used only to verify the calibration of other temperature-measuring devices. It must have a stated accuracy of ± 0.5 °C, be able to distinguish temperature changes of 0.1 °C and equilibrate rapidly. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Temperature. Requirement: To check a compliance temperature-measuring device, compare readings at two temperatures that bracket the range of compliance samples routinely analyzed against a Page 13 #5212 Envirolink Inc. Reference Temperature-Measuring Device and record all four readings. The readings from both devices must agree within 0.5ºC. 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: This Finding applies to the temperature-measuring devices used for compliance reporting by analysts based out of the Raleigh office of Envirolink Inc. Envirolink Inc. agrees to submit a copy of a passing temperature verification, along with a copy of the NIST Traceable certificate for the acceptable Reference device used to verify all compliance temperature- measuring device(s) by March 8, 2023. The original deadline was extended to minimize the impact on daily operations. Proof of acceptable verifications of the compliance temperature measuring devices and the NIST Traceable certificate for the acceptable Reference device was submitted on March 28, 2023. Settleable Residue – Standard Methods, 2540 F-2015 (Aqueous) Comment: The laboratory does not currently analyze compliance samples for Settleable Residue. Proficiency Testing data was not available for review on the date of audit. Reporting GG. Finding for Immediate Response: The laboratory has contracted compliance monitoring for field parameters to an uncertified laboratory. Requirement: “Uncertified Data" means any analytical result, including the Supporting Records, obtained using a method or procedure that is not acceptable to the State Laboratory pursuant to these Rules; analytical results produced by a laboratory for an analysis not within the scope of the rules of this Section; or analytical results produced by a laboratory without proper Certification. Ref: 15A NCAC 02H .0803 (35). Requirement: All Uncertified Data shall be documented as such on the benchsheet and on the final report. Ref: 15A NCAC 02H .0805 (e) (3). Requirement: Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division’s Laboratory Certification Section (919 733-3908) or visit https://deq.nc.gov/about/divisions/water-resources/water-resources-data/water- sciences-home-page/laboratory-certification-branch for information regarding laboratory certifications. Facilities whose personnel are conducting testing of field-certified parameters only must hold the appropriate field parameter laboratory certifications. Ref: NPDES Permit Standard Conditions (D) (4). Comment: Albemarle Environmental has been subcontracted by Envirolink Inc. to analyze Field Parameters for several facilities in the Outer Banks region. Albemarle Environmental does not possess a laboratory certification issued by the NC WW/GW LCB. This Finding applies to laboratory data reported by Albemarle Environmental to Envirolink Inc. for the below listed permits: • WQ0004696 – Carolina Village WWTP • WQ0014306 – Eagle Creek WWTP • WQ0015052 – Village at Ocean Hill WWTP • WQ0031030 – Shawboro Elementary School • WQ0035706 – Moyock Regional WWTP Page 14 #5212 Envirolink Inc. The laboratory was instructed to qualify all data reported by Albemarle Environmental on the Non-Discharge Monitoring Reports (nDMR) for the affected permits. The laboratory was given a deadline of March 8, 2023 to contract with a North Carolina certified laboratory to analyze Field Parameters for all permits. The laboratory notified NC WW/GW LCB that Envirolink, Inc. began analyzing Field Parameters effective March 1, 2023, and Environmental Chemists, Inc. (Certification #94) has been contracted to analyze all non-Field Parameters. HH. Finding: The laboratory does not report results of all tests on the characteristics of the effluent. Requirement: Reporting shall be in accordance with 15A NCAC 02B .0506 except as otherwise provided by applicable rules in this Subchapter. Ref: 15A NCAC 02T .0105 (l). 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 02B .0506 (b) (3) (J). Comment: On April 6, 2021 and July 20, 2021, the results for Total Nitrogen and Total Phosphorus were not transferred from the contract laboratory report to the nDMR for the Town of Bailey WWTF (WQ0002560). II. Finding: The laboratory is analyzing compliance monitoring samples without proper certification. Requirement: Commercial Laboratories shall obtain Certification for Field Parameter Methods used to generate data that will be reported by the client to the State in accordance with the rules of this Section. Municipal and Industrial laboratories shall obtain Certification for Field Parameter Methods used to generate data that will be reported to the State in accordance with the rules of this Section. Ref: 15A NCAC 02H .0804 (a). Comment: At the time of the inspection, the laboratory was not properly certified for one of the parameter methods in use for DO. They are certified for SM 4500 O G-2016, which is a membrane sensor technology. In practice, they are also using a luminescence sensor technology (LDO), which is a separate parameter method (i.e., SM 4500 O H-2016). Comment: The laboratory is analyzing samples for Turbidity without North Carolina Wastewater/Groundwater Laboratory Certification. This Finding applies to the below listed permits: • WQ0002560 – Town of Pikeville WWTP • WQ0013200 – Southeast Brunswick WWTP JJ. Finding: The laboratory is reporting Uncertified Data without qualifying it as such. Requirement: “Uncertified Data" means any analytical result, including the Supporting Records, obtained using a method or procedure that is not acceptable to the State Laboratory pursuant to these Rules; analytical results produced by a laboratory for an analysis not within the scope of the rules of this Section; or analytical results produced by a laboratory without proper Certification. Ref: 15A NCAC 02H .0803 (35). Requirement: All Uncertified Data shall be documented as such on the benchsheet and on the final report. Ref: 15A NCAC 02H .0805 (e) (3). Page 15 #5212 Envirolink Inc. Comment: At the time of the inspection, the laboratory was not properly certified for one of the parameter methods in use for DO. They are certified for SM 4500 O G-2016, which is a membrane sensor technology. In practice, they are also using a luminescence sensor technology (LDO), which is a separate parameter method (i.e., SM 4500 O H-2016). Comment: The laboratory is analyzing reporting data for Turbidity without North Carolina Wastewater/Groundwater Laboratory Certification. This Finding applies to the below listed permits: • WQ0002560 – Town of Pikeville WWTP • WQ0013200 – Southeast Brunswick WWTP KK. Finding: Values less than the established reporting limit are being reported on the DMR. Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (4). Requirement: For all calibration options, the range of standard concentrations must bracket the permitted discharge limit concentration, the range of sample concentrations to be analyzed and anticipated PT Sample concentrations. One of the standards must have a concentration less than the permitted Daily Maximum Limit. The lower reporting limit concentration is equal to the lowest standard concentration. Sample concentrations that are less than the lower reporting limit must be reported as a less-than value. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Total Residual Chlorine (DPD Colorimetric by SM 4500 Cl G- 2011). Comment: Measured values below the lowest concentration commonly verified on the annual curve (10 µg/L) for low-level TRC are reported on the DMR. LL. Finding: Data qualifiers from the contract laboratory reports are not being transferred to the DMR. Requirement: Each certified Field Laboratory shall be in accordance with Paragraph (e) of this Rule. Ref: 15A NCAC 02H .0805 (g) (17). Requirement: Reported data associated with quality control failures, improper sample collection, holding time exceedances, or improper preservation shall be qualified as such. Ref: 15A NCAC 02H .0805 (e) (5). Comment: The Total Suspended Residue (TSR) result for Grande Oak WWTP (NC0056731) reported by Meritech, Inc. (Certification #165) on April 27, 2021 contained the following qualifier not transferred to the DMR: “Elevated PQL due to insufficient sample size”. 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 Village at Ocean Hills WWTP (WQ0015052) for April, May, June and July 2021, Town of Robersonville WWTP (NC0026042) for January 2022, Town of Bailey WWTF (WQ0002560) for April and July 2021, Elm City WWTP (WQ0003405) for April 2021, and Grande Oak WWTP (NC0056731) for April 2021. The following errors were noted: Page 16 #5212 Envirolink Inc. Date Permit Parameter Location Value on Contract Laboratory Report Value on DMR 1/12/2022 NC0026042 Total Nitrogen Effluent 1.07 mg/L 1.09 mg/L 1/19/2022 NC0026042 Total Kjeldahl Nitrogen Effluent 0.61 mg/L 1.61 mg/L 1/20/2022 NC0026042 Total Suspended Residue Influent 1940 mg/L 194 mg/L 1/27/2022 NC0026042 Total Suspended Residue Influent 260 mg/L 360 mg/L 7/20/2021 WQ0002560 Total Nitrogen Effluent 30.2 mg/L No value 7/20/2021 WQ0002560 Total Phosphorus Effluent 4.32 mg/L No value 4/6/2021 WQ0002560 Total Nitrogen Effluent 12.3 mg/L No value 4/6/2021 WQ0002560 Total Phosphorus Effluent 2.18 mg/L No value V. CONCLUSIONS: We are concerned with the Findings that were cited previously and not corrected. Laboratory Decertification Ref: 15A NCAC 02H .0807 (a) (1), (13), (14) and (20): A laboratory may be decertified for any or all parameters for up to one year for any or all of the following infractions: (1) Failing to maintain the facilities, or records, personnel, equipment, or quality control program as set forth in these Rules; or (13) Failing to respond to requests for information by the date due; or (14) Failing to comply with any other terms, conditions, or requirements of this Section or of Laboratory certification; or (20) Failing to correct findings in an inspection report. Correcting the above-cited Findings and implementing the Recommendation(s) will help this laboratory to produce quality data and meet Certification requirements. The inspectors would like to thank the staff for its 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: Jill Puff Date: March 7, 2023 Report reviewed by: Jason Smith Date: March 9, 2023 Certificate Number:5212 Effective Date:1/1/2023 Expiration Date:12/31/2023 Lab Name:Envirolink Inc. Address:1415 W. Gannon Ave. Suite #101 Zebulon, NC 27597 North Carolina Wastewater/Groundwater Laboratory Certification Certified Parameters Listing Date of Last Amendment:10/21/2021 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 CHLORINE, TOTAL RESIDUAL SM 4500 Cl G-2011 (Aqueous) DISSOLVED OXYGEN SM 4500 O G-2016 (Aqueous) pH SM 4500 H+B-2011 (Aqueous) RESIDUE, SETTLEABLE SM 2540 F-2015 (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.