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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
February 29, 2024
5701
Mr. Rod Holley
Maple Commerce Park WWTP
444 Maple Road
Currituck, NC 27929
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. Holley:
Enclosed is a report for the inspection performed on December 14, 2023 by Tom 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 (984) 220-
5439.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Todd Crawford, Tom Halvosa, #5701
On-Site Inspection Report
LABORATORY NAME: Maple Commerce Park WWTP
WATER QUALITY PERMIT #: WQ0035231 and WQ0035706
ADDRESS: 105 Barco Way
Maple, NC 27929
CERTIFICATE #: 5701
DATE OF INSPECTION: December 14, 2023
TYPE OF INSPECTION: Field Municipal Initial
AUDITOR: Tom Halvosa
LOCAL PERSON CONTACTED:
Rod Holley
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.
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
March 31, 2024.
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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# 5701 Maple Commerce Park WWTP
Contracted analyses are performed by Environmental Chemists Inc./Outer Banks Div. (Certification # 628).
The Approved Procedure document for the analysis of the facility’s currently certified Field Parameter was
provided at the time of the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: The laboratory pH benchsheet is lacking required documentation: the method or
Standard Operating Procedure reference; the laboratory identification; the instrument
identification; the proper units of measure and the quality control assessments.
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; the laboratory identification; the instrument identification; the proper
units of measure and the quality control assessments. 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), (B), (C), (L) and (O).
Comment: The laboratory was provided with an example pH benchsheet at the time of the
inspection.
B. Finding: Uncertified data is not documented as such on the benchsheets.
Requirement: Each certified Field Laboratory shall be in accordance with Paragraph (e)
of this Rule. Ref: 15A NCAC 02H .0805 (g) (17).
Requirement: All uncertified data must be clearly documented as such on the benchsheet
and on the final report. Ref: 15A NCAC 02H .0805 (e) (3).
Comment: The benchsheets do not identify process control data which includes uncertified
parameter analyses. This makes it appear that uncertified analyses are being performed on
regulatory compliance samples.
C. Finding: The laboratory is not documenting 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
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 (03/27/2020).
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# 5701 Maple Commerce Park WWTP
Comment: The laboratory was provided with an example receipt log for purchased materials,
reagents and standards at the time of the inspection.
D. 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).
E. 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: The laboratory’s training program may be outlined in each of the applicable
parameter SOPs. After the inspection, the laboratory was provided with an example of training
documentation.
Proficiency Testing
F. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
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
(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.
Comment: The laboratory’s current practice is to record the instrument reading directly into
the PT Vendor’s electronic submission form. No record of the analysis is maintained.
G. Finding: PT Samples are not analyzed in the same manner as routine Compliance Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
Parameter Method and in each associated matrix on the laboratory’s CPL. The same PT
Sample may be analyzed by one or more methods. Laboratories shall conduct the analyses
in accordance with their routine testing, calibration and reporting procedures, unless otherwise
specified in the instructions supplied by the Accredited PT Sample Provider. This means that
they are to be logged in and analyzed using the same staff, sample tracking systems, standard
operating procedures including the same equipment, reagents, calibration techniques,
analytical methods, preparatory techniques (e.g., digestions, distillations and extractions) and
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# 5701 Maple Commerce Park WWTP
the same quality control acceptance criteria. PT Samples shall not be analyzed with additional
quality control. They are not to be replicated beyond what is routine for Compliance Sample
analysis. Although, it may be routine to spike Compliance Samples, it is neither required, nor
recommended, for PT Samples. PT sample results from multiple analyses (when this is the
routine procedure) must be calculated in the same manner as routine Compliance Samples.
Ref: Proficiency Testing Requirements, January 1, 2023, Revision 6, Section 3.6.
Comment: The laboratory is analyzing the PT Samples multiple times and averaging the two
values that are closest to each other for reporting to the PT vendor.
Reporting
H. 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 monthly report forms.
Ref: 15A NCAC 02B .0506 (b) (3) (J).
Comment: The laboratory is recording the temperature of the effluent when analyzing
compliance samples for pH. Temperature is not a parameter on any of their permits.
I. 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).
pH - Standard Methods, 4500 H+ B-2011 (Aqueous)
Recommendation: The laboratory currently reports pH compliance sample results to one decimal
place on their benchsheet. It is recommended that the laboratory measure and document sample
results on the benchsheet to two decimal places and round to the nearest 0.1 S.U. when reporting
results on the Non-Discharge Monitoring Report (NDMR).
J. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior to
sample analysis.
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. Ref: NC WW/GW LCB
Approved Procedure for the Analysis of pH.
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# 5701 Maple Commerce Park WWTP
Comment: Following the inspection, the laboratory emailed documentation showing they
began analyzing and evaluating a check standard buffer on December 15, 2023.
K.Finding: The pH probe is not being stored in the recommended storage solution.
Requirement: The pH probe must be stored in the solution recommended by the probe
manufacturer between analyses. A solution with a conductivity greater than 4000 µhos/cm is
recommended. Tap water is a better substitute than distilled water, but pH 4 buffer is best for
the single glass electrode and saturated KCl is preferred for the calomel and Ag/AgCl
reference electrode. Saturated KCl is preferred for a combination electrode. Keep electrodes
wet by returning them to the storage solution whenever the pH meter is not in use. Ref:
Standard Methods, 4500 H+ B-2011. (4) (a).
Requirement: Probes can become permanently damaged if kept in a storage solution that is
not specified by the manufacturer. Use only the specified storage solution (Hach pH electrode
storage solution or 3 M KCl). Do not store the probe in deionized water or in samples of low
ionic strength. Put the soaker bottle that contains the storage solution on the probe when not
in use. Make sure to only use the specified storage solution. Ref: Hach User Manual,
DOC022.53.80023 PHC101 6/2021, Edition 5, Section 8.4.
Comment: The laboratory stores the electrode in de-ionized (DI) water.
IV. 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: January 11, 2024
Report reviewed by: Tonja Springer Date: January 16, 2024
Certificate Number:5701
Effective Date:1/1/2023
Expiration Date:12/31/2023
Lab Name:Maple Commerce Park
Address:540 Barco Drive
Maple, NC 27929
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:
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
pH
SM 4500 H+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.