#5247_2022_0614_JP_FINAL

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
June 23, 2022
5247
Mr. Shawn Gillette
North Brunswick Sanitary District Belville WWTP
P.O. Box 2230
Leland, NC 28451
Subject: North Carolina Wastewater/Groundwater Laboratory Certification Branch (NC
WW/GW LCB) Maintenance Inspection
Dear Mr. Gillette:
Enclosed is a report for the inspection performed on June 14, 2022 by Jill Puff. 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, Jason Smith, Master File #5247

On-Site Inspection Report

LABORATORY NAME: North Brunswick Sanitary District Belville WWTP
NPDES PERMIT #: NC0075540
ADDRESS: 9911 Chappelle Loop Rd.
Leland, NC 28451
CERTIFICATE #: 5247
DATE OF INSPECTION: June 14, 2022
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Jill Puff

LOCAL PERSON(S) CONTACTED:

Shawn Gillette and Brian Griffith

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 for the 2022 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, 2022.

The laboratory is reminded that 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 January 31, 2023.

The laboratory is also 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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Contracted analyses are performed by Environmental Chemists, Inc. (Certification # 94).

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

Recommendation: It is recommended that the laboratory add the NC WW/GW LCB Certification
number (#5246) to the benchsheet to improve the legal defensibility of the data.

A. 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).

B. Finding: The laboratory benchsheet is 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).

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.

D. Finding: Chemical containers are not dated when received and when opened.

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Requirement: Chemical containers shall be dated when received and when opened. Ref:
15A NCAC 02H .0805 (g) (7).

Quality Control

E. Finding: Error corrections are not always 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: pH data were overwritten on January 7, January 13, January 14, January 26,
and February 21, 2022. Temperature error corrections were not dated on December 29,
2021 and January 26, 2022.

F. Finding: An inconsistency was noted between the SOP and laboratory practice as follows:
The instructions for preparing the annual PT Sample specifies the use of volumetric
glassware. A 1000 mL beaker was used to dilute the Proficiency Testing Sample for Total
Residual Chlorine (TRC).

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).

G. Finding: The laboratory is not calibrating the mechanical volumetric liquid-dispensing
device used for critical measurements at least once every 12 months.

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: The pipettor is used for the preparation of the annual PT Sample for TRC. The
laboratory was informed that the purchase of a volumetric pipette would eliminate the
annual calibration requirement.

Proficiency Testing

H. Finding: The laboratory is not documenting PT Sample analyses in the daily analysis records.

Requirement: All PT Sample analyses must be recorded in the daily analysis records as for
any Compliance Sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 19, 2020, Revision 5, 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
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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, February 19, 2020, Revision
5, Section 4.0.

Requirement: The analysis of Proficiency Testing (PT) Samples is designed to evaluate the
entire process used to routinely analyze and report Compliance Sample results. PT Samples
must be analyzed the same as Compliance Samples. Also, documentation must be made on
the same benchsheets used for Compliance Samples. Ref: NC WW/GW LCB Proficiency
Testing Samples Analyzed and Documented Same as Compliance Samples Policy.

Comment: The results of PT testing were written on the instructions from the vendor packet.
The NC WW/GW LCB ‘Proficiency Testing Samples Analyzed and Documented Same as
Compliance Samples’ Policy was updated on March 9, 2022 to include the requirement that
PT Sample analysis be documented on the same benchsheet that is used for Compliance
Samples.

I. 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,
February 19, 2020, Revision 5, Section 3.6.

Comment: Dating and initialing the instruction sheet for each prepared PT Sample would
satisfy the documentation requirement.

Temperature – Standard Methods, 2550 B-2010 (Aqueous)

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 DWR’s Precision in Discharge Monitoring Reports document.

pH – Standard Methods, 4500 H+ B-2011 (Aqueous)

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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Comment: The laboratory performs a 2-standard calibration daily and reads a third buffer as
the check standard. This buffer is not clearly identified as a check buffer on the laboratory
benchsheet.

K. 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).

Comment: The laboratory is reporting pH to two decimal places on the DMR.

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.

L. Finding: The units of measure (i.e., Standard Units or S.U.) are not 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).

Total Residual Chlorine – Standard Methods, 4500 Cl G-2011 (Aqueous)

Comment: The facility utilizes UV disinfection and did not have compliance data available for
review. Proficiency Testing data was evaluated for this parameter.

M. Finding: The laboratory is not analyzing a low-level PT sample for TRC.

Requirement: For colorimetric procedures, TRC PT Samples must be analyzed on the
same spectrophotometric program using the same procedure that is used for routine
Compliance Sample analysis. There are two options for achieving this when you have a
low-level permit requirement:

1. If a facility having a low-level permit requirement analyzes a regular-level TRC PT
Sample, it must be diluted to the verified range of the low-level curve routinely used. The
reported result must then be calculated using the dilution factor and the TRC value
obtained.

2. Since the dilution factor in option 1 may introduce error, it is recommended that facilities
having a low-level permit requirement order and analyze a low-level TRC PT Sample. This
PT Sample should be within the range of your verified curve on the low-level program. Ref.
NC WW/GW LCB Proficiency Testing Requirements, February 19, 2020, Rev. 5, Section
3.7.1.

Comment: The LaMotte colorimeter in the laboratory does not meet the detection limit of
13 µg/L required by the current NPDES permit. If the laboratory intends to analyze
compliance data, even on an emergency basis, the equipment utilized must meet those
specifications. Alternatively, the facility may elect to have a system in place for a contract
lab to come in and analyze samples in the event of an incident.

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N. Finding: The laboratory has not assigned the sealed liquid standard a true value.

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). Please submit a copy
of the sealed liquid standard verification with the report reply.

O. Finding: The laboratory benchsheet is lacking required documentation: Date of most
recent TRC calibration curve verification.

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).

Dissolved Oxygen – Standard Methods, 4500 O G-2016 (Aqueous)

P. Finding: The laboratory is not certified for the method currently in use.

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: Standard Methods 4500 O G-2016 refers to the measurement of Dissolved
Oxygen (DO) utilizing membrane technology. The laboratory purchased a new DO meter
with an LDO probe in 2021, which requires certification by a separate method (SM 4500 O
H-2016). The laboratory was provided with an Amendment Application and SOP template
for SM 4500 O H-2016 to obtain certification for the correct method.

Q. Finding: The Luminescence Dissolved Oxygen (LDO) meter calibration is not being
verified each day that sample measurements are taken.

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. For
LDO sensors that cannot be calibrated by the user, the internal calibration must be verified
each day of use. This can be performed by back calculating the theoretical DO for the
current air calibration conditions (e.g., temperature, elevation, barometric pressure, etc.).
The calculated DO value must verify the meter reading within ±0.5 mg/L. Refer to the
Dissolved Oxygen Meter Calibration Verification handout at the end of this document. If the
meter verification does not read within ±0.5 mg/L of the theoretical DO, corrective action
must be taken. Ref: NC WW/GW LCB Approved Procedure for the Analysis of Dissolved
Oxygen (DO).
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Comment: The DO reading is recorded each day of use, but no assessment against the
theoretical DO is made.

Reporting

R. Finding: The laboratory does not report all characteristics of the pollutants analyzed from
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 facility began collecting weekly Fecal Coliform samples at the effluent on
January 10, 2022, as part of an engineering study. Staff were instructed to report the data
in the Comments section of the DMR.

S. 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 samples analyzed by Environmental Chemists, Inc. on February 9, 2022,
were lacking the following qualifications on the DMR: BOD – The sample did not meet quality
control requirements: The blank depleted 1.09 mg/l (>0.20 mg/L) and GGA=127% above the
limit of 85-115%. The samples analyzed by Environmental Chemists, Inc. on February 24,
2022, were lacking the following qualifications on the DMR: BOD – The sample did not meet
quality control requirements: The blank result of 0.31 mg/l was above the acceptable limit of
0.20 mg/l.

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 Belville WWTP (NPDES permit # NC0075540) for December 2021, January 2022 and
February 2022. The following errors were noted:

Date Parameter Location
Value on
Benchsheet

Value on DMR

12/03/2021 DO Effluent 9.0 mg/L 9.3 mg/L
12/06/2021 pH Effluent 6.68 S.U. 6.98 S.U.
12/14/2021 DO Effluent 8.7 mg/L 8.07 mg/L
12/21/2021 Temperature Effluent 19.9 °C 19.1 °C
12/29/2021 DO Effluent 9.0 mg/L 9.3 mg/L
01/06/2022 Temperature Effluent 20.6 °C 17.8 °C
01/10/2022 pH Effluent 6.74 S.U. 6.84 S.U.

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To avoid questions of legality, it is recommended that you contact the appropriate Regional Office for
guidance as to whether an amended DMR(s) will be required. A copy of this report will be made available
to the Regional Office.

V. CONCLUSIONS:

Correcting the above-cited Findings and implementing the Recommendation(s) 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: Jill Puff Date: June 16, 2022
Report reviewed by: Tonja Springer Date: June 17, 2022

Certificate Number:5247
Effective Date:1/1/2022
Expiration Date:12/31/2022
Lab Name:North Brunswick Sanitary District Belville WWTP
Address:9911 Chappelle Loop Rd
Leland, NC 28451
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
Date of Last Amendment:9/29/2021
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)
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.