NC0005762_Lab Inspection_20030729

r
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
. July 29, 2003
156
Mr. Yancy Helton
WestPoint Stevens Wastewater Laboratory
P.O. Box 388
Wagram, NC 28396
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Mr. Helton:
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
•
Enclosed is a report for the inspection performed on June 25, 2003 by Mr. Frederick
L. Bone. Where deficiencies are cited in this report, a response is required as well as for
all lettered comments and/or recommendations. Within thirty days of receipt, please supply
this office with a written item for item description of how these deficiencies, comments
and/or recommendations were corrected. If the deficiencies cited in the enclosed report are.
not corrected, enforcement actions will be recommended. For certification maintenance,
your laboratory must continue to carry out the requirements set forth in 15A NCAC for 2H
.0800.
Copies of the checklists completed during the inspection may be requested from this
office. Thank you for your cooperation during the inspection. If you wish to obtain an
electronic copy of this report by email, or if you have questions or need additional
information please contact us at 919-733-3908.
Sincerely,
ggMe4 ��% l
rt.
James W. Meyer
Laboratory Section
Enclosure
cc: Frederick L. Bone
Fayetteville Regional Office
NCD€t
N.C. Division of Water Quality Laboratory Section 1623 Mail Service Center Raleigh, North Carolina 27699-1623 [phone]
FAX: [phone]

On -Site Inspection Report
LABORATORY NAME: WestPoint Stevens Wastewater Laboratory
ADDRESS:
P.O. Box 3888
Airbase Road
Wagram, NC 28396
CERTIFICATE NO: 156
DATE OF INSPECTION: July 25, 2003
TYPE OF INSPECTION: Maintenance
EVALUATOR: Frederick L. Bone
LOCAL PERSON(S) CONTACTED: George Brown and Roy Guinn
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the
analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory is spacious and well equipped. All facilities and equipment are well maintained. Records are
well kept and most data looked good. Some further quality control procedures need to be implemented.
III. DEFICIENCIES, RECOMMENDATIONS, REQUIREMENTS, AND COMMENTS:
General:
A. COMMENT: The laboratory does not qualify data that does not meet established quality control criteria.
Example:
Qualifying. Versus Rejecting BOD Data
The lab is not qualifying the data when quality control requirements are not met. The following information is
provided to enable compliance.
It is the desire of the State of North Carolina that all data generated for any permitted location under NPDES
requirements is to be reported. " Every person subject to [15A NCAC 2B .0506] shall file certified monitoring
reports setting forth the results of tests and measurements conducted pursuant to NPDES permit monitoring
requirements." Reference: 15A NCAC 2B .0506 (a) (1). Additionally, " the results of all tests of the
characteristics of the effluent, including but not limited to NPDES Permit Monitoring Requirements, shall be
reported on monthly report forms." Reference: 15A NCAC 2B .0506 (b) (3) (J).
The NPDES Permit itself states in Part II, Section D, Monitoring and Records, Number 7 - Recording Results,
" for each measurement or sample taken pursuant to the requirements of this permit, the permittee shall
record the following information...the results of such analyses." .

Page 2
This means all data are reported and none are rejected. If all quality control requirements are not met, it is
required that the data be flagged and the qualification appear on the back of the Discharge Monitoring Report
(DMR). Any rejection of data from the storets will be issued by the agency which receives the data.
The Quality Control requirements of the method are outlined below:
1. The DO depletion of the dilution water blank must not be more than 0.2 mg/I.
2. The seed controls must deplete at least 2.0 mg/I DO and have at least 1.0 mg/I DO remaining.
3. The samples must also deplete at least 2.0 mg/I DO and have at least 1.0 mg/I DO remaining.
4. No evidence of toxicity should be present. This can only be evident when at least three dilutions are
analyzed. This is characterized by an increasing BOD value as the sample concentration decreases.
5. The glucose glutamic acid standard must be in the acceptable range of 198 mg/I +/- 30.5 mg/I.
6. The seed correction, calculated from the seed controls, must be between 0.6 and 1.0 mg/I.
Anytime any of the above quality control requirements are not met, the data must be flagged. The qualifying
statement should indicate that all QC requirements were not met. But the data must always be reported:
REQUIREMENT: When data indicates a quality control failure, the data must be qualified and corrective
action taken. The quality control failure must be stated on the laboratory benchsheet, all final data reports,
and the discharge monitoring report where applicable. It is recommended that the laboratory state in its
qualification whether or not the data appears to be valid based on the degree of the quality control failure.
B. COMMENT: The laboratory is not making corrections to the data in an approved manner. The laboratory is
writing over data results and in some instances the use of "white out" correction fluid was observed.
REQUIREMENT: If an error is. made in data recording the error must be removed by making a single line
through the incorrect entry, recording the correct entry beside error, and initialing and dating the change. Ref:
SW 846 Sept 1994 Test Methods for Evaluating Wastes Chapter One pg. 13.
Dissolved Oxygen and Temperature (field benchsheets)
C. COMMENT: Some of the field benchsheets used by the laboratory, do not contain all of the necessary
labeling information. No units of measure are associated with some of the data values listed on the field
benchsheets for Dissolved Oxygen and Temperature.
REQUIREMENT: The laboratory should review all of their bench sheets and log books to make sure that
every entry is marked with the appropriate unit of measure. Every number recorded on a bench sheet or
logbook must have an appropriate unit assigned to it.
COD
1. DEFICIENCY: The laboratory is not analyzing and recording a standard at the mid -range of the calibration
curve daily for COD.
Note: As was discussed at the time of the audit the mid -range is to be defined, for all North Carolina
samples, as one half the concentration of the high standard.
The mid -range check standard must be prepared from the same stock standards as the analytical curve. A
second source laboratory control standard (LCS) must be analyzed in addition to the mid- range check
standard daily. A second source LCS sample does not constitute daily mid -range verification.

Page 3
The laboratory increased the linear dynamic range of its COD curve. After increasing the range of the curve,
the laboratory did not reevaluate the midpoint to compensate for this increased range. Whenever an
adjustment is made to an analytical curve, the laboratory must reassess the midpoint values.
REQUIREMENT: Verify the standard curve daily by analyzing one or more standards within the linear range,
as specified in the individual method. The curve must be updated as set forth in the standard procedures,
each time the slope changes by more than 10 percent at midrange. Ref: Standard Methods 18th Edition 1020
B. Quality. Control section 5 p. 1-5, and Ref: 15A NCAC 2H .0805 (a) (7) (i).
phi
Note: Most of the influent values for pH monitoring are at a pH value of 11.0. Although linearity is assumed
between zero and 14 when calibrating the pH meter, it would be in the laboratory's best interest to purchase a
pH 11 or 12 calibration check standard in order to fully verify these data point readings.
Totals Suspended Solids:
D. COMMENT: The laboratory does not list the acceptance ranges of quality control samples on the
laboratory benchsheets. CITED TWICE PREVIOUSLY (this item was cited previously in the last inspection
report in the Residual Chlorine and general comment sections)
Note: Also include the laboratory accepted range for %RPD on all bench worksheets.
RECOMMENDATION: It is strongly recommended that the laboratory list the acceptance ranges for each
quality control sample on the bench sheet. This will enable the analyst to be able to compare the analytical
result to the acceptable range in a timely fashion. If the sample is out of the acceptable range, it can then be
reanalyzed immediately and within all holding times.
BOD:
E. COMMENT: The laboratory is currently reporting a " I" or "OK "as verification of calibration or drift checks.
RECOMMENDATION: It is strongly recommended that the laboratory report an actual analytical value
rather than a " I" or "OK "as verification of calibration or drift checks.
Color:
2. DEFICIENCY: The laboratory is not analyzing a second source QC standard daily for color analysis.
REQUIREMENT: Analyze one known standard in addition to calibration standards each day samples are
analyzed to document accuracy. This LCS (laboratory control standard) must be from a second source. For
held curves for colorimetric methods, it must be analyzed after the initial CCV (continuing calibration
verification standard) is analyzed. It is recommended that this laboratory control standard, like the CCV, have
a mid -range concentration and not vary by more than ± 10%. If it does, the analysis is out of control. The
analysis must be terminated and the problem corrected. Ref: 15A NCAC 2H .0805 (a) (7) (B), (F), and
Standard Methods, 18th Edition - Method 1020 B.3.
IV. PAPER TRAIL INVESTIGATION:
This consisted of comparing data reported on DMR's submitted to this Division with the values obtained on
laboratory bench worksheets. Data reviewed for the months of October and December 2002, February and
May 2003 indicated no problems in proper data reporting.

Page 4
V. CONCLUSIONS:
Correcting the above deficiencies and comments and implementing the recommendations should help them
to produce quality data and meet certification requirements.
Please respond to all numbered Deficiencies and lettered Comments cited in this
report.
Report prepared by: Frederick L. Bone Date: July 28, 2003