#5302_2020_0226_JMS_FINAL

Laboratory Cert. #:
5302
Laboratory Name:
South Fork Industries
Inspection Type:
Field Industrial Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
February 26, 2020
Date Forwarded for Initial
Review:
March 11, 2020
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed:
March 12, 2020
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
(to use: rt click, properties, chock)
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist II:
Todd Crawford
Date Received:
3/12/2020
Date Forwarded to Admin.:
3/24/2020
Date Mailed:
Special Mailing Instructions:

ROY COOPER
Governor
MICI iAEL S. REGAN
Secretary
S. DANIEL SMITH
0h actor
5302
Mr. Donald Burkey Jr.
South Fork Industries
P.O. Box 742
Maiden, NC 28650-
NORTH CAROLINA
Environmental Quality
March 25, 2020
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Burkey:
Enclosed is a report for the inspection performed on February 26, 2020 by Jason Smith. Where
Finding(s) are cited in this report, a response is required. Within thirty days of receipt, 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 2H .0800.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list
will 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 wish to obtain an electronic copy of this report by email or if you have
questions or need additional information, please contact me at [phone] Ext. 259.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Jason Smith, Dana Satterwhite
DNorth Carolina Department ofEnvironmental Quality I Division of Water Resources - E Q 2� 4405 Reedy Creek Road 1 1623 Mail Service Center i Raleigh, North Carolina 27699-1623
NORM C -OUNAA
F�,r!rocme,- +v 919.733.3908

LABORATORY NAME: South Fork Industries
Z' I:j D 11 I I &111• •1
ADDRESS: 100 West Pine Street
Maiden, NC 28650
CERTIFICATE : 5302
DATE OF INSPECTION: February 26, 2020
TYPE OF INSPECTION Field Industrial Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Jamie Rhyne, Todd Burgin and Brad Poovey
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements
of 15A NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The inspector would like to commend the laboratory for staying current with changes in
laboratory certification program requirements by visiting the NC WW/GW LC website and
proactively implementing new requirements (such as implementing most new documentation
requirements) prior to the on -site inspection.
The facility is neat and well organized and has all the equipment necessary to perform the
analyses. Benchsheets are well designed, easy to follow and concise. Records are well
organized and easy to retrieve. The laboratory has been proactive in keeping up with updates
and changes required by this Program, particularly in the area of consumable traceability.
All required Proficiency Testing (PT) Samples for the 2020 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, 2020.
The laboratory is reminded that Standard Operating Procedure (SOP) documents are required to
be implemented by July 1, 2020. SOP templates may be found on the NC WW/GW LC website
here: httos://dea.nc.aov/about/divisions/water-resources/water-resources-data/water-sciences-
home-pane/laboratorv-certification-branch/technical-assistance-policies Additionally, a
documented training program for current and future analysts must be implemented by August 1,
2020. These requirements and the SOP templates posted on the NC WW/GW LC website were

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#5302 South Fork Industries
discussed during the inspection. Any time changes are made to laboratory procedures, the
laboratory must update the SOP document(s) and inform relevant staff. In some instances, the
laboratory may need to create an SOP to document how new functions or policies will be
implemented.
The laboratory is also reminded that SOPS are intended to describe procedures exactly as they
are to be performed. Use of the word "should" is not appropriate when describing requirements
(e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper
use of the word "should".
Contracted analyses are performed by Research & Analytical Laboratories (Certification # 34).
911,01 • f x ..
Documentation
Recommendation: It is recommended that instrument identification include serial number. They
are currently identified by manufacturer and model.
A. 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: Error corrections are not consistently initialed and dated.
B. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents.
Requirement: Chemical containers shall be dated when received and when opened.
Reagent containers shall be dated, identified, and initialed when prepared. Chemicals and
reagents exceeding the expiration date shall not be used. Chemicals and reagents shall
be assigned expiration dates by the laboratory if not given by the manufacturer. If the
laboratory is unable to determine an expiration date for a chemical or reagent, a one-year
time period from the date of receipt shall be the expiration date unless degradation is
observed prior to this date. The laboratory shall have a documented system of traceability
for all chemicals, reagents, standards, and consumables. Ref: 15A NCAC 02H .0805 (g)
(7).
Requirement: All chemicals, reagents, standards and consumables used by the
laboratory must have the following information documented: 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,

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#5302 South Fork Industries
solids and bacteria filters, etc. are included in this requirement. Ref: NC WW/GW LC
Policy.
Comment: The laboratory is not documenting the expiration date of reagents. An example
traceability log was emailed to the laboratory on March 2, 2020.
C. Finding: The sample collector is not clearly identified.
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. Ref: 15A NCAC
02H .0805 (g) (2) (D).
Comment: Up to three people are documented on the Chain of Custody (CoC) as the
sample collector. The individual that physically collects the sample is to be the only one
identified as the sample collector.
Recommendation: It is recommended that the sample collector also be documented on
the benchsheet.
D. Finding: The laboratory benchsheet is lacking required documentation: the method or
Standard Operating Procedure.
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: The method reference for Temperature is incorrectly listed as SM 2510 13-
2000. The method reference for pH is incorrectly listed as "SM 4500 H+ B-201 ". There is
no method reference documented for DO.
Comment: The methods for which the lab is certified are:
® Dissolved Oxygen — Hach 10360-2011
® pH — SM 4500 H+ B-2011
® Temperature — SM 2510 B-2010
E. Finding: The laboratory benchsheet is lacking required documentation: the proper units of
measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the proper units
of measure. Each item shall be recorded each time samples are analyzed. Ref: 15A
NCAC 02H .0805 (g) (2) (L).
Comment: The calibration section of the benchsheet does not include units of measure
for pH.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)

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#5302 South Fork Industries
Comment: The laboratory is currently documenting the value obtained for each calibration buffer
during the calibration process. This is not required. For calibration, the laboratory is required to
document the true values of the buffers used for calibration and for the check standard and the
value obtained for the check standard.
F. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior
to sample analysis.
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 LC Approved Procedure for the Analysis of pH.
Comment: The laboratory is calibrating the meter, analyzing the samples and then
analyzing a check buffer.
Dissolved Oxygen — Hach 10360-2011, Rev. 1.2 (LDO) (Aqueous)
G. Finding: The laboratory is not calibrating the meter at each sample site prior to analysis or
performing a Post -Analysis Calibration Verification when analyses are performed at
multiple sample sites.
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 LC Approved Procedure for the Analysis of Dissolved Oxygen (DO).
Reporting
H. Finding: Values for pH 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: Per PT Vendor instructions, the PT Sample results should be reported to
two decimal places.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract laboratory reports to Discharge Monitoring Reports (DMRs) submitted to the
North Carolina Division of Water Resources. Data were reviewed for South Fork Industries
(NPDES permit # NC0006190) for May, July and November 2019. The following errors were
noted:

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#5302 South Fork Industries
Date
Parameter
Location
Value on Denchsheet
*Contract Laboratory
Data
Value on DMR
5/2/19
Ammonia Nitrogen
Effluent
*0.214 mg/L
0.021 mg/L
5/2/19
pH
Effluent
8.36 S.U.
8.11 S.U.
5/2/19
Dissolved Oxygen
Effluent
8.11 mg/L
8.36 mg/L
7/24/19
Temperature
Effluent
26.4 °C
36.4 °C
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.
Correcting the above -cited Findings and implementing the Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like
to thank the staff for their assistance during the inspection and data review process. Please
respond to all Findings and include supporting documentation, implementation dates
and steps taken to prevent recurrence for each corrective action.
Report prepared by: Jason Smith
Report reviewed by: Anna Ostendorff
Date: March 10, 2020
Date: March 12, 2020

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