#122_2018_0726_TLH_FINAL

Laboratory Cert. :
122
Laboratory Name:
Contentnea Metro Sewage District Laboratory
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Tom Halvosa, Todd Crawford, Beth Swanson and Michael Cumbus
Inspection Date:
July 26, 2018
Date Forwarded for Initial
Review:
August 15, 2018
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed:
August 22, 2018
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
❑Insp. No Finding ❑Insp. CP
❑Corrected ❑Insp. Reg. Delay
(to use: rt click, properties, check)
Unit Supervisor/Chemist II:
Todd Crawford
Date Received:
8/24/18
Date Forwarded to Admin.:
August 31, 2018
Date Mailed:
August 31, 2018
Special Mailing Instructions:

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August 31, 2018
122
Ms. Renee Smith
Contentnea Metro Sewage District Laboratory
P.O. Box 477
Grifton, NC 28530
ROY COOPER
MICHEAL S. REGAN
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Smith:
Enclosed is a report for the inspection performed on July 26, 2018 by Tom Halvosa. 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].
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tom Halvosa, Master File #122
Water Sc€ences Sect€on
NC Wastewater/Groundwater Lahorat©ry Certification rBranch
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LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE :
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Contentnea Metro Sewage District Laboratory
NC0032077
900 Wiley Gaskins Road
Grifton, NC 28530
122
July 26, 2018
Municipal Maintenance
Tom Halvosa, Todd Crawford, Beth Swanson and Michael
Cumbus
Renee Smith
This laboratory was inspected by representatives 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 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 proactive in adopting the necessary changes.
All required Proficiency Testing (PT) Samples for the 2018 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, 2018.
The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedures
(SOP) document(s) in advance of the inspection. These documents were reviewed and editorial
and substantive revision requirements and recommendations were made by this program
outside of this formal report process. Although subsequent revisions were not requested to be
submitted, they must be completed by July 31, 2019.
The laboratory is reminded that any time changes are made to laboratory procedures, the
laboratory must update the QA/SOP document(s) and inform relevant staff. Any changes made
in response to the pre -audit review or to Findings, Recommendations or Comments listed in this
report must be incorporated to insure the method is 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

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#122 Contentnea Metro Sewage District Laboratory
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.
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".
Laboratory Fortified Matrix (LFM) and Laboratory Fortified Matrix Duplicate (LFMD) are also
known as Matrix Spike (MS) and Matrix Spike Duplicate (MSD) and may be used
interchangeably in this report.
Requirements that reference 15A NCAC 2H .0805 (a) (7) (A), stating "All analytical data pertinent
to each certified analysis must be filed in an orderly manner so as to be readily available for
inspection upon request", are intended to be a requirement to document information pertinent to
reconstructing final results and demonstrating method compliance. Use of this requirement is not
intended to imply that existing records are not adequately maintained unless the Finding speaks
directly to that.
Contracted analyses are performed by Environment 1, Inc. (Certification # 10).
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:
General Laboratory
A. Finding: The National Institute of Standards and Technology (MIST) traceable
thermometer used for verifying the Fecal Coliform water bath thermometer does not
have a stated accuracy of at least ± 0.1 °C.
Requirement: The Reference Temperature -Measuring Device used to verify the
calibrations of any device used in an incubator must have a stated accuracy of at least ±
0.1 °C. Ref: NC WW/GW LC Policy.
B. Finding: The laboratory has not verified the infrared (IR) temperature -measuring device
quarterly.
Requirement: Infrared (IR) temperature -measuring devices may only be used to
measure the temperature of samples for thermal preservation verification. The device
must be verified at least quarterly (i.e., every 3 months) using a Reference
Temperature -Measuring Device at a minimum of three different temperatures over the
full temperature range of use (e.g., 0 °C, 5 °C and 10 °C). Each day of use, perform a
verification of the IR temperature -measuring device by checking the temperature of a
bottle of water at a single temperature between 0 and 10 *C. The two measurements
must agree within 0.5 °C, or the device must be recalibrated or replaced. Document the
quarterly and daily verifications. The correction factor from the quarterly verification
must be indicated on the IR temperature -measuring device and applied when
documenting temperature measurements. Temperature correction factors are not to be
adjusted based on daily temperature verifications. Ref: NC WW/GW LC Policy.
Comment: The IR temperature -measuring device was being verified annually.

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##122 Contentnea Metro Sewage District Laboratory
Documentation
Recommendation: It is recommended that the laboratory document the lot numbers for the
purchased positive control and buffered dilution water on the fecal coliform benchsheet.
C. Finding: Temperature correction factors were not being documented correctly.
Requirement: The laboratory must maintain records of established correction factors to
correct all measurements. Document any correction that applies (e.g., add 0.2 °C,
subtract 0.3 °C, or if no correction needed; 0.0 °C) on both the temperature -measuring
device and in a format that can be retained for a minimum of five years. Ref: NC
WW/GW LC Policy.
Requirement: All analytical records must be available for a period of five years. Ref:
15A NCAC 2H .0805 (a) (7) (G).
Comment: The laboratory was documenting thermometer temperature correction
factors on the transparent plastic cover of the temperature logs where it was
subsequently erased the next time a temperature correction factor was calculated.
D. Finding: Error corrections are not always properly performed
Requirement: All documentation errors must 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. Write the correction adjacent
to the error. The correction must be initialed by the responsible individual and the date
of change documented. All data and log entries must be written in indelible ink. Pencil
entries are not acceptable. Ref: NC WW/GW LC Policy.
E. Finding: The units of measure are not consistently documented on the benchsheets.
Requirement: All laboratories must use printed laboratory bench worksheets that
include a space to enter the signature or initials of the analyst, date of analyses, sample
identification, volume of sample analyzed, value from the measurement system, factor
and final value to be reported and each item must be recorded each time samples are
analyzed. Ref: 15A NCAC 2H .0805 (a) (7) (H).
Comment: The benchsheet for Total Suspended Residue is missing units for "Total
Suspended Residue" and "Reported Value". The benchsheet for Ammonia is missing
units for "Meter Reading". The benchsheet for Vector Attraction Reduction, Option 4:
Specific Oxygen Uptake Rate (VAR Option 4) is missing units for dissolved oxygen.
Additionally, chain of custody benchsheets lacked units for pH and temperature.
Comment: On the Total Suspended Residue benchsheet the units for Filter & Residue
Weight should be listed as grams (g), not milligrams (mg).
F. Finding: The laboratory needs to increase documentation of standards and reagents
prepared in the laboratory.
Requirement: 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

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#122 Contentnea Metro Sewage District Laboratory
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. Ref: NC WW/GW LC Policy.
G. Finding: For chemicals/reagents/consumables that do not have an expiration date, the
laboratory has not established a policy for assigning expiration dates.
Requirement: Adherence to manufacturer expiration dates is required.
Chemicals/reagents/ consumables exceeding the expiration date can no longer be
considered reliable. If the expiration is only listed as a month and year (with no specific
day of the month), the last day of the month will be considered the actual date of
expiration. Monitor materials for changes in appearance or consistency. Any changes
may indicate potential contamination and the item should be discarded, even if the
expiration date is not exceeded. If no expiration date is given, the laboratory must have
a policy for assigning an expiration date. If no date received or expiration date can be
determined, the item should be discarded. Ref: NC WW/GW LC Policy.
H. Finding: The laboratory benchsheet for pH was lacking pertinent data: Facility name,
sample site (ID or location), permit number and instrument identification.
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A
NCAC 2H .0805 (a) (7) (A).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Facility name, sample site (ID or location), permit number and
instrument identification (serial number preferred). Ref: NC WW/GW LC Approved
Procedure for the Analysis of pH.
Comment: Following are examples of where the laboratory benchsheet was lacking
pertinent data:
The laboratory is calibrating and using more than one pH meter for compliance
monitoring. The laboratory needs to identify which meter is being used for each
specific sampling site.
® When the pH probe is replaced, the instrument identification (serial number
preferred) needs to be updated.
Finding: The laboratory benchsheet for Ammonia was lacking pertinent data: volume of
sample analyzed.
Requirement: All laboratories must use printed laboratory bench worksheets that
include a space to enter the signature or initials of the analyst, date of analyses, sample
identification, volume of sample analyzed, value from the measurement system, factor
and final value to be reported and each item must be recorded each time samples are
analyzed. The date and time BOD and coliform samples are removed from the incubator
must be included on the laboratory worksheet. Ref: 15A NCAC 2H .0805 (a) (7) (H).
J. Finding: The laboratory does not document that the pH of Ammonia samples is greater
than 11 S.U. upon addition of NaOH during the analysis. This is considered pertinent
data.

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#122 Contentnea Metro Sewage District Laboratory
Requirement: Add a sufficient volume of 10N NaOH solution (1 mL usually is sufficient)
to raise pH above 11. Ref: Standard Methods, 4500-NH3 D-2011 (4) (b).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A
NCAC 2H .0805 (a) (7) (A).
K. Finding: The Vector Attraction Reduction laboratory benchsheet was lacking pertinent
data: drying oven temperature and drying time.
Requirement: Evaporate to dryness on a water bath, dry at 103 to 1050C for 1 h, cool
to balance temperature in an individual desiccator containing fresh desiccant, and
weigh. Ref: Standard Methods, 2540 G-2011. (3) (a) (2) (a).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A
NCAC 2H .0805 (a) (7) (A).
Comment: Following are examples of where the laboratory benchsheet was lacking
pertinent data:
® For the VAR Option 4 analysis, the drying oven temperature was not recorded on
the benchsheets.
® For the VAR Option 4 analysis, the time in and time out of the oven were not
recorded on the benchsheets.
Proficiency Testing
L. Finding: Additional QC beyond what is routine for Compliance Samples is being
analyzed with PT Samples.
Requirement: Laboratories are required to analyze an appropriate PT Sample by each
parameter method on the laboratory's Certified Parameters Listing (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. methods, preparatory techniques (e.g., digestions, distillations and
extractions) and 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, May 31, 2017, Revision 2.0.
M. Finding: PT Samples have not been distributed among all analysts 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

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#122 Contentnea Metro Sewage District Laboratory
analyses), that represents the routine operation of the work group at the time the PT
Sample analysis is conducted. Ref: Proficiency Testing Requirements, May 31, 2017,
Revision 2.0.
Comment: The personnel conducting pH analyses need to be included in the analysis
of the annual PT Samples for that parameter.
N. 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 (e.g., pH), but it is recommended that the instructions be
maintained. Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Comment: Dating and initialing the instruction sheet for each prepared PT Sample
would satisfy the documentation requirement.
Bacteria — Coliform Fecal - IDEXX Colilert @18 (MIPN) (Aqueous)
Comment: For fecal coliform analysis, the laboratory is purchasing sample collection bottles
containing sodium thiosulfate. Since the facility does not use chlorine in any of their processes,
the use of sample collection bottles containing sodium thiosulfate for fecal coliform analysis is not
necessary.
O. Finding: The laboratory is using a total immersion thermometer in the fecal water bath
improperly.
Requirement: Thermometers with no indicated depth are the total immersion type.
When a partial -immersion thermometer is used, the bottom of the thermometer up to the
immersion line should be exposed to the temperature being measured, with the
remainder of the thermometer exposed to ambient conditions. When a total immersion
thermometer is used, the bulb and the entire portion of the stem containing liquid,
except for the last 1 cm, are exposed to the temperature being measured. If the
thermometer is not used in this manner, the thermometer immersion is incorrect. Ref:
"User -Friendly Guidance on the Replacement of Mercury Thermometers",
https://vv�rvvv .00v/etas/�uct�on/file/201 --`l /documents/ni to �,f,iiendj t ide fy
Comment: The laboratory was using a total immersion thermometer like a partial
immersion thermometer and it was resting on the metal bottom of the water bath.
Recommendation: It is recommended that the laboratory use a partial immersion
thermometer correctly positioned in the water bath.
BOD — Standard Methods, 5210 B-2011 (Aqueous)
P. Finding: Documentation does not demonstrate that the initial DO is measured within 30
minutes of sample preparation. This is considered pertinent data.
Requirement: After preparing dilution, measure initial DO within 30 min. Ref: Standard

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#122 Contentnea Metro Sewage District Laboratory
Methods, 5210 B-2011. (5) (g).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Comment: Documenting the dilution start time and the time that samples are placed in
the incubator would demonstrate compliance with the requirement since all DO
measurements would have to occur between those two times.
Q. Finding: The meter is not being calibrated according the manufacturer's instruction.
Requirement: Dissolved Oxygen (DO) AUTO Cal: The Model 5000 does not contain a
barometer; therefore, the current barometric pressure must be entered before an AUTO
Cal is performed. The pressure value displayed is the setting that was entered and
stored during the previous calibration. Ref: YSI Model 5000 Operations Manual.
Comment: The laboratory is not entering the current barometric pressure into the
calibration set-up on the YSI Model 5000 DO Meter as required by the Operations
Manual.
Recommendation: It is recommended that the laboratory obtain a barometer or use
local meteorological data available over the internet to be able to enter the current
barometric pressure into the DO meter.
pH — Standard Methods, 4500 H+S-2011 (Aqueous)
R. Finding: The laboratory is not analyzing a post -analysis check standard buffer when
analyses are performed at multiple locations.
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 LC Approved Procedure for the Analysis of pH.
Comment: The laboratory was only performing a post -analysis calibration verification on
the pH meter used for analysis of effluent samples. When the meter is used at multiple
pretreatment sites, a post -analysis calibration verification must be performed.
S. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent when duplicate sample analyses are performed.
Requirement: If more than one pH concentration has been taken for a particular day,
these values cannot be averaged due to the logarithmic nature of pH concentration. All
values must be reported on the DMR either in the daily cell or the comments section. Ref:
NC WW/GW LC Approved Procedure for the Analysis of pH.

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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 213.0506 (b) (3) (J).
Comment: The following convention must be followed when deciding which value to
report in the daily cell:
® Any value in violation of permit limits must be reported in the daily cell. If multiple
samples yielded noncompliant results, the most extreme noncompliant value must
be reported in the daily cell.
® If all values taken during the day were compliant with the permit limits, the value
closest to the bounds of the limit range (high or low) must be reported in the daily
cell.
® The other value not reported in the daily cell must be reported in the comment
section.
Comment: Duplicates are not required for pH.
T. 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).
Residue, Suspended — Standard Methods, 2540 D-2011 (Aqueous)
U. Finding: The laboratory is not analyzing 10% of samples in duplicate each day analyses
are performed.
Requirement: Analyze at least 10% of all samples in duplicate. Ref: Standard Methods,
2540 D-2011. (3) (c).
V. Finding: The laboratory is not evaluating the dry blank against the acceptance criterion.
Requirement: If pre -prepared filters are not used, the method requires that filters must be
weighed to a constant weight after washing. Repeat cycle of drying, cooling, desiccating,
and weighing until a constant weight is obtained or until weight change is less than 4% of
the previous weighing or 0.5 mg, whichever is less. In lieu of this process, it is acceptable
to analyze a single daily dry filter blank to fulfill the method requirement of drying all filters
to a constant weight prior to analysis. This is performed by washing all filters as required
by the method, then drying and desiccating them. The process of repeatedly heating,
cooling, desiccating, and weighing until a constant weight is documented is not required.
Instead, a single dry blank filter (i.e., no additional rinsing during the analysis) is analyzed.
The acceptance criterion for the blank is a weight change of less than 4% of the filter's
initial weight or 0.5 mg, whichever is less. Ref: NC WW/GW LC Policy.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).

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#122 Contentnea Metro Sewage District Laboratory
Comment: A dry blank is analyzed but not evaluated.
W. Finding: The laboratory is not performing the annual temperature -measuring device
check procedure correctly.
Requirement: To check a compliance temperature -measuring device, compare
readings at two temperatures that bracket the range of compliance samples routinely
analyzed against a National Institute of Standards and Technology (NIST) traceable
temperature -measuring device and record all four readings. The readings from both
devices must agree within 0.5 °C. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Temperature.
Comment: The laboratory is only using one temperature (-22 °C) for the comparison.
Additionally, when a pH probe used for compliance temperature monitoring is replaced,
an initial temperature verification check is not being performed.
Vector Attraction Reduction - Option 4: Specific Oxygen Uptake Rate
X. Finding: In determining total solids, the sample drying cycle is not repeated until the
weight change is less than 4% or 50 mg, whichever is less.
Requirement: Total solids concentration is determined by Standard Method 2540 G.
Ref: Control of Pathogens and Vector Attraction in Sewage Sludge, EPA/625/R-92/013,
July 2003, Appendix D (2).
Requirement: Repeat drying (1 h), cooling, weighing, and desiccating steps until the
weight change is less than 4% or 50 mg, whichever is less. Ref: Standard Methods,
2540 G-2011. (3) (a) (2) (b).
Comment: The laboratory was performing an annual drying study to determine the daily
drying time for Total Solids analysis. Drying studies may not be used for VAR analyses.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for the Contentnea Metro Sewage
District Laboratory (NPDES permit #NC0032077) for September 2017, and January and April
2018. No transcription errors were observed. The facility appears to be doing a good job of
accurately transcribing data.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspectors 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: August 13, 2018
Report reviewed by: Anna Ostendorff Date: August 22, 2018

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