#256_2018_1115_TLH_FINAL

Laboratory Cert. #:
256
Laboratory Name:
LaGrange WWTP Laboratory
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Tom Halvosa and Todd Crawford
Inspection Date:
November 15, 2018
Date Forwarded for Initial
Review:
November 28, 2018
Initial Review by:
Jason Smith
Date Initial Review
Completed:
December 3, 2018
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg
❑Insp. No Finding ❑Insp. CP
❑Corrected ❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
December 4, 2018
Date Forwarded to Admin.:
December 18, 2018
Date Mailed:
December 19, 2018
Special Mailing Instructions:

ROY COOPER
C eiv,;; ;,r.,...,
ILINDA CUI.PFf"fR 'R
December 19, 2018
256
Mr. James W. Sutton
LaGrange WWTP Laboratory
P.O. Box 368
LaGrange, NC 28551
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Sutton:
Enclosed is a report for the inspection performed on November 15, 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# 256
North Carolina Department of Environmental Quality I Division of Water Resources
1623 Mail Service Center I Raleigh, North Carolina 27699-1623
Phone 919.733,3908/Fax [phone]

CERTIFICATE :
�' • & - • • I
LaGrange WWTP Laboratory
NC0021644
WQ0034386
700 E King St
LaGrange, NC 28551
256
November 15, 2018
Municipal Maintenance
Tom Halvosa and Todd Crawford
LOCAL PERSON(S) CONTACTED: Wesley Sutton and Carl Foster
INTRODUCTION:
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 has all the equipment necessary to perform the analyses. Staff were forthcoming and
seemed eager to adopt necessary changes.
All required Proficiency Testing (PT) Samples have been analyzed for the 2018 PT Calendar Year
and the graded results were 100% acceptable.
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 November 29, 2019.
The laboratory is reminded that any time changes are made to laboratory procedures, the
laboratory must update the QA/SOP documents 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

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#256 LaGrange WWTP Laboratory
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.
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".
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.
General Laboratory
A. Finding: The analytical balance has not been serviced in the past twelve months.
Requirement: Laboratory analytical balance must be serviced by a qualified
vendor/technician at a minimum every 12 months to ensure that the balance is
functioning within manufacturer's specifications. Documentation that this service has
been performed must be available for review upon request. If the operational capabilities
of the balance are in question at any time during the 12-month period, corrective action
must be taken. Ref: NC WW/GW LC Policy.
B. Finding: The analytical balance is not being checked with three weights quarterly.
Requirement: The analytical balance must be checked with one class S, or equivalent,
standard weight each day used and at least three standard weights quarterly. The
values obtained must be recorded in a log and initialed by the analyst. Ref: 15A NCAC
2H .0805 (a) (7) (k).
Comment: The laboratory last performed a quarterly three weight check of the
analytical balance on March 30, 2018 and prior to that on June 22, 2017.
C. Finding: The laboratory's two Reference Temperature -Measuring Device calibrations
were expired.
Requirement: A Reference Temperature -Measuring Device is a National Institute of
Standards and Technology (NIST) traceable temperature -measuring device used only to
verify the calibration of other temperature -measuring devices (i.e., limited use only). It
must be recalibrated in accordance with the manufacturer's recalibration date (not to
exceed five years). If no recalibration date is given, the Reference Temperature -
Measuring Device must be recalibrated, at a minimum, every five years. A new

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#256 LaGrange WWTP Laboratory
certificate of traceability must be issued and maintained for inspection upon request.
Recalibrate sooner if the device has been exposed to temperatures beyond the
manufacturer's recommended range of use. Ref: NC WW/GW LC Policy.
Comment: The laboratory has two total immersion NISI traceable thermometers that
are used as Reference Temperature -Measuring Devices. Both of the thermometers'
calibration dates exceeded five years. One (ERTCO serial # 1670) was last calibrated
on May 11, 2006 and the other (ERTCO serial # 6683) on June 1, 2007.
D. Finding: The laboratory is using total immersion thermometers improperly.
Requirement: Thermometers with no indicated depth are the total immersion type.
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",
CodLi� io F'file /,20 i 5 I e)r'C`oc ryie s/nisfL)s it i C JFr C f.
E. Finding: Fecal Coliform and Biochemical Oxygen Demand (BOD) thermometers are not
being checked against a Reference Temperature -Measuring Device quarterly.
Requirement: Digital temperature -measuring devices and temperature -measuring
devices used in incubators must be verified at least quarterly (i.e., every 3 months) (or
sooner if the temperature -measuring device has been exposed to temperatures beyond
the manufacturer's recommended range of use or other stresses) against a Reference
Temperature -Measuring Device with the appropriate accuracy and the process
documented. Ref: NC WW/GW LC Policy.
Comment: Fecal Coliform and BOD thermometers are being checked against a
Reference Temperature -Measuring Device annually.
Documentation
F. 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.
G. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents, as well as 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
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,

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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.
Comment: The laboratory does not have a receipt log or a standard and reagent
preparation log. Example log templates were provided to the laboratory with
instructions on use at the time of the inspection.
H. Finding: Sample collection date is not documented for Fecal Coliform.
Requirement: A record of date collected, time collected, sample collector, and use of
proper preservatives must be maintained. Each sample must clearly indicate the -State
of North Carolina collection site on all record transcriptions. Ref: 15 NCAC 2H .0805 (a)
(7) (M).
Requirement: Sample identification must be associated with the date and time of
sample collection and analysis. The time elapsed between sampling and analysis must
be documented to determine if hold times are met. Ref: NC WW/GW LC Policy.
Recommendation: It is recommended that the laboratory revise their benchsheet to
include time and date of sample collection together.
Finding: The laboratory benchsheets for TRC, Dissolved Oxygen (DO), pH and
Temperature are lacking pertinent data: Date and time of sample collection, and permit
number, units of measure, instrument identification and method reference.
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: Date and time of sample collection, sample site (ID or location)
and permit number, units of measure, instrument identification (serial number preferred)
and method reference. Ref: NC WW/GW LC Approved Procedure for the Analysis of
Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of
Dissolved Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH and NC
WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: The laboratory documents DO and Temperature results in a notebook that
does not contain sufficient documentation of collection time, permit number, units of
measure, instrument identification (serial number preferred) and method references.
The TRC benchsheet lacks a method reference and units of measure for volume. The
DO notebook lacked meter calibration time and units of measure. The pH benchsheet
lacked a method reference and units of measure. Temperature needs to include
"Celsius" or "C" next to ""' in the units of measure.
Recommendation: It is recommended that the laboratory implement the use of a
benchsheet for Temperature and DO that allows for documentation of the
aforementioned pertinent data. The TRC and pH benchsheets need to be revised so the
correct method descriptions and proper units of measure are listed.
J. Finding: The time the BOD samples are removed from the incubator is not always
documented.

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Requirement: 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)•
Quality Control
Comment: The laboratory is analyzing sample duplicates for Total Residual Chlorine (TRC) and
pH. Duplicate analyses are not a required quality control element for Field Parameters.
K. Finding: SOPs have not been developed and/or updated for all of the methods included
on the laboratory's Certified Parameters Listing (CPL).
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).
Comment: The following methods were lacking an SOP at the time of the inspection:
Temperature — Standard Methods, 2550 B-2010 (Aqueous)
Dissolved Oxygen — Standard Methods, 4500 O G-2011 (Aqueous)
L. Finding: An inconsistency was noted between the SOP and laboratory practice as
follows: For BOD, the laboratory was using 2 mL of seed where the SOP states the use
of 4 m L.
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).
Recommendation: It is recommended that the seed volume not be specified in the
SOP since it can sometimes vary.
M. 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.
Proficiency Testing
N. Finding: The laboratory does not have a documented plan for PT procedures.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.

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Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
Requirement: Laboratories must have a documented plan (this is usually detailed in the
laboratory's Quality Assurance Manual or may be a separate Standard Operating
Procedure (SOP)) of how they intend to cover the applicable program requirements for
Proficiency Testing per their scope of accreditation. This plan shall cover any commercially
available PT Samples and any inter -laboratory organized studies, as applicable. The
laboratory must also be able to explain when PT Sample analysis is not possible for
certain methods and provide a description of what the laboratory is doing in lieu of
Proficiency Testing. This shall be detailed in the plan. The plan must also address the
laboratory's process for submission of PT results and related Corrective Action Reports
(CARs). Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Bacteria — E. coli - IDEXX Colilert® (24 hr.) (MPN) (Aqueous)
Comment: The Fecal Coliform incubator water bath thermometer was resting on the metal
bottom of the water bath. Acceptable corrective action was performed during the inspection by
raising the thermometer off the bottom of the water bath and securing it in that position.
A
7
Finding: Duplicate analyses are not performed at the required frequency.
Requirement: Analyze five percent of all samples in duplicate to document precision.
Laboratories analyzing less than 20 samples per month must analyze at least one
duplicate each month samples are analyzed. Ref: 15A NCAC 2H .0805 (a) (7) (C).
Comment: Only one duplicate was being analyzed per month. Since the laboratory
analyzes Fecal Coliform five times weekly the laboratory would need to analyze a
minimum of two duplicates most months.
Finding: There is no acceptance criterion for duplicates.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Ref: 15A NCAC 2H .0805 (a) (7).
Comment: The lab must set an acceptance criterion at all concentration levels. IDEXX
recommends basing acceptance on the 95% confidence range. Looking at the sample
and duplicate ranges, they are acceptable as long as those 2 ranges overlap. Go to the
following website to download a program where you can enter results and it will
calculate the MPN and 95% confidence range-
https://www.idexx.com/en/water/resources/mpn-generator/. Alternately, a chart that
contains all possible MPN results with the corresponding 95% confidence levels can be
found on the technical assistance portion of our website.
Recommendation: It is recommended that the laboratory add duplicate acceptance
criteria and a place to document it on the benchsheet.
BOD —Standard Methods, 5210 B-2011 (Aqueous)
Comment: Prior to May 2018, BOD results that should have been reported as <2.0 mg/L were
being reported as zero on Discharge Monitoring Reports (DMRs). The Regional Inspector
noticed this mistake and had them start reporting the correct value.

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Q. Finding: The DO meter is not being calibrated according to the manufacturer's
instructions.
Requirement: Calibration Value: The correct Calibration Value is the solubility of
oxygen in fresh water at your barometric pressure as a percentage of the solubility of
oxygen at standard pressure. Ref: YSI 59 Operator's Manual.
Comment: The laboratory needs to obtain the true barometric pressure for their
laboratory to calculate the correct Calibration Value. When initially calibrating the YSI 59
DO meter the Calibration Value (when prompted to enter the cal value % during the
calibration set-up) is equal to the barometric pressure (mm of Hg) in your laboratory
divided by 760 mm of Hg. Alternatively, you can use the chart in Appendix B of the
operator's manual to obtain the correct Calibration Value. For example, if the true
barometric pressure of the laboratory is 714 mm of Hg, then the Calibration Value is
714/760 = 94%.
R. Finding: Samples are not checked and/or adjusted for pH.
Requirement: Check pH; if it is not between 6.0 and 8.0, adjust sample temperature to
20 ± 3 °C, then adjust pH to 7.0 to 7.2 using a solution of sulfuric acid or sodium
hydroxide of such strength that the quantity of reagent does not dilute the sample by
more than 0.5%. The pH of dilution water should not be affected by the lowest sample
dilution. Always seed samples that have been pH adjusted. Ref: Standard Methods,
5210 B-2011. (4) (b) (1).
S. Finding: The DO meter is not checked for drift at the end of the analytical series, or the
check is not always documented.
Requirement: If the membrane electrode method is used, take care to eliminate drift in
calibration between initial and final DO readings. Ref: Standard Methods, 5210 B-2011.
(5) (g)•
Requirement: Immediately after calibration, measure the DO of a BOD bottle of dilution
water. Stopper the bottle. Document the concentration on the benchsheet (day one
initial drift check). At the end of the sample set reanalyze the drift check bottle and
document the concentration (day one final drift check). The laboratory should verify the
DO Meter calibration throughout the sample set if needed. Repeat process on Day 5. If
the meter drifts more than 0.20 mg/L, recalibrate meter and reanalyze all samples since
the last drift check. Ref: NC WW/GW LC Policy.
T. Finding: Three dilutions of each sample are not being analyzed.
Requirement: Using the dilution water prepared as in ¶ a above, make at least three
dilutions of prepared sample estimated to produce a residual DO of at least 1.0 mg/L
and a DO uptake of at least 2.0 mg/L after 5-d incubation. Five dilutions are
recommended if experience with a particular sample does not produce at least three
bottles having acceptable minimum DO depletions and residual limits (5210B.6a). Ref:
Standard Methods, 5210 B-2011. (5) (c).
Comment: The laboratory was analyzing two dilutions.
U. Finding: Three glucose-glutamic acid (GGA) standard solutions are not being analyzed.

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Requirement: Add sufficient amounts of standard glucose-glutamic acid solution
(5210B.3h) to give 3.0 mg glucose/L and 3.0 mg glutamic acid/L in each of three test
bottles (20 mL GGA solution/L seeded dilution water or 6.0 mL/300-mL bottle). The
resulting average BOD for the three bottles, after correction for dilution and seeding,
must fall into the range of 198 ± 30.5 mg/L. Ref: Standard Methods, 5210 B-2011. (6)
(b).
Comment: The laboratory was only analyzing two GGA samples.
V. Finding: Initial DO concentrations of all bottles other than the blank are not always
brought to the required range of 7 - 9 mg/L.
Requirement: The working range is equal to the difference between the maximum initial
DO (7 to 9 mg/L) and minimum DO residual of 1 mg/L corrected for seed, and multiplied
by the dilution factor. Ref: Standard Methods, 5210 B-2011. (8) (b).
Comment: The laboratory uses a medium diameter tube to aerate the dilution water
with large bubbles resulting in poor oxygen saturation of the dilution water.
Recommendation: It is recommended that the laboratory use a stone -type bubbler
attached to the end of air tube to produce a fine stream of small bubbles to assist in
increasing initial DO concentrations.
W. Finding: Initial DO concentration of the water used to make dilution water is not always
verified to be at least 7.5 mg/L.
Requirement: Check to ensure that the dissolved oxygen concentration is at least 7.5
mg/L before using water for BOD tests. Ref: Standard Methods, 5210 B-2011. (5) (a).
Comment: The laboratory uses a medium diameter tube to aerate the water with large
bubbles resulting in poor oxygen saturation of the dilution water.
Recommendation: It is recommended that the laboratory use a stone -type bubbler
attached to the end of air tube to produce a fine stream of small bubbles to assist in
increasing initial DO concentrations.
X. Finding: Seed controls with less than 2.0 mg/L DO depletion are used for seed
correction calculation.
Requirement: For the ratio method, divide the DO depletion by the volume of seed in
milliliters for each seed control bottle having a 2.0 mg/L depletion and greater than 1.0
mg/L minimum residual DO and average the results. Ref: Standard Methods, 5210 B-
2011. (6) (d).
Residue, Suspended — Standard Methods, 2540 D-2011 (Aqueous)
Y. Finding: Filters are not weighed to constant weight prior to sample analysis, nor is a dry
filter blank analyzed with each set of samples.
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

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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. Ref: NC WW/GW
LC Policy.
Z. Finding: The laboratory is not analyzing a volume of sample to yield a minimum of 2.5
mg dried residue.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue.
If volume filtered fails to meet minimum yield, increase sample volume up to 1 L. Ref:
Standard Methods, 2540 D-1997 (3) (b).
Comment: The laboratory sometimes has difficulty filtering some of their samples
therefore they do not always use the 1000 mL of sample as required by the method to
yield between 2.5 and 200 mg dried residue. This is, in part, due to the small diameter
filter used.
Recommendation: It is recommended that the laboratory use a larger filter to either
consistently obtain at least 2.5 mg of dried residue or filter 1000 mL of sample.
AA. Finding: The laboratory is not basing the reporting limit on the minimum weight gain
required by the method.
Requirement: The minimum weight gain allowed by any approved method is 2.5 mg.
Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes
a minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If
complete filtration takes more than 10 minutes increase filter diameter or decrease
sample volume. In instances where the weight gain is less than the required 2.5 mg, the
value must be reported as less than the appropriate value based upon the volume used.
Ref: NC WW/GW LC Policy.
BB. 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).
CC. Finding: A check standard is not being analyzed quarterly.
Requirement: Analyze one suspended residue, one dissolved residue, one residual
chlorine and one oil and grease standard quarterly. Ref: 15 NCAC 2H .0805 (a) (7) (B).
Comment: A Celite check standard was last analyzed in March 2015.
Chlorine, Total Residual — Standard Methods, 4500 CI G-2011 (Aqueous)
DD. Finding: The laboratory is not verifying the instrument's Factory -set Calibration Curve
every 12 months.
Requirement: Annual Factory -set Calibration Curve Verification: This type of calibration
curve verification must be performed initially, at least every 12 months and any time the
instrument optics are serviced. Zero the instrument with a Calibration Blank and then
analyze a Reagent Blank and a series of five standards (do not use gel or sealed liquid

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VA
standards for this purpose). The calibration standard values obtained must not vary by
more than 10% from the known value for standard concentrations greater than or equal
to 50 pg/L and must not vary by more than 25% from the known value for standard
concentrations less than 50 pg/L. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: The laboratory has not verified the instrument's Factory -set Calibration
Curve since 2016.
EE. Finding: Values less than the established reporting limit are being reported on the
DMR.
Requirement: For analytical procedures requiring analysis of a series of standards, the
concentrations of those standards must bracket the concentration of the samples
analyzed. One of the standards must have a concentration equal to the laboratory's
lower reporting concentration for the parameter involved. Ref: 15A NCAC 02H .0805 (a)
(7) (1).
Requirement: For all calibration options, the range of standard concentrations must
bracket the permitted discharge limit concentration, the range of sample concentrations
to be analyzed and anticipated PT Sample concentrations. One of the standards must
have a concentration equal to or less than the permitted discharge limit. The lower
reporting limit concentration is equal to the lowest standard concentration. Sample
concentrations that are less than the lower reporting limit must be reported as a less -
than value. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.
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 LaGrange WWTP Laboratory
NPDES permit # NC0021644 for December 2017 and March and July 2018. The following error
was noted:
Value on
Date
Parameter
Location
Benchsheet
Value on DMR
12/7/2017
Fecal Coliform
Effluent
22 MPN/100 mL
2 MPN/100 mL
To avoid questions of legality, it is recommended that you contact the appropriate Regional Office
for guidance as to whether an amended eDMR 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 Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like

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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: November 28, 2018
Report reviewed by: Jason Smith Date: December 3, 2018

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