#5144_2018_0502_MC_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5144
Laboratory Name:
Greater Badin WWTP
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Beth Swanson, Michael Cumbus
Inspection Date:
May 2, 2018
Date Forwarded for Initial
Review:
May 8, 2018
Initial Review by:
Jason Smith
Date Initial Review
Completed:
May 16, 2018
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
❑ Insp. Reg
®Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Beth Swanson
Date Received:
May 17, 2018
Date Forwarded to Admin.:
May 22, 2018
Date Mailed:
May 23, 2018
Special Mailing Instructions:
Michael cc: Wes Bell

May 23, 2018
5144
Ms. Donna Davis
Greater Badin WWTP
1000 N. First Street, Suite 12
Albemarle, NC 28001
ROY COOPfsR
MICHAI`T, S. REGAN
LINDA CULPE PPE R
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SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Davis:
Enclosed is a report for the inspection performed on May 2, 2018 by Beth Swanson and Michael
Cumbus. 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 and include an implementation date for each corrective action.
We are concerned with the Finding that was cited previously and not corrected. 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 21-1.0800.
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,
9�
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment
cc: Michael Cumbus, Dana Satterwhite

LABORATORY NAME:
NPDES PERMIT :
ADDRESS:
CERTIFICATE :
DATE OF INSPECTION:
TYPE OF INSPECTION
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Greater Badin WWTP
NC0074756
Ironwood Dr.
Badin NC, 28009
5144
May 2, 2018
Field Municipal Maintenance
Beth Swanson, Michael Cumbus
Earl Almond and Donald Mullis
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 environmental samples.
II. GENERAL COMMENTS:
Records are well organized and easy to retrieve. 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.
Requirements that reference 15A NCAC 2H .0805 (g) (1) stating "Data pertinent to each analysis
must be maintained for five years. Certified Data must consist of date collected, time collected,
sample site, sample collector, and sample analysis time. The field benchsheets must provide a
space for the signature or initials of the analyst and proper units of measure for all analyses" are
intended to be a requirement to document all pertinent information for historical reconstruction of
data. It is not intended to imply that existing records are not adequately maintained unless the
Finding speaks directly to that.
Requirements that reference 15A NCAC 2H .0805 (g) (2), stating "A record of instrument
calibration where applicable. 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 meter calibration. Use of
this requirement is not intended to imply that existing records are not adequately maintained
unless the Finding speaks directly to that.

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#5144 Greater Badin yW TP
Contract analyses are performed by Environment 1, Inc. (Certification #10).
Quality Assurance (QA) Policies for Field Laboratories and 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 maintain an equipment log to record
routine maintenance (e.g., battery replacement, membrane replacement, etc.).
A. Finding: The laboratory benchsheet was lacking pertinent data: analyst's initials, facility
name, permit number, units of measure, instrument identification (serial number
preferred), method reference, time of sample collection, time of sample analysis and Total
Residual Chlorine (TRC) calibration curve verification date.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified
data must consist of date collected, time collected, sample site, sample collector, and
sample analysis time. The field bench sheets must provide a space for the signature of the
analyst, and proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: facility name, permit number, method reference, units of measure,
instrument identification (serial number preferred), collector's/analyst's name or initials,
time of sample analysis to verify the 15-minute holding time is met (alternatively, one time
may be documented for collection and analysis with the notation that samples are
measured in situ or immediately at the sample site), date of most recent calibration curve
verification. 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 benchsheets are kept in bound notepads, each containing one month's
worth of data. Many of these items can be recorded on a cover sheet at the beginning of
each notepad.
Comment: The laboratory documents one time for Dissolved Oxygen and Temperature,
without notation that the analyses are conducted in -situ (i.e., in stream). The collection and
analysis time for TRC and pH are recorded.
B. 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: 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. 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

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#5144 Greater Badin WWTP
manufacturer, lot number, and expiration date must be retained for chemicals, reagents,
standards and consumables used for a period of five years. Consumable materials such
as pH buffers and lots of pre -made standards are included in this requirement. Ref:
Quality Assurance Policies for Field Laboratories.
Comment: The laboratory has a documented procedure for preparing the TRC
Standards. It would be acceptable to create an additional document page stating that the
standards were prepared by the aforementioned procedure and have a place for the
analyst to record their signature and date each time that the procedure is used to prepare
standards. These subsequent pages must be traceable to the preparation document
mentioned in this Comment.
Comment: The laboratory is currently documenting the Date Opened (in use), Vendor, Lot
Number and Expiration Date.
C. Finding: Documentation of the calibration for the Dissolved Oxygen meter does not
include all pertinent data.
Requirement: A record of instrument calibration, where applicable, must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (g) (2).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: calibration variables (elevation, temperature, barometric pressure
[in mmHg], salinity) and final calibration information (final DO reading in mg/L, the slope or
% efficiency). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen.
Comment: The Dissolved Oxygen meter uses elevation and temperature to calibrate but
only the elevation is recorded.
General Laboratory
Recommendation: Laboratory personnel has changed since the last inspection. Due to the
Finding previously cited, it is recommended that the laboratory adopt a formal documented
training process for new employees which includes, at a minimum, documentation of the following:
® Staff have read the applicable Approved Procedures and QA Policies for Field
Laboratories
® Staff have read the most recent inspection report
D. Finding: The auto-pipettor used to make critical measurements has not been calibrated
every twelve months. Cited previously on January 20, 2010.
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and
adjustable auto-pipettors, bottle -top dispensers, etc.), used for critical measurements,
must be calibrated at least every twelve months and documented. Each liquid
dispensing device must meet the manufacturer's statement of accuracy. For variable
volume devices used at more than one setting, check the accuracy at the maximum,
middle and minimum values. Testing at more than three volumes is optional. When a
device capable of variable settings is dedicated to dispense a single specific volume,
calibration is required at that setting only. Ref: Quality Assurance Policies for Field
Laboratories.

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#5144 Greater Badin WWTP
Comment: This was previously cited on January 20, 2010. However, personnel have
changed. It is critical that action be taken to ensure that this Finding is corrected and
does not recur in the future; even if there are changes in personnel, as it may impact
data integrity and legal defensibility.
Comment: Preparing standards and the PT Sample are considered critical
measurements.
Comment: Another laboratory can aid in fulfilling this requirement.
Proficiency Testing
E. 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 the preparation of the TRC PT
Sample would satisfy the documentation requirement.
F. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
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, May 31, 2017, Revision 2.0.
pH - Standard Methods, 4500 H+ B-2011 (Aqueous)
G. 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 performs a three-point calibration but does not reanalyze one
of the buffers as a check.
Comment: If the check buffer does not read within ±0.1 S.U., the lab should first try
pouring a new aliquot of the check buffer and reading it again. If it still does not read within
±0.1 S.U., the meter must be recalibrated. If, after recalibration, the check buffer does not
read within ±0.1 S.U., the meter and/or probe operation may be suspect and may require
servicing. If the laboratory does not have a back-up meter/electrode, or another
meter/electrode cannot be procured, it is recommended that the lab report the measured
pH results with a qualifier that indicates the value is estimated.

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#5144 Greater Badin UWVfP
Chlorine, Total Residual - Standard Methods 4500 Cl G-2011 (Aqueous)
Recommendation: The laboratory is currently analyzing 20, 40, 100, 200 and 400 pg/L standards
as part of the Factory -set Calibration Curve Verification. It is recommended that the laboratory
analyze a 50 pg/L standard in place of the 100 pg/L standard. This standard would verify accuracy
at the Division of Water Resources' compliance limit for TRC.
H. Finding: The laboratory is not analyzing a Reagent Blank when preparing standards or
analyzing a PT Sample.
Requirement: If preparing standards, analyzing a PT Sample or analyzing diluted
samples, a Reagent Blank is required. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine.
Comment: A Reagent Blank is made from the same laboratory water source used to
make liquid standards. The concentration of Reagent Blanks must not exceed 50% of the
reporting limit (i.e., the lowest calibration or calibration verification standard concentration)
or corrective action must be taken.
Finding: The laboratory is not evaluating whether the Factory -set Calibration Curve
Verification standards are within the acceptable recovery range.
Requirement: 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 µg/L
and must not vary by more than 25% from the known value for standard concentrations
less than 50 µg/L. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
Requirement: If the factory -set readings vary by more than the stated acceptance
criteria, the stored calibration program must not be used for compliance monitoring until
troubleshooting is carried out to determine and correct the source of error. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The standards were all within acceptable limits for the Factory -set Calibration
Curve Verification that was reviewed during the inspection.
J. Finding: The laboratory is not verifying the "gel -type" standard concentration every 12
months.
Requirement: Purchased "gel -type" or sealed standards may be used only for daily
calibration curve verifications. These standards must have a true value assigned initially
and with each subsequent calibration curve generation/verification thereafter. When this is
done, these standards may be used after the manufacturer's expiration date. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine. Please
submit a copy of the gel verification with the report reply.
Comment: It is only necessary to assign a true value to the gel -type or sealed liquid
standard which falls within the concentration range of the calibration curve used to
measure sample concentrations. For example, since the laboratory is measuring samples

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#5144 Greater Badin WWTP
against a low -range calibration curve, a 200 pg/L standard would be verified, and not the
800 pg/L standard.
Comment: The assigned true value will be used until a new calibration curve verification is
performed and the true value is reassigned. See the NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine document for guidance on assigning
true values.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g. laboratory benchsheets, notepads,
etc.) and contract lab reports to Discharge Monitoring Reports (DMRs) submitted to the North
Carolina Division of Water Resources. Data were reviewed for Greater Badin WWTP (NPDES
permit #NC0074756) for September 2017, January 2018 and March 2018. The following error
was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
3/29/2018
Total Residual Chlorine
Effluent
Not Analyzed/No Value
< 2 pg/L
Comment: This was believed to be a typographical error, as the adjacent column on the DMR
(BOD) had a recorded value of <2 mg/L. This error did not affect the monthly average.
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended DMR 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
to thank the staff for its 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: Michael Cumbus Date: May 8, 2018
Report reviewed by: Jason Smith Date: May 16, 2018

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