#5268_2018_0308_TH_FINAL

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To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5268
Laboratory Name:
Town of Hookerton
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tom Halvosa and Todd Crawford
Inspection Date:
March 8, 2018
Date Forwarded for Initial
Review:
March 22, 2018
Initial Review by:
Tonja Springer
Date Initial Review
Completed:
March 27, 2018
Cover Letter to use:
❑ Insp. Initial
❑Insp. No Finding
❑Corrected
® Insp. Reg
❑Insp. CP
❑Insp. Reg. Delay
Unit Supervisor/Chemist III:
Todd Crawford
Date Received:
March 27, 2018
Date Forwarded to Admin.:
March 29, 2018
Date Mailed:
April 2, 2018
Special Mailing Instructions:

Water Resources
[-:T4V1R0NM,LNTA.L QUALITY
April 2, 2018
5268
Mr. Tyler Shirley
Town of Hookerton
P.O. Box 296
Hookerton, NC 28538
ROY COOPER
MICHEAL S. REGAN
LINDA CULPEPPER
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Shirley:
Enclosed is a report for the inspection performed on March 8, 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 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].
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tom Halvosa
Water Sciences Section
NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Phone; 919-733-3906 i FAX: [phone]
Internet.http:ildeq.nc.goviabouUdivisions/water•resources/water-resources•datalwater-sciences-home•oageflaboratoryicertification-branch

LABORATORY NAME: Town of Hookerton
NPDES PERMIT #: NC0025712
ADDRESS: 303 E. Main Street
Hookerton, NC 28538
CERTIFICATE #: 5268
DATE OF INSPECTION: March 8, 2018
TYPE OF INSPECTION: Field Municipal Maintenance
AUDITOR(S): Tom Halvosa and Todd Crawford
LOCAL PERSON(S) CONTACTED: Tyler Shirley
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 environmental 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 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.
Contracted analyses are performed by Environmental Chemists Inc. (Certification # 94).
Quality Assurance 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
A. Finding: Error corrections are not properly performed.

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#5268 Town of Hookerton
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. Ref: Quality Assurance Polices for Field Laboratories.
D. Finding: The analyst is not always signing or initialing laboratory benchsheets. This is
considered pertinent data.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Collector's/analyst's name or initials. NC WW/GW LC Approved
Procedure for the Analysis of pH.
Requirement: Data pertinent to each analysis must be maintained for five years. Certified
data must consist of date collected, time collected, samples 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).
C. Finding: Data qualifiers from the contract laboratory reports are not being transferred to
the electronic Discharge Monitoring Report (eDMR).
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. Part of the
corrective action is notification to the end user. If data qualifiers are used to qualify
samples not meeting QC requirements, the data may not be useable for the intended
purposes. It is the responsibility of the laboratory to provide the client or end -user of the
data with sufficient information to determine the usability of the qualified data. Where
applicable, a notation must be made on the Discharge Monitoring Report (DMR) form, in
the comment section, when any required sample quality control does not meet specified
criteria and another sample cannot be obtained. Ref: Quality Assurance Policies for
Field Laboratories.
Comment: The BOD qualifier (i.e., "GGA failed") was not transferred to the eDMR from
the client report for October 12, 2017.
Holding Time
D. Finding: The holding time for pH analysis is sometimes exceeded.
Requirement: Analyze within 15 minutes. Ref: Code of Federal Regulations, Title 40,
Part 136; Federal Register Vol. 82, No. 165, August 28, 2017; Table 11.
Comment: The holding time was exceeded for pH on March 6, 2017. There were
numerous occasions where the holding times for both pH and Total Residual Chlorine
(TRC) were at the 15-minute limit.
Recommendation: It is recommended that the laboratory calibrate the pH meter before
collecting the sample and to start documenting TRC analysis as the time the DPD
reagent is added to the sample.

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#5268 Town of Hookerton
Proficiency Testing
E. 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.
Comment: The analysis of PT samples is designed to evaluate the entire process used
to routinely report environmental analytical results; therefore, PT samples must be
analyzed and the process documented in the same manner as Compliance Samples.
F. 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.
Total Residual Chlorine — Standard Methods, 4500 Cl G-2011 (Aqueous)
G. Finding: The laboratory is not verifying the instrument's factory -set calibration curve every
12 months.
Requirement: Zero the instrument with chlorine -free water and then analyze a reagent
blank (i.e., reagent water plus buffer and DPD) and a series of five standards. The curve
verification must bracket the range of the samples to be analyzed. This type of curve
verification must be performed at least every 12 months. The values obtained must not
vary by more than 10% of the known value for standard concentrations greater than or
equal to 50 pg/L and must not vary by more than 25% of the known value for standard
concentrations less than 50 pg/L. The reagent blank concentration must not exceed half
the concentration of the lowest standard. The overall correlation coefficient of the curve
must be >_0.995. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine.
Comment: The factory -set calibration curve was last verified on October 31, 2016.
H. Finding: Values less than the established reporting limit are being reported on the eDMR.
Requirement: The concentrations of the calibration standards must bracket the
concentrations of the samples analyzed. One of the standards must have a concentration
equal to or below the lower reporting concentration for Total Residual Chlorine. The lower
reporting limit must be less than or equal to the permit limit. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.

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#5268 Town of Hookerton
Comment: The reporting limit established by the Annual Factory -set Standard Curve
Verification on October 31, 2016 was 10 pg/L.
Dissolved Oxygen — Standard Methods, 4500 O G-2011 (Aqueous)
I. Finding: The laboratory is not performing a post -analysis calibration verification when
analyses are performed at multiple sample sites.
Requirement: When performing analyses at multiple sample sites, a post -analysis
calibration verification must be performed at the end of the run, regardless of meter
type. It is recommended that a mid -day calibration verification be performed when
samples are analyzed over an extended period of time. The calculated Dissolved
Oxygen (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. Alternatively, if the meter is calibrated at each sample site prior to analysis, a
post -analysis calibration verification is not required. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen.
Recommendation: It is recommended that the laboratory perform a new calibration at
each sampling site.
pH — Standard Methods, 4500 H+ B-2011 (Aqueous)
J. 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).
Temperature — Standard Methods, SM 2550 B-2010 (Aqueous)
K. Finding: The temperature sensor on the DO meter used to obtain reported temperature
values has not been checked against a National Institute of Standards and Technology
(NIST) traceable thermometer every 12 months.
Requirement: All compliance temperature-measurinq devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. Documentation must include
the serial number of the device being checked. The serial number, stated accuracy and
expiration date of the NIST traceable temperature -measuring device used in the
comparison must also be documented. Verification data must be kept on file and be
available for inspection for 5 years. (NOTE: Vendors or other Certified laboratories may
provide assistance in meeting this requirement., When a vendor or other Certified
laboratory provides this assistance, they must provide a copy of their NIST Certificate or
the serial number, accuracy and calibration expiration date.) Ref: NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
Comment: The annual NIST Traceable Thermometer/Meter Sensor (probe) Check was
last performed on August 22, 2016.

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#5268 Town of Hookerton
IV.
L. Finding: The thermometer calibration verification documentation did not include the stated
accuracy or the expiration date of the NIST traceable temperature -measuring device that
was used in the comparison. This is considered pertinent data.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref:
15A NCAC 2H .0805 (g) (1).
Requirement: All compliance temperature -measuring devices without a valid NIST
certificate must be checked initially and every 12 months against an NIST traceable
temperature -measuring device and the process documented. Documentation must include
the serial number of the device being checked. The serial number, stated accuracy and
expiration date of the NISI traceable temperature -measuring device used in the
comparison must also be documented. Verification data must be kept on file and be
available for inspection for 5 years. (NOTE: Vendors or other Certified laboratories may
provide assistance in meeting this requirement. When a vendor or other Certified
laboratory provides this assistance, they must provide a copy of their NIST Certificate or
the serial number, accuracy and calibration expiration date.) Ref: NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for Town of Hookerton (NPDES permit #NC0025712) for
January, June and October 2017. The following errors were noted:
Value on
Benchsheet
Date
Parameter
Location
Value on eDMR
*Contract Lab
Data
1/20/2017
Temperature
Outfall
16.1 °C
15.6 °C
1/20/2017
DO
Outfall
8.10 mg/L
7.50 mg/L
10/12/2017
NH3
Effluent
*1.4 mg/L
0.04 mg/L
To avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended eDMR(s) 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 and implementation dates for each
corrective action.
Report prepared by: Tom Halvosa
Report reviewed by: Tonja Springer
Date: March 15, 2017
Date: March 26, 2018

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