#5277_2017_0418_TS_FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5277
Laboratory Name:
Reidsville Water Plant
Inspection Type:
Field Municipal Maintenance
Inspector Name(s):
Tonja Springer
Inspection Date:
April 18, 2017
Date Forwarded for Initial
Review:
May 10, 2017
Initial Review by:
Anna Ostendorff
Date Initial Review
Completed:
May 18, 2017
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:
May 18, 2017
Date Forwarded to Admin.:
May 25, 2017
Date Mailed:
May 26, 2017
Special Mailing Instructions:

Water Resources
ENVIRONMENTAL QUALJY
May 26, 2017
5277
Mr. Scott Jewell
Reidsville Water Plant
278 Reid Lake Rd.
Reidsville, NC 27320-
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Jewell:
Enclosed is a report for the inspection performed on April 18, 2017 by Tonja Springer. Since the
Finding(s) cited during the inspection were all corrected prior to the completion of the enclosed report, a
response is not required. The staff is commended for taking the initiative in correcting the Findings in
such a timely manner. 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 electronic mail, or if you have questions or need additional information,
please contact me at [phone] ext. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tonja Springer, Master File # 5277

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
Reidsville Water Plant
NC0046345
278 Reid Lake Rd.
Reidsville, NC 27320
5277
April 18, 2017
Field Municipal Maintenance
Tonja Springer
LOCAL PERSON(S) CONTACTED: Greg Purcell
INTRODUCTION:
This laboratory was inspected by a representative of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements
of 15A NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses. The laboratory analyst was
very forthcoming and receptive to implementing the necessary changes in response to the
Findings and Recommendations noted during the inspection.
All required Proficiency Testing (PT) samples for the 2017 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, 2017.
Contracted analyses are performed by Meritech, Inc. (Certification #165).
Current 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
Comment: The Date Opened (in use) is not always documented in the reagent logbook for pH
buffers and Total Residual Chlorine (TRC) DPD liquid reagents. NC WW/GW LC Quality
Assurance Policies for Field Laboratories states: 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. Consumable
materials such as pH buffers and lots of pre -made standards are included in this requirement.
Notification of acceptable corrective (i.e., submitted a Standard Operating Procedure (SOP) for
logging in lab reagents which includes to document Date Opened (in use) along with a statement

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#5277 Reidsville Water Plant
that they will start consistently documenting date in use in the logbook with an implementation
date of April 21, 2017) was received by email on May 8, 2017. No further response is
necessary for this Finding.
Proficiency Testing
Comment: The preparation of the TRC PT sample is not documented. The Proficiency Testing
Requirements, February 20, 2012, Revision 1.2. document states: PT samples received as
ampules must be diluted according to the PT provider's instructions. The preparation of PT
samples must be documented in a traceable log or other traceable format. The diluted PT
sample becomes a routine environmental sample and is added to a routine sample batch for
analysis. Notification of acceptable corrective action (i.e., a statement that beginning with the
2017 PT samples, the PT vendor's preparation instructions will be initialed and dated and kept
as a permanent record for five years) was received by email on May 8, 2017. No further
response is necessary for this Finding.
Comment: The laboratory is not documenting TRC and pH PT sample analyses in the same
manner as environmental samples. PT sample results are documented directly on the vendor
report form and not on the benchsheet. The Proficiency Testing Requirements, February 20,
2012, Revision 1.2. document states: All PT sample analyses must be recorded in the daily
analysis records as for any environmental sample. This serves as the permanent laboratory
record. Notification of acceptable corrective action (i.e., a statement that beginning with the
2017 PT study, PT samples will be analyzed and documented like the regular samples on the
benchsheet) was received by email on May 8, 2017. No further response is necessary for
this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
Comment: The laboratory benchsheet was lacking pertinent data: Instrument identification. The
NC WW/GW LC Approved Procedure for the Analysis of Temperature, NC WW/GW LC
Approved Procedure for the Analysis of pH, and NC WW/GW LC Approved Procedure for the
Analysis of Total Residual Chlorine documents state: The following must be documented in
indelible ink whenever sample analysis is performed: Instrument identification. Notification of
acceptable corrective action (i.e., an updated benchsheet which includes instrument identification
with an implementation date of April 27, 2017) was received by email on May 8, 2017. No further
response is necessary for this Finding.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Comment: The laboratory was not analyzing a check standard each analysis day. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document states:
Analyze a check standard each analysis day. Notification of acceptable corrective action (i.e.,
an updated benchsheet that includes the space to document the check standard daily with an
implementation date of April 25, 2017) was received by email on April 25, 2017. No further
response is necessary for this Finding.
Comment: The check standard has not been verified initially. The NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine document states: Purchased "Gel -type" or
sealed liquid ampoule standards may be used for daily standard curve verification only. These
standards must be verified initially and every 12 months thereafter, with the standard curve.

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#5277 Reidsville Water Plant
When this is done, these standards may be used after the manufacturer's expiration date.
Notification of acceptable corrective action (i.e., submitted documentation of the gel standard
verification with an implementation date of April 25, 2017) was received by email on April 25,
2017. No further response is necessary for this Finding.
Comment: The laboratory is not verifying the instrument's factory set curve every 12 months.
The NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine document
states: 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 µg/L and must not vary
by more than 25% of the known value for standard concentrations less than 50 µg/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. Notification of acceptable corrective
action (i.e., a copy of the curve verification that was performed on April 25, 2017) was received
by email on April 25, 2017. No further response is necessary for this Finding.
Comment: The sample collection time and sample analysis time is documented as one time.
The sample is collected and then brought back to the lab for analysis. North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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 or initials of the analyst, and proper units of measure for all analyses.
Notification of acceptable corrective action (i.e., an updated benchsheet that includes a sample
collection time and sample analysis time with an implementation date of April 21, 2017) was
received by email on April 21, 2017. No further response is necessary for this Finding.
RHH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comment: The pH calibration log was lacking pertinent data: Units of measure. North Carolina
Administrative Code, 15A NCAC 2H .0805 (g) (1) states: 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 or initials of the analyst, and proper units of measure for all analyses.
Notification of acceptable corrective action (i.e., an updated calibration log that includes units of
measure with an implementation date of April 21, 2017) was received by email on April 21,
2017. No further response is necessary for this Finding.
Comment: Values were reported that exceed the method specified accuracy of 0.1 units.
Standard Methods, 4500 H+ B-2000. (6) states: 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. Notification of acceptable corrective action (i.e., a statement that pH values
are now being reported to one decimal place with an implementation date of April 21, 2017)
was received by email on April 21, 2017. No further response is necessary for this Finding.
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

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#5277 Reidsville Water Plant
Carolina Division of Water Resources. Data were reviewed for Reidsville Water Plant (NPDES
# NC0046345) for January, February and March 2017. The following errors were noted:
All January 6, 2017 results were reported on the DMR on January 3, 2017.
All January 18, 2017 results were reported on the DMR on January 19, 2017.
All February 24, 2017 results were reported on the DMR on February 21, 2017.
In order 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:
All Findings noted during the inspection were adequately addressed prior to the completion of this
report. The inspector would like to thank the staff for its assistance during the inspection and data
review process. No response is required.
Report prepared by: Tonja Springer Date: May 10, 2017
Report reviewed by: Anna Ostendorff Date: May 18, 2017

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