#5593_2017_0822_TLH_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5593
Laboratory Name:
Hawkins Wastewater Lab
Inspection Type:
Field Commercial Maintenance
Inspector Name(s):
Tom Halvosa, Todd Crawford
Inspection Date:
August 22, 2017
Date Forwarded for Initial
Review:
August 31, 2017
Initial Review by:
Jason Smith
Date Initial Review
Completed:
August 31, 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:
September 7, 2017
Date Forwarded to Admin.:
September 8, 2017
Date Mailed:
September 11, 2017
Special Mailing Instructions:
Copies to Robbie Bullock and Sarah Toppen (Washington Regional Office)

Water Resources
E N V t R 0 N P"M, E N 7 A, L CUAL.!?V
September 11, 2017
5593
Mr. Tony R. Hawkins
Hawkins Wastewater Lab
202 Hwy 41 W
Trenton, NC 28585
ROY COOPER
MICHEAL S. REGAN
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Hawkins:
Enclosed is a report for the inspection performed on August 22, 2017 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 findings were corrected and include an implementation
date for each corrective action.
We are concerned with the findings that were 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 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] ext. 251.
Sincerely,
Todd Crawford
Technical Assistance & Compliance Specialist
NC WW/GW Laboratory Certification Branch
Attachment
cc: Dana Satterwhite, Tom Halvosa, Master File # 5593
Robert Bullock, Sarah Toppen
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: [phone] ! PAX: 919-733-6241
Internet: http:l/dea.nc.gov/about/divisions/water-resources/water-resources-datalwater-sciences-home-pagellaboratorv-certification branch

• • X . • •
LABORATORY NAME: Hawkins Wastewater Lab
NPDES PERMIT #: NC0021342
WATER QUALITY PERMIT # : WQ0007283
ADDRESS: 609 Jones St.
Trenton, NC 28585
CERTIFICATE #: 5593
DATE OF INSPECTION: August 22, 2017
TYPE OF INSPECTION: Field Commercial Maintenance
AUDITOR(S): Tom Halvosa and Todd Crawford
LOCAL PERSON(S) CONTACTED: Tony R. Hawkins
I. 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.
Ill. GENERAL COMMENTS:
The inspection was requested by the Washington Regional Office of the NC Department of
Environmental Quality (NCDEQ) Division of Water Resources due to concerns with the Dissolved
Oxygen (DO) data reported for the Town of Trenton. In addition to NC WW/GW LC staff, Robbie
Bullock, Senior Specialist, and Sarah Toppen, Environmental Specialist, of NCDEQ Washington
Regional Office were also present.
The facilities at the Trenton WWTP (NC0021342) were in a rudimentary, dirty condition and the
operator said the facility had been flooded on several occasions. Housekeeping, in general, was
poor. Also, there was a lack of proper ventilation. Plans for the construction of a new facility are in
preliminary stages of development. The operator was forthcoming and seemed eager to adopt
necessary changes that were easy to make at the time. In the meantime, a best effort must be
made to perform analyses in a manner where possible sources of contamination or error will not
be introduced.
This laboratory also performs analyses for the Town of Pollocksville (WQ0007283). While this
report will address issues at the Town of Pollocksville, the facility was not visited during the
inspection.
All required Proficiency Testing (PT) samples have been analyzed for the 2017 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

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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.
Contracted analyses are performed by Environment 1, Inc. (Certification # 10) and Vann
Laboratories (Certification # 22).
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:
Facilities and Equipment
A. Finding: Facilities lacked a source of distilled or deionized water to rinse probes and
equipment used for testing.
Requirement: Each facility must have glassware, chemicals, supplies, equipment and a
source of distilled or deionized water that will meet the minimum criteria for the approved
methodologies. Ref: 15A NCAC 02H .0805 (g) (4).
Recommendation: At a minimum, it is recommended that the facility have a wash bottle
of distilled or deionized water for use at the facility at all times.
B. Finding: The Dissolved Oxygen meter currently in use was not made available for
inspection.
Requirement: Each facility must have glassware, chemicals, supplies, equipment and a
source of distilled or deionized water that will meet the minimum criteria for the approved
methodologies. Ref: 15A NCAC 021-1.0805 (g) (4).
Proficiency Testing
C. Finding: The preparation of the Proficiency Testing (PT) Samples is not documented.
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 Total
Residual Chlorine (TRC) PT would satisfy.the documentation requirement.
D. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: As specified in 15 NCAC 2H .0800, in order to meet the minimum
standards for Certification, laboratories must use acceptable analytical methods. The

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acceptable methods are those defined or referenced in the current State and federal
regulations for the environmental matrix being tested. All samples, (including PT
Samples) that are, or that may, be used for Certification purposes, must be analyzed
using approved methods only. All PT Samples are to be analyzed and the results
reported in a manner consistent with the routine analysis and reporting requirements of
Compliance Samples. Laboratories must document any exceptions. 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.
E. Finding: The laboratory is not analyzing PT Samples in the same manner as routine
Compliance Samples.
Requirement: As specified in 15 NCAC 2H .0800, in order to meet the minimum
standards for Certification, laboratories must use acceptable analytical methods. The
acceptable methods are those defined or referenced in the current State and federal
regulations for the environmental matrix being tested. All samples, (including PT
Samples) that are, or that may, be used for Certification purposes, must be analyzed
using approved methods only. All PT Samples are to be analyzed and the results
reported in a manner consistent with the routine analysis and reporting requirements of
Compliance Samples. Laboratories must document any exceptions. 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 analyst replicated PT samples at least three times and reported the
average, but does not replicate Compliance Samples. The analysis of PT Samples is
designed to evaluate the entire process used to routinely report Compliance Sample
results; therefore, PT Samples must be analyzed and the process documented in the
same manner as Compliance Samples.
Documentation
F. Finding: All original records for the Town of Trenton are not being maintained for five
years.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref:
15A NCAC 2H .0805 (g) (1).
Comment: The testing data results are sometimes initially written on "scrap paper" then
transported back to the laboratory and transferred to the benchsheet. This "scrap paper" is
then discarded.
Recommendation: It is recommended that if this system of documentation is maintained,
that the data be recorded on some type of bound notebook to conveniently keep pages
together and ensure the 5-year record retention requirement is met.
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: All chemicals, reagents, standards and consumables used by the
laboratory must have the following information documented: Date Received, Date

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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 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.
Requirement: Data pertinent to each analysis must be maintained for five years. Ref:
15A NCAC 2H .0805 (g) (1).
Comment: Traceability documentation for pH was missing the manufacturer of the
standard buffer solutions. Traceability documentation for TRC reagents (DPD) currently
in use was not accurate.
H. Finding: Error corrections are not 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. White -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.
Finding: The benchsheet for the Town of Trenton was lacking pertinent data: facility
name.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Sample site including facility name and location, ID, etc. Ref: NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, NC
WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen and NC WW/GW LC Approved
Procedure for the Analysis of Temperature.
J. Finding: The laboratory benchsheets for both the Town of Trenton and the Town of
Pollocksville were lacking pertinent data: Instrument Identification.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: Instrument Identification. 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 and NC WW/GW LC Approved
Procedure for the Analysis of pH.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
K. Finding: The benchsheet for the Town of Pollocksville was lacking pertinent data: meter
calibration time, true value of check standard, instrument identification, sample
collection time, analysis time, analyst's initials, units of measure.

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Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: meter calibration time, instrument identification, sample collection
time, analysis time, analyst's initials and units of measure. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: TRC results were being written on the Environment 1, Inc. chain of custody
form only.
Recommendation: It is advised that the laboratory have a benchsheet for the Town of
Pollocksville that combines all the analyses being done there (pH and Total Residual
Chlorine) on the same benchsheet or similar benchsheet.
L. Finding for Immediate Response: The laboratory is not verifying the instruments'
factory set curve every 12 months. Cited previously on June 13, 2012.
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. Please respond with the corrective actions taken to prevent
further recurrence of this Finding.
Comment: The Hach DR 5000 meter currently in use is on loan from the City of New
Bern WWTP. The analyst did not have any 5-point calibration curve verification
documentation for the meter and did not know if or when a 5-point calibration curve
verification was performed last. Due to this fact and the fact that the laboratory had been
previously cited for not having performed the required 5-point calibration curve
verification, a Notice of Finding for Immediate Response (NOFIR) was issued. A
response time of one week was negotiated with the analyst and agreed upon. The
laboratory performed an acceptable curve verification and submitted the documentation
to this office on August 24, 2017.
M. Finding: The Hach Pocket Colorimeter II meter currently in use at the Town of
Pollocksville had not had the calibration curve verification performed prior to being put
into initial use.
Requirement: Instruments are to be calibrated according to the manufacturer's
calibration procedure or a standard curve verification must be performed prior to
analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine.
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

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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.
N. Finding: The laboratory is not analyzing a check standard prior to analysis of samples
each day compliance monitoring is performed.
Requirement: Instruments are to be calibrated according to the manufacturer's
calibration procedure or a standard curve verification must be performed prior to
analysis of samples each day compliance monitoring is performed. Ref: NC WW/GW
LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The laboratory has recently purchased Gel® Standards and is in the process
of incorporating them into their analysis at both Trenton and Pollocksville.
O. Finding: Manufacturer expiration dates for the DPD color reagents are exceeded.
Requirement: Adherence to manufacturer expiration dates is required. Chemicals,
reagents, standards, 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: Quality Assurance Policies for Field
Laboratories.
Dissolved Oxygen — Standard Methods, 4500 O G-2001 (Aqueous)
Comment: The analyst stated that immediately following the Regional Office's inspection on July
25, 2017, during which time a large air bubble was observed underneath the DO probe's
membrane, he discontinued use of the Town of Trenton's YSI 55 meter and began using a meter
borrowed from the City of New Bern WWTP. The analyst has requested that the Town of Trenton
purchase a new DO meter.
P. Finding: The laboratory benchsheet for the Town of Trenton was lacking pertinent data:
meter calibration time.
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: meter calibration time. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Dissolved Oxygen.
Q. Finding: The laboratory is not performing a post -analysis calibration verification when
analyses are performed away from the certified laboratory's primary location.
Requirement: When performing analyses away from the certified laboratory's primary
location, a post -analysis calibration verification must be analyzed at the end of the run. It
is recommended that a mid -day calibration verification be performed when samples are
analyzed over an extended period of time. The calculated 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. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen.

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Comment: An alternative to performing the post -analysis check would be to perform the
initial calibration at each site of analysis.
Recommendation: It is recommended that if DO cannot be measured in the stream,
that the sample not be transferred from the sampling container to another before DO is
measured. This technique, which was observed by Regional Office staff, can aerate the
sample and artificially elevate the DO concentration.
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Comments: When the analyst was asked to demonstrate pH analysis, the Hach SensION pH
meter failed to power up. The analyst had to leave and obtain new batteries in order to power
up the meter. The battery strength indicator on the meter still indicated low battery level even
after new batteries were installed; however, the pH meter appeared to calibrate properly.
Recommendation: It is recommended that the method reference on the benchsheet include
the approval year.
R. Finding: The pH probe is not being stored in the recommended storage solution.
Requirement: The pH probe must be stored in the solution recommended by the probe
manufacturer between analyses. A solution with a conductivity greater than 4000
phos/cm is recommended. Tap water is a better substitute than distilled water, but pH 4
buffer is best for the single glass electrode and saturated KCI is preferred for the
calomel and Ag/AgCI reference electrode. Saturated KCI is preferred for a combination
electrode. Keep electrodes wet by returning them to the storage solution whenever the
pH meter is not in use. Ref: Standard Methods, 4500 H+ B-2000. (4) (a).
S. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Cited previously on June 13, 2012.
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-2000. (6).
Comment: The analyst stated values were correctly reported prior to the conversion
from Discharge Monitoring Reports (DMRs) to electronic Discharge Monitoring Reports
(eDMRs). This was verified by the auditor during the Paper Trail investigation.
T. Finding: The pH probe electrode is not being rinsed between readings.
Requirement: Before use, remove electrodes from storage solution, rinse, blot dry with
a soft tissue, place in initial buffer solution, and set the isopotential point (4500-H+
B.2a). Select a second buffer within 2 pH units of sample pH and bring sample and
buffer to same temperature, which may be the room temperature; a fixed temperature,
such as 25°C; or the temperature of a fresh sample. Remove electrodes from first
buffer, rinse thoroughly with distilled water, blot dry, and immerse in second buffer.
Record temperature of measurement and adjust temperature dial on meter so meter
indicates pH value of buffer at test temperature (this is a slope adjustment). Use the pH
value listed in the tables for the buffer used at the test temperature. Remove electrodes

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from second buffer, rinse thoroughly with distilled water and dry electrodes as indicated
above. Immerse in a third buffer below pH 10, 3 pH units different from the second; the
reading should be within 0.1 unit for the pH of the third buffer. Ref: Standard Methods,
4500 H+ B-2000. (4) (a).
Requirement: Steps must be taken to eliminate cross contamination between
measurements (e.g., rinsing and blotting the electrode dry, dipping the electrode in
stream multiple times, etc.). Ref: NC WW/GW LC Approved Procedure for the Analysis
of pH.
Temperature — Standard Methods, 2550 B-2000 (Aqueous)
U. Finding: The thermometer verification was not performed in the approximate range of
the sample temperatures measured.
Requirement: All thermometers and temperature measuring devices used for
compliance monitoring must be checked every 12 months against a NIST traceable
temperature measuring device and the process documented. To check a thermometer
or temperature sensor of a meter, read the temperature of the thermometer/meter
against a NIST traceable temperature measuring device and record the two
temperatures. The verification must be performed in the approximate range of the
sample temperatures measured. The thermometer/meter readings must be less than or
equal to 0.5°C from the NIST traceable temperature measuring device reading. If it is
not, the thermometer/meter may not be used for compliance monitoring. The calibration
verification documentation must include the serial number of the thermometer/meter
being checked and the NIST traceable temperature measuring device that was used in
the comparison. Document the verification data and keep on file. (NOTE: Other Certified
laboratories may provide assistance in meeting this requirement). Ref: NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
Comment: The temperature verification documentation indicated two temperature
ranges; 0-15 °C and 15-30 'C. The observed temperature documented for the 0-15 °C
was 10.5 °C and mistakenly documented in the 15-30 °C column as well. Verification at
multiple Temperatures is not required.
Comment: The verification was performed at 10.5 °C; however, the sample temperature
range observed on the eDMR over the last two years was between 180C and 24 'C.
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) and electronic Discharge
Monitoring Reports (eDMRs) submitted to the North Carolina Division of Water Resources. Data
was reviewed for the Town of Trenton (NPDES permit # NC0021342) for February 2013, August
2015 and June 2017. No transcription errors were observed. A Paper Trail was not performed for
the Town of Pollocksville.
V. CONCLUSIONS:
We are concerned with the Findings that were cited previously and not corrected.
Laboratory Decertification Ref: 15A NCAC 2H .0807 (a) (1), (13) and (14):

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A laboratory may be decertified for any or all parameters for up to one year for any or all of the
following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control
program as set forth in the application, and these Rules; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this Section or of a
Laboratory certification.
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 Date: August 31, 2017
Report reviewed by: Jason Smith Date: September 1, 2017

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