#5524_2016_0317_BS_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. ##:
5524
Laboratory Name:
Cooleemee WWTP
Inspection Type:
Field Maintenance
Inspector Name(s):
Beth Swanson, Jason Smith
Inspection Date:
March 17, 2016
Date Report Completed:
March 28, 2016
Date Forwarded to Reviewer:
March 28, 2016
Reviewed by:
Nick Jones
Date Review Completed:
March 29, 2016
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Unit Supervisor/Chemist III: Gary Francies
Date Received: March 31, 2016
Date Forwarded to Admin: April 6, 2016
Date Mailed: April 7, 2016

Water Resources
ENVIRONMf N I AL QUA L.1TY
April 6, 2016
5524
Mr.Tim Smith
Cooleemee WWTP
PO Box 768
Cooleemee NC, 27014
PAT MCCRORY
DONALD R. VAN DER VAART
S. JAY ZIMMERMAN
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Smith:
Enclosed is a report for the inspection performed on March 17, 2016 by Beth Swanson and Jason
Smith. 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.
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,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Attachment
cc: Beth Swanson
Master File
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; 919-733-39081 FAX, 919-733-6241
Internet htfp fideg nc govfabouttdivisionsfwater resourcesiwater-resources-data/water-sciences-home page/laboratoey-certification-branch

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
Tk1t_ZT*_y9TF1qK6H
On -Site Inspection Report
Cooleemee WWTP
NC0024872
PO Box 768
Cooleemee NC, 27014
5524
March 17, 2016
Field Maintenance
Beth Swanson and Jason Smith
Tim Smith
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:
Dissolved Oxygen was removed from the facility's Certified Parameter Listing following the inspection
It was not needed since the parameter is no longer included in the facility's permit.
Proficiency Testing (PT) samples for the 2016 proficiency testing calendar year have not yet been
analyzed. The laboratory is reminded that these results must be submitted to this office directly from
the vendor by September 30, 2016.
Contracted analyses are performed by Statesville Analytical, Inc. (Certification #440).
Current Quality Assurance Policies for Field Laboratories and Approved Procedures for the analysis of
the facility's currently certified parameters were provided at the time of the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. 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. 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:
Quality Assurance Policies for Field Laboratories.
Comments: Instances of over -writing errors and corrections with no date documented were
found.

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#5524 Cooleemee WWTP
B. Finding: The laboratory needs to increase the documentation of purchased materials.
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. 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.
Comment: There is currently no documentation linking traceability of consumable materials.
Proficiency Testing
C. Finding: The preparation of Proficiency Testing (PT) samples is not documented.
Requirement: 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. Ref: Proficiency Testing
Requirements, February 20, 2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the Total
Residual Chlorine (TRC) PT would satisfy the documentation requirement. The pH PT
sample does not require preparation documentation since it is analyzed as a whole volume
sample.
D. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner
as compliance samples.
Requirement: 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 and
any other samples analyzed according to the requirements of 15A NCAC 2H .0800. Ref:
Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Comment: The laboratory's common practice was to analyze a known standard along with
the PT sample as additional quality control. Since this is not performed with all environmental
samples, it is considered additional quality control. However, known samples are
recommended when analyzing remedial PT samples as part of the troubleshooting and
corrective action process.
E. Finding: The laboratory is not documenting Proficiency Testing (PT) sample analyses in the
same manner as environmental samples.
Requirement: All PT sample analyses must be recorded in the daily analysis records as for
any environmental sample. This serves as the permanent laboratory record. Ref: Proficiency
Testing Requirements, February 20, 2012, Revision 1.2.
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 environmental samples (i.e., on the daily
benchsheet after acceptable calibration).

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#5524 Cooleemee WWTP
pH — Standard Methods, 4500 H+ B-2000 (Aqueous)
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
Temperature — Standard Methods, 2550 B-2000
F. Finding: The laboratory benchsheet is 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
pH, NC WW/GW LC Approved Procedure for the Analysis of Temperature.
pH — Standard Methods, 4500 H+ 5-2000 (Aqueous)
G. Finding: The obtained value of the check standard buffer is not documented.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Value obtained for the check standard buffer (verification of ± 0.1 S.U.). Ref: NC
WW/GW LC Approved Procedure for the Analysis of pH.
Comment: The analyst was using the 7 S.U. pH buffer for the check, but was recording 7.0",
not the obtained reading.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
H. Finding: The meter calibration time is not documented.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Meter calibration and meter calibration time(s). Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine.
Comment: The meter calibration time is considered the time when the daily check standard is
analyzed.
1. Finding: A reagent blank is not analyzed each day prepared standards are analyzed.
Requirement: Each day that prepared standards are analyzed, a reagent blank must be
analyzed. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine.
Comment: A reagent blank (sometimes also referred to as a method blank) is only required
when laboratory water is used to make quality control and/or calibration standards. If you are
using a sealed standard (e.g., gel) for your daily check standard, a reagent blank would only be
analyzed when preparing the 5 annual calibration curve verification standards and when
preparing and analyzing the Total Residual Chlorine (TRC) PT standard. A reagent blank is
made from the same laboratory water source used to make quality control and/or calibration
standards with DPD. The concentration of reagent blanks must not exceed 50% of the
reporting limit (i.e., the lowest calibration or calibration verification standard concentration),
unless otherwise specified by the reference method or corrective action must be taken.
J. Finding: The annual 5-standard calibration curve verification did not pass all of the individual
standard recovery criteria.

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#5524 Cooleemee WWTP
Requirement: Analyze a calibration blank to zero the instrument and then analyze a series of
five standards (do not use gel or sealed liquid standards for this purpose). The curve
verification must check 5 concentrations (not counting the blank) that bracket the range of the
sample concentrations to be analyzed. This type of standard 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 ug/L and must not
vary by more than 25% of the known value for standard concentrations less than 50 Pg/L. The
overall correlation coefficient of the curve must be >_0.995. If the stored program readings vary
by more than the above acceptance criteria, the stored calibration program must not be used
for quantitation 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 laboratory's curve verification was performed by Statesville Analytical, Inc.
(Certification #440) on September 21, 2015. The 50 pg/L standard recovery was 86 % (i.e., not
within ±10%), so the curve verification is not acceptable.
K. Finding: Values less than the established reporting limit are being reported on the Discharge
Monitoring Report (DMR).
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.
Comment: The standard concentration range for the calibration verification performed on
September 21, 2015 is 15 — 400 pg/L. Any values less than 15 pg/L must be reported as <15
pg/L.
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 Carolina
Division of Water Resources. Data were reviewed for NPDES permit #NC0024872 for August,
October, and December, 2015. No transcription errors were detected.
Fecal coliform results of <1 cfu/100mL are reported as 1 cfu/100mL on the DMR. A "less than" value
would be considered 1 cfu/100 mL for calculation of the geometric mean only. The Directions for
Completing Monthly Discharge Monitoring Reports document is included with this report.. [See Section
V. (3) (b)]
V. CONCLUSIONS:
Correcting the above -cited Findings will help this lab 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 date for each corrective action.
Report prepared by: Beth Swanson Date: March 28, 2016
Report reviewed by: Nick Jones Date: March 29, 2016

DIRECTIONS FOR COMPLETING MONTHLY DISCHARGE MONITORING REPORTS
(Forms MR-1, MR-1.1, MR-2 & MR-3)
I: FACILITY INFORMATION
1. NPDES Permit No. Operator In Responsible Charge
2. Discharge No. Grade
3. Facility Name Certified Laboratory
4. Class Person(s) Collecting Samples
5. County Signature Of Operator In Responsible Charge
II: DATA REPORTING
1. Operator Arrival Time Units of Measurement
2. Operator Time On Site Additional Parameters
3. ORC on Site? Average, Maximum, Minimum
4. Data Sample Type
5. Flow Monthly Limit
6. Parameter Codes
III: FACILITY STATUS INFORMATION
1. Status Information
2. Signature of Permittee
IV: STREAM MONITORING INFORMATION
1. Stream
2. Location
V: GENERAL
1. Submitting Reports Calculations
2. Appearance Enforcement
3. Order of Report Forms Number of Reports
4. Multiple Submittals Permits for Other Program Areas
5. Toxicity Reporting Corrected or Amended Reports
6. Contacts
I. FACILITY INFORMATION
1. NPDES Permit No. - Number issued by the Division of Water Resources consisting of
the letters "NC" followed by a seven digit number. Information from non -discharge
facilities should not be reported on the MR series of forms.
2. Discharge No. - Three -digit number which corresponds to the effluent pipe for which
the data are being reported (i.e., 001, 002, 003, etc.). Numbers are found within the
NPDES permit.
3. Facility Name - Name of the facility as it appears on the NPDES permit.
4. Class - The class of the facility as designated by the Water Pollution Control System
Operators Certification Commission. The rating will be either 0, I, II, III or IV. You
should enter the water quality classification of the receiving stream in this space.

5. County - County in which the discharge outfall is located.
6. Operator In Responsible Charge -The printed name of the certified WWTP operator
designated as operator in responsible charge. Unrated (class 0) facilities do not require an
operator in responsible charge.
7. Grade - Certificate grade of the operator in responsible charge as awarded by the
Water Pollution Control System Operators Certification Commission.
8. Certified Laboratory - Name of the certified laboratory (-ies) performing analyses (if
applicable).
9. Person(s) Collecting Samples - Printed name of the individual who collected the
sample for which the data was reported. In the case of several individuals, please specify
as a group name, such as "operators" or "staff," etc.
10. Signature Of Operator In Responsible Charge - Dated signature of the operator in
responsible charge. Each month's report must include an original signature in ink. Copies
are not acceptable.
II. DATA REPORTING
1. Operator Arrival Time -Record the time of arrival of a certified operator using a
2400 clock value. If the facility is staffed by operators 24 hours a day, record the arrival
time of the 1 st shift operator.
2. Operator Time On Site - Record the number of hours spent by certified operators at
the facility. If the facility is staffed on all three shifts, enter "24." If more than one
operator is on duty at the same time, this value is not the sum of all hours worked by the
operators, but the total number of hours the facility was staffed.
3. ORC On Site? - Record yes (Y) or no (N) as to whether the designated ORC visited
the site on that date. If the designated backup operator served as ORC on a particular day,
record "B" in this column for that date. It is also appropriate to record "H" in the cell if
the date is a legal holiday.
4. Data - Enter the analytical results for each sample under the appropriate parameter
code in the row that corresponds to the day upon which the sample was taken. Please note
that Flow should always be reported as a decimal number (do not use scientific notation)
in units of millions of gallons per day (MGD), unless the permit states otherwise.
5. Parameter Codes - Codes for the more commonly monitored parameters can be found
on the back of form MR-1 or MR- 1.1. A complete list of parameter codes can be found
on the NPDES website.
6. Units of Measurement - All data values must be accompanied by corresponding units
of measurement, noted at the top of the data column for the particular parameter. If your
permit contains a numeric limit for any parameter, then the reporting units must be the
same units of measurement of that limit. If your reporting units are other than those on
Revised 812014

the pre-printed form, the printed units should be marked out and the reporting units be
clearly designated at the top of the column.
7. Additional Parameters - Enter the appropriate parameter code, name of the parameter
and units of measurement in the space provided.
8. Average, Maximum, Minimum - Enter the average, maximum and minimum values
for the results recorded in the data column. Please note no average is to be calculated for
pH. Any average for Fecal Coliform is to be calculated as a geometric mean. If you are
uncertain about how to calculate the geometric mean, please contact your local DWR
Regional Office or a member of the NPDES Compliance/Enforcement Unit staff at (919)
807-6300. If only one value is reported for a parameter during the reporting month, that
value should be reported as the average, maximum and minimum.
9. Sample Type - Enter the sample description in each column for which data is being
reported. Enter the letter "C" for composite or the letter "G" for grab.
10. Monthly Limit - Enter the monthly limit for each parameter as found in the current
NPDES permit, Special Order by Consent or Judicial Order by Consent.
III. FACILITY STATUS INFORMATION
1. Facility Status - Mark the appropriate box to show whether facility was compliant or
noncompliant with regard to permit, SOC or JOC requirements. If noncompliant, use the
comment section to explain in detail the course of action taken or to be taken to achieve
compliance.
2. Signature of Permittee - Record the name of the permittee or his or her authorized
agent (printed or typed), the dated signature of that person and a mailing address and
phone number at which he or she may be reached during working hours. If someone other
than the permittee is to be the signatory, the requirement noted by the double asterisk
"M*" must be met. Also record the expiration date of the current permit in this section.
While this is not on the form, you may also wish to provide an e-mail address in this
space that can provide the Division with another avenue of communication.
IV. STREAM MONITORING INFORMATION
1. Stream - Name of the stream from which the upstream or downstream monitoring
samples are taken.
2. Location - Location of the site on the stream from which the sample was taken. This
may be recorded as a distance (e.g. "100 feet upstream of outfall") or a specific location
(e.g. "S.R. 1111 ").
V. GENERAL
1. Submitting Reports - An original and one copy of each month's monitoring report is
required to be submitted to the Division of Water Resources's Central Files office
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(address listed on form MR-1) and must be received by the Division within thirty (30)
days after the end of the month for which the report is made.
2. Appearance - Forms must be completed in ink. Please make all entries on forms
legible. All information other than signatures must be printed or typed. If you fill out
forms by hand, please make sure the originals are completed in ink and that all entries are
legible. Copies of the original report must also be readable and must include a
reproduction of the backside of the effluent reporting form containing the permittee's
certification. If you utilize a computer -generated report, you must also ensure that the
report is legible and that proper copies are made. DWR will notify if you are the user of
a form that is deemed deficient and will advise you of what modifications need to be
made.
3. Calculations
(a) Averages. All averages are to be calculated as the arithmetic mean of the
recorded values with the exception of that of Fecal Coliform, which is to be
calculated as a geometric mean. If you are uncertain about how to calculate the
geometric mean, please contact your local DWR Regional Office or a member of
the NPDES Compliance/Enforcement Unit staff at [phone].
(b) Use of "less than "values. For calculation purposes only, recorded values of
less than a detectable limit (< #.##) may be considered to equal zero (0) for all
parameters except Fecal Coliform, for which values of "less than" may be
considered to be equal to one (1). Values of results which are less than a
detectable limit should be reported in the daily cells using the "less than" symbol
(<) and the detectable limit used during the testing (or the value with appropriate
unit conversion). Please note there is never a case when an average would need to
be recorded along with a "less than" symbol.
(c) Use of "greater than "values. Such values are only expected (and then only
infrequently) in the reporting of Fecal Coliform and BOD. If a "greater than"
value is reported, the numeric portion of the value should be sufficiently high so
as to make the facility aware of the extent of any problems with treatment
efficiency. Upon receipt of "greater than" testing results, a facility should consult
its laboratory to see if changes in testing procedure need to be made in order to
get discreet values from the analysis. For calculation purposes only, the numeric
portion of the value must be used to calculate either an arithmetic or geometric
mean.
4. Enforcement - Failure to comply with any of the requirements listed above may result
in the facility being issued a Notice of Violation or being subject to other appropriate
enforcement action.
5. Order of Report Forms - DMR submittals typically include the results of monitoring
of the facility's effluent, its influent and its receiving stream. It is requested that for any
DMR, the report be bound with the Effluent page(s) (DWR form MR-1 or MR- 1.1) on
top, followed by the Influent page (form MR-2, if influent monitoring is required) and
finally the Upstream/Downstream page (form MR-3).
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6. Number of Reports - You are required to submit the original and one copy of the
report to DWR. Each copy should be a discreet report for the month, put together in the
order described above.
7. Multiple Submittals - School systems and contract operations, please take note of this
request. If you submit reports for multiple permits within one mailing, please bind
together the submittals (original and one copy) for the various facilities. Please do not
segregate the reports into any other type of organization (e.g., binding together all
effluent or stream monitoring pages). To do so will cause reports to be taken apart and
placed together properly, which slows processing and introduces opportunity for mistakes
to be made. If you send many DMRs in one envelope, it is advisable that you send a
summary sheet along with the DMRs that lists what reports are contained in the package.
8. Permits for Other Program Areas - Please note that this discussion pertains to
submittal of DMRs required of NPDES permittees (point source discharge pipes to
streams). You may have permits for activities in other program areas such as DWR's non
discharge program (wastewater spray irrigation or land application of residuals) or the
Division of Environmental Health's public water supply program (drinking water). Please
consult those permits for instructions for their submittal. It is not advisable to submit any
other reports along with your DMR submittals.
9. Toxicity Reporting - Some permittees will have monitoring requirements for Toxicity
within their permits. Please be aware that this parameter has a dual reporting requirement.
Results of toxicity testing should be reported on DMR forms, but the toxicity testing
results forms must be submitted to the Aquatic Toxicity Unit at the address listed below.
Aquatic Toxicology Unit
DWR Environmental Sciences Branch
1621 Mail Service Center Raleigh, NC 27699-1621
10. Corrected or Amended Reports - In the event that you omit or erroneously report
data on a DMR, the information should be updated with the submittal of an amended
report. To best handle the amended data, the following procedure is recommended:
l . Regenerate or make a copy from your files of the DMR previously submitted to
DWR.
2. Make changes to the individual data points on the form, including updated
summary information.
3. Initial and highlight changes to the original submittal.
4. At the top of the reporting page, write very conspicuously: "Amended Report" or
"Corrected Report."
5. Provide a short cover page describing the changes to the DMR or note changes in
the comment area on the back of the MR-1 form.
Use of this procedure will be a great help to DWR's data entry staff. Without
specifically identifying changes on the DMR, each data point must be evaluated
between the original and amended reports to ensure the values in our database are
correct. Calling attention to just those values that are changed both speeds up our
processes and decreases the possibility for errors to be made.
Revised 812014

11. Contacts - DWR deals with a tremendous number of permitted entities that may be
experiencing their own changes involving administration and personnel. In dealing with
NPDES permit matters, DWR must deal with only one representative of the permitted
facility (someone with authority to see that changes are made at the facility if they are
necessary) in order to be effective. You are encouraged to keep DWR informed of any
updates as to the person responsible for the permit, addresses or phone numbers in order
to facilitate the best possible communication between our two organizations. This can be
done by sending an e-mail to our Unit or by using the back of the MR-1 form under the
permittee certification section. Regulations regarding who may be deemed responsible
for a permit and who may sign as the "permittee" on the DMR can be found
(respectively) in the North Carolina Administrative Code in sections 15A NCAC 2H
.106(e) and 15A NCAC 2B .0506 (b)(2).
Revised 812014