#237_08_2015_FINAL

C4JY,)
MCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
September 17, 2015
237
Mr. Tom Williams
City of Brevard WWTP
95 West Main Street
Brevard, NC 28712
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Williams:
,Enclosed is a report for the inspection performed on August 6, 2015 by Jason Smith. I apologize
for the delay in getting this report to you. 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. 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 us at (828)
296-4677.
Attachment
cc: Jason Smith
Master file
Sincerely,
COY
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
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]E FAX: [phone]
Internet. www.dWglab.org
An Equal Opportunity 1 Affin native Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
237
Laboratory Name:
City of Brevard WWTP
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Jason Smith
Inspection Date:
August 6, 2015
Date Report Completed:
August 25, 2015
Date Forwarded to Reviewer:
August 25, 2015
Reviewed by:
Nick Jones
Date Review Completed:
September 4, 2015
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:
9/14/2015
Date Forwarded to Linda:
II
_9jt712U1_5_ q 8I5 IC_
Date Mailed:

On -Site Inspection Report
LABORATORY NAME: City of Brevard WWTP
NPDES PERMIT #: NCO060534 and NCO044784
ADDRESS: 95 West Main Street
Brevard, NC 28712
CERTIFICATE #: 237
DATE OF INSPECTION: August 6, 2015
TYPE OF INSPECTION: Municipal Maintenance
AUDITOR(S): Jason Smith
LOCAL PERSON(S) CONTACTED: Tom Williams and Brett Taylor
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.
II. GENERAL COMMENTS:
The laboratory requested an inspection due to concerns about the Suspended Residue results. No
procedural discrepancies or inaccuracies were found that indicated any significant errors in results. The
Requirements associated with the Findings related to Suspended Residue are required for legal
defensibility. Additionally, Proficiency Testing (PT) results submitted were very accurate for Suspended
Residue; the laboratory reported a result of 32.4 mg/L for a PT sample that had a true value of 32.6 mg/L.
PT samples have been analyzed for all certified parameters for the 2015 proficiency testing calendar year
and the graded results were 100% acceptable.
The facility has all the equipment necessary to perform the analyses. In addition to their own samples, the
laboratory also analyzes samples for Suspended Residue for the City of Brevard WTP. Contracted
analyses are performed by Pace Analytical Services, Inc. Asheville (Certification #40).
The laboratory is reminded that any time changes are made to laboratory operations; the laboratory
must update the Quality Assurance (QA)/Standard Operating Procedures (SOP) document(s). Any
changes made in response to the Findings, Recommendations or Comments listed in this report must
be incorporated to insure the method is being performed as stated, references to methods are
accurate, and the QA and/or SOP document(s) is in agreement with approved practice and regulatory
requirements. In some instances, the laboratory may need to create a SOP to document how new
functions or policy will be implemented.
Current Quality Assurance Policies for Field Laboratories and Approved Procedures for the analysis of
the facility's currently certified parameters were provided by email after the inspection.
The requirements associated with Findings C, D, G, H, L, S, V, W, X, Y, AA, BB, DD, and EE have
been implemented by our program since the last inspection.

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III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
Quality Control
Comment: The balance weights were purchased July, 2010 and were past due to be verified, replaced or
recertified. NC WW/GW LC Policy states: ASTM Class 1 and 2 weights must be verified at least every
5 years. ASTM Class 1 weights (20 g to 25 kg) and ASTM Class 2 weights (10 g to 1 mg) are
equivalent to the NBS Class S weights specified in 15A NCAC 2H .0805 (a) (7) (K). Notification of
acceptable corrective action (i.e., a new set of weights were ordered September 4, 2015 and will be put
into use upon receipt) was received by email on September 11, 2015. No further response is
necessary for this Finding.
A. Finding: Laboratory thermometers have not been checked annually (every 12 months).
Requirement: All thermometers must meet National Institute of Standards and Technology
(NIST) specifications for accuracy or be checked, at a minimum annually, against a NIST
traceable thermometer and proper corrections made. Ref: 15A NCAC 2H .0805 (a) (7) (0).
Comment: Thermometers were last checked July 21, 2014.
B. Finding: Thermal and/or chemical preservation of effluent BOD, Fecal Coliform, Ammonia, and
Suspended Residue samples is not always performed within 15 minutes of sample collection.
Requirement: Except where noted in this Table II and the method for the parameter, preserve
each grab sample within 15 minutes of collection. Add the preservative to the sample container
prior to sample collection when the preservative will not compromise the integrity of a grab
sample, a composite sample, or aliquot split from a composite sample within 15 minutes of
collection. Ref: Code of Federal Regulations, Title 40, Part 136; Federal Register Vol. 77, No. 97,
May 18, 2012; Table II, Footnote 2.
Documentation
Comment: The meter calibration time was not documented on the benchsheets for pH, TRC, and
Dissolved Oxygen (DO). The NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine, NC WW/GW LC Approved Procedure for the Analysis of pH, and NC WW/GW LC Approved
Procedure for the Analysis of Dissolved Oxygen documents state: The following must be documented in
indelible ink whenever sample analysis is performed: Meter calibration and meter calibration time(s). This
requirement is a new policy that has been implemented by our program since the last inspection.
Notification of acceptable corrective action (i.e., a statement saying meter calibration times for all three
parameters are being documented, effective immediately) was received by email on September 11,
2015. No further response is necessary for this Finding.
Comment: Instrument identification was not documented on the benchsheets for Temperature, pH, DO,
and TRC. The 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 documents state: The following must be documented in indelible ink
whenever sample analysis is performed: Instrument Identification. The NC WW/GW LC Approved
Procedure for the Analysis of Temperature states: The following must be documented in indelible ink
whenever sample analysis is performed: Thermometer/instrument identification. This requirement is a
new policy that has been implemented by our program since the last inspection. Notification of
acceptable corrective action (i.e., a statement saying the benchsheets have been edited to reflect the
serial number of each instrument and immediately implemented) was received by email on September
11, 2015. No further response is necessary for this Finding.

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#237 City of Brevard VWVTP
Comment: The name of the facility is not on the benchsheets for pH and (TRC). The NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine and NC WW/GW LC Approved
Procedure for the Analysis of pH documents state: The following must be documented in indelible ink
whenever sample analysis is performed: Sample site including facility name and location, ID, etc.
Notification of acceptable corrective action (i.e., a statement saying the benchsheets have been edited
to include the facility name in the header and immediately implemented) was received by email on
September 11, 2015. No further response is necessary for this Finding.
Comment: The units of measure are not consistently documented on the benchsheets for DO and
Temperature. The North Carolina Administrative Code, 15A NCAC 2H .0805 (a) (7) (H) states: All
laboratories must use printed laboratory bench worksheets that include a space to enter the signature or
initials of the analyst, date of analyses, sample identification, volume of sample analyzed, value from the
measurement system, factor and final value to be reported and each item must be recorded each time
samples are analyzed. Notification of acceptable corrective action (i.e., a statement saying units of
measure were documented where missing, and the benchsheet has been updated to indicate units of
measure rather than hand writing them. The updated benchsheet was immediately implemented) was
received by email on September 11, 2015. No further response is necessary for this Finding.
C. Finding: Error corrections are not dated.
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: NC WW/GW LC Policy.
D. Finding: The laboratory needs to increase the 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 (where specified). 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 primary standards, chemicals, reagents, and materials
used for a period of five years. Consumable materials such as pH buffers, lots of pre -made
standards and/or media, solids and bacteria filters, etc. are included in this requirement. Ref:
NC WW/GW LC Policy.
Comment: The filters were not included on the reagent and materials receipt log and the vendors
were not consistently documented.
Comment: Preparation of Suspended Residue standard is not consistently documented on the
reagent preparation log. Additionally, the reagent preparation logs for other parameters, such as
BOD, do not clearly show what is being prepared each day.
E. Finding: The influent composite sample collection time for the Brevard WWTP is not
documented.

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#237 City of Brevard WWTP
Requirement: A record of date collected, time collected, sample collector, and use of proper
preservatives must be maintained. Each sample must clearly indicate the State of North Carolina
collection site on all record transcriptions. Ref: 15A NCAC 2H .0805 (a) (7) (M).
Comment: Composite influent samples are collected and arrive in the lab within a couple of
minutes. Arrival time at lab is documented, but collection time is not. Collection time must be
documented to demonstrate that holding times are being met.
F. Finding: The analysts are not initialing the Ammonia, BOD and Suspended Residue
benchsheets.
Requirement: All laboratories must use printed laboratory bench worksheets that include a space
to enter the signature or initials of the analyst, date of analyses, sample identification, volume of
sample analyzed, value from the measurement system, factor and final value to be reported and
each item must be recorded each time samples are analyzed. Ref: 15A NCAC 2H .0805 (a) (7)
(H).
Comment: The BOD and Suspended Residue benchsheets have the analyst's initials
permanently printed on them but the analyst does not physically initial them.
Proficiency Testing
G. 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 PT would satisfy
the documentation requirement.
H. Finding: The laboratory does not have a documented plan for proficiency testing procedures.
Requirement: Each laboratory shall develop and maintain a document outlining the analytical
quality control practices used for the parameters included in their certification. Supporting records
shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A
NCAC 2H .0805 (a) (7).
Requirement: Laboratories must have a documented plan (this is usually detailed in the
laboratory's Quality Assurance Manual) of how they intend to cover the applicable program
requirements for proficiency testing per their scope of accreditation. This plan shall cover any
commercially available proficiency testing and any inter -laboratory organized studies, as
applicable. The laboratory must also be able to explain when proficiency testing is not possible for
certain parameters and provide a description of what the laboratory is doing in lieu of proficiency
testing. This shall be detailed in the plan. The plan must also address the laboratory's process for
submission of proficiency testing results and related corrective action responses. Laboratory
Standard Operating Procedures (SOPs) must address how low level samples will be analyzed,
including concentration of the sample or adjustment of the normality of a titrant. These instructions
shall be followed when the concentration of a PT sample falls below the range of their routine
analytical method. Instructions shall also be included in the laboratory's SOP for how high level
samples will be analyzed, including preparation of multiple dilutions of the sample. These

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#237 City of Brevard VWVfP
instructions will be followed when the concentration of a PT falls above the range of their routine
analytical method. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
Ammonia, Nitrogen — Standard Methods, 4500 NH3 D-1997
Finding: Preservation verification (pH <2 S.U.) is not performed upon sample receipt.
Requirement: Each sample container must be checked upon receipt in the laboratory for the
effectiveness of any required pH adjustment and the results documented. Ref: NC WW/GW LC
Policy.
J. Finding: Ammonia Nitrogen samples are not checked for Total Residual Chlorine (TRC).
Requirement: Residual chlorine reacts with ammonia; remove by sample pretreatment. If a
sample is likely to contain residual chlorine, immediately upon collection, treat with dechlorinating
agent as in 4500-NH3.B.3d. Ref: Standard Methods, 4500 NH3 A-1997. (2).
Requirement: Dechlorinating agents used at the time of sampling must be documented to have
been effective upon receipt in the laboratory. A variety of field testing kits are considered to be
adequate for most chlorine interference checks and a maximum detection limit of 0.5 mg/L is
allowed. Ref: NC WW/GW LC Policy.
Comment: The laboratory has assumed that there is no TRC in the sample based on the grab
TRC result. However, this is not an accurate assumption since the Ammonia Nitrogen samples
are composite samples. Therefore, the composite Ammonia Nitrogen samples must be checked
for TRC.
K. Finding: pH adjustment to >11 S.U. is not being documented. This is considered pertinent
information.
Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly
manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a)
(7) (A)•
Comment: The benchsheet has a column to document that the pH is adjusted to >11 S.U., but
this column is not being filled out.
L. Finding: The laboratory is not analyzing a Laboratory Fortified Matrix Duplicate (LFMD).
Requirement: Include at least one LFM/LFMD daily or with each batch of 20 or fewer samples.
Ref: SM 4020 B-2009, Rev. 2011, Table 4020:1 and (2) (g).
Comment: LFM and LFMD are also known a Matrix Spike (MS) and Matrix Spike Duplicate
(MSD).
Comment: Analysis of the LFMD (or MSD), at the required frequency, is acceptable to satisfy
the sample duplicate requirement listed in North Carolina Administrative Code, 15A NCAC 2H
.0805 (a) (7) (C).

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#237 City of Brevard WWTP
M. Finding: Quality Control acceptance criteria are not specified in the SOP.
Requirement: Each laboratory shall develop and maintain a document outlining the analytical
quality control practices used for the parameters included in their certification. Supporting records
shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A
NCAC 2H .0805 (a) (7).
Requirement: Each method typically includes acceptance -criteria guidance for precision and bias
of test results. If not, the laboratory should determine its own criteria via control -charting
techniques. Ref: SM 4020 A-2009. Additional revisions, 2011.
Comment: Additional guidance can be found in Section 4020 B of the 22nd Edition of Standard
Methods.
N. Finding: The SOP does not describe in detail how the LFM is prepared.
Requirement: Each laboratory shall develop and maintain a document outlining the analytical
quality control practices used for the parameters included in their certification. Supporting records
shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A
NCAC 2H .0805 (a) (7).
O. Finding: Quality Control results are not calculated on the benchsheets.
Requirement: Each laboratory shall develop and maintain a document outlining the analytical
quality control practices used for the parameters included in their certification. Supporting records
shall be maintained as evidence that these practices are being effectively carried out. Ref: 15A
NCAC 2H .0805 (a) (7).
P. Finding: The formula in the SOP does not account for instances where the volume of 10N
NaOH used in the samples versus the calibration standards is different.
Requirement: When the volume of 1 ON NaOH used for the samples is different than that used
for the calibration standards this must be compensated for in the calculation. The following
formula must be used in the calculation:
mg NH3—N/L=AxBx (100+D)
l
1 (100 + C) J
A= Dilution Factor
B= Concentration of NH3-N/L, mg/L, from calibration curve
C= Volume of 1 ON NaOH added to the calibration standards, mL
D= Volume of 1ON NaOH added to sample, mL
Ref: Standard Methods, 4500 NH3 D-1997. (5).
Comment: None of the data reviewed required adjustment because the volumes of 1 ON NaOH
used were never different; however the formula must be included in the SOP and applied if
necessary.

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#237 City of Brevard VW TP
Q. Finding: Preservatives are not added to the reagent blank and laboratory -fortified blank.
Requirement: A reagent blank (method blank) consists of reagent water (see Section 1080)
and all reagents (including preservatives) that normally are in contact with a sample during the
entire analytical procedure. Ref: Standard Methods, 1020 B-2011. (5).
Requirement: A laboratory -fortified blank [laboratory control standard (LCS)] is a reagent water
sample (with associated preservatives) to which a known concentration of the analyte(s) of
interest has been added. Ref: Standard Methods, 1020 B-2011. (6).
Suspended Residue —Standard Methods, 2540 D-1997
R. Finding: The samples are not weighed to constant weight, nor is an annual multiple weighing
study to verify the adequacy of the drying time, performed.
Requirement: Constant weights must be documented. The approved methods require the
following: "Repeat the cycle of drying, cooling, desiccating, and weighing until a constant weight
is obtained or until the weight change is less than 4% of the previous weight or 0.5 mg,
whichever is less." In lieu of this, an annual study documenting the time required to dry
representative samples to a constant weight may be performed. Verify minimum daily drying
time is greater than or equal to the time used for the initial verification study drying cycle. Drying
cycles must be a minimum 1 hour for verification. Ref: NC WW/GW LC Policy.
Comment: North Carolina allows for an annual drying study in lieu of the requirement above to
repeat the drying cycle for every sample. A random full set of samples should be used for the
drying study. The repeated drying time in the oven should be at least 1 hour long. The time
used for the annual drying study is the minimum time that samples are to be dried until a new
drying study is performed.
Comment: Samples are typically dried in the oven overnight. Since the method requires a one
hour minimum drying time, overnight drying should be sufficient to dry the filters.
S. Finding: The laboratory is not basing the reporting limit on the minimum weight gain required
by the method.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. To
obtain the required residue yield, successive aliquots of samples may be added to the same
dish after evaporation or adjust reporting level based upon the weight gain and sample volume
used. The minimum reporting value is established at 2.5 mg/L based upon a sample volume
used of 1000 mL. Ref: NC WW/GW LC Policy.
Comment: For example, if 100 mL sample is analyzed, and less than 2.5 mg of dried residue is
obtained, the value reported would be <25 mg/L.
T. Finding: The times that filters are put in and removed from the oven are not documented.
Drying times cannot be determined without this data. This is considered pertinent information.
Requirement: All analytical data pertinent to each certified analysis must be filed in an orderly
manner so as to be readily available for inspection upon request. Ref: 15A NCAC 2H .0805 (a)
(7) (A)•
Requirement: Dry for at least 1 h at 103 to 105°C in an oven, cool in a desiccator to balance
temperature, and weigh. Ref: SM 2540 D-1997. (3)(c).

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Biochemical Oxygen Demand — Standard Methods, 5210 B-2001
Comment: The laboratory was analyzing one glucose-glutamic acid (GGA) standard with each sample
group. Standard Methods, 5210 B-2001. (6) (b) states: Add sufficient amounts of standard glucose-
glutamic acid solution (¶ 3h) to give 3.0 mg glucose/L and 3.0 mg glutamic acid/L in each of three test
bottles (20 mL GGA solution/L seeded dilution water or 6.0 mU300-mL bottle). The resulting average
BOD for the three bottles, after correction for dilution and seeding, must fall into the range of 198 ± 30.5
mg/L. This is a new method requirement that has been implemented since the last inspection. Notification
of acceptable corrective action (i.e., three GGA standards are now analyzed with each batch of
samples, effective immediately) was received by email on September 11, 2015. No further response
is necessary for this Finding.
U. Finding: BOD samples are not checked for TRC.
Requirement: It is acceptable to screen samples with DPD powder for the presence of Total
Residual Chlorine (use pillows appropriate for the volume of sample tested). Generally total
residual chlorine test strips are not adequate; however, these may be used for samples where
interference with DPD precludes their use. If DPD yields no pink color, chlorine is absent.
Document and proceed to set sample. Ref: NC WW/GW LC Policy.
Comment: The laboratory has assumed that there is no TRC in the sample based on the grab
TRC result. However, this is not an accurate assumption since the BOD samples are composite
samples. Therefore, the BOD samples must be checked for TRC prior to analysis.
V. Finding: Samples were not pH adjusted according to the current method requirements.
Requirement: Check pH; if it is not between 6.0 and 8.0, adjust sample temperature to 20 ± 3 °C,
then adjust pH to 7.0 to 7.2 using a solution of sulfuric acid or sodium hydroxide of such strength
that the quantity of reagent does not dilute the sample by more than 0.5%. The pH of dilution
water should not be affected by the lowest sample dilution. Always seed samples that have been
pH adjusted. Ref: Standard Methods, 5210 B-2001. (4) (b) (1).
Comment: The laboratory was adjusting samples to 6.5-7.5 S.U.
W. Finding: The laboratory is not seeding samples that are stored for more than 6 hours after
collection.
Requirement: Some samples (for example, some untreated industrial wastes, disinfected wastes,
high -temperature wastes, wastes having pH values less than 6 or greater than 8, or wastes stored
more than 6 h after collection) do not contain sufficient microbial population. Seed such samples
by adding a population of suitable microorganisms. Ref: SM 5210 B-2001. (4) (d).
X. Finding: Initial DO values of the dilution water (blank) are not always >_7.5 mg/L.
Requirement: Preparation of dilution water. Check to ensure that the dissolved oxygen
concentration is at least 7.5 mg/L before using water for BOD tests. If not, add DO by by shaking
bottle or by aerating with organic -free filtered air. Alternatively, store the water in cotton -plugged
bottles long enough for the DO concentration to approach saturation. Ref: SM 5210 B-2001. (5)
(a).

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Y. Finding: Initial DO values of prepared dilutions are not always 7-9 mg/L.
Requirement: The working range is equal to the difference between the maximum initial DO (7 to
9 mg/L) and minimum DO residual of 1 mg/L corrected for seed, and multiplied by the dilution
factor. Ref: SM 5210 B-2001. (8) (b).
Fecal Coliform —Standard Methods, 9222 D-1997
Z. Finding: Samples are not collected in sterile bottles.
Requirement: Collect samples for microbiological examination in clean, sterile, nonreactive
borosilicate glass or plastic bottles or presterilized plastic bags appropriate for microbiological use.
Ref: Standard Methods, 9060 A-2006. (1).
AA. Finding: Plate comparison counts are not being conducted.
Requirement: For routine performance evaluation, repeat counts on one or more positive
samples at least monthly, record results, and compare the counts with those of other analysts
testing the same samples. Replicate counts for the same analyst should agree within 5% (within
analyst repeatability of counting) and those between analysts should agree within 10% (between
analysts reproducibility of counting). If they do not agree, initiate investigation and any necessary
corrective action. Ref: Standard Methods, 9020 B-2005. (9) (a).
BB. Finding: Incubator temperature is only being checked once each day.
Requirement: When incubator is in use, monitor and record calibration -corrected temperature
twice daily. Ref: Standard Methods, 9020 B-2005. (5) (d).
CC. Finding: The water in the incubator is not being properly circulated.
Requirement: For optimum operation, equip water bath with a gable cover to prevent evaporation
and with a circulating pump to maintain even temperature distribution. Ref: Standard Methods,
9020 B-2005. (4) (n).
Comment: The incubator is equipped with a "shaker" system that would provide adequate
circulation to maintain even temperature distribution. The laboratory has not had this turned on.
DD. Finding: The laboratory is not monitoring the quality of the reagent water used in fecal coliform
analysis.
Requirement: Fecal coliform reagent water must be analyzed every twelve months to ensure
suitability. At a minimum analyses must be performed for conductivity, TOC, Cd, Cr, Cu, Pb, and
Zn. Recommended limits for reagent water quality are given in Standard Methods 9020 B-2005
Table 9020: II. If these limits are not met, investigate and correct or change water source. Ref: NC
WW/GW LC Policy and Standard Methods, 9020 B-2005. (5) (f).
EE. Finding: The laboratory is not testing a culture positive with each batch of media prepared.
Requirement: Use certified reference cultures. For each lot of medium received, each laboratory
prepared batch of medium, and each lot of purchased prepared medium, verify appropriate
response by testing with known positive and negative control cultures for the organism(s) under
test. Record results. Ref: Standard Methods, 9020 B-2005. (9) (b).

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#237 City of Brevard WNTP
Comment: Standard Methods, 9020 A-2005 states that the quality control (QC) requirements in
section 9020 are not mandatory. Each laboratory must develop its own QC suitable for its needs
and, in some cases, as required by regulatory agencies, standard setting organizations, and
laboratory certification or accreditation programs. 9020 A-2005 also states that the program must
be practical and require only a reasonable amount of time or it will be bypassed. Once a Quality
Assurance (QA) program is established, about 15% of overall laboratory time should be spent on
different aspects of the program. Based upon this language, and in conjunction with method
specified requirements, the NC WW/GW LC program has established minimum requirements for
maintaining certification with our program. At this time, negative control cultures are not required
for coliform analyses.
Temperature — Standard Methods, 2550 B-2000
FF. Finding: The temperature sensor on the Dissolved Oxygen meter used to obtain reported
temperature values has not been checked against a National Institute of Standards and
Technology (NIST) traceable thermometer annually.
Requirement: Thermometers and temperature measuring devices, used to measure
temperature for compliance monitoring, must be checked every 12 months against a NIST
traceable thermometer. The thermometer/meter readings must be less than or equal to 10C
from the NIST traceable thermometer reading. The documentation must include the serial
number of the NIST traceable thermometer that was used in the comparison. Document any
correction that applies on both the thermometer/meter and on a separate sheet to be filed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of Temperature.
Comment: The most recent check was performed May 8, 2013.
Total Residual Chlorine — Standard Methods, 4500 Cl G-2000
Comment: The factory -set calibration curve verification had not been performed at least every 12
months. The NC WW/GW LC Approved procedure for the Analysis of Total Residual Chlorine states:
Most field photometric instruments have factory -set calibration programs, which when selected in
combination with the optimum wavelength for a particular analysis, give a direct readout in concentration.
These factory -set calibration programs are acceptable for quantitation, but due to possible analyst error,
variation in sample or standard preparation, variation in reagents or malfunction of the instrument, the
factory -set calibration must be verified at least every 12 months. The last curve verification was
performed on January 28, 2013. Acceptable corrective action (i.e., a curve verification was performed
prior to the inspection on July 31, 2015 as well as a statement that all future curve verifications will be
performed every twelve months) was provided during the inspection and by email on September 16,
2015. 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 Carolina
Division of Water Resources. Data were reviewed for City of Brevard WWTP (NPDES permit #
NC0060534) for January, February, and March, 2015. No transcription errors were detected. The
facility appears to be doing a good job of accurately transcribing data.

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#237 City of Brevard VWVfP
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 an implementation date for each
corrective action.
Report prepared by: Jason Smith Date: August 25, 2015
Report reviewed by: Nick Jones Date: September 4, 2015