#5339_03_2015_FINAL

A=*Ar.R
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 2, 2015
5339
Mr. Aubrey Deaver
A&D Maintenance, Inc.
P.O. Box 1407
Pisgah Forest, NC 28768
Donald R. van der Vaart
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Deaver:
Enclosed is a report for the inspection performed on March 11, 2015 by Jason Smith and myself.
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. 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. If you
have questions or need additional information, please contact us at [phone].
Attachments
cc: Master file
Jason Smith
Butch Howell
WSRO Office
Sincerely,
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, 919-733-3908 l FAX: [phone]
Internet: www.dwglab.org
An Equal Opportunity t Affirmative Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
Laboratory Name:
Inspection Type:
Inspector Name(s):
Inspection Date:
Date Report Completed:
Date Forwarded to Reviewer:
Reviewed by:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Linda:
Date Mailed:
5339
A&D Maintenance, Inc.
Field Commercial Maintenance Abbreviated
Gary Francies & Jason Smith
March 11, 2015
March 25, 2015
March 25, 2015
Tonia Springer
March 25, 2015
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Gary Francies
3/25/2015
4/2/2015
L�1(4115 L�_

On -Site Inspection Report
LABORATORY NAME: A&D Maintenance, Inc.
NPDES PERMIT #: NCO030325
ADDRESS: P.O. Box 1407
Pisgah Forest, NC 28768
CERTIFICATE #: 5339
DATE OF INSPECTION: March 11, 2015
TYPE OF INSPECTION: Field Commercial Maintenance Abbreviated
AUDITOR(S): Gary Francies and Jason Smith
LOCAL PERSON(S) CONTACTED: Butch Howell
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:
This was an abbreviated inspection performed at the request of the Division of Water Resources in the
Winston-Salem Regional Office for Buffalo Meadows WWTP NPDES permit #NC0030325. The following
parameters were reviewed: pH, Temperature, and Total Residual Chlorine.
Proficiency Testing (PT) samples for the 2015 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, 2015.
Contracted analyses are performed by Environmental Testing Solutions, Inc. (Certification #600).
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 and also
enclosed with this report.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The time of sample collection and analysis was not documented for any analyses. The 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, samples site,
sample collector, and sample analysis time. The field benchsheets must provide a space for the
signature of the analyst, and proper units of measure for all analyses. Demonstration of acceptable
corrective action (i.e., updated benchsheets which include sample collection and analysis times and a
note that if only one time is recorded, the sample was analyzed in situ) was received by email on March
24, 2015. No further response is necessary for this finding.

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Comment: The time of meter calibration was not documented for pH and Total Residual Chlorine
analyses. The NC WW/GW LC Approved Procedure for the Analysis of pH and the NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine state: The following must be documented
in indelible ink whenever sample analysis is performed: Meter calibration and meter calibration time(s).
Demonstration of acceptable corrective action (i.e., updated benchsheets which include meter calibration
times) was received by email on March 24, 2015. No further response is necessary for this finding.
Comment: Units of measure were not documented for pH, Total Residual Chlorine (TRC), and
Temperature. The 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, samples site, sample collector, and sample analysis time. The field benchsheets must
provide a space for the signature of the analyst, and proper units of measure for all analyses.
Demonstration of acceptable corrective action (i.e., updated benchsheets which include units of measure
for all analyses) was received by email on March 24, 2015. No further response is necessary for this
finding.
Comment: The laboratory needed to increase the documentation of purchased materials and reagents.
The Quality Assurance Policies for Field Laboratories document 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 (where specified).
Demonstration of acceptable corrective action (i.e., a traceability log for recording all required information)
was received by email on March 24, 2015. No further response is necessary for this finding.
Comment: Instrument identification was not documented on the benchsheets for pH, TRC, and
Temperature. The NC WW/GW LC Approved Procedure for the Analysis of pH, NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine, and NC WW/GW LC Approved
Procedure for the Analysis of Temperature documents state: The following must be documented in
indelible ink whenever sample analysis is performed: Instrument identification. Demonstration of
acceptable corrective action (i.e., updated benchsheets which include a space to record instrument
identification) was received by email on March 24, 2015. No further response is necessary for this
finding.
Comment: Indelible ink was not used to record information. A pencil was used until March 1, 2015 and
ink that was not indelible was used after that. The NC WW/GW LC Approved Procedure for the Analysis
of pH, NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine, and NC
WW/GW LC Approved Procedure for the Analysis of Temperature documents state: The following must
be documented in indelible ink whenever sample analysis is performed. Notification of acceptable
corrective action (i.e., indelible ink is now being used) was received by email on March 25, 2015. No
further response is necessary for this finding.
Comment: The laboratory was not transcribing data qualifiers from the contract laboratory reports to the
Discharge Monitoring Report (DMR). The following omission was noted: 7/1/14, Fecal Coliform: Duplicate
was outside acceptable established limits. Validity of data is not affected. The Quality Assurance Policies
for Field Laboratories document states: When quality control (QC) failures occur, the laboratory must
attempt to determine the source of the problem and must apply corrective action. Part of the corrective
action is notification to the end user. If data qualifiers are used to qualify samples not meeting QC
requirements, the data may not be useable for the intended purposes. It is the responsibility of the
laboratory to provide the client or end -user of the data with sufficient information to determine the
usability of the qualified data. Where applicable, a notation must be made on the Discharge Monitoring
Report (DMR) form, in the comment section or on a separate sheet attached to the DMR form when
any required sample quality control does not meet specified criteria and another sample cannot be

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obtained. Notification of acceptable corrective action (i.e., future data qualifiers will be recorded on the
DMR) was received by email on March 25, 2015. No further response is necessary for this finding.
Proficiency Testing
Comment: Proficiency Testing data was not reviewed.
pH — Standard Methods, 4500 H + B-2000
Comment: Values were reported that exceed the method specified accuracy of 0.1 units. Standard
Methods, 4500 H+ B-2000, (6) states in part: 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 results would be reported to 0.1 units.) was received by e-mail on March 25, 2015.
No further response is necessary for this finding.
Comment: A pH check buffer was not analyzed after meter calibration. The NC WW/GW LC Approved
Procedure for the Analysis of pH states: In addition to the calibration buffers, the meter calibration must
be verified with a third standard buffer solution. Demonstration of acceptable corrective action (i.e., an
updated calibration log that includes the check buffer and acceptance criterion) was received by email on
March 24, 2015. No further response is necessary for this finding.
Temperature — Standard Methods, 2550 B-2000
Comment: The temperature correction was not posted on the meter. The NC WW/GW LC Approved
Procedure for the Analysis of Temperature states: The temperature correction (even if it is zero) must be
posted on the meter as well as in hard copy format (to be retained for 5 years). Notification of acceptable
corrective action (i.e., the temperature correction is now posted on the meter) was received by email on
March 25, 2015. No further response is necessary for this finding.
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
A. Finding: A Division of Water Resources approved meter has not been used for TRC analyses
since August 19, 2014.
Requirement: Each facility must have glassware, chemicals, supplies, equipment, and a source
of distilled or deionized water that will meet the minimum criteria of the approved methodologies.
Ref: 15A NCAC 2H .0805 (g) (4).
Requirement: This letter serves as notification to facilities with effluent permit limits for Total
Residual Chlorine (TRC) that effective July 1, 2002, the Division of Water Quality expects these
facilities to utilize an instrument or method that will detect and measure TRC concentrations to
levels that are below the permit discharge requirements. Please note that if a facility has no
effluent limit for TRC Oust a monitoring requirement), then use of a hand-held meter, sometimes
described as a pocket colorimeter, and the reporting of <100 pg/L as a TRC value is acceptable.
The Environmental Protection Agency (EPA) and the State have determined that in the interest of
overall program equity, to ensure water quality protection, and to comply with 15A NCAC 2B
.0505 (e) (4), the Division will require all facilities with TRC limits to utilize instruments or methods
that will produce detection and reporting levels that are below the permit discharge requirements
for TRC.... The EPA has approved two methods for low-level TRC analyses: the Amperometric
Titration Method and the DPD Colorimetric Method.... Because TRC must be analyzed within 15
minutes of sample collection due to its volatile nature, these facilities are not able to send these

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samples out for analysis to a commercial lab. They must rely on a field technique, which will
typically utilize the low-level DPD Colorimetric Method. Please see attached letters for further
information. Ref: NC DWQ letter dated August 14, 2001,
Comment: The meter (Hach Pocket Colorimeter) provided to the certified laboratory's personnel
per their contractual agreement does not meet Division requirements. Although Hach indicated
that the meter would be adequate, the Division has specifically stated that it is not. Pocket
colorimeters are only acceptable for reporting down to 0.1 mg/L (100 pg/L). In order to achieve the
permit required level of 28 pg/L, a spectrophotometer must be used. The Hach literature states
the meter can measure concentrations from 0.02 — 2.0 mg/L. This is not the same as measuring
to 20 pg/L. The pocket colorimeter only allows measurements in increments of 0.01 mg/L — that is
.01 mg/L, .02 mg/L, .03 mg/L, etc.
B. Finding: The meter has not had the internal curve verified annually.
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 pg/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. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total
Residual Chlorine. Please submit a copy of the curve verification with the reply to this
report.
C. Finding: Meter calibration is not verified daily.
Requirement: When a five -standard annual standard curve verification is used, the laboratory
must check the calibration curve each analysis day. To do this, the laboratory must analyze a
calibration blank to zero the instrument and analyze a check standard each day that samples are
analyzed. The value obtained for the check standard must read within 10% of the true value of the
check standard. If the obtained value is outside of the ±10% range, corrective action must be
taken. Ref: NC WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: A benchsheet was submitted on March 24, 2015 which has a space to record the
gel standard value.
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 Buffalo Meadows (NPDES permit #NC0030325)
for July, August, September, October, November and December, 2014. The following error was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
8/6/14
Total Residual Chlorine
Effluent
No value recorded
12 pg/L
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be made available to the Regional Office.

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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: March 25, 2015
Report reviewed by: Tonja Springer Date: March 25, 2015