#5409_03_2015_FINAL

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:
5409
Currituck Co. Southern Outer Banks W.S.
Field Maintenance
Nick Jones
March 25, 2015
April 10, 2015
April 10, 2015
Beth Swanson
April 15. 2015
❑ Insp. Initial ❑ Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
® Corrected
Gary Francies
April 15, 2015
4/29/2015
4/30/1 I

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
Currituck Co. Southern Outer Banks W.S.
NCO087670
734 Ocean Trail
Corolla, NC 27927
5409
March 25, 2015
Field Maintenance
Nick Jones
Benjie Carawan and David Chunn
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 was clean and well organized. The facility has all the equipment necessary
to perform the analyses.
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 Chemists, Inc. (Certification #94)
and 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.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: The lab did not have a system of traceability for the documentation of
purchased materials and reagents, as well as documentation of standards and reagents

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#5409 Currituck Co. Southern Outer Banks W.S.
prepared in the laboratory. The NC WW/GW LC 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. 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. Demonstration of acceptable corrective action (i.e.,
laboratory personnel implemented the traceability log supplied by the inspector) was
witnessed during the inspection. No further response is necessary for this finding.
Comment: Error corrections were not performed properly. The NC WW/GW LC Quality
Assurance Policies for Field Laboratories document states: 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. Notification of acceptable
corrective action (i.e., a statement that as of 3/25/2015 the lab will make error corrections
according to the NC WW/GW LC policy) was received by email on 3/26/2015. No further
response is necessary for this finding.
Comment: The preparation of Proficiency Testing (PT) samples was not documented.
The NC WW/GW LC Proficiency Testing Requirements document states: PT samples
received as ampules must be diluted according to the PT provider's instructions. The
preparation of PT samples must be documented in a traceable log or other traceable
format. The diluted PT sample becomes a routine environmental sample and is added to
a routine sample batch for analysis. 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 that as of 4/10/2015 the lab would begin dating and
initialing the instruction sheet of the Total Residual Chlorine PT) was received by email
on 4/10/2015. No further response is necessary for this finding.
Comment: The laboratory was not documenting Proficiency Testing (PT) sample
analyses in the same manner as environmental samples. The NC WW/GW LC
Proficiency Testing Requirements document states: All PT sample analyses must be
recorded in the daily analysis records as for any environmental sample. This serves as
the permanent laboratory record. 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 that as of 4/10/2015 PT sample analysis will be documented in the
same manner as environmental samples) was received by email on 4/10/2015. No further
response is necessary for this finding.

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#5409 Currituck Co. Southern Outer Banks W.S.
PH - Standard Methods, 4500 H+ B-2000
Comment: pH values were reported that exceed the method specified accuracy of 0.1
units. Standard Methods, 4500 H+ B-2000, (6) states: By careful use of a laboratory pH
meter with good electrodes, a precision of ±0.02 unit and an accuracy of ±0.05 unit can
be achieved. However, ± 0.1 pH unit represents the limit of accuracy under normal
conditions, especially for measurement of water and poorly buffered solutions. For this
reason, report pH values to the nearest 0.1 pH unit. Demonstration of acceptable
corrective action (i.e., the Electronic Discharge Monitoring Report was modified to round
pH values to one decimal place) was witnessed during the inspection. No further
response is necessary for this finding.
Dissolved Oxygen - Standard Methods, 4500 O G-2001
PH - Standard Methods, 4500 H+ B-2000
Temperature - Standard Methods, 2550 B-2000
Comment: The units of measure were not consistently documented on the benchsheets
for pH, Dissolved Oxygen (DO), 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, sample site, sample collector, and sample analysis time. The field bench
sheets must provide a space for the signature of the analyst, and proper units of
measure for all analyses. Notification of acceptable corrective action (i.e., a statement that
as of 4/10/2015 units of measure will be documented on the benchsheets and submission
of said benchsheets) was received by email on 4/10/2015. No further response is
necessary for this finding.
Temperature - Standard Methods, 2550 B-2000
Comment: The benchsheets for Temperature used by the laboratory did not contain all of
the necessary labeling information. Facility name and instrument identification are not
documented. The 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: document facility name and 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 that as of
3/25/2015 the lab has updated their benchsheets to include facility name, meter
calibration time and instrument identification) was received by e-mail on 3/26/2015. No
further response is necessary for this finding.
Dissolved Oxygen - Standard Methods, 4500 O G-2001
pH - Standard Methods, 4600 H+ B-2000
Total Residual Chlorine — Standard Methods, 4500-CI G-2000
Comment: The benchsheets for Total Residual Chlorine (TRC), pH and DO used by the
laboratory did not contain all of the necessary labeling information. Facility name, meter
calibration time and instrument identification are not documented. 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. The following must be documented in indelible ink

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#5409 Currituck Co. Southern Outer Banks W.S.
whenever sample analysis is performed: document meter calibration time, facility name
and 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 that as of 3/25/2015 the lab has updated their benchsheets to include
facility name, meter calibration time and instrument identification) was received by e-
mail on 3/26/2015. No further response is necessary for this finding.
Total Residual Chlorine — Standard Methods, 4500-CI G- 2000
Comment: Values less than the established reporting limit (i.e., values <20µg/L) were
being reported on the Discharge Monitoring Report (DMR). The lab's permit limit is
13µg/L. The labs current calibration verification range is 20µg/L to 200µg/L. The NC
WW/GW LC Approved Procedure for the Analysis of Total Residual Chlorine states: 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. Notification of acceptable corrective action (i.e., a
statement that from now on the lab will utilize the following concentrations for the
calibration verification standards: 10, 30, 50, 200 and 400µg/L) was received by email
on 4/10/2015. Notification of acceptable corrective action (i.e., a new acceptable
calibration verification performed on 4/22/2014) was received by email on 4/23/2015. 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
December, 2014, and January and February, 2015. The following errors were noted:
Date
Parameter
Location
Value on
Benchsheet
*Contract Lab Data
Value on
DMR
12/1/14
Temperature
Downstream
17.6 °C
17.8 °C
12/1/14
Temperature
Effluent
19.6 °C
19.5 °C
12/1/14
pH
Effluent
7.93 S.U.
7.92 S.U.
12/29/14
TSS
Effluent
* <2.6 mg/L
<2.8 mg/L
1/6/15
NH3
Effluent
* 21.1 mg/L
17.8 mg/L
2/9/15
Conductivity
Downstream
34800 µmhos/cm
34600
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

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#5409 Currituck Co. Southern Outer Banks W.S.
Monitoring Report will be required. A copy of this report will be made available to the
Regional Office.
V. CONCLUSIONS:
All findings noted during the inspection were adequately addressed prior to the
completion of this report. The inspector would like to thank the staff for its assistance
during the inspection and data review process. No response is required
Report prepared by: Nick Jones Date: April 10, 2015
Report reviewed by: Beth Swanson Date: April 10, 2015

A=40
North Carolina Department of Environment and Natural resources
Pat McCrory
Governor
April 30, 2015
5409
Mr. Benjie Carawan
Currituck Co. Southern Outer Banks W.S.
734 Ocean Trail
Corolla, NC 27927
Donald R, van der Vaart
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Carawan:
Enclosed is a report for the inspection performed on March 25, 2015 by Nick Jones. No findings
are cited in this report, a response is not required. We appreciate the fine job you and your staff
are doing. As a certification requirement, 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: Master file
Nick Jones
Sincerely,
ca��x �Z'4� e--a�
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] ! FAX: [phone]
Internet: www.d Iab.orq
An Equal Opportunity t Affirmative Action Employer