#5490_0306_finalTC_2015_

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Pat McCrory Donald R, van der Vaart
Governor Secretary
March 11, 2015
5490
Mr. Mikel Seely
Sherwood MHP
110 Glencroft Road
Hubert, NC 28539
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr Seely:
Enclosed is a report for the inspection performed on March 6, 2015 by Todd Crawford. 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 (919)
733-3908.
Attachment
cc: Todd Crawford
Sincerely,
Dana Satterwhite, Environmental Program Supervisor
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] t FAX: [phone]
Internet: www.dwgiab.org
An Equal Opportunity `, 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:
5490
Sherwood MHP
Field Maintenance
Todd Crawford
March 6, 2015
March 10, 2015
March 10, 2015
Nick Jones
March 10, 2015
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Dana Satterwhite
March 10, 2015
March 11, 2015
March 12, 2015 Lf--

LABORATORY NAME:
WATER QUALITY PERMIT # :
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
On -Site Inspection Report
Sherwood MHP
NCO022462
110 Glencroft Rd
Hubert, NC 28539
5490
March 6, 2015
Field Maintenance
Todd Crawford
LOCAL PERSON(S) CONTACTED: Mikel Seely
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.
GENERAL COMMENTS:
The facility has all the equipment necessary to perform the analyses.
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 Beacham Labs — Division of Environmental Chemists (Certification
#1).
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.
The requirements associated with Findings B, C, D and E have been implemented by our program since
the last inspection.
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: Error corrections are not performed properly.
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

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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.
Comment: Over -written entries were observed.
B. Finding: The laboratory benchsheet was lacking pertinent data for all parameters: Instrument
identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument Identification. Ref: NC WW/GW LC Approved Procedure for the Analysis
of Total Residual Chlorine, NC WW/GW LC Approved Procedure for the Analysis of Dissolved
Oxygen, NC WW/GW LC Approved Procedure for the Analysis of pH and NC WW/GW LC
Approved Procedure for the Analysis of Temperature.
Performance 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 PT would satisfy the documentation requirement.
D. Finding: The laboratory is not analyzing Proficiency Testing (PT) samples in the same manner as
environmental 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 was analyzing samples multiple times and reporting an average of all
results. Environmental samples are not analyzed and reported in this manner.
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.

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Total Residual Chlorine — SM 4500 CI G-2000
F. Finding: The laboratory is not verifying the instrument's factory set curve every 12 months.
Requirement: Analyze a water blank to zero the instrument and then analyze a series of five
standards. The curve verification must check 5 concentrations (not counting the blank) that
bracket the range of the samples to be analyzed. This type of curve verification must be
performed at least every 12 months. The values obtained must not vary by more than 10% of the
known value for standard concentrations greater than or equal to 50 µg/L and must not vary by
more than 25% of the known value for standard concentrations less than 50 µg/L. The overall
correlation coefficient of the curve must be >_0.995. Ref: Approved Procedure for the Analysis of
Total Residual Chlorine.
Comment: The last 5-standard curve verification was performed on 9/28/12.
G. Finding: The laboratory is not verifying the Gel@ Standard every 12 months.
Requirement: Purchased "Gel -type" or sealed liquid ampoule standards may be used for daily
standard curve verification only. These standards must be verified initially and every 12 months
thereafter, with the standard curve. When this is done, these standards may be used after the
manufacturer's expiration date. It is only necessary to verify the gel or sealed liquid standard
which falls within the concentration range of the curve used to measure sample concentrations.
For example, if you are measuring samples against a low range curve, a 200 µg/L standard would
be verified. Ref: Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: The value of the Gel@ standard obtained at the time of the 5 point verification, will be
the "true value" used until a new curve is verified within the next twelve months.
PH — Standard Methods, 4500 H+g-2000
H. Finding: The units of measure are not documented on the benchsheets.
Requirement: 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 bench sheets must provide a space for the signature of the analyst, and rp oper
units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: The units of measure for pH are Standard Units (S.U.).
Finding: The value of the check buffer is not being documented to one decimal place. This
makes it impossible to determine whether or not the calibration verification is acceptable.
Requirement: For routine work, use a pH meter accurate and reproducible to 0.1 pH unit with a
range of 0 to 14, equipped with a temperature compensation device. Follow all manufacturers'
recommendations for the calibration of the meter each analysis day. In all cases, the meter must
be calibrated with at least two buffers. Calibrating with the pH 4 and pH 10 buffers meets standard
methods requirements and brackets the pH range for most monitoring (with the exception of
sludge) scenarios. The calibration; however, must bracket the range of the samples being
analyzed. In addition to the calibration standards, the meter must be verified with a third
calibration standard (e.g., pH 7 buffer). In order to meet the above -specified criteria the standard
must read within a range of PH 6.9 to 7.1 to be acceptable. Ref: Approved Procedure for the
Analysis of pH.

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#5490 Sherwood MHP
Dissolved Oxygen — Standard Methods, 4500-0 G-2001
J. Finding: The meter was not being calibrated according the manufacturer's instructions.
Requirement: Ensure that the sponge inside the instrument's calibration chamber is moist. Insert
the probe into the calibration chamber. Ref: YSI 550A Operator's Manual.
Comment: The sponge and end cap of the calibration well were missing. Therefore the
calibration was being performed with the probe exposed to the atmosphere. The probe must be in
saturated air to achieve a proper calibration. The accuracy of DO readings are dependent upon a
proper meter calibration.
Temperature — Standard Methods, 2550 B-2000
K. Finding: Temperature readings are not always measured in -situ.
Requirement: Immediate (i.e., in situ) analysis is required. Ref: Code of Federal Regulations,
Title 40, Part 136; Federal Register Vol. 77, No. 97, May 18, 2012; Table II.
Requirement: When analyzing samples at a site where in situ analysis will interfere with obtaining
an accurate reading due to conditions present (e.g., low flow, etc.), it is acceptable to collect the
sample in a container and analyze on site. Ref: NC WW/GW LC Approved Procedure for the
Analysis of Temperature.
Recommendation: It is recommended that temperature values always be obtained with the DO
meter and never with the benchtop pH meter. The analyst stated that both meters were
sometimes used to obtain temperature readings. Although either meter would be acceptable, the
DO measurements are made in -situ, whereas the pH measurements are made at the bench. NC
WW/GW LC defines on site as being as close as safely possible to the point of sample collection.
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 November and December, 2014 and January, 2015. The
following error was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
01/07/15
Dissolved Oxygen
Effluent
9.0 mg/L
8.0 mg/L
In addition to the error noted above, the monthly averages were incorrectly calculated when "less than"
values were included. The averages were calculated as if there were no "less than" values. The "less
than" sign was then added back on to the reported average. The NC DWR NPDES Permitting
Calculation of Data document states: Complications may arise in calculations when dealing with testing
results showing values of less than a minimum detection level for the testing method. Current Division
policy gives permittees the benefit of doubt all the way to the lowest levels when performing calculations
using such "less than" values. When calculating an arithmetic mean you may consider a "less than"
value as equal to zero. For the calculation of a geometric mean a "less than" value may be considered to

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be equal to one. Remember, this procedure pertains only to the calculation of an average You must
report individual data values on the DMR exactly as reported to you by your laboratory. The NC DWR
NPDES Permitting Instructions for Completing a DMR states: 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
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether amended Discharge Monitoring Reports will be required. A copy of
this report will be made available to the Regional Office.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendation 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.
Report prepared by: Todd Crawford Date: March 10, 2015
Report reviewed by: Nick Jones Date: March 10, 2015