#5291_3_finalTS_2015_

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RCDENR
North Carolina Department of Environment and Natural Resources
April 8, 2015
5291
Randy Wright
Hoke County Regional Water System
P.O. Box 240
Raeford, NC 28376
Donald R. van der Vaart
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Wright:
Enclosed is a report for the inspection performed on March 11, 2015 by Tonja Springer. 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: Tonja Springer
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] FAX: [phone]
Internet: www.dWglab.org
An Equal Opportunity 1 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:
5291
Hoke Countv Reaional Water Svstem
Field Maintenance
Tonia Springer
March 11, 2015
March 24, 2015
March 24, 2015
Todd Crawford
Date Review Completed: March 25, 2015
Cover Letter to use: ❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Unit Supervisor/Chemist III: Dana Satterwhite
Date Received: 3/25/2015
Date Forwarded to Linda: 4/8/2015
Date Mailed: `� �,

On -Site Inspection Report
LABORATORY NAME: Hoke County Regional Water System
ADDRESS: P.O Box 240
Raeford, NC 28376
NPDES PERMIT # NC0086037, NCO086045
CERTIFICATE #: 5291
DATE OF INSPECTION: March 11, 2015
TYPE OF INSPECTION: Field Maintenance
AUDITOR(S): Tonja Springer
LOCAL PERSON(S) CONTACTED: Randy Wright
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 facility has all the equipment necessary to perform the analyses.
Proficiency Testing 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 Microbac Laboratories, Inc. (Certification #11).
Current quality assurance policies for Field Laboratories, an example benchsheet 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 A, B, F and G have been implemented by our program since
the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Recommendation: The laboratory's data defensibility would be improved with the addition of an
instrument maintenance log. This can be as simple as a description in a comment box on a
benchsheet. One example of instrument maintenance is replacing a bulb on the Total Residual
Chlorine meter.

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#5291 Hoke County Regional Water System
A. Finding: The laboratory benchsheets for pH and Total Residual Chlorine (TRC) were lacking
pertinent data: Instrument identification.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Instrument identification. Ref: The NC WW/GW LC Approved Procedure for the
Analysis of pH and NC WW/GW LC Approved Procedure for the Analysis of Total Residual
Chlorine. Please submit a copy of an updated benchsheet that includes sample results
with the response to this report.
Recommendation: It is also recommended that the name of the laboratory performing the
analyses for the various permitted locations be documented on laboratory benchsheets. There
was a space provided on the benchsheet to document the facility name but the permit # and
location for the sample sites were documented in this space instead.
Comment: An example benchsheet was sent to the lab that included a space to document both
the laboratory name (i.e., Hoke County Regional Water System) as well as the permittee's
information (permit # and location) for the sample sites.
B. Finding: The laboratory needs to increase the documentation of purchased reagents.
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. 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. Ref: The Quality Assurance Policies for Field Laboratories. Please submit a copy
of an updated completed benchsheet [or a log form may be used] that includes the
required traceability information with the response to this report.
Total Residual Chlorine — Standard Methods, 4500 Cl G-2000
C. Finding: The Total Residual Chlorine meter's factory set curve is not verified every twelve
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 initially and 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. When a five -standard annual
verification curve is generated, 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 the samples are analyzed. Ref: NC WW/GW LC Approved Procedure
for the Analysis of Total Residual Chlorine. Please send a copy of the calibration curve
verification with the report response.

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#5291 Hoke County Regional Water System
Requirement: Data pertinent to each analysis must be maintained for five years. Ref: 15A NCAC
2H .0805 (g) (1).
Recommendation: It is recommended that the laboratory verify the internal calibration using
the following concentrations: 10 (or 15), 20, 50, 200 and 400 pg/L. This will verify the analytical
range used to measure Proficiency Testing (PT) samples, gel standards; as well as
environmental samples.
Comment: The last annual curve verification was performed in 2013. Records were observed
for annual curve verifications from 2008-2013.
D. Finding: The Gel® standard is not verified 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. Please
send a copy of the Gel® standard verification with the report response.
Comment: The Gel® standard was last verified on 9/27/2013. The Gel® standard will need to
be verified against the verified calibration curve and reassigned a new value.
E. Finding: The meter calibration time is not being documented.
Requirement: The following must be documented in indelible ink whenever sample analysis is
performed: Meter calibration time. Ref: The NC WW/GW LC Approved Procedure for the Analysis
of Total Residual Chlorine. Please submit a copy of an updated completed benchsheet that
includes sample results with the response to this report.
Proficiency Testing
F. Finding: The preparation of TRC 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: The Proficiency Testing Requirements, February
20, 2012, Revision 1.2.
Comment: Dating and initialing the instruction sheet for the preparation of the TRC PT would
satisfy the documentation requirement.
G. Finding: The laboratory is not documenting 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.

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#5291 Hoke County Regional Water System
Comment: PT samples are not being documented on the benchsheets. Results were only
documented on the vendor reporting form then submitted electronically or faxed.
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 Arabia WTP (NPDES permit # NC0086037) and
Antioch WTP (NPDES permit # NC0086045) for August and December, 2014 and February, 2015. No
transcription errors were detected. The facility appears to be doing a good job of accurately
transcribing data.
V. CONCLUSIONS:
Correcting the above -cited findings and implementing the recommendations 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: Tonja Springer Date: March 24, 2015
Report reviewed by: Todd Crawford Date: March 25, 2015