#177 - 04 - 2012 - FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
177
Laboratory Name:
Water and Sewer Authority of Cabarrus County
Inspection Type:
Commercial Maintenance
Inspector Name(s):
Chet Whiting
Inspection Date:
April 25, 2012
Date Report Completed:
May 18, 2012
Date Forwarded to Reviewer: May 18, 2012
Reviewed by:
Jason Smith
Date Review Completed:
May 29, 2012
Cover Letter to use: _
Insp. Initial X Insp. Reg. _ Insp. No Finding _ Insp. CP _ Corrected
Unit Supervisor:
Gary Francies
Date Received:
5/30/2012
Date Forwarded to Linda:
6/6/2012
Date Mailed:
1, b I 1 A

Beverly Eaves Perdue
Governor
Division of Water Quality
Charles Wakild, P. E.
Director
June 7, 2012
177
Mr. Tim Furr
Water and Sewer Authority of Cabarrus County
6400 Breezy Lane
Concord, NC 28025
Dee Freeman
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Furr:
Enclosed is a report for the inspection performed on April 25, 2012 by Chet Whiting, Gary
Francies. Jason Smith and Nick Jones. 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. 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.
Sincerely,
Gary Francies
Certification Unit Supervisor
Laboratory Section
Enclosure
cc: Chet Whiting
Master File
DENR DWO Laboratory Section NC Wastewater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699-1623
Location: 4405 Reedy Creek Road. Raleigh, North Carolina 27607-6445
Phone: [phone] \ FAX: [phone]
Internet: www.dwglab.org
Nahoully
One
NorthCarolna
An Equal Opportunity \ Affirmative Action Employer

On -Site Inspection Report
LABORATORY NAME: Water and Sewer Authority of Cabarrus County
NPDES Permit #: NCO036296 (Rocky River WWTP) and NCO081621 (Muddy Creek
WWTP)
ADDRESS: 6400 Breezy Lane
Concord, NC 28025
CERTIFICATE M 177
DATE OF INSPECTION: April 25, 2012
TYPE OF INSPECTION: Commercial Maintenance
AUDITOR(S): Chet Whiting, Gary Francies, Jason Smith, Nick Jones
LOCAL PERSON(S) CONTACTED: Tim Furr
I. INTRODUCTION:
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
II. GENERAL COMMENTS:
It was evident from the inspection that the laboratory tries to stay abreast of changing requirements
and implements new procedures as they arise. Examples include the implementation of matrix spiking
procedures and the updated Total Suspended Solids (TSS) weight gain requirement. In addition, the
laboratory has implemented quality control (QC) procedures that exceed laboratory certification
requirements, such as the analysis of blind quarterly QC samples for most parameters.
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.
Findings A, B, C, D, E, F, G, H and J are new policies that have been implemented by our program since
the last inspection
Ill. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Recommendation: Some instrument maintenance is documented on a sticker posted on the instrument.
It is recommended that this information be documented in a log book for retention. Documentation of
instrument maintenance is not currently a requirement; however, it is good laboratory practice and can
provide valuable supporting documentation for troubleshooting and/or training purposes.

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#177 Water and Sewer Authority of Cabarrus County
Recommendation: Preservation checks for Total Residual Chlorine (i.e., Ammonia Nitrogen, Fecal
Coliform, and BOD [prescreen]) are documented as <0.025 mg/L. The aliquot of sample tested for the
presence of total residual chlorine does not have to be a quantitative analysis performed on the
spectrophotometer. it is recommended that this be documented as presence or absence.
Comment: The autoclave log did not document the items autoclaved (e.g., Total Phosphorus sample
numbers for digestion, buffered sterile dilution water, fecal filtration units, etc.) The North Carolina
Administrative Code, 15A NCAC 2H .0805 (a) (7) states: 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. Demonstration of acceptable corrective action (i.e., revised autoclave log sheets with a
column to document the materials sterilized during each use) was received by email on 4/26/12. No
further response is necessary for this finding.
Comment: It was recommended that use of the internal thermometer be documented. This information
was on the submitted revised autoclave log sheet.
A. Finding: Data that does not meet all quality control requirements is not qualified on the
Discharge Monitoring Report (DMR).
Requirement: 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. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: Where applicable, a notation must be made on the Discharge Monitoring Report
(DMR) form, in the comment section, when any required sample quality control does not meet
specified criteria and another sample cannot be obtained.
Comment: One instance, in the data reviewed, was observed where a quality control failure was
not qualified on the data or DMR (Total Phosphorus, Matrix Spike failure on 5/4/11).
Recommendation: Having a visual cue can be helpful in preventing the above -cited omission.
It is recommended that the Matrix Spike acceptance criterion be recorded on the benchsheet.
B. 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.
C. Finding: The laboratory's Standard Operating Procedure (SOP) does not address the
preparation, analysis and documentation of PT samples.
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.

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#177 Water and Sewer Authority of Cabarrus County
The quality control document shall be available for inspection by the State Laboratory. Ref: 15A
NCAC 2H .0805 (a) (7).
D. Finding: The preparation of standards and reagents is not documented in such a way as to
provide traceability from preparation to analysis.
Requirement: 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: North
Carolina Wastewater/Groundwater Laboratory Certification Policy.
Comment: The laboratory has an effective system documenting traceability of chemical receipt
and primary stock standards prepared in the laboratory, however preparation of secondary
standards is not (e.g. curve standards check standards prepared from stock standards) are not
documented.
General Laboratory
E. Finding: The laboratory is analyzing additional quality control (i.e., purchased known value
sample) with PT samples.
Requirement: Laboratories shall conduct proficiency tests in accordance with their routine
testing, calibration and reporting procedures, unless otherwise specified in the instructions
supplied by the PT provider. This means that they are to be logged in and analyzed using the
same staff, sample tracking systems, standard operating procedures including the same
equipment, reagents, calibration techniques, analytical methods and preparatory techniques
such as digestions, distillations and extractions. They shall not be analyzed with additional
duality control or replicated beyond what is routine for environmental sample analysis. Results
from multiple analyses (when this is the routine procedure) must be calculated in the same
manner as routine environmental samples. The same quality control acceptance criteria must
also be used. Ref: Proficiency Testing Requirements, February 20, 2012, Revision 1.2.
F. Finding: A calibration blank and/or calibration verification standard (mid -range) are not
analyzed at the end of the sample group and/or after every tenth sample for colorimetric, ion
electrode or metals analyses.
Requirement: The calibration blank and calibration verification standard (mid -range) must be
analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end of each
sample group to check for carry over and calibration drift. If either fall outside established
quality control acceptance criteria, corrective action must be taken (e.g., repeating sample
determinations since the last acceptable calibration verification, repeating the initial calibration,
etc.). Ref: North Carolina Wastewater/Groundwater Laboratory Certification Policy based upon
Standard Methods, 20th Edition, 1020 B. (10) (c), 3020 B. (2) (b), and 4020 B. (2).
Metals — Standard Methods, 18th Edition, 3111 B
Metals — Standard Methods, 18th Edition, 3113B
Recommendation: The temperature of some cells in the hot block digester is not checked. It is
recommended that the laboratory rotate temperature checks so that all cells are tested. In addition it is
recommended that standards (including Q.C), blanks and samples be rotated through cells.

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#177 Water and Sewer Authority of Cabarrus County
C. Finding: The laboratory is analyzing only post digestion spikes and they are not identified as
such.
Requirement: Post Digestion Spikes (PDS) are used for some analyses (e.g., metals) to
assess the ability of a method to successfully recover target analytes from an actual sample
matrix after the digestion process has been performed. The PDS results are used with Matrix
Spike (MS) results to evaluate matrix interferences. The MS and PDS should be prepared from
the same environmental sample. A PDS is not to be analyzed in place of a MS. Post Digestion
Spikes must be reported as post -digested and must not be misrepresented as pre-digested
spikes. (Exception: TCLP and SPLP samples are always spiked post digestion.) Ref: Matrix
Spiking Policy and Technical Assistance Document.
Ammonia Nitrogen — Standard Methods, 18th Edition, 4500 NH3 F
H. Finding: After the addition of the 10 N NaOH, the pH is not verified and documented to be
greater than 11.
Requirement: Add a sufficient volume of 10N NaOH solution to raise pH above 11. Ref:
Standard Methods, 18th Edition, 4500 NH3 D. (4) (b).
Requirement: Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
I. Finding: Standard recovery results are not calculated.
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: Any time quality control results indicate an analytical problem, the problem must be
resolved and any samples involved must be rerun if the holding time has not expired. Ref: 15A NCAC
2H .0805 (a) (7) (F).
J. Funding: The Ammonia Nitrogen Standard Operating Procedure (SOP) has not been updated
to include matrix spiking 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).
Fecal Coliform (Membrane Filter) — Standard Methods, 18th Edition, 9222 D
Recommendation: It is recommend that the laboratory consider an alternate method for evaluating fecal
coliform duplicates that reflects a more realistic assessment. Standard Methods, 21st Edition, 9020 B (8)
(b) (1 — 5) uses a statistical approach to evaluate fecal duplicates. Another option could be a two tiered
system, one for results with less than 20 fecal colonies based on raw colony counts, and another
criterion for results with 20-60 colonies based upon a Relative Percent Difference calculation.
Recommendation: The laboratory is measuring the 100 ml sample volumes using the graduation on the
filter funnel. It is recommended that the laboratory use a graduated cylinder that has been sterilized.

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#177 Water and Sewer Authority of Cabarrus County
Total Suspended Solids - Standard Methods, 181h Edition, 2540 C
Recommendation: The laboratory is folding Total Suspended Solids (TSS) filters and putting them in
Gooch crucibles for drying. This also necessitates the filter being handled with gloves. There is a concern
that material may flake off or.that the filter may otherwise be compromised. It is recommended that the
laboratory switch to aluminum weighing dishes or some other method that allows the filters to be dried
flat.
Finding: Units of measure were not documented on the 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).
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for Rocky River WWTP (NPDES permit #NC0036296) for March and May, 2012. 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.
Report prepared by: Chet Whiting Date: May 18, 2012
Report reviewed by: Jason Smith Date: May 29, 2012