#5221_11_2014_FINAL

North'AGA
NCD
Carolina Department oEnvironment
__._ oeand Natural Resources
Pat McCrory
Governor
November 24, 2014
5221
Mr. Rusty Campbell
Lee S. Dukes Water Treatment Plant
7980 Babe Stillwell Farm Road
Huntersville, NC 28078
John E. Skvarla, III
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Campbell:
Enclosed is a report for the inspection performed on November 13, 2014 by Gary Francies and
Beth Swanson. 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.
Attachment
cc: Beth Swanson
Master File
Sincerely,
Gary Francies, Technical Assistance/Compliance Specialist
Division of Water Resources
Water Sciences Section
NC Wastowater/Groundwater Laboratory Certification Branch
1623 Mail Service Center, Raleigh, North Carolina 27699.1623
Location; 4405 Reedy Creek Road, Raleigh, North Carolina 27607
Rhone, 919-733-39081 FAX; 919-733-6241
Internet; Mw A lab.or�
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:
Date Review Completed:
Cover Letter to use:
Unit Supervisor/Chemist III:
Date Received:
Date Forwarded to Linda:
Date Mailed:
5221
Lee S. Dukes Water Treatment Plant
Field Maintenance
Beth Swanson and Gary Francies
November 13 2014
November 21, 2014
November 21, 2014
Nick Jones
November 24, 2014
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected ❑ Insp. Reg. Delay
Gary Francies
November 24 2014
CC: Wes Bella MRO: wes.bell(a)-ncdenr.gov
11 /24/2014

On -Site Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Lee S. Dukes Water Treatment Plant
NCO084387
7980 Babe Stillwell Farm Road
Huntersville, NC 28078
5221
November 13, 2014
Field Maintenance
Beth Swanson and Gary Francies
Dave Banick and Gabe Sasser
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. Additional analyses are performed
by the Charlotte Mecklenburg Utilities Environmental Laboratory Services (Certification # 192).
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.
Proficiency Testing (PT) samples have been analyzed for all certified parameters for the 2014 proficiency
testing calendar year and the graded results were 100% acceptable.
The requirements associated with Findings A, E, F, G and I have been implemented by our program
since the last inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: The laboratory benchsheet was lacking pertinent data: 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 pH, NC
WW/GW LC Approved Procedure for the Analysis of Temperature.
B. Finding: The laboratory benchsheet was lacking pertinent data: units of measure.

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#5221 Lee S. Dukes WTP
Requirement: 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 or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 02H .0805 (g) (1).
Recommendation: Some units of measure were present in the calibration logs and benchsheets,
but not all. It is recommended that a standardized statement be placed at the beginning of the
calibration log book and at the bottom of the benchsheets. It would state that all pH values are in
S.U, all Total Residual Chlorine values are in ug/L, and all Temperature values are in °C, unless
otherwise noted.
C. Finding: Data is not written in indelible ink and 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-OutO, 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. Ref: Quality Assurance Policies for Field
Laboratories.
Comment: The calibration logs and the traceability log were written in pencil.
Comment: There was evidence of pencil erasure in several places and write-overs on the
benchsheet.
D. Finding: The laboratory needs to increase the documentation of its purchased materials.
Requirement: All chemicals, reagents, standards and consumables used by the laboratory
must have the followinq information documented: Date Received, Date Opened (in use),
Vendor, Lot Number, and Expiration Date. 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: Quality Assurance
Policies for Field Laboratories.
Comment: A reagent and consumables log was posted in the laboratory but it was lacking the
information for pH buffers and the currently used GeIO standard set.
Proficiency Testing
E. 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.
F. Finding: The laboratory is not analyzing 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

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#5221 Lee S. Dukes WTP
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's common practice is to analyze a known standard along with the PT
sample. Since this is not performed with all environmental samples, it is considered additional
quality control. However, known samples are recommended when analyzing remedial PT
samples as part of the troubleshooting and corrective action process.
G. Finding: The preparation of 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. The pH sample requires no
preparation.
Total Residual Chlorine — Standard Methods, 4500 CI G-2000
Comment: The lid to the Gel® standard set (where the lot number and expiration date are printed) had
been lost. During the inspection, a unique identifier was assigned to the set: LSD001.
Recommendation: The annual verification of the calibration curve for Total Residual Chlorine (TRC) is
emailed from the analyst as an attachment and kept in a folder with the benchsheets. It is
recommended that the analyst initial and date the printed curve verification in the event that the email
is separated from the attachment.
Recommendation: A flow-thru cell is used for TRC analysis and the cell and associated tubing is
cleaned quarterly. This is a good practice and it is recommended that a maintenance log be filled out to
keep as a record of this and any other maintenance performed on the meter and accessories.
H. Finding: The laboratory is not analyzing a reagent blank with the annual TRC curve
verification.
Requirement: Reagent Blank: A reagent blank (sometimes also referred to as a method
blank) is only required when laboratory water is used to make quality control and/or calibration
standards. If you are using a sealed standard (e.g., gel) for your daily check standard, a
reagent blank would only be analyzed when preparing the annual 5-point calibration curve or 5
annual calibration curve verification standards. Ref: NC WW/GW LC Approved Procedure for
the Analysis of Total Residual Chlorine.
Comment: A reagent blank is made from the same laboratory water source used to make
calibration standards with the addition of DPD. The concentration of the reagent blank must not
exceed 50% of the reporting limit (i.e., the lowest calibration or calibration verification standard
concentration which is currently 10 ug/L), unless otherwise specified by the reference method,
or corrective action must be taken.
pH — Standard Methods, 4500 H+ B-2000
Finding: Values were reported that exceed the method specified accuracy of 0.1 units.

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#5221 Lee S. Dukes V TP
Requirement: 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. Ref: Standard
Methods, 4500 H+ B-2000, (6).
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 March, July and September, 2014. 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 inspectors would like to thank the staff
for its assistance during the inspection and data review process. Please respond to all findings.
Report prepared by: Beth Swanson Date: November 21, 2014
Report reviewed by: Nick Jones Date: November 24, 2014