#473_03_2014_FINAL

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North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
May 27, 2014
473
Ms. Cherie Shaw
Harnett Co. Dept. of Public Utilities
PO Box 1119
Lillington, NC 27546
John E, Skvarla, 11
Secretary
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Ms. Shaw:
Enclosed is a report for the inspection performed on March 4, 2014 by Nick Jones. 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: Master file
Tonja Springer
Nick Jones
Sincerely,
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; 919-733-6241
Internet: www.dM[ab.orp
An Equal Opportunity t AffErmative Action Employer

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. #:
473
Laboratory Name:
Harnett Co. Dept. of Public Utilities
Inspection Type:
Municipal Maintenance
Inspector Name(s):
Nick Jones
Inspection Date:
March 4, 2014
Date Report Completed:
April 25, 2014
Date Forwarded to Reviewer:
April 25, 2014
Reviewed by:
Tonia Springer
Date Review Completed:
April 29, 2014
Cover Letter to use:
❑ Insp. Initial ® Insp. Reg.
❑ Insp. No Finding ❑ Insp. CP
❑ Corrected
Unit Supervisor/Chemist III: Gary Francies
Date Received: May 7, 2014
Date Forwarded to Linda: May 27, 2014
Date Mailed: 5/28/14 Ic

LABORATORY NAME:
NPDES PERMIT #:
WATER QUALITY PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
Harnett Co. Dept. of Public Utilities
NC0021636, NC0088366,
NC0007684
WQ0028562
PO Box 1119
Lillington, NC 27546
473
March 4, 2014
Municipal Maintenance
Nick Jones
Cherie Shaw
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. Laboratory personnel communicate well with sample collectors
and coordinate sample analyses effectively to manage workload and holding times.
Proficiency Testing (PT) samples have not been analyzed for all certified parameters for
the 2014 proficiency testing calendar year. The laboratory is reminded that these results
must be submitted to this office directly from the vendor by September 30, 2014.
Contracted analyses are performed by Environment 1, Inc. (Certification #10) & Meritech,
Inc. (Certification #165).
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.

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#473 — Harnett Co. Dept. of Public Utilities
The requirement associated with Findings E, G and H have been implemented by our
program since the last inspection.
On March 27, 2014 the laboratory voluntarily dropped certification for Dissolved Oxygen,
Temperature, pH and Total Residual Chlorine. These parameters are now being
performed under the lab's field certificate (Cert # 5399). No further response is
necessary for these four parameters.
Ill. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Quality Control
A. Finding: The Quality Assurance/ Quality Control (QA/QC) Manual as well as the
Standard Operating Procedures (SOPs) do not reflect current laboratory
practices.
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).
Please submit each revised SOP for review. They are due on August 15,
2014.
Requirement: The laboratory must have an updated Quality Control/Standard
Operating Procedures document for the parameters included on the certificate
attachment by August 15, 2014. This must be submitted for review upon
completion. Please submit the revised QA/QC Manual and SOPs.
Comment: The dates of last revision are as follows:
QA/QC Manual — 6/2002
Ammonia Nitrogen — 6/2008
Coliform Fecal — 6/2002
Residue Suspended — 6/2002
Recommendation: It is recommended that SOPs include a revision and/or
review history with relevant dates (e.g., effective, review and revision dates) and
a brief description of the change(s) made.
B. Finding: Error corrections are not performed properly (overwriting).
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 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:
North Carolina Wastewater/ Groundwater Laboratory Certification Policy.

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#473 — Harnett Co. Dept. of Public Utilities
C. Finding: The laboratory has been utilizing an expired NIST traceable thermometer
to check the laboratory's thermometers. The laboratory's. NIST traceable
thermometer expired on December 31, 2011.
Requirement: All thermometers must meet National Institute of Standards
and Technology (NIST) specifications for accuracy or be checked, at a
minimum annually, against a NIST traceable thermometer and proper corrections
made. 15A NCAC 02H .0805 (a) (7) (0). Please submit your new unexpired
NIST traceable documentation and subsequent temperature sensing device
verifications.
D. Finding: The laboratory needs to increase the documentation of standards and
reagents prepared in the laboratory and consumables for Residue —Suspended,
Ammonia -Nitrogen and Coliform-Fecal.
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 (where specified). 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 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.
Proficiency Testing
E. Finding: The laboratory does not have a documented plan for proficiency testing
procedures.
Requirement: Laboratories must have a documented plan (this is usually detailed
in the laboratory's Quality Assurance Manual) of how they intend to cover the
applicable program requirements for proficiency testing per their scope of
accreditation. This plan shall cover any commercially available proficiency testing
and any inter -laboratory organized studies, as applicable. The plan must also
address the laboratory's process for submission of proficiency testing results and
related corrective action responses. Ref: Proficiency Testing Requirements,
February 20, 2012, Revision 1.2.
Coliform, Fecal — Standard Methods, 9222 D-1997 (MF)
F. Finding: The laboratory benchsheet was lacking pertinent data: sample filtration
start time, incubation start and end times for each sample.

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#473 — Harnett Co. Dept. of Public Utilities
i
Requirement: Place prepared dishes in waterproof plastic bags and seal, invert,
and submerge petri dishes in water bath: incubate for 24 ± 2 h at 44.5 ± 0.2°C.
Anchor dishes below water surface to maintain critical temperature requirements.
Place all prepared cultures in the water bath within 30 min after filtration. Ref:
Standard Methods, 9222 D-1997 (2) (d)
Requirement: All analytical data pertinent to each certified analysis must be
filed in an orderly manner so as to be readily available for inspection upon
request. Ref: 15A NCAC 02H .0805 (a) (7) (A).
Requirement: All laboratories must use printed laboratory bench worksheets
that include a space to enter the signature of 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. The date and time BOD and
coliform samples are removed from the incubator must be included on the
laboratory worksheet. Ref: 15A NCAC 02H .0805 (a) (7) (H).
G. Finding: The lab is only recording the calibration -corrected temperature of the
incubator once per day.
Requirement: When incubator is in use, monitor and record calibration -
corrected temperature twice daily. Ref: Standard Methods, 9020 B-2005, (4) (n).
Total Suspended Residue — Standard Methods, 2540 D-1997
H. Finding: The laboratory allows all samples to filter for more than 10 minutes.
Requirement: If complete filtration takes more than 10 min, increase filter
diameter or decrease sample volume. Ref: Standard Methods, 2540 D-1997, (3)
(b).
I. Finding: Every sample type is not represented in the laboratory's drying time
study.
Requirement: Constant weights must be documented. The approved methods
require the following: "Repeat the cycle of drying, cooling, desiccating, and
weighing until a constant weight is obtained or until the weight change is less
than 4% of the previous weight or 0.5 mg, whichever is less." In lieu of this, an
annual study documenting the time required to dry representative samples to a
constant weight may be performed. Verify minimum daily drying time is greater
than or equal to the time used for the initial verification study drying cycle. Drying
cycles must be a minimum 1 hour for verification. Ref: North Carolina
Wastewater/Groundwater Laboratory Certification Policy.
Comment: North Carolina allows for an annual drying study in lieu of the
requirement above to repeat the drying cycle for every sample. A random full set
of samples should be used for the drying study. The repeated drying time in the
oven should be at least 1 hour long. The time used for the annual drying study is

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#473 — Harnett Co. Dept. of Public Utilities
the minimum time that samples are to be dried until a new drying study is
performed.
Comment: Only influent and effluent samples from NPDES # NC0021636 were
included in the drying time study. Effluent from WQ0028562, NC0007684,
NC0088366 and Influent from NC0088366 were not included in the study.
Ammonia Nitrogen —Standard Methods, 4500 NH3 D-1997
Comment: The laboratory is distilling more sample volume than is required. Currently
the samples are being distilled until 400 mL of distillate is collected. Standard Methods,
4500 NH3 B-1997 states that at least 200 mL must be collected.
J. Finding: The laboratory is adding 400 mL of water to 25 mL of borate buffer to
steam out the distillation apparatus.
Requirement: Add 500 mL of water and 20 mL of borate buffer, adjust pH to 9.5
with 6N NaOH and add to a distillation flask. Ref: Standard Methods, 4500 NH3
B-1997 (4) (a).
K. Finding: The laboratory is adding 400 mL of sample to 25 mL of borate buffer
for distillation.
Requirement: Use 500 mL dechlorinated sample or a known portion diluted to
500 mL with water. Add 25 mL borate buffer solution and adjust to pH 9.5 with
6N NaOH using a pH meter. Ref: Standard Methods, 4500 NH3 B-1997 (4) (b).
Comment: If the lab continues to use 400 mL of sample, then it must be diluted
to 500 mL with water before adding the aliquot of borate buffer.
L. Finding: The laboratory's Standard Operating Procedure (SOP) states that the
probe is not immersed in the sample until after the pH is raised to >11 S.U.
Requirement: Keep electrode in solution until a stable millivolt reading is
obtained. Do not add NaOH solution before immersing electrode, because
ammonia may be lost from a basic solution. Ref: Standard Methods, 4500 NH D-
1997, (4) (b).
Comment: This Finding is severe, with the potential for a significant impact on
the data, resulting in a low bias. 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.
Finding: The lab is not demonstrating that the reagent blank meets the required
acceptance criterion.
Requirement: For analyses requiring a calibration curve, the concentration of
reagent, method and calibration blanks must not exceed 50% of the reporting

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limit or as otherwise specified by the reference method. Ref: North Carolina
Wastewater/Groundwater Laboratory Certification Policy.
Comment: The laboratory is reporting blanks as <1.0 mg/L, which is the
laboratory's reporting limit.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing field testing records, laboratory benchsheets and
contract lab reports to DMRs submitted to the North Carolina Division of Water
Resources. Data were reviewed for HCPU North & South Harnett Regional WWTPs
(NPDES permit #s NCO021636 & NC0088366, respectively) for October, November and
December, 2013; Harnett County Regional Water Treatment Plant (NPDES permit #
NC0007684) for October, 2013; North Harnett Regional Spray Field (NPDES permit #
WQ0028562) for November, 2013. 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 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: Nick Jones Date: April 25, 2014
Report reviewed by: Tonja Springer Date: April 29, 2014