#5191 - 06 -2010 - FINAL

INSPECTION REPORT ROUTING SHEET
To be attached to all inspection reports in-house only.
Laboratory Cert. M
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:
Date Received:
Date Forwarded to Alberta:
Date Mailed:
5191
Carolina Water Services. Inc. of NC
Field Commercial Maintenance
Jason Smith
May 24, 25, 26, and June 3, 2010
July 7, 2010
July 7, 2010
Tonja Springer
July 9, 2010
Insp. Initial X Insp. Reg. Insp. No Finding ® Insp. CP
Gary Francies
7112/2010
7/12/2010
-�

NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
July 13, 2010
5191
Mr. Darrell Young
Carolina Water Services, Inc. of NC
P.O. Box 337
Banner Elk, NC 28604
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Hear Mr. Young:
Dee Freeman
Secretary
Enclosed is a report for the inspection performed on May 24, 25, 26, and June 3, 2010 by Mr. Jason Smith.
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 cant' 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 me at 828-296-4677.
Sincerely,
C�
Gary Franctes
Unit Supervisor
Laboratory Section
CC: Jason Smith
Central files
DENR DWQ 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] t FAX: [phone]
Internet: www.dwgiab.org
AnEqual OpportunilytAifirrrativeActionEmployer Customer Service:1-877-623-6748 www,ncwatergtiality.org
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ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
Carolina Water Services, Inc. of NC
P.O. Box 337
Banner Elk, NC 28604
5191
May 24, 25, 26, and June 3, 2010
Field Commercial Maintenance
Jason Smith
Darrell Young, Rex Woody, Robby Woody, Beverly Grinstead,
David Medling, and Pete McNeely
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for
the analysis of environmental samples.
IF d #kl.:;L1R01alIT ld,IA to
The laboratory consists of three operators working out of the Banner Elk office as well as three other
operators that work at the facility that they operate elsewhere in the region. All operators were provided
copies of applicable technical assistance documents at the time of the inspection.The operators have all
the equipment necessary to perform the analyses. Unless otherwise noted, findings pertain to all facilities
operated by the laboratory. Findings A, B, C, and G are new policies that have been implemented by our
program since the last inspection.
III. FINDINGS REQUIREMENTS COMMENTS AND RECOMMENDATIONS:
General Laboratory
Recommendation: Further standardization of benchsheets between ail operators is recommended. This
would allow management to better ensure that all documentation requirements are met by all operators.
The majority of the findings relating to documentation in this report do not apply to all operators.
Recommendation: The analyst for Sapphire Valley stated that the Dissolved Oxygen meter and pH
meter seem to take a long time to stabilize. The meters appeared to be older than the meters used by the
other operators. It is recommended that new meters be obtained to replace the old meters for this facility.
A. Finding: The auto-pipettors have not been calibrated annually.
Requirement: Mechanical volumetric liquid -dispensing devices (e.g., fixed and adjustable auto-
pipettors, bottle -top dispensers, etc.) must be calibrated at least every twelve months. Each
liquid -dispensing device must meet the manufacturer's statement of accuracy. For variable
volume devices used at more than one setting, check the accuracy at the maximum, middle and
minimum values. Testing at more than three volumes is optional. When a device capable of

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#E5191 Carolina Water Services, Inc. of NC
variable settings is dedicated to dispense a single specific volume, calibration is required at that
setting only. Ref: Quality Assurance Policies for Field Laboratories.
Comment: The auto-pipettors are used for Total Residual Chlorine (TRC) analysis to pipette
1.0 mL of the DPD and buffer reagents into the sample.
Recommendation: Use of the Hach liquid reagents is not required. It is recommended that the
powdered DPD reagent be used in order to eliminate the need for auto-pipettors. The laboratory
would no longer be required to calibrate the auto-pipettors if they are no longer used.
B. Finding: The laboratory needs to increase the documentation of purchased materials and
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: Quality Assurance Policies for Field
Laboratories.
Comment: This documentation may either be added to the applicable benchsheets or a separate
log sheet.
C. 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. This requirement applies to samples
analyzed by this laboratory as well as any samples analyzed by a contract laboratory.
Dissolved Oxygen — Standard Methods, 20"' Edition, 4500 O G
D. Finding: The time of meter calibration is not documented at Sugar Mountain, Elk River, Wolf
Laurel, and Hound Ears.
Requirement: The time(s) of calibration must be documented whenever sample analysis is
performed. Ref: Technical Assistance for Field Analysis of Dissolved Oxygen.

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#5191 Carolina Water Services, Inc. of NC
E. Finding: The time of sample collection is not documented at Sugar Mountain, Elk River, Wolf
Laurel, Hound Ears, and Sapphire Valley.
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
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: For samples analyzed in situ, a statement indicating that collection and analysis times
are the same may be added to the benchsheet, or the column header may be changed to "Time
Collected/Analyzed."
Total Residual Chlorine — Standard Methods, 201h Edition, 4500 Cl G
Comment: The get standards used to verify the calibration curve daily were not assigned true values at
Bent Creek, Transylvania Utilities, and Sapphire Valley. The Technical Assistance for Field Analysis of
Total Residual Chlorine states: Purchased "Get -type" or sealed liquid ampoule standards may be used for
daily calibration verification only. These standards must be verified initially and every 12 months
thereafter, with the standard curve. The assigned values will be used for the next twelve months, or until a
new curve verification is performed. The gel standard verification must be performed for each instrument
on which they are to be used. If multiple instruments and/or standard sets are used, each must have
assigned values specific for the instrument and standard set. Technical assistance was provided to each
analyst to assign true values to the gel standards during the inspections. No further response is
necessary for this finding.
F. Finding: The time of analysis of the gel standard is not documented at Sugar Mountain, Elk
River, Wolf Laurel, and Hound Ears.
Requirement: The time the calibration check was performed must be documented whenever
sample analysis is performed. Ref: Technical Assistance for Field Analysis of Total Residual
Chlorine.
2H — Standard Methods, lath Edition, 4500 H+ B
C. Finding: The pH samples and calibration buffers do not have proper units of measurement (S.U.)
associated with the pH values at Sugar Mountain, Elk River, Wolf Laurel, Hound Ears,
Transylvania Utilities, and Sapphire Valley.
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 benchsheets must provide a space for the signature or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
H. Finding: A check standard is not analyzed following calibration at Sapphire Valley.
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

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#5191 Carolina Water Services, Inc. of NC
calibration standard fe.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: Technical Assistance for Field
Analysis of pH.
I. Finding: The temperature sensing device on the pH meter is not checked against and a NIST
certified or NIST traceable thermometer every 12 months at Transylvania Utilities.
Requirement: All thermometers and temperature measuring devices must be checked every 12
months against a NIST certified or NIST traceable thermometer and the process documented. To
check a thermometer or the temperature sensor of a meter, read the temperature of the
thermometer/meter against a NIST certified or NIST traceable thermometer and record the two
temperatures. The thermometer/meter readings must be less than or equal to 1 °C from the NIST
certified or NIST traceable thermometer reading. The documentation must include the serial
number of the NEST certified thermometer or NIST traceable thermometer that was used in the
comparison. Also document any correction that applies on both the thermometerlmeter and on a
separate sheet to be filed. Other certified laboratories may provide assistance in meeting this
requirement. Ref: Technical Assistance for Field Analysis of pH.
Comment: The operator had a NIST certified thermometer dated 12-17-04. North Carolina
Wastewater/Groundwater Laboratory Certification Policy requires NIST certified thermometers to
be calibrated every five years, so this thermometer may not be used to check other meters or
thermometers unless it is recertified. The traceable thermometer used to analyze temperature,
however, may be used to check the pH meter. NIST traceable thermometers must be recalibrated
or replaced in accordance with the manufacturer's recalibration date. If no recalibration date is
given, the NIST traceable thermometer must be recalibrated or replaced annually.
Temperature -- Standard Methods, 20f" Edition, 2550 B
Recommendation: It is recommended that Temperature analyses be performed with the Dissolved
Oxygen or pH meter. This would allow the company to purchase fewer traceable thermometers because
the temperature sensing devices for all meters could be checked with a shared traceable or certified
thermometer. This would also reduce the risk of breaking a glass thermometer in the field.
J. Finding: The collection and analysis times are not clearly documented.
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
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
Comment: Since Temperature is analyzed in situ, a statement indicating that collection and
analysis times are the same may be added to the benchsheet, or the column header may be
changed to "Time Collected/Analyzed."
K. Finding: Proper units of measure (°C) are not documented at Sugar Mountain, Elk River, Wolf
Laurel, Hound Ears, and Sapphire Valley.
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 benchsheets must provide a space for the signature or initials of the analyst, and
proper units of measure for all analyses. Ref: 15A NCAC 2H .0805 (g) (1).
L. Finding: Temperature is not analyzed within EPA holding time at Transylvania Utilities.

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#5191 Carolina Water Services, Inc. of NC
Requirement: Immediate analysis is required. Ref: Code of Federal Regulations, Title 40, Part
136; Federal Register Vol. 72, No. 47, March 12, 2007; Table II.
pH — Standard Methods, 20t" Edition, 4500 H{' B
Dissolved OMen — Standard Methods, 201" Edition, 4500 O G
M. Finding: The temperature correction is not posted on the meters at Sapphire Valley.
Requirement: Document any correction that applies on both the thermometer/ meter and on a
separate sheet to be filed. Ref: Technical Assistance for Field Analysis of pH and Technical
Assistance for Field Analysis of Dissolved Oxygen.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing laboratory bench sheets and contract lab reports to Discharge
Monitoring Reports (DMRs) submitted to the North Carolina Division of Water Quality. Data were
reviewed for the following facilities for the listed months: Elk River (NPDES Permit #NC0058378) for
December, 2009; Wolf Laurel (NPDES Permit # NC0076431) for April 2010; Hound Ears (NPDES
Permit #NC0032123) for February, 2010; Bent Creek (NPDES Permit #NC0036684) for April, 2010;
Transylvania Utilities, Inc. #1 (NPDES Permit #NC0024295) for April, 2010; and Sapphire Valley
(NPDES Permit #NC0022985) for April, 2010. The following error was noted:
Date
Parameter
Location
Value on Benchsheet
Value on DMR
04-29-10
Total Nitrogen
Sapphire Valley
Effluent
5.66 mg/L
1.78 mg/L*
*The value on the DMR was the value of the Total Kjeldahl Nitrogen (TKN). The Nitrate + Nitrite result
of 3.88 mg/L was not added to the TKN value in order to obtain Total Nitrogen. The facility does not
have a limit on Total Nitrogen
In order to avoid questions of legality, it is recommended that you contact the appropriate Regional
Office for guidance as to whether an amended Discharge Monitoring Report will be required. A copy of
this report will be forwarded to the Regional Office.
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: Jason Smith Date: July 7, 2010
Report reviewed by: Tonja Springer Date: July 9, 2010