#539 - 09- 2009- FINAL

Cover Letter to use:
Unit Supervisor:
Date Received:
Date Forwarded to Alberta:
Date Mailed:
539
ONWASA Laboratory
Municipal Maintenance
David Livingston
August 13, 2009
August 18, 2009
August 18, 2009
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 Reoort Completed:
Date Forwarded to Reviewer:
Reviewed by: Ramon L. Cook
Date Review Completed: September 14, 2009
Insp. Initial X Insp. Reg. _ Insp. No Finding
Gary Francies
9/14/2009
9/25/2009

Beverly Eaves Perdue
Governor
September 28, 2009
539
Mr. Todd Roberts
ONWASA Laboratory
228 Georgetown Drive
Jacksonville, NC 28540
SUBJECT: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW LC)
Maintenance Inspection
Dear Mr. Roberts:
Dee Freeman
Secretary
Enclosed is a report for the inspection performed on August 13, 2009 by David Livingston. 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 me at 828-296-4677.
Sincerely,
C
Gary Francies
Unit Supervisor
Laboratory Section
CC: Wilmington Regional Office
David Livingston
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] FAX: [phone]
Internet: wavw.dwglab.org
Nor(hCarolina
atlfrall
An Equal Opportunity \Affirmative Action Employer Customer Service: 1-877-623-6748 www.ncwaterquality.org

LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
INTRODUCTION:
On -Site Inspection Report
ONWASA Laboratory
NC0023230, NC0030813, NC0083551, and NCO083321
228 Georgetown Dr.
Jacksonville, NC 28540
539
August 13, 2009
Municipal Maintenance
David Livingston
Todd Roberts, Gale Huffman and Terri Maggard
This laboratory was inspected to verify its compliance with the requirements of 15A NCAC 2H .0800 for the analysis
of environmental samples.
GENERAL COMMENTS:
Attached to this report is a procedure for verifying the calibration of an LDO probe. This information can also be
found on our web site www.dwolab.orq.
The Wilmington Regional office requested laboratory certification to perform an inspection of ONWASA's Laboratory
operations for Total Phosphorus samples from the Town of Richlands Waste Water Treatment Plant (WWTP). Total
Phosphorus data were reviewed for the months of June and July 2009. The laboratory's annual curve was acceptable
>_ 0.995 correlation coefficient. The blanks were well below Y2 of the laboratory's reporting limit of 0.1 mg/L. All
continuing calibration verification standards (0.5 mg/L) recovered within +- 10%. The second source standards (0.5
mg/L) were also acceptable. The duplicate samples were analyzed and evaluated to be within Laboratory % RPD
criteria. The split samples performed in conjunction with Environmental Chemists, Inc. and ONWASA showed
comparable recoveries for the samples but the spiked sample recoveries were not comparable. The sample spikes
for June 23, June 26 and June 29, 2009 for the Richlands plant show almost no recovery for the spiked samples.
ONWASA reanalyzed those three samples several times with the same results, almost no recovery for the spiked
samples. The laboratory did try corrective action including making new reagents, new glassware and began spiking
all samples to try and find the reason for the low spike recoveries. No cause for the low spike recoveries was
determined. The Total Phosphorus spiked sample recoveries, for the Town of Richlands WWTP are now recovering
between 80-120% which is within laboratory limits.
FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Dissolved Oxygen — ASTM D 888-05
A. Finding: The laboratory is not performing and documenting the daily calibration verification for the
luminescence DO probe.
Requirement: North Carolina Wastewater/Groundwater Laboratory Certification requires that an LDO probe
must be calibrated or have the calibration verified each day of use. Ref: North Carolina Wastewater/
Groundwater Laboratory Certification Policy.
B. Finding: The laboratory did not have units of measure associated with all of the DO measurements at the
Kenwood treatment plant.

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#539 ONWASA Laboratory
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 .0800 (a) (7) (H).
IV. PAPER TRAIL INVESTIGATION:
C. Finding: Values of zero are reported on the Discharge Monitoring Report (DMR).
Requirement: Values of results which are less than a detectable limit should be reported in the daily cells
using the "less than" symbol (<) and the detectable limit used during the testing (or the value with
appropriate unit conversion). Ref: Division of Water Quality document; Directions for Completing Monthly
Discharge Monitoring Reports.
D. Finding: Fecal Coliform data values of <1 CFU are averaged as zero. Fecal Coliform data must be averaged
using the geometric mean.
Requirement: For calculation purposes only, recorded values of less than a detectable limit (< #####) may
be considered to equal zero (0) for all parameters except Fecal Coliform for which values of "less than"
may be considered to be equal to one (1). Values of results which are less than a detectable limit should
be reported in the daily cells using the "less than" symbol (<) and the detectable limit used during the
testing (or the value with appropriate unit conversion). Please note there is never a case when an average
would need to be recorded along with a "less than" symbol. Ref: Division of Water Quality document;
Directions for Completing Monthly Discharge Monitorinq Reports.
E. Finding: Data that was estimated as "greater than" did not have the qualifier ">" documented on the DMR.
Requirement: Use of "greater than" values. Such values are only expected (and then only infrequently) in
the reporting of Fecal Coliform and BOD. If a "greater than" value is reported, the numeric portion of the
value should be sufficiently high so as to make the facility aware of the extent of any problems with
treatment efficiency. Upon receipt of "greater than" testing results, a facility should consult its laboratory to
see if changes in testing procedure need to be made in order to get discreet values from the analysis. For
calculation purposes only, the numeric portion of the value must be used to calculate either an arithmetic
or geometric mean. Ref: Division of Water Quality document; Directions for Completing Monthly
Discharge Monitoring Reports.
The paper trail consisted of comparing laboratory benchsheets to Discharge Monitoring Reports (DMRs)
submitted to the North Carolina Division of Water Quality. Data were reviewed for the ONWASA Laboratory for
April, May and June 2009. No transcription errors were detected.
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: David Livingston Date: August 18, 2009
Report reviewed by: Ramon L. Cook Date: September 14, 2009

Luminescence DO (LDO) Daily Check
Although many manufacturers of LDO probes indicate that the probes require calibration only every 6
months or so, NC WW/GW LC requires that an LDO probe must be calibrated or have the calibration
verified each day of use.
Below is a procedure for verifying the calibration of an LDO probe.
1) Place probe in a plastic bag with a wet sponge or a BOD bottle partially filled with water
2) Make sure the bag is effectively sealed (zip, rubber band, or twist tie)
3) Allow appropriate instrument warm up time
4) Read D.O. and temperature
5) Check the reading vs. the Solubility Table below and apply appropriate atmospheric (barometric)
pressure or altitude correction factor
6) Calculated D.O. value must verify meter reading within ± 0.5 mg/L
The Solubility Table can be found on our web site.
Go to Certification Branch
Click on Applications and Forms and then scroll down to daily LDO calibration verification.