NC0023957_Lab Certification Inspection_20030710

�W A 9 Michael F. Easley, Governor f 14-Z
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QG William G. Ross Jr., Secretary O t// North Carolina Department of Environment and Natural Resources
r Alan W. Klimek, P. E. Director 1413 ----/
Division of Water Quality n
Coleen H. Sullins, Deputy Director h-- /
Division of Water Quality i -
sof
July 10, 2003
7
Ms. Debra Douglas
Fayetteville Cross Creek WWTP Lab
P.O. Box 1089
Fayetteville, NC 28302-1089
SUBJECT: Laboratory Certification Maintenance Inspection
Dear Ms. Douglas:
Enclosed is a report for the inspectionperformed on June 10, 2003 by Mssrs.
Frederick L. Bone and James W. Meyer. Where deficiencies are cited in this report, a
response is required as well as for all lettered comments and/or recommendations. Within
thirty days of receipt, please supply this office with a written item for item description of how
these deficiencies, comments and/or recommendations were corrected. If the deficiencies
cited in the enclosed report are not corrected, enforcement actions will be recommended.
For certification maintenance, your laboratory must continue to carry out the requirements
set forth in 15A NCAC for 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 919-733-3908.
Sincerely,
onted (1//11
James W. Meyer
Laboratory Section
Enclosure
cc: Frederick L. Bone
Fayetteville Regional Office
Q+1�
N. C. Division of Water Quality Laboratory Section 1623 Mail Service Center Raleigh, North Carolina 27699-1623 [phone]
FAX: [phone]

On -Site Inspection Report
LABORATORY NAME: Fayetteville Cross Creek WWTP Lab
ADDRESS: P.O. Box 1089
Fayetteville, NC 28302-1089
CERTIFICATE NO: 7
DATE OF INSPECTION: June 10, 2003
TYPE OF INSPECTION: Maintenance
EVALUATOR: Frederick L. Bone and James W. Meyer
LOCAL PERSON(S) CONTACTED: Debra Douglas, Debra Long , Carrie Manning, and William
Butler
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:
The laboratory is spacious and well equipped. All facilities and equipment are well maintained.
Records are well kept and most data looked good. Some further quality control procedures need
to be implemented.
III. DEFICIENCIES, RECOMMENDATIONS, REQUIREMENTS, AND COMMENTS:
General:
Note: The laboratory is using a LIMS system that does not generate all of the required
information for laboratory benchsheets. Discussions were held concerning the uses of the
LIMS system as opposed to laboratory benchsheet data. Based upon the information
provided during the audit, the laboratory is using the I IMS system as a reporting device, while
maintaining their regulatory compliance data on laboratory benchsheets. Laboratory bench
worksheets are currently being implemented throughout laboratory.
REQUIREMENT:. The laboratory benchsheets must include all relevant information pertaining
to each analysis. This includes' information such as stating how each result was calculated,
quality control acceptance ranges and results, final values to be reported, blanks, - units of
measure, etc. As a minimum 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).

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1. DEFICIENCY: The laboratory is not analyzing and recording a standard at the mid -range of
the calibration curve daily for some of the analytical methods. (Examples: Nitrate + Nitrite,
Ammonia, TP)
Note: As was discussed at the time of the audit the mid -range is to be defined, for all North
Carolina samples, as one half: the concentration of the high standard. The mid -range check
standard must be prepared from the same stock standards as the analytical curve. A second
source laboratory control standard (LCS) must be analyzed in addition to the mid range check
standard daily. A second source LCS sample does not constitute daily mid -range verification.
REQUIREMENT: Verify the standard curve daily by analyzing one or more standards within
the linear range, as specified in the individual method. -The curve must be updated as set forth
in the standard procedures, each time the slope changes by more than 10 percent at
midrange. Ref: Standard Methods 18th Edition 1020 B. Quality Control section 5 p. 1-5, and
Ref: 15A NCAC 2H .0805 (a) (7) (i).
A. COMMENT: The laboratory indicated at the time of the inspection that it may wish to drop
the following parameters: Hardness, Orthophosphate, COD, Total Solids. CITED
PREVIOUSLY
REQUIREMENT: The laboratory must complete and submit an amendment to the application
form requesting the deletion of these parameters from its certified parameter list. This form
may be obtained at the website: dwglab.org.
B. COMMENT: The laboratory does not correctly list the analytical method that was used to
perform each analysis on the laboratory benchsheet. (examples: Oil and Grease and
Nitrate+Nitrite)
Note: There are instances .where the laboratory is listing methods on the laboratory.
benchsheet that are not on the laboratory's current certified method list. In some cases the
laboratory is analyzing by Standard Methods, and is certified for. the EPA methodologies ,
while in other instances the laboratory will cite EPA references on the laboratory benchsheet,
and be certified for the Standard Methods versions on a certified analyte list.
REQUIREMENT: The laboratory must verify that each method citation . on its laboratory
benchsheets are correctly listing, the methodology that .is performed in the laboratory. The
laboratory must also further ensure that they are maintaining proper certification . for each
method listed on the benchsheets. The laboratory must clearly state the methodologythat is
being followed in order to perform each analytical test.
C. COMMENT: The laboratory does not list the acceptance ranges of quality control samples
on the laboratory benchsheets. ,CITED TWICE PREVIOUSLY
RECOMMENDATION: It is strongly recommended that the laboratory list the acceptance
ranges for each quality control sample on the benchsheet. This will enable the analyst to be
able to compare the analytical result to the acceptable range in a timely fashion. If the sample
is out of the acceptable range,it can then be reanalyzed immediately andwithin all holding
times.

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Total Suspended Solids:
2. DEFICIENCY: The laboratory has not implemented the new bench worksheet that includes
all of the relevant reporting information for the analysis of Total Suspended Solids.
Note: The laboratory is still using the old bench worksheet that does not provide adequate
information concerning the Total Suspended Solids analysis. A new benchsheet has been
developed that contains all of the relevant information, but this benchsheet is not being used
by the analyst performing the analysis. There were indications that data had been copied from
the older worksheets to the new benchsheet by the laboratory supervisor, however; it did not
appear that the proper benchsheets were being used by the analyst to record all relevant data.
REQUIREMENT: The laboratory benchsheets must include all relevant information pertaining
to each analysis. This includes information such as stating how each result was calculated,
quality . control acceptance ranges and results, final values to be reported, blanks, units of
measure, etc. As .a minimum 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).
Oil and Grease:
3. DEFICIENCY: The lab is not analyzing a quarterly standard for Oil and. Grease.
REQUIREMENT: Analyze one Oil and Grease standard quarterly. Ref: 15A NCAC 2H .0805
(a) (7) (B).
COD:
D. COMMENT: The laboratory does not record the elapsed time of digestion for COD
samples. CITED TWICE PREVIOUSLY
Note: The time samples were placed onto the reactor is not clearly labeled.
RECOMMENDATION: It is strongly recommended that the laboratory record the time that
the samples were placed into the reactor and removed from the reactor in order to verify that
the samples were digested for the appropriate amount of time. ' All relevant data must be
clearly labeled.
BOD:
E. COMMENT: The seed controls used by the laboratory were occasionally outside of the
accepted range. The laboratory only analyzes two seed controls daily.
RECOMMENDATION: It is strongly recommended that a seed control be analyzed at a
dilution that will achieve about 50% depletion, and analyze one above that dilution and one
below that dilution in order to have at least one that will meet the proper criteria to be used for

Page 4
calculating the seed correction. If all the dilutions meet the proper criteria, they should be
averaged, after calculation, for the seed correction.
Fecal Coliform:
F. COMMENT: The laboratory is averaging plates that do not meet the 20 — 60 colonies per
plate rule with. 100 ml wholevolume samples.
REQUIREMENT: The laboratory should report all data based on the 100 ml sample volume
provided that the 100 ml whole volume sample is not greater than 60 colonies /100 ml.
Compute the density from the sample quantities that produced MF counts within the desired
range of 20 to 60 fecal coliform colonies. Ref. Standard Methods, 18th Edition 9222D. (3) p. 9-
61..
Nitrate + Nitrite:
4. DEFICIENCY: The laboratory does not record that the midpoint check standard is within
10% of its true value each analysis day.
REQUIREMENT: Verify the standard curve daily by analyzing one or more standards within
the linear range, as specified in the individual method. The curve must be updated as set forth
in the standard procedures, each time the slope changes by more than 10 percent at
midrange. Ref: Standard Methods 18th Edition 1020 B. Quality Control section 5 p. 1-5, and
Ref: 15A NCAC 2H .0805 (a) (7) (i).
Residual Chlorine:
5. DEFICIENCY: The laboratory records the time that the Residual Chlorine sample is
received into laboratory, but does not record time of sample collection on the laboratory
benchsheet. This does not provide adequate documentation that the sample was collected
and analyzed within the required 15 minute holding time.
REQUIREMENT: The maximum holding time for Residual Chlorine samples is 15 min. Ref:
40CFR Ch.1(7-1-95) p. 644 table II.
G. COMMENT: The laboratory does not record the pH electrode calibration information on the
same benchsheet with the sample data. The calibration information is logged on the chain of
custody forms.
RECOMMENDATION: It is strongly 'recommended that the laboratory record all calibration
information on the same benchsheet as the sample data. This allows for ease of data
verification as well as eliminating the possibility, of data becoming separated from essential
calibration information. .

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TKN:
H. COMMENT: The laboratory does not analyze an organic standard in conjunction with the
TKN sample analysis.
RECOMMENDATION: It is strongly recommended that the laboratory analyze an organic
standard with each TKN analysis. A recommended standard for this purpose is Glutamic acid.
Metals:
I. COMMENT: The digestion Togs used by the laboratory do not contain adequate information
to fully document all aspects of the metals sample digestion. These logs need to be modified
to include information such as dilutions, initial volumes, and final volume achieved etc.
REQUIREMENT: The laboratory documents must include all relevant information pertaining to
each analysis. Ref: 15A NCAC 2H .0800 (a) (7) (h).
VI. CONCLUSIONS:
Correcting the above deficiencies and comments and implementing the recommendations
should help the,Lab to produce quality data and meet certification requirements.
Please respond to all numbered Deficiencies and lettered Comments cited in this report.
Report prepared by: Frederick L. Bone Date: June 18, 2003