#5515_2020_1111_MWC_FINAL

To be attached to all inspection reports in-house only.
Laboratory Cert. #:
5515
Laboratory Name:
Synagro Central
Date Mailed:
Special Mailing Instructions:

ROY COOPER
c � o yeas or
MICHAEL S.
Secretary
S. REGAN
Director
December 21, 2020
5515
Mr. Adam Brigman
SYNAG RO CENTRAL
12701 Lancaster Hwy.
Pineville, NC 28134-
Subject: North Carolina Wastewater/Groundwater Laboratory Certification (NC WW/GW
LC) Maintenance Inspection
Dear Mr. Brigman:
Enclosed is a report for the inspection performed on November 11, 2020 by Michael Cumbus.
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. Please describe the steps taken to prevent recurrence and include an implementation
date for each corrective action. 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.
A copy of the laboratory's Certified Parameter List at the time of the audit is attached. This list
will reflect any changes made during the audit. 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 [phone] Ext. 259.
Sincerely,
Beth Swanson
Technical Assistance & Compliance Specialist
Division of Water Resources
Attachment cc: Michael Cumbus, Todd Crawford
North Carolina epar tment of Eriviront- ental Quality I Division ion of Water esources
4405 Reedy Creek Road � 1623 Mail Service Center~ Raleigh, North Carolina olina 1699 1623
NORTH CAROLINA

WATER QUALITY PERMIT #: WQ0013981 (Inactive)
CERTIFICATE #: 5515
.......................................................................................................................................................................................................................................................................................................
DATE OF INSPECTION: November 117 2020
....................................................................................................................................................................................................................................................................................
TYPE OF INS---- --PECTION: Field Industrial Maintenance
AUDITOR(S): Michael Cumbus
....... ....................... ... ....... I ..................... .......................... ...... - .................... ........ .............. - ..........................................................................................................................................
LOCAL PERSON(S) CONTACTED: Nate Roth
I. INTRODUCTION:
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 02H .0800 for the analysis of compliance monitoring samples.
II. GENERAL COMMENTS:
The inspection was performed remotely due to the coronavirus pandemic. The laboratory submitted
requested documentation and pictures of their consumables and instruments electronically on November
11, 2020 and December 1, 2020.
The laboratory is not currently analyzing compliance samples and has not analyzed anything other than
Proficiency Testing (PT) Samples since 2012. Analyses were performed for land application purposes
under permit WQ0013981 until 2012, when the subject wastewater treatment plant began using other
methods of residual disposal. In the event that the laboratory is involved with another land application
project, their Certified Parameters Listing (CPL) must be amended to reflect the proper Vector Attraction
Reduction (VAR) option being used. Approved Procedure documents for the three VAR options currently
allowed for Field Laboratories were provided to the laboratory prior to the inspection material submission
deadline.
The facility has all the equipment necessary to perform the analysis. Staff was forthcoming and
responded well to suggestions from the auditor.
The laboratory submitted their Standard Operating Procedure (SOP) document in advance of the
inspection. The document was reviewed, and editorial and substantive revision requirements and

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#5515 Synagro Central
recommendations were made by this program outside of this formal report process. Although
subsequent revisions were not requested to be submitted, they must be completed by June 30, 2021.
The laboratory is reminded that any time changes are made to laboratory procedures, the laboratory
must update the QA/SOP document(s) and inform relevant staff. Any changes made in response to the
pre -audit review or to 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 each approved practice, test, analysis,
measurement, monitoring procedure or regulatory requirement being used in the laboratory. In some
instances, the laboratory may need to create an SOP to document how new functions or policies will be
implemented.
The laboratory is also reminded that SOPs are intended to describe procedures exactly as they are to be
performed. Use of the word "should" is not appropriate when describing requirements (e.g., Quality Control
(QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper use of the word "should".
All required PT Samples have been analyzed for the 2020 PT Calendar Year and the graded results were
100% acceptable.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
Comment: NC WW/GW LC was previously allowing pH certification to substitute for VAR Options 6
and 12 since they were not certifiable parameters for Field laboratories. However, certification for
these VAR Options is now offered for laboratories classified as Field.
A. Finding: The laboratory benchsheet is lacking required documentation: the instrument
identification, the date of sample collection and the proper units of measure.
Requirement: All laboratories shall use printable laboratory benchsheets. Certified Data
shall be traceable to the associated sample analyses and shall consist of: the instrument
identification, date and time of sample collection and the proper units of measure. Each item
shall be recorded each time samples are analyzed. Analyses shall conform to
methodologies found in Subparagraph (a)(1) of this Rule. Ref: 15A NCAC 02H .0805 (g) (2)
(C), (F) and (L).
Comment: The 2-hour column is lacking the units of measure (S.U.).
Comment: The laboratory benchsheet includes only one date. It is unclear if this date is the
sample collection date, date that sample analysis is initiated or both. The benchsheet also
lacks a date for the 24-hour sample collection and analysis.
Recommendation: It is recommended that the laboratory utilize the serial number of the pH
meter as the instrument identification.
B. Finding: The laboratory is not documenting traceability information for purchased reagents
and standards.
Requirement: 15A NCAC 02H .0805 (a)(7)(K) and (g)(7) requires laboratories to have a
documented system of traceability for the purchase, preparation, and use of all chemicals,
reagents, standards, and consumables. That system must include documentation of the
following information: 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

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#5515 Synagro Central
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: NC WW/GW LC Policy.
Comment: The bottles of pH buffers were dated when received and when opened. While
this can provide a traceability link by comparing dates on the bottles to laboratory
benchsheets, this link is lost once the bottles are discarded.
C. Finding: Error corrections are not always properly performed.
mentatiumerrQrs-shall--be--corrected-bY-cfrawirrg-a- single -fin 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; instead the correction shall be written adjacent to the
error. The correction shall be initialed by the responsible individual and the date of change
documented. Ref: 15A NCAC 02H .0805 (g) (1).
Comment: The laboratory benchsheet lists the pH buffers used in calibration as 10 S.U.
and 13 S.U. These were changed to 4 S.U. and 7 S.U. with a single line but lacked the date
and initials of the analyst. A bottle of pH 4 S.U. buffer was noted to have the year received
(2020) partially obscured with multiple markings and replaced with 2019. This was also
lacking date and initials.
�H — SW-846 Method 9040 C (Aqueous)
�H — SW-846 Method 9045 D (Non -Aqueous)
Comment: The laboratory does not appear to be using a low -sodium electrode. While not
necessary at this time, a low -sodium electrode will be necessary to measure values over 10 S. U. if
the analysis of biosolids resumes.
D. Finding: The pH meter is not calibrated with standards that bracket the range of the sample
measurements encountered.
Requirement: Each instrument/electrode system must be calibrated at a minimum of two
points that bracket the expected pH of the samples and are approximately three pH units or
more apart. Ref: EPA SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods; 3rd Edition, Method 9040 C. Rev. 3, November 2004, Section 7.1.2.
Comment: The laboratory is calibrating the pH meter with 4 S. U. and 7 S. U. buffers, with no
additional check buffer to extend the range. This range did not cover the value of the PT
sample analyzed in 2019. Calibration with 4 S.U. and 10 S.U. buffers would cover the
expected range of the PT samples. Alternatively, the laboratory may choose to calibrate with
the 4 S.U. and 7 S.U. buffers and analyze the 10 S.U. buffer as a calibration check,
depending on the manufacturer's requirements for calibrating the pH meter.
E. Finding: The laboratory is not analyzing a check standard buffer after calibration and prior
to sample analysis.

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#5515 Synagro Central
Requirement: Laboratory procedures shall comply with Subparagraph (a)(1) of this Rule.
Ref: 15A NCAC 02H .0805 (g) (4).
Requirement: Instruments are to be calibrated according to the manufacturer's calibration
procedure prior to analysis of samples each day compliance monitoring is performed.
Calibration must include at least two buffers. The meter calibration must be verified with a
third standard buffer solution (i.e., check buffer) prior to sample analysis. All check standard
buffers must read within ± 0.1 S. U.to be acceptable. If the meter verification does not read
within ± 0.1 S.U., corrective actions must be taken before any samples are analyzed. Ref:
NC WW/GW LC Approved Procedure for the Analysis of pH.
Comment: To address this Finding, the benchsheet must be updated with a space for the
check buffer result, true value and acceptance criteria in S.U.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing copies of original records (e.g., laboratory benchsheets,
logbooks, etc.) to PT results. Data were reviewed for 2019 and 2020 PT studies. No transcription errors
were noted. 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 laboratory to
produce quality data and meet Certification requirements. The inspector would like to thank the staff for
their assistance during the inspection and data review process. Please respond to all Findings and
include supporting documentation, implementation dates and steps taken to prevent recurrence
for each corrective i .
Report prepared by: Michael Cumbus Date: December 10, 2020
Report reviewed by: Anna Ostendorff Date: December 16, 2020

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